Final

Preliminary Assessment Report

South Burlington Army Aviation 

Support Facility/Readiness Center 

Burlington, Vermont

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

April 2019

Prepared for:

Army National Guard Headquarters

111 S. George Mason Drive

Arlington, VA 22204

US Army Corps of Engineers, Baltimore District

2 Hopkins Plaza

Baltimore, MD 21201

Prepared by:

AECOM

12420 Milestone Center Drive, Suite 150

Germantown, MD 20876

aecom.com

Contract Number: W912DR-12-D-0014

Delivery Order: W912DR17F0192
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

i

Table of Contents

Executive Summary...................................................................................................1

1. Introduction........................................................................................................................5

1.1 Authority and Purpose ..............................................................................................5

1.2 Preliminary Assessment Methods .............................................................................6

1.3 Report Organization..................................................................................................6

1.4 Facility Location and Description...............................................................................6

1.5 Facility Environmental Setting...................................................................................7

1.5.1 Geology .........................................................................................................7

1.5.2 Hydrogeology.................................................................................................7

1.5.3 Hydrology.......................................................................................................8

1.5.4 Current and Future Land Use.........................................................................9

1.5.5 Climate...........................................................................................................9

2. Fire Training Areas...........................................................................................................13

3. Non-Fire Training Areas ...................................................................................................14

3.1 Maintenance and Storage Hangar ..........................................................................14

3.2 Waste Water Treatment Plant .................................................................................14

3.3 Landfills ..................................................................................................................15

4. Emergency Response Areas............................................................................................17

4.1 Cessna Private Plane Crash...................................................................................17

5. Adjacent Sources.............................................................................................................19

5.1 Vermont Air National Guard Fire and Non-Fire Training Areas ................................19

5.2 Champlain Cable Corporation.................................................................................20

6. Conceptual Site Model.....................................................................................................22

6.1 AOI 1 Cessna Private Plane Crash.........................................................................22

7. Conclusions .....................................................................................................................25

7.1 Findings..................................................................................................................25

7.2 Uncertainties...........................................................................................................25

7.3 Potential Future Actions ..........................................................................................27

8. References ......................................................................................................................29
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

ii

Figures

Figure ES-1 So. Burlington AASF/RC Summary of Findings

Figure ES-2 Conceptual Site Model, So. Burlington AASF/RC

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features 

Figure 3-1 Non-Fire Training Areas

Figure 4-1 Emergency Response Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Conceptual Site Model, AOI 1 Cessna Private Plane Crash

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

iii

Acronyms and Abbreviations

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

amsl above mean sea level

AOI Area of Interest

AR Administrative Record

AST above ground storage tank

bgs below ground surface

CCC Champlain Cable Corporation

CERCLA Comprehensive Environmental Response, Compensation, and 

LiabilityAct

Champlain Lowland Champlain Lowland Physiographic Province

CSM conceptual site model

EDR Environmental Data Resources, Inc.

EM Environmental Manager

F Fahrenheit

FD Fire Department

FTA Fire Training Areas

ft feet

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PHAL provisional health advisory levels

POL Petroleum, oil, and lubricants

ppt parts per trillion

RC Readiness Center

SI Site Inspection

So. Burlington AASF/RC South Burlington Army Aviation Support Facility/Readiness Center

sqft square foot

UCMR 3 Third Unregulated Contaminant Monitoring Rule

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

UST underground storage tank

VTANG Vermont Air National Guard

VTARNG Vermont Army National Guard

WWTP Waste water treatment plant
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

1 

Executive Summary

The United States (US) Army Corps of Engineers (USACE) Baltimore District on behalf of the 

Army National Guard (ARNG)-Installations & Environment Division, Cleanup Branch contracted 

AECOM Technical Services, Inc. (AECOM) to perform Preliminary Assessments (PAs) and Site 

Inspections (SIs) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) 

Impacted Sites at ARNG Facilities Nationwide. The ARNG is assessing potential effects on human 

health related to processes at facilities that used per- and poly-fluoroalkyl substances (PFAS), 

primarily in the form of aqueous film forming foam (AFFF) released as part of firefighting activities, 

although other PFAS sources are possible. 

AECOM completed a PA for PFAS at the Vermont Army National Guard (VTARNG) South 

Burlington Army Aviation Support Facility/Readiness Center (So. Burlington AASF/RC) in South 

Burlington, Vermont, to assess potential PFAS release areas and possible exposure pathways to 

receptors. The performance of this PA included the following tasks: 

• Reviewed data resources to obtain information relevant to suspected PFAS releases

• Conducted a 1-day PA site visit on 16 May 2018

• Interviewed current VTARNG personnel and individuals with the US Air Force Fire and

Emergency Services, Vermont Air National Guard (VTANG) Fire Department, and VTANG

Environmental Management Office

• Completed visual site inspections at known or suspected PFAS release locations and

documented with photographs

• Developed a conceptual site model (CSM) to outline the potential release and pathway of

PFAS for the Areas of Interest (AOIs) and the facility

During the PA, one AOI related to PFAS release was identified at So. Burlington AASF/RC based 

on PA data. The AOI is shown on Figure ES-1 and described in the table below:

Area of 

Interest

Name Used by Potential Release 

Dates

AOI 1 Cessna Private Plane 

Crash

Burlington International 

Airport 1988

Interviews with VTARNG staff whose first-hand knowledge span the entire history of the So. 

Burlington AASF/RC (2007-present) indicate that VTARNG activities have not contributed PFAS 

contamination to the environment; however, VTANG activities may have resulted in potential 

PFAS releases at AOI 1 and the off-facility Burlington Air National Guard Base. An unknown 

quantity of AFFF was used by the VTANG Fire Department in response to a 1988 plane crash at 

AOI1, potentially resulting in PFAS release to the environment. 

Based on the documented PFAS releases at AOI 1, there is potential for So. Burlington AASF/RC 

site and construction worker exposure to PFAS contamination in subsurface soils via inhalation 

and ingestion. Drinking water for VTARNG is provided by the Champlain Water District. Although 

several drinking water wells exist downgradient within 4 miles of the facility, the Winooski River 

acts as a natural hydraulic barrier between the facility and those wells. If PFAS is present in 

groundwater at the facility and migrates beyond the Winooski River, or unregistered private wells 

exist within the vicinity of the facility, residential use of groundwater for domestic purposes may 

expose residents to PFAS via ingestion. PFAS may be present in groundwater beneath the So. 

Burlington AASF/RC facility, but groundwater is not considered a complete pathway for PFAS to 
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

2 

site and construction workers due to depth to groundwater. A summary of PA findings is shown 

on Figure ES-1. The CSM for So. Burlington AASF/RC is shown on Figure ES-2. 

The VTANG PFAS PA Report for the adjacent Burlington Air National Guard Base recommended 

initiating an SI at the Cessna private plane crash location on VTARNG property (CH2M HILL, 

2015). The 2018 Final SI Report for the Burlington Air National Guard Base did not include an 

investigation of the Cessna private plane crash location (Aerostar SES LLC, 2018); the 

forthcoming expanded SI will investigate the area. As such, future actions under the CERCLA

process will be performed by the VTANG, not the VTARNG.
Stormwater Pond

Fire Supression

Control Room

POL Room

Cessna Private

Plane Crash

AOI 1

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Wetland

River/Stream

Summary of Findings

Figure ES-1

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0 125 250 500

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Media

SOURCE PATHWAY RECEPTOR

AOI 1 –

Cessna

Private

Plane Crash

Location

Emergency

Response

Flame 

Suppression

PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure ES-2

Conceptual Site Model

So. Burlington AASF/RC

Potential

Off-Facility

Source Not

under

Control of

ARNG

Recreational User

Recreational User

4
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

5

1. Introduction

1.1 Authority and Purpose

The United States (US) Army Corps of Engineers (USACE) Baltimore District on behalf of the 

Army National Guard (ARNG)-Installations & Environment Division, Cleanup Branch contracted 

AECOM Technical Services, Inc. (AECOM) to perform Preliminary Assessments (PAs) and Site 

Inspections (SIs) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA) 

Impacted Sites at ARNG Facilities Nationwide under Contract Number W912DR-12-D-0014, Task 

Order W912DR17F0192, issued 11 August 2017. The ARNG is assessing potential effects on 

human health related to processes at their facilities that used per- and poly-fluoroalkyl substances 

(PFAS), primarily releases of aqueous film forming foam (AFFF) although other sources of PFAS 

are possible. In addition, the ARNG is assessing businesses or operations adjacent to the ARNG 

facility (not under the control of ARNG) that could potentially be responsible for a PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing 

regulatory interest due to their potential risks to human health and the environment. PFAS 

formulations contain highly diverse mixtures of compounds. Thus, the fate of these PFAS 

compounds in the environment will vary. The regulatory framework at both federal and state levels 

continues to evolve. The US Environmental Protection Agency (USEPA) issued Drinking Water 

Health Advisories for PFOA and PFOS in May 2016, but there are currently no promulgated 

national standards regulating PFAS in drinking water. In the absence of federal maximum 

contaminant levels, some states have adopted their own drinking water standards for PFAS. On 

10 July 2018 the Vermont Department of Health issued a Drinking Water Health Advisory level of 

20 parts per trillion (ppt) combined for five PFAS chemicals (PFOA, PFOS, perfluorohexane 

sulfonic acid, perfluoroheptanoic acid, and perfluorononanoic acid) (Vermont Department of 

Health, 2018).

As a result of this Health Advisory and several known PFAS exposures, the Agency of Natural 

Resources adopted two emergency rules to regulate these substances. The Investigation and 

Remediation of Contaminated Properties Rule was amended to list these five PFAS chemicals as 

hazardous materials, and the Groundwater Protection Rule and Strategy was amended to adopt 

an enforcement standard of 20 ppt for these substances. Like the standard for PFOA and PFOS, 

the 20 ppt enforcement standard applies to the sum of these substances (Vermont Agency of 

Natural Resources, 2018).

This report presents findings of a PA for PFAS at the Vermont Army National Guard (VTARNG) 

South Burlington Army Aviation Support Facility/Readiness Center (So. Burlington AASF/RC) in 

South Burlington, Vermont in accordance with the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), as amended, the National Oil and Hazardous 

Substances Pollution Contingency Plan (40 Code of Federal Regulations Part 300), and USACE 

requirements and guidance.

This PA documents locations where PFAS may have been released to the environment at So. 

Burlington AASF/RC. The term PFAS will be used throughout this report to encompass all PFAS 

chemicals being evaluated, including PFOS and PFOA, which are key components of AFFF.
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

6 

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks: 

• Reviewed data resources to obtain information relevant to suspected PFAS releases.

• Conducted a 1-day PA site visit on 16 May 2018.

• Interviewed current VTARNG personnel and individuals with the US Air Force Fire and

Emergency Services, and Vermont Air National Guard (VTANG) Fire Department.

• Completed visual site inspections at locations where AFFF is stored at the facility and

documented with photographs.

• Developed a conceptual site model (CSM) to outline the potential release, pathway, and

receptors of PFAS for So. Burlington AASF/RC.

1.3 Report Organization

This report has been prepared in accordance with the USEPA Guidance for Performing 

Preliminary Assessments under CERCLA (USEPA, 1991). The report sections and descriptions 

of each are:

Section 1 – Introduction: identifies the project purpose and authority and describes the facility 

location, environmental setting, and methods used to complete the PA

Section 2 – Fire Training Areas: describes the fire training areas (FTAs) at the facility identified 

during the site visit 

Section 3 – Non-Fire Training Areas: describes other locations of PFAS releases at the facility 

identified during the site visit 

Section 4 – Emergency Response Areas: describes areas of AFFF release at the facility, 

specifically in response to emergency situations 

Section 5 – Adjacent Sources: describes sources of PFAS release adjacent to the facility that 

are not under the control of ARNG 

Section 6 – Conceptual Site Model: describes the pathways of PFAS transport and receptors 

at the facility 

Section 7 – Conclusions: summarizes the data findings and presents the conclusions of the PA 

Section 8 – References: provides the references used to develop this document

Appendix A – Data Resources

Appendix B – Preliminary Assessment Documentation

Appendix C – Photographic Log

1.4 Facility Location and Description

The So. Burlington AASF/RC occupies approximately 27 acres in central Chittenden County, 

Vermont, in the northwest corner of Burlington International Airport, which lies in the northeast 

portion of the City of South Burlington, and is situated approximately 3 miles east of Lake 

Champlain (Figure 1-1). The facility is bound by Airport Parkway and commercial properties to 

the north and northwest, a mix of industrial and commercial properties and the southern extension 
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

7

of Shamrock Road to the east, and by the Burlington International Airport to the south and 

southwest.

VTARNG began using the facility in 2007. The property is licensed to the VTARNG through the 

USACE from Burlington International Airport. The property deed is included in Appendix A. The 

facility includes a 95,000 square foot Army Aviation Support Facility with five hangar bays used 

for the maintenance of rotary wing aircraft and a 49,000 square foot facility that includes the Civil 

Support Team and a Readiness Center northeast and connected to the hangar. The property is 

largely developed with buildings, roads, parking lots, and a tarmac used for aircraft parking. The 

relatively flat concrete tarmac is connected to a Burlington International Airport taxi-way.

1.5 Facility Environmental Setting

The So. Burlington AASF/RC is in central Chittenden County, Vermont, within the City of South 

Burlington. Surface topography in the eastern and northeastern portions of the site slopes towards 

an unnamed drainage feature in the northern portion of the property at an elevation of 

approximately 242 feet above mean sea level (amsl). The majority of the site is developed with 

buildings, concrete, or asphalt features. There are no naturally occurring surface waterways 

located on the So. Burlington AASF/RC property, but terrain in the west and northwest portions of 

the site slope downwards towards an offsite unnamed drainage that directly feeds the Winooski 

River.

1.5.1 Geology

The So. Burlington AASF/RC is on the eastern edge of the Champlain Lowland Physiographic 

Province (Champlain Lowland). The Champlain Lowland consists of a north-to-south-trending 

structural trough located between the Green Mountains to the east, the Adirondack Mountains to 

the west, and the Taconic Mountains to the southeast. The Champlain Lowland is 12 to 15 miles 

wide and contains the north-to-south-trending Lake Champlain bounded by flat and gently rolling 

lands, most of which lie below 1,500 feet amsl.

The So. Burlington AASF/RC is approximately 4 miles east of the Champlain Thrust Fault and 

approximately 3.5 miles west of the Hinesburg-Oak Hill Thrust Fault. Bedrock beneath the facility

is composed of carbonate platform rocks of the Shelburne Marble, an informal member of the 

Lower Ordovician Beekmantown Group. Shelburne Marble is predominantly light-gray- to whiteand bluish-gray-streaked calcite marble and massive white- and green-streaked calcite marble 

that locally contains intermediate dolostone and gray limestone beds. Rocks of the Beekmantown 

Group below the surface of the facility occur just east of the fold axis within the western limb of 

the recumbent, isoclinal, south-southeastward plunging Hinesburg synclinorium (Ratcliffe et al., 

2011), resulting in variable bedding attitudes beneath the site. Depths to bedrock range locally 

from surface outcrop to greater than 200 feet below ground surface (bgs) (AFCEC, 2015). 

Overburden materials consist of medium fine sand (Wright et al., 2009), and artificial fill (Marin 

Environmental Inc., 2001a). The bedrock geology beneath the So. Burlington AASF/RC and 

adjacent areas is presented in Figure 1-2.

1.5.2 Hydrogeology

The So. Burlington AASF/RC is in an area with good to moderate water supply potential. 

Unconsolidated sand and gravel deposits and, to a lesser extent, underlying fractured bedrock 

provide usable quantities of groundwater, with yields reportedly ranging from low to high. Areas 

of greatest potential occur proximal to the Winooski River (AFCEC, 2015).
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

8 

Recoverable groundwater primarily resides within the carbonate solution features and faults and

fractures in the marble. Wells screened in the bedrock formation have water yields ranging from 

6 to 40 gallons per minute. The Vermont Department of Water Resources has classified the 

bedrock groundwater in the area of VTANG, upgradient of the facility, as a Class III water 

resource, which is characteristic of a groundwater aquifer suitable for domestic water supply, 

irrigation, agricultural use, and general industrial and commercial use. 

There are no potable groundwater supply wells at the So. Burlington AASF/RC (AFCEC, 2015). 

The facility purchases potable water from the Champlain Water District (CWD), which obtains its 

public water supply from Lake Champlain (AFCEC, 2015). There are no known public water 

supply wells within a 1-mile radius of the facility. There are 6 water wells within 1-mile; four of 

which are hydraulically upgradient and two are cross-gradient of the facility. The well depths range 

from 128 to 498 feet bgs and are reported to be domestic in use. Figure 1-2 presents the location 

of these wells. There are no monitoring wells at the facility.

Groundwater flow beneath the site presumably flows to the northwest, consistent with topography 

and surface water drainage patterns. Groundwater beneath the site occurs within unconsolidated 

sand and gravel deposits and, to a lesser extent, underlying fractured bedrock (Marin 

Environmental Inc., 2001a, 2001b). Depth to groundwater in an area adjacent to the Burlington 

International Airport is approximately 10 feet bgs.

1.5.3 Hydrology 

The So. Burlington AASF/RC is on the south side of the Winooski River, within the Winooski River 

Watershed. The Winooski River flows 90 miles from its headwaters in the town of Cabot, Vermont 

to Lake Champlain in Colchester, Vermont. The Winooski River drains approximately 1,080 

square miles in central Vermont. The watershed encompasses all of Washington County, about 

half of Chittenden County, and portions of Lamoille and Orange counties (AFCEC, 2015). 

Several small, unnamed drainages located west of the site within approximately 1,000 feet flow 

generally northwestward and enter the Winooski River approximately 0.5 miles northwest of the 

facility boundary. Another small, unnamed drainage located less than 500 feet east of the facility 

flows generally northward and enters the Winooski River approximately 0.3 miles northeast of the 

facility boundary (AFCEC, 2015). Several wetlands areas have been designated to the east and 

west within approximately 1,000 feet of the facility (USFWS, 2018). Surface drainage features do 

not originate on the facility. Regional watersheds and surface drainage features from the 

surrounding area are presented in Figure 1-3. 

The USEPA collects occurrence data for potential contaminants that may be present in drinking 

water, but do not have enforceable drinking water standards under the Third Unregulated 

Contaminant Monitoring Rule (UCMR 3). The UCMR 3 data for local water purveyors within a 10-

mile radius of So. Burlington AAFF/RC was searched for PFAS-specific chemical data results. 

Appendix A includes the UCMR 3 2013 tabulated data, which indicated that PFAS and 

associated compounds were not reported above the laboratory method detection limits. 

No naturally occurring surface water features are located on So. Burlington AASF/RC (Marin 

Environmental Inc., 2001a); however, one artificial stormwater pond is situated along the eastern 

boundary of the facility. The stormwater pond was presumably constructed at the same time as 

the AASF/RC facility. The pond is divided into two sections and is fed by stormwater runoff from 

the AASF building, parking areas, and helipad via drainage ditches and a network of catch basins. 

The majority of surface water runoff from the facility drains to the stormwater pond, which drains 
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

9 

to an unnamed tributary of the Winooski River (VTARNG, 2018). A stormwater drainage map from 

the facility’s Stormwater Pollution Prevention Plan is included in Appendix A. 

Additionally, stormwater drainage grates are located along the western edge of Shamrock Road 

adjacent to the eastern boundary of the facility, and on both sides of Airport Parkway at the 

northwestern corner of the facility. 

1.5.4 Current and Future Land Use

The So. Burlington AASF/RC serves the ARNG 86th Air Medical Company, the Operational 

Support Airlift, and the 15th Civil Support Team. The So. Burlington AASF/RC is an operating 

support and maintenance facility for rotary wing aircraft. In addition, the facility has administrative 

space for the 86th Air Medical Company, the Operational Support Airlift, and the 15th Civil Support 

Team. Reasonably anticipated future land use is not expected to change from the current land 

use.

1.5.5 Climate 

So. Burlington AASF/RC is within the Vermont Lowlands physiographic region. The region is 

bound by the Adirondack Mountains to the west in New York and the Green Mountains to the east, 

both of which rise high enough to afford protection from storms. Temperatures are moderated 

year round by the proximity of Lake Champlain to the west. Cool breezes blow inland off the lake 

in the summer; in the winter, the Lake acts as a heat reservoir that moderates local land 

temperature. Air temperature highs in July and lows in January average 80° Fahrenheit (F) and 

18°F, respectively (NOAA, 2018). 

Rainfall data indicates an average of approximately 38 inches of precipitation per year. 

Precipitation is well distributed throughout the year but typically heavier in the summer than in the 

winter. Strong thunderstorms in the summer produce the heaviest local rainfall intensities 

(NOAA,2018).
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Wells

!P Potable Well

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Muddy Brook

Watershed

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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

13

2. Fire Training Areas

During the site visit interviews, the VTARNG Environmental Manager confirmed that there are no 

FTAs at So. Burlington AASF/RC. FTAs are considered a primary potential release area for PFAS 

because of the common use of AFFF in training events. The VTANG Fire Department serves as 

the first responder to emergencies at So. Burlington AASF/RC. FTAs associated with the VTANG 

Fire Department are discussed in Section 5. The Colchester Fire Department also responds to 

fires at the facility.
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Facility/Readiness Center, Vermont

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3. Non-Fire Training Areas

Locations that are considered non-FTA include but are not limited to, hangars, fire stations, 

landfills, and other locations where AFFF may have been released or had potential to be released 

to the environment. One non-FTA was identified during the PA where AFFF is stored as part of a 

fire suppression system: the Maintenance and Storage Hangar. Two AFFF above ground storage 

tanks (ASTs) are stored within the hangar; one is situated in the fire suppression control room, 

and one is situated in the petroleum, oils, and lubricants (POL) storage room. A description of the 

ASTs and fire suppression system is presented below and shown on Figure 3-1. Interview records 

with relevant information appear in Appendix B, and site visit photographs are presented in 

Appendix C. 

3.1 Maintenance and Storage Hangar

The Maintenance and Storage Hangar is in the center of the facility property, northwest of Runway 

15 and the approximate center of flightline. The geographic coordinates and surface elevation at 

the approximate center of the hangar structure are 44°28’58.9” N, 73°09’55.9” W, and 305 feet 

amsl, respectively. The area is accessible only to So. Burlington AASF/RC personnel. The hangar 

has been in continuous use since its construction in 2007 and is used for aircraft maintenance 

and storage. The hangar is surrounded by flat paved, concreted surfaces to the west, north, and 

south, and a mix of paved and grassy areas that slope gently downhill to the east/northeast. 

Groundwater flow beneath the hangar is to the northwest.

The Maintenance and Storage Hangar has an automatic fire suppression system that uses AFFF. 

The ASTs, located within the fire suppression control room and POL storage room (Figure 3-1), 

are charged with a solution of water and Buckeye Platinum 3% Alcohol Resistant AFFF. 

Additionally, Chemguard 3% AFFF C-301MS concentrate is stored in three 55-gallon containers 

in the hangar fire suppression control room. Material safety data sheets for AFFF products 

currently or historically stored at the facility are included in Appendix A. According to the VTARNG 

Facilities Maintenance Manager, no AFFF releases have occurred in the fire suppression control 

room or POL storage room. Additionally, no AFFF has been released from this fire suppression 

system elsewhere in the hangar. Testing of the fire suppression system is completed by 

contractors regularly but does not require the release of fire suppression materials. AFFF at the 

facility has been procured through Firetech Sprinkler Corporation, and FireProTec provide the 

AFFF and test the fire suppression system on a regular basis without releasing fire suppression 

materials. According to VTARNG personnel, AFFF has not been disposed of to date. 

3.2 Waste Water Treatment Plant

There is no Waste Water Treatment Plant (WWTP) at So. Burlington AASF/RC. Surface water 

runoff from the building, parking areas, and helipad is part of a closed system draining to a 

stormwater pond that discharges to an unnamed tributary to the Winooski River. Stormwater 

runoff from the parking and roadway enters a grass channel to an existing swale that eventually 

drains to a wetland near the Winooski River. Sewer water is directed to an off-facility municipal 

WWTP. WWTPs are not usually a primary potential release area of PFAS, but sludges and liquids 

from areas of potential release that area treated at WWTPs may create a secondary source of 

contamination. No information obtained during the PA that indicated PFAS-related materials from 

the facility were treated at a WWTP.
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

15

3.3 Landfills

There are no landfills at So. Burlington AASF/RC. Landfills are not usually a primary potential 

release area of PFAS, but materials disposed of in landfills may create a secondary source of 

contamination. Such materials, to name a few, may include sludge from a WWTP that processes 

PFAS-laden water, used AFFF storage containers, or products associated with waterproofing 

uniforms or boots. At So. Burlington AASF/RC facility, no information obtained indicates PFASrelated materials were disposed of in a landfill.
Maintenance 

and Storage

Hangar

Stormwater Pond

Fire Supression

Control Room

POL Room

Legend

No Suspected Release

Facility Boundary

Wetland

River/Stream

Non-Fire Training Area

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4. Emergency Response Areas

The VTARNG Environmental Compliance Manager confirmed that no crashes or other 

emergencies resulting in AFFF use have occurred at So. Burlington AASF/RC since its use began 

in 2007; however, a private plane crash did occur within the current VTARNG facility footprint 

before the facility’s construction in 2005 and 2006. 

4.1 Cessna Private Plane Crash

A Cessna private plane crash occurred in 1988 within the current VTARNG facility footprint before 

its construction. The VTANG Fire Department responded to the crash and used AFFF to 

extinguish the crash flames. VTARNG construction activities in 2005 and 2006 may have resulted 

in the removal and regrading of some of the potentially contaminated soil, and a concrete slab 

now covers the former crash location (CH2M HILL, 2015). The approximate crash location is now 

the paved parking area southwest of the AASF/RC Maintenance and Storage Hangar. The type, 

volume, and concentration of AFFF used during the emergency response is unknown. The crash 

location is shown on Figure 4-1. Historical aerial imagery indicates that no surface water existed 

in the vicinity of the crash in 1988. AFFF used in response to the crash would likely have been 

sprayed directly onto the crashed aircraft and surrounding ground surface.
Maintenance 

and Storage

Hangar

Stormwater Pond

Cessna Private

Plane Crash

Legend

Potential PFAS Release

Facility Boundary

Wetland

River/Stream

Emergency Response Area

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South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

19

5. Adjacent Sources

Several off-facility PFAS sources adjacent to the So. Burlington AASF/RC were identified during 

the PA and are discussed below. Figure 5-1 presents the location of the potential adjacent PFAS 

sources. 

5.1 Vermont Air National Guard Fire and Non-Fire Training Areas

The Burlington Air National Guard Base property borders the So. Burlington AASF/RC to the east. 

The VTANG property occupies approximately 281 acres of the 942-acre Burlington International 

Airport property since 1951. Use of AFFF during training exercises and emergency responses, 

and accidental spills of AFFF have resulted in multiple releases of PFAS to the environment. In 

June 2015, the US Air Force Civil Engineer Center ordered the cease of all AFFF use except in 

the case of emergencies. The VTANG has conducted a PA (CH2M HILL, 2015) and an SI for 

PFAS and reported findings in 2018 (Aerostar SES LLC, 2018) (Appendix A). Based on the 

VTANG PA results, AFFF was released to the environment in six areas on or near the Burlington 

Air National Guard Base. Concentrations of PFAS in groundwater and surface water were 

detected above screening levels. Concentrations of PFAS in groundwater exceeded the 20 ppt 

Vermont Department of Health Drinking Water Health Advisory; there is no promulgated screening 

value for PFAS in surface water. The Cessna private plane crash, which the VTANG responded 

to with AFFF, is discussed in Section 4. A brief summary of the PFAS releases are summarized

below and shown on Figure 5-1. 

Potential VTANG Release Area Nature of Release

Former FTA-1 Fire training area with no known engineered 

containment where AFFF likely used as 

extinguishing agent. The type, volume, and 

concentration of AFFF used during the training 

activities is unknown.

Building 90 (Former Fire Station) Small quantity of AFFF storage and area in 

which fire department trucks are filled and 

washed.

Building 60 (Current Fire Station) Engineered containment area in which fire 

trucks are filled and washed with less than 0.5-

gallon confirmed release of AFFF in one area.

Fire Department Equipment 

Testing Area

Non-engineered containment area where 

equipment containing AFFF testing performed 

annually for several years. The type, volume,

and concentration of AFFF used is unknown.

Bird Strike Emergency Response 

at North End of Runway

AFFF was used to extinguish flames on the tail 

end of an F-16 after a bird strike incident in 

1995 or 1996. The specific location is 

unknown, likely on runway north of North 

Barrier Road. The type, volume, and 

concentration of AFFF used during the 

emergency response is unknown.
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

20

Potential VTANG Release Area Nature of Release

Private Plane Crash Emergency 

Response at North End of 

Runway

Discussed in Section 4.

Additionally, the VTANG currently stores AFFF in 5-gallon buckets in their Supply Building 70, 

located northeast of the current fire station. At the time of the VTANG PA site visit in 2015, a total 

of 515 gallons of 3% AFFF was stored in Building 70. There have been no reported spills or 

releases of AFFF in Building 70 (CH2M HILL, 2015). The VTANG PFAS PA report for the 

Burlington Air National Guard Base recommended initiating an SI for several of the areas 

identified in the table above, including the Cessna private plane crash location. The 2018 Final SI 

Report for the Burlington Air National Guard Base did not include an investigation of the Cessna 

private plane crash location (Aerostar SES LLC, 2018); the forthcoming expanded SI will 

investigate the area.

The VTANG is currently undergoing construction to accommodate for new aircrafts. Earth moving 

activities are occurring at VTANG facilities adjacent to the main Burlington International Airport 

flight line. 

5.2 Champlain Cable Corporation

The 39-acre Champlain Cable Corporation (CCC) property is located approximately 2 miles 

northwest of the So. Burlington AASF/RC. Founded in 1955, the CCC facility manufactures wire 

and cable coatings for the aircraft, computer, and energy industries. Industrial processes include 

metal cleaning and degreasing operations, thermoplastic extrusion of wire insulation, lacquer 

coating, tape wrapping, and cold drawing of wire to produce wire of various sizes. The waste 

products have historically contained lubricating solutions, degreasing solvents and liquid 

corrosives, and have been found to contain PFAS. 

Between 1966 and 1977, liquid wastes were poured onto the ground outside of the building, 

including along the roadway east of the facility and in an area northeast of the facility, referred to 

as the “sand pit” (USEPA, 1995). Groundwater samples collected in August 2018 showed PFAS 

detections in 23 of 24 wells sampled, with PFAS compounds exceeding the 20 ppt Vermont 

Department of Health Drinking Water Health Advisory in 22 samples. The highest total 

concentration of the five state-regulated compounds (7,065 ppt) was detected in the “sand pit” 

area, where state investigators are focusing their attention (ATC Group Services, LLC, 2018).

PFAS has also been detected in surface water on the adjacent VTARNG Camp Johnson property, 

with the source as yet undetermined (see Preliminary Assessment Report, Camp Johnson, 

Colchester, Vermont, February 2019). Although documented releases have occurred at the CCC 

facility, they are unlikely to affect the So. Burlington AASF/RC due to distance, groundwater flow 

direction, and their separation by the Winooski River.

.
Su nderland Brook

Winooski River

Stormwater Pond

VTANG AFFF Storage

VTANG F-16 Bird Strike Incident

VTANG Fire Department Equipment Testing Area

VTANG Fire Department

VTANG Former Fire Department

VTANG Former FTA-1

Champlain Cable Corporation

Legend

Potential PFAS Release

Facility Boundary

ANG Facility Boundary

Water Body

Wetland

River/Stream

0 1,400 2,800 5,600

Feet

Adjacent Sources

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Facility/Readiness Center, Vermont

22

6. Conceptual Site Model

Based on the PA findings, one AOI was identified at the So. Burlington AASF/RC: AOI 1 Cessna 

Private Plane Crash. The AOI location is shown on Figure 6-1. The following section describes 

the CSM components and the specific CSM developed for the AOI. The CSM identifies the three 

components necessary for a potentially complete exposure pathway: (1) source, (2) pathway, (3) 

receptor. If any of these elements are missing, the pathway is considered incomplete. 

In general, the potential PFAS exposure pathways are ingestion and inhalation. Dermal contact 

is not considered to be a potential exposure pathway as studies have shown very limited 

absorption of PFAS through the skin (National Ground Water Association, 2018). Receptors for 

the So. Burlington AASF/RC include site workers, construction workers, residents, and 

recreational users/trespassers. The CSM indicates which specific receptors could potentially be 

exposed to PFAS.

6.1 AOI 1 Cessna Private Plane Crash

AOI 1 is the location of the 1988 Cessna private plane crash. The VTANG Fire Department 

responded to the crash and used an unknown quantity of AFFF to extinguish the crash flames. 

VTARNG construction activities in 2005 and 2006 may have resulted in the removal and regrading 

of some of the potentially contaminated soil, and a concrete slab now covers the former crash 

location (CH2M HILL, 2015). The approximate crash location is now the paved parking area 

southwest of the facility maintenance and storage hangar. 

At the time of the crash, the area was unpaved, and AFFF may have infiltrated the ground. PFAS 

are water soluble and can migrate readily from soil to groundwater or surface water via leaching 

and run-off. Groundwater beneath the facility is classified by the Vermont Department of Water 

Resources as a Class III water resource (EarthTech, 1997), which is suitable for domestic water 

supply, irrigation, agricultural use, and general industrial and commercial use. Drinking water for 

VTANG and surrounding areas is provided by the CWD. Several drinking water wells, owned by 

private or local government entities, exist downgradient within 4 miles of the facility, but they are 

located beyond the Winooski River which acts as a natural hydraulic barrier (CH2M HILL, 2015). 

If PFAS is present in groundwater at the facility and migrates beyond the Winooski River, or 

unregistered private wells exist within the vicinity of the facility, residential use of groundwater for 

domestic purposes may expose residents to PFAS via ingestion. 

Stormwater drainage at the facility primarily occurs as sheet flow towards the artificial stormwater 

pond and tributaries of the Winooski River. Current migration of PFAS from the crash area to 

surface water is unlikely based on the paved surface. At the time of the crash, no surface water 

existed at the property. Additionally, the nearest unnamed tributary of the Winooski River is 

ephemeral in nature, with no known water intakes or collection points. As such, the pathway for 

site and construction workers, as well as recreational users and off-facility residents, to PFAS in 

the surface water and sediment at the facility is incomplete.

Surface soil at the AOI is paved over, resulting in an incomplete pathway for PFAS contamination 

in surface soil to all receptors; however, ground-disturbing activities beneath the pavement to 

subsurface soil could result in site and construction worker exposure to potential PFAS 

contamination in soil via ingestion and inhalation. Accidental ingestion of groundwater is not 

considered a complete pathway for exposure to PFAS during construction activities due to the 

depth to groundwater beneath the facility. The CSM for AOI is shown on Figure 6-2.
!P

!P

!5

!P

Winooski R iver

Winooski River

Winooski River

Stormwater Pond

Muddy Brook

Watershed

Winooski

River

Watershed

Fire Supression Control Room

POL Room

Cessna Private

Plane Crash

VTANG AFFF

Storage

VTANG F-16 Bird

Strike Incident

VTANG Fire Department

Equipment Testing Area

VTANG Fire Department

VTANG Former

Fire Department

VTANG Former

FTA-1

AOI 1

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

ANG Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow

Direction

Inferred Groundwater

Flow Direction

!P Potable Well

!5 Agricultural Well

Areas of Interest

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Media

SOURCE PATHWAY RECEPTOR

AOI 1 –

Cessna

Private

Plane Crash

Location

Emergency

Response

Flame 

Suppression

PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure 6-2

Conceptual Site Model

AOI 1 Cessna Private Plane Crash Location

Potential

Off-Facility

Source Not

under

Control of

ARNG

Recreational User

Recreational User

24
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South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

25

7. Conclusions

This report presents a summary of available information gathered during the PA on the use and 

storage of AFFF and other PFAS-related activities at So. Burlington AASF/RC. The PA findings 

are based on personnel interviews, environmental investigations and reports, historical 

documents, and the visual site inspection (Appendix A and Appendix B). 

7.1 Findings

One AOI related to potential PFAS release was identified at So. Burlington AASF/RC during the

PA (Figure 7-1):

Area of 

Interest

Name Used by Potential Release 

Dates

AOI 1 Cessna Private Plane 

Crash

Burlington International 

Airport 1988

AOI 1 is the location of a 1988 Cessna private plane crash that the VTANG Fire Department 

responded to with an unknown quantity of AFFF. Based on the known PFAS release at AOI 1, 

there is potential for exposure to PFAS contamination in subsurface soils to site and construction 

workers via inhalation and ingestion, and in groundwater to residents via ingestion if PFAS is 

present in groundwater at the facility and migrates beyond the Winooski River, or unregistered 

private wells exist within the vicinity of the facility. 

Additionally, the adjacent Burlington Air National Guard Base has documented releases of PFAS 

to the environment. According to the 2018 SI Report, AFFF releases at the adjacent Burlington 

Air National Guard Base have resulted in PFAS concentrations in groundwater and surface water 

above screening levels; however, no potential receptor pathways with immediate impacts to 

human health were identified. No exceedances were observed in soil or sediment. A forthcoming, 

expanded SI will include the investigation of the Cessna private plane crash location (AOI 1). 

Documented releases have also occurred at the CCC facility approximately 2 miles northwest, 

but these releases are unlikely to affect the So. Burlington AASF/RC.

7.2 Uncertainties 

A number of information sources were investigated during this PA to determine the potential for 

PFAS-containing materials to have been present, used, or released at the facility. Historically, 

documentation of PFAS use was not required because PFAS were considered benign. Therefore, 

records were not typically kept by the VTARNG or available during the PA on the use of PFAS in 

training, firefighting, other non-traditional activities, or on its disposition. 

The conclusions of this PA are predominantly based on the information provided during interviews 

with personnel who had direct knowledge of PFAS use at the facility. Sometimes the provided 

information was vague. Gathered information has a degree of uncertainty due to the absence of 

written documentation, the limited number of personnel with direct knowledge due to staffing 

changes, the time passed since PFAS was first used at the Burlington Air National Guard Base 

(1970 to June 2015). and a reliance on personal recollection. Inaccuracies may arise in potential 

PFAS release locations, dates of release, volume of releases, and the concentration of AFFF 

used. There is also a possibility the PA has missed a source of PFAS, as the science of how PFAS 

may enter the environment continually evolves.
Final PFAS Preliminary Assessment Report

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Facility/Readiness Center, Vermont

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In order to minimize the level of uncertainty, readily available data regarding the use and storage 

of PFAS was reviewed, multiple personnel were interviewed, multiple persons were interviewed 

for the same potential source area, and potential source areas were visually inspected.

The following table summarizes the uncertainties associated with the PA:

Area of Interest Source of Uncertainty

AOI 1 (Cessna Private

Plane Crash)

The type, volume, and concentration of AFFF released 

during the emergency response is unknown. Drainage 

pathways for the area prior to the construction of the 

VTARNG facility are unclear. The volume, if any, of

PFAS-containing materials removed during the 

construction of the facility is unknown. It is unclear 

whether potential PFAS at AOI 1 could be from

adjacent sources. 

Non-AOIs Source of Uncertainty

F-16 Bird Strike Incident The precise location of the incident is unknown. The 

type, volume, and concentration of AFFF released 

during the emergency response is unknown. Drainage 

pathways for the area prior to the construction of the 

VTARNG facility are unclear.

VTANG Fire Department 

Equipment Testing Area

The type, volume, and concentration of AFFF and 

duration released during nozzle testing is unknown. 

Runoff at this location flows northwest along the 

taxiway in the direction of the So. Burlington AASF/RC, 

it is unknown if runoff from the equipment testing area 

could migrate to the VTARNG facility.

VTANG Facilities Significant construction and earth moving on VTANG 

properties could have moved potential PFAS sources 

(i.e. soil) their original location. Identification of PFAS 

source areas could be obscured by recent and/or 

ongoing construction activities. 

Burlington International 

Airport

Recent construction of a large underground stormwater 

collection system on the west side of the Burlington 

International Airport flight line could have moved 

potential PFAS sources (i.e. soil) from their original 

location. Identification of PFAS source areas could be 

obscured by recent and/or ongoing construction 

activities at the airport. 
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

27

7.3 Potential Future Actions

Interviews with VTARNG facility staff whose first-hand knowledge span the entire history of the 

So. Burlington AASF/RC (2007-present) indicate that neither current nor past ARNG activities 

contributed PFAS contamination to soil, groundwater, surface water, or sediment at the facility or 

adjacent areas. 

Records and interviewees (whose first-hand facility knowledge span approximately 1988-present) 

indicate that VTANG Fire Department support may have resulted in potential PFAS releases at 

AOI 1 at the time of the crash. Based on the CSM developed for AOI 1, there is potential for site 

and construction workers to be exposed to PFAS contamination in subsurface soil. If PFAS is 

present in groundwater at the facility and migrates beyond the Winooski River, or unregistered 

private wells exist within the vicinity of the facility, residential use of groundwater for domestic 

purposes may expose residents to PFAS via ingestion. Table 7-1 summarizes the rationale used 

to determine if the AOI should be considered for further investigation under the CERCLA process 

and undergo a Site Inspection (SI). 

The VTANG PFAS PA Report for the adjacent Burlington Air National Guard Base recommended 

initiating an SI at the Cessna private plane crash location on VTARNG property (CH2M HILL, 

2015). The 2018 Final SI Report for the Burlington Air National Guard Base did not include an 

investigation of the Cessna private plane crash location (Aerostar SES LLC, 2018). Further 

assessment of PFAS impacts at each of the AFFF release areas already investigated may be 

warranted (via expanded SI or remedial investigation). The forthcoming expanded SI will 

investigate the Cessna private plane crash location. As such, future actions under the CERCLA 

process will be performed by the VTANG, not the VTARNG.

Table 7-1 PA Findings Summary

Area of Interest AOI Location Rational VTANG Potential 

Future Action

AOI 1 Cessna 

Private Plane 

Crash

44°48'24.3"N and 

73°16'56.1"W

Unknown quantity of AFFF 

used to extinguish the crash 

flames

Proceed to an SI, focus 

on soil and groundwater
Stormwater Pond

Fire Supression

Control Room

POL Room

Cessna Private

Plane Crash

AOI 1

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Wetland

River/Stream

Summary of Findings

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8. References

Aerostar SES LLC, 2018. Final Site Inspections Report of Fire Fighting Foam Usage at Vermont 

Air National Guard Burlington Air National Guard Base, Chittenden County, Vermont. January 

2018.

Air Force Civil Engineering Center (AFCEC), 2015. Final Preliminary Assessment Report for 

Perfluorinated Compounds at Vermont Air National Guard South Burlington, Vermont. 

ATC Group Services, LLC, 2018. Long Term Monitoring Report, August 2018 PFAS Sampling; 

Champlain Cable Corporation Facility. October 23, 2018.

Champlain Water District (CWD), 2018. Water Quality 2018.

http://www.champlainwater.org/vertical/sites/%7B0A660058-838C-4456-B2E9-

CCDA30420B07%7D/uploads/2018_Water_Quality_Report.pdf (Accessed August 2018)

CH2M HILL, 2015. Final Preliminary Assessment Report for Perfluorinated Compounds at 

Vermont Air National Guard, South Burlington, Vermont. October 2015.

DEW Construction Corp (DEW). Army Aviation Support Facility & Readiness Center.

http://www.dewcorp.com/portfolio-items/army-aviation-support-facility-readiness-center/. 

(Accessed August 2018)

EarthTech, 1997. Final Supplemental Remedial Investigation Report, Installation Restoration

Program for Sites 1 and 2, Volume I. August 1997.

Lens, J. E., Dewoolkar, M. M., Springton, G. E., and Becker, L. R., 2013. Seismic Hazard for the 

Burlington and Colchester, Vermont USGS 7-1/2 Minute Quadrangles. 

Marin Environmental Inc. 2001a. Phase I Environmental Baseline Study, Proposed Vermont 

National Guard AASF and Readiness Center.

Marin Environmental Inc. 2001b. Phase II Environmental Baseline Study, Proposed Vermont 

National Guard AASF and Readiness Center.

National Ground Water Association, 2018. Groundwater and PFAS: State of Knowledge and 

Practice. January 2018.

National Oceanic and Atmospheric Administration (NOAA). Climate of Vermont. 

https://www.ncdc.noaa.gov/climatenormals/clim60/states/Clim_VT_01.pdf. (Accessed July 

2018). 

Ratcliffe, N.M., Stanley, R.S., Gale, M.H., Thompson, P.J., and Walsh, G.J., 2011, Bedrock 

geologic map of Vermont: U.S. Geological Survey Scientific Investigations Map 3184, 3 sheets, 

scale 1:100,000.

US Environmental Protection Agency (USEPA), 1991. Guidance for Performing Preliminary 

Assessments under CERCLA. EPA/540/G91/013. September 1991. 

USEPA, 2015. Final Site Inspection Report, Champlain Cable Corporation, Colchester, Vermont. 

November 17, 1995.
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

30

USEPA, 2015. 2013-2015 Environmental Occurrence Data for the Unregulated Contaminant 

Monitoring Rule (UCMR) https://www.epa.gov/dwucmr/occurrence-data-unregulatedcontaminant-monitoring-rule#3. (Accessed August 2018)

U.S. Fish and Wildlife Service (USFWS) 2018. U.S. Fish and Wildlife Service National Wetlands 

Inventory. https://www.fws.gov/wetlands/data/Mapper.html. (Accessed August 2018). 

VANR, 2018. Department of Environmental Conservation – ANR Adopting Emergency PFAS 

Rules. July 16, 2018. https://dec.vermont.gov/news/PFAS-emergency-rule. (Accessed January 

9, 2019).

Vermont Department of Health, 2018. Memorandum: Drinking Water Health Advisory for Five 

PFAS (per- and polyfluorinated alkyl substances). July 10, 2018.

VTARNG, 2018. Stormwater Pollution Prevention Plan, Army Aviation Support Facility. 

September 5, 2018.

Wright, S., Fuller, S., Jones, S., McKinney, A., Rupard, S., Shaw, S. D., 2009, Surficial Geologic 

Map of the Burlington, Vermont 7.5 Minute Quadrangle, scale 1:23,000. 
Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix A

Data Resources
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PFAS Preliminary Assessment Report

South Burlington Army Aviation Support Facility/ 

Readiness Center Burlington, VT

Data Resources will be provided separately on CD. Data Resources for South Burlington Army 

Aviation Support Facility/ Readiness Center includes:

South Burlington Army Aviation Support Facility/ Readiness Center Deed Information

• 1968 South Burlington AASF/ RC Deed

Previous Investigations at South Burlington Army Aviation Support Facility/ Readiness 

Center

• 2001 Phase I Environmental Baseline Study

• 2001 Phase II Environmental Baseline Study

• 2015 Final Preliminary Assessment Report For Perfluorinated Compounds at Vermont Air 

National Guard South Burlington, Vermont

• 2015 South Burlington Army Aviation Support Facility/ Readiness Center Stormwater 

Pollution Prevention Plan Drainage Map

• 2018 Final Site Inspections Report of Fire Fighting Foam Usage at Vermont Air National 

Guard Burlington Air National Guard Base, Chittenden County, Vermont

South Burlington Army Aviation Support Facility/ Readiness Center Stored AFFF 

Information

• 2006 CHEMGUARD 3% AFFF C-301MS Material Safety Data Sheet

• 2015 BUCKEYE PLATINUM 3%-3% ARAFFF Safety Data Sheet

• 2015 BUCKEYE 3% MIL SPEC AFFF Safety Data Sheet

• 2017 ANSULITE 3% AFFF (AFC-3MS-C) Safety Data Sheet

South Burlington Army Aviation Support Facility/ Readiness Center EDR Report

• 2018 South Burlington Army Aviation Support Facility/ Readiness Center EDR Report

5385364
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix B

Preliminary Assessment Documentation
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix B.1

Interview Records
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VTARNG Interviewees:

Don Morrisseau

Tom Moore

LTC Rick Trayah

Notes from the interview with VTANG FD are included on the following pages.








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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix B.2

Visual Site Inspection Checklists
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix B.3

Conceptual Site Model Information
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Preliminary Assessment – Conceptual Site Model Information

Site Name: South Burlington Army Aviation Support Facility / Readiness Center

Why has this location been identified as a site?

This site is an ARNG facility with aviation assets that commonly use AFFF for fire suppression. It is also

located on an airstrip with potential neighboring PFAS sources. 

Are there any other activities nearby that could also impact this location?

The Burlington Air National Guard, Burlington International Airport, and other private aviation 

Industry facilities

Training Events

Have any training events with AFFF occurred at this site? No fire training has ever occurred at the facility

If so, how often? NA

How much material was used? Is it documented? NA

***AFFF is stored on the facility and charged in suppression systems****

Identify Potential Pathways: Do we have enough information to fully understand over land surface 

water flow, groundwater flow, and geological formations on and around the facility? Any direct 

pathways to larger water bodies?

Surface Water:

Surface water flow direction? Generally north/northwest towards the Winooski River

Average rainfall? Approximately 38 inches annually (NOAA, 2018)

Any flooding during rainy season? Unknown

Direct or indirect pathway to ditches? Yes

Direct or indirect pathway to larger bodies of water? Yes

Does surface water pond any place on site? Yes, along the eastern boundary

Any impoundment areas or retention ponds? Unknown

Any NPDES location points near the site? Unknown

How does surface water drain on and around the flight line? Drainage at the facility generally flows east

towards ponds and a stream tributary of the Winooski River
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction? Northeast, consistent with topography

Depth to groundwater? Groundwater in an area adjacent to the airport is approximately 10ft bgs

Uses (agricultural, drinking water, irrigation)? No known use. Champlain Water District (CWD) supplies

public water from Lake Champlain

Any groundwater treatment systems? No

Any groundwater monitoring well locations near the site? No known monitoring wells nearby

Is groundwater used for drinking water? No

Are there drinking water supply wells on installation? No

Do they serve off-post populations? No

Are there off-post drinking water wells downgradient Yes

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present? No

If so, do we understand the process and which water is/was treated at the plant? NA

Do we understand the fate of sludge waste? NA

Is surface water from potential contaminated sites treated? NA

Equipment Rinse Water

1. Is firefighting equipment washed? Where does the rinse water go?

Yes, at a non-engineered containment area and Building 90.

2. Are nozzles tested? How often are nozzles tested? Where are nozzles tested? Are nozzles cleaned after 

use? Where does the rinse water flow after cleaning nozzles?

Unknown

3. Other?
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker - Yes

Construction Worker - Yes

Recreational User - Yes

Residential - Potentially

Child 

Ecological - Yes

Note what is located near by the site (e.g. daycare, schools, hospitals, churches, agricultural, livestock)?

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur?
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Final PFAS Preliminary Assessment Report

South Burlington Army Avaiation Support 

Facility/Readiness Center, Vermont

Appendix C

Photographic Log
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Preliminary Assessment Report

South Burlington Army Aviation Support Facility/

Readiness Center Perfluorooctane-Sulfonic Acid (PFOS)

and Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS

South Burlington Army Aviation 

Support Facility/ Readiness Center Vermont

Photograph No. 1

Description:

View of AFFF AST stored in 

the POL storage room.

Photograph No. 2

Description:

Close-up view of the POL 

storage room AFFF AST 

containing 55-gallons of 

Buckeye Platinum 3% AFFF.
Preliminary Assessment Report

South Burlington Army Aviation Support Facility/ 

Readiness Center Perfluorooctane-Sulfonic Acid (PFOS) 

and Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS

South Burlington Army Aviation 

Support Facility/ Readiness Center Vermont

Photograph No. 3

Description:

View of AST used to 

pressurize fire suppression 

system.

Photograph No. 4

Description: 

View of three 55-gallon 

plastic containers stored in the 

fire suppression system closet.
Preliminary Assessment Report

South Burlington Army Aviation Support Facility/ 

Readiness Center Perfluorooctane-Sulfonic Acid (PFOS) 

and Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS

South Burlington Army Aviation 

Support Facility/ Readiness Center Vermont

Photograph No. 5

Description:

Close-up view of 55-gallon 

plastic container containing 

Chemguard 3% AFFF.

Photograph No. 6

Description: 

View of fire suppression 

system piping at ceiling level.
Preliminary Assessment Report

South Burlington Army Aviation Support Facility/

Readiness Center Perfluorooctane-Sulfonic Acid (PFOS)

and Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS

South Burlington Army Aviation 

Support Facility/ Readiness Center Vermont

Photograph No. 7

Description:

View of the fire suppression

control room AFFF AST and

fire suppression system piping 

components. This system 

serves the hangar.

Photograph No. 8

Description: 

View of carts stored in hangar 

containing dry chemical fire 

retardant.
Preliminary Assessment Report

South Burlington Army Aviation Support Facility/

Readiness Center Perfluorooctane-Sulfonic Acid (PFOS)

and Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM