FINAL

Site Inspection Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Site Inspection for Perfluorooctanoic Acid (PFOA), Perfluorooctanesulfonic Acid (PFOS), 

Perfluorohexanesulfonic Acid (PFHxS), Perfluorononanoic Acid (PFNA), Hexafluoropropylene 

Oxide Dimer Acid (HFPO-DA), and Perfluorobutanesulfonic Acid (PFBS)

ARNG Installations, Nationwide

August 2023

Prepared for:

Army National Guard Headquarters 

111 S. George Mason Drive 

Arlington, VA 22204

UNCLASSIFIED
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TABLE OF CONTENTS

Page

LIST OF APPENDICES................................................................................................................ iv

LIST OF FIGURES ........................................................................................................................ v

LIST OF TABLES......................................................................................................................... vi

LIST OF ACRONYMS AND ABBREVIATIONS ..................................................................... vii

EXECUTIVE SUMMARY ............................................................................................................ 1

1. INTRODUCTION ...............................................................................................1-1

1.1 Project Authorization............................................................................... 1-1

1.2 Site Inspection Purpose............................................................................ 1-1

2. FACILITY BACKGROUND..............................................................................2-1

2.1 Facility Location And Description........................................................... 2-1

2.2 Facility Environmental Setting ................................................................ 2-1

2.2.1 Geology.....................................................................................2-1

2.2.2 Hydrogeology ...........................................................................2-2

2.2.3 Hydrology .................................................................................2-3

2.2.4 Climate......................................................................................2-4

2.2.5 Current and Future Land Use....................................................2-4

2.2.6 Sensitive Habitat and Threatened/Endangered Species............2-4

2.3 History of PFAS use ................................................................................ 2-4

3. SUMMARY OF AREAS OF INTEREST...........................................................3-1

3.1 AOI 1 – Current Leach Field ................................................................... 3-1

3.2 AOI 2 – Former Leach Field.................................................................... 3-2

3.3 Adjacent Sources ..................................................................................... 3-2

4. PROJECT DATA QUALITY OBJECTIVES .....................................................4-1

4.1 Problem Statement................................................................................... 4-1

4.2 Information Inputs ................................................................................... 4-1

4.3 Study Boundaries..................................................................................... 4-1

4.4 Analytical Approach ................................................................................ 4-1

4.5 Data Usability Assessment ...................................................................... 4-2

5. SITE INSPECTION ACTIVITIES......................................................................5-1

5.1 Pre-Investigation Activities ..................................................................... 5-2
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5.1.1 Technical Project Planning .......................................................5-2

5.1.2 Utility Clearance .......................................................................5-2

5.1.3 Source Water and PFAS Sampling Equipment Acceptability..5-3

5.2 Soil Borings and Soil Sampling............................................................... 5-3

5.3 Temporary Well Installation and Groundwater Grab Sampling.............. 5-4

5.4 Synoptic Water Level Measurements...................................................... 5-5

5.5 Surveying ................................................................................................. 5-5

5.6 Investigation-Derived Waste ................................................................... 5-5

5.7 Laboratory Analytical Methods............................................................... 5-6

5.8 Deviations from SI UFP-QAPP Addendum ............................................ 5-6

6. SITE INSPECTION RESULTS ..........................................................................6-1

6.1 Screening Levels...................................................................................... 6-1

6.2 Soil Physicochemical Analyses............................................................... 6-2

6.3 AOI 1 – Current Leach Field ................................................................... 6-2

6.3.1 AOI 1 Soil Analytical Results...................................................6-2

6.3.2 AOI 1 Groundwater ..................................................................6-3

6.3.2.1 AOI 1 – Current Leach Field Groundwater Analytical Results.............................6-3

6.3.2.2 AOI 1 - Upgradient Source Area Groundwater Analytical Results......................6-3

6.3.3 Conclusions...............................................................................6-4

6.4 AOI 2 – Former Leach Field.................................................................... 6-4

7. EXPOSURE PATHWAYS..................................................................................7-1

7.1 Soil Exposure Pathway ............................................................................ 7-1

7.1.1 AOI 1 – Current Leach Field ....................................................7-2

7.1.1.1 AOI 1 – Upgradient Source Area.........................................................................7-2

7.1.2 AOI 2 – Former Leach Field.....................................................7-2

7.2 Groundwater Exposure Pathway.............................................................. 7-2

7.2.1 AOI 1 – Current Leach Field ....................................................7-3

7.2.1.1 AOI 1 – Upgradient Source Area.........................................................................7-3

7.2.2 AOI 2 – Former Leach Field.....................................................7-3

7.3 Surface Water and Sediment Exposure Pathway..................................... 7-4

7.3.1 AOI 1 – Current Leach Field ....................................................7-4

7.3.1.1 AOI 1 – Upgradient Source Area.........................................................................7-4
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7.3.2 AOI 2 – Former Leach Field.....................................................7-5

8. SUMMARY AND OUTCOME ..........................................................................8-1

8.1 SI Activities ............................................................................................. 8-1

8.2 Outcome................................................................................................... 8-1

9. REFERENCES ....................................................................................................9-1
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LIST OF APPENDICES

Appendix A. Data Usability Assessment and Validation Reports

Appendix B. Field Documentation

B1. Log of Daily Notice of Field Activities

B2. Sampling Forms 

B3. Survey Data

B4. Investigation-Derived Waste Placement Locations

Appendix C. Photographic Log

Appendix D. Technical Project Planning Meeting Minutes

Appendix E. Boring Logs and Well Construction Diagrams

Appendix F. Analytical Results

Appendix G. Laboratory Reports
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LIST OF FIGURES

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Surface Water Features

Figure 2-5 Groundwater Elevations, May 2022

Figure 3-1 Areas of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOS Detections in Soil

Figure 6-2 PFOA Detections in Soil

Figure 6-3 PFBS Detections in Soil

Figure 6-4 PFHxS Detections in Soil

Figure 6-5 PFNA Detections in Soil

Figure 6-6 PFOS, PFOA, and PFBS Detections in Groundwater

Figure 6-7 PFHxS and PFNA Detections in Groundwater

Figure 7-1 Conceptual Site Model, AOI 1 – Current Leach Field

Figure 7-2 Conceptual Site Model, AOI 1 – Upgradient Source Area

Figure 7-3 Preliminary Conceptual Site Model, AOI 2 – Former Leach Field
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LIST OF TABLES

ES-1 Screening Levels (Soil and Groundwater)

ES-2 Summary of Site Inspection Findings and Recommendations

5-1 Samples by Medium, New Hampshire National Guard Training Site, Center 

Strafford, New Hampshire Site Inspection Report

5-2 Soil Boring Depths and Temporary Well Screen Intervals, New Hampshire 

National Guard Training Site, Center Strafford, New Hampshire Site Inspection 

Report

5-3 Groundwater Elevation, New Hampshire National Guard Training Site, Center 

Strafford, New Hampshire Site Inspection Report

6-1 Screening Levels (Soil and Groundwater)

6-2 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil, Site Inspection 

Report, New Hampshire National Guard Training Site

6-3 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil, 

Site Inspection Report, New Hampshire National Guard Training Site

6-4 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Deep Subsurface Soil, Site 

Inspection Report, New Hampshire National Guard Training Site

6-5 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater, Site Inspection 

Report, New Hampshire National Guard Training Site

8-1 Summary of Site Inspection Findings and Recommendations
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LIST OF ACRONYMS AND ABBREVIATIONS

°C Degrees Celsius

°F Fahrenheit

% Percent

μg/kg Microgram(s) per kilogram

AECOM AECOM Technical Services, Inc. 

AFFF Aqueous Film Forming Foam

AGQS Ambient Quality Groundwater Standards

amsl Above mean sea level

AOI Area of Interest

ARNG Army National Guard

bgs Below ground surface

btoc Below top of casing

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

COC Chain-of-custody

CSM Conceptual site model

DA Department of the Army

DoD Department of Defense

DOT Department of Transportation

DPT Direct-push technology

DQI Data quality indicator

DQO Data quality objective

DUA Data Usability Assessment

EA EA Engineering, Science, and Technology, Inc., PBC

EB Equipment Blank 

EIS Extraction internal standards

ELAP Environmental Laboratory Accreditation Program

EM Engineer Manual

FB Field blank

FedEx Federal Express

ft Foot (feet)

FTS fluorotelomer sulfonate

GAC Granulated activated carbon

GPR Ground penetrating radar

GPS Global positioning system

HA Health Advisor

HDPE High-density polyethylene
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HFPO-DA Hexafluoropropylene oxide dimer acid

HQ Hazard Quotient

HSA hollow stem auger

IDW Investigation-derived waste

ITRC Interstate Technology Regulatory Council

LC/MS/MS Liquid chromatography tandem mass spectrometry

LCS Laboratory control sample 

LCSD Laboratory control sample duplicate

LOQ Limit of quantification

MIL-SPEC military specification

MS Matrix spike

MSD Matrix spike duplicate

NELAP National Environmental Laboratory Accreditation Program 

ng/L Nanogram(s) per liter

NHNGTS New Hampshire National Guard Training Site

No. Number

OSD Office of the Secretary of Defense

PA preliminary assessment

PFAS per- and polyfluoroalkyl substances

PFBS perfluorobutanesulfonic acid

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PID photoionization detector

ppt parts per trillion

PQAPP Programmatic Uniform Federal Policy Quality Assurance Project Plan

PVC polyvinyl chloride

QA Quality assurance

QAPP Quality Assurance Project Plan 

QC Quality control

QSM Quality Systems Manual

RI Remedial investigation 

RPD Relative percent difference

SDS Safety Data Sheet

SI Site Inspection

SL Screening level
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TOC Total organic carbon

TPP Technical Project Planning

UFP Uniform Federal Policy 

USACE U.S. Army Corps of Engineers

USEPA U.S. Environmental Protection Agency

Wood Wood Environment & Infrastructure Solutions, Inc.

WSP WSP USA Environment & Infrastructure, Inc.
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EXECUTIVE SUMMARY

The Army National Guard (ARNG) G-9 is performing Preliminary Assessments (PAs) and Site 

Inspections (SIs) at ARNG facilities nationwide based on the current or potential historical use of 

per- and polyfluoroalkyl substances (PFAS) with a focus on the six compounds presented in the 

memorandum regarding Investigating Per- and Polyfluoroalkyl Substances within the 

Department of Defense Cleanup Program (Assistant Secretary of Defense, 2022) from the Office 

of the Secretary of Defense (OSD) dated 6 July 2022. The six compounds listed in the OSD 

memorandum include perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), 

perfluorobutanesulfonic acid (PFBS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic 

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1

. These compounds are 

collectively referred to as “relevant compounds” throughout the document, and the applicable 

Screening Levels (SLs) are provided below in Table ES-1. 

The PA identified Areas of Interest (AOIs) where PFAS-containing materials were used, stored, 

and/or disposed, or released historically (see Table ES-2 for AOI locations). The objective of the 

SI is to identify whether there has been a release to the environment from the AOIs identified in 

the PA and determine whether further investigation is warranted, a removal action is required to 

address immediate threats, or no further action is required based a comparison of SI results to 

screening levels (SLs) for the relevant compounds. This SI was completed at the New Hampshire 

National Guard Training Site (NHNGTS) in Center Strafford, New Hampshire and determined 

that further investigation is warranted for AOI 1 (the only AOI investigated): Current Leach 

Field and AOI 2: Former Leach Field. NHNGTS will also be referred to as the “Facility” 

throughout this document. 

The Facility, operated by New Hampshire ARNG (NHARNG), encompasses approximately 

104.7 acres in Center Strafford, New Hampshire. The NHNGTS is located at 1 Austin Cate

Drive, Center Strafford, New Hampshire 03884. Agricultural lands border the Facility to the 

southeast and northwest. The northeast edge of the Facility and beyond is forested. Currently, the 

NHNGTS property is owned by the State of New Hampshire and operated by both the New 

Hampshire Army National Guard (federal technicians), and state employees who are personnel 

of the State of New Hampshire Department of Military Affairs and Veterans Services. 

The PA identified one AOI for investigation during the SI phase, based on engineering drawings 

that indicated that the current and former leach fields were in the same location. SI sampling 

results from the AOI were compared to OSD SLs. After the SI fieldwork was completed, 

NHARNG determined that the former leach field was located southwest (and upgradient) of the 

current leach field. Based on this new information, one additional potential PFAS release area 

was identified, AOI 2: Former Leach Field. As the identification of AOI 2 did not occur until 

after the SI fieldwork, AOI 2 was not investigated as part of the SI. Table ES-2 summarizes the 

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as 

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS.
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SI results for the AOIs. Based on the results of this SI, further evaluation under Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA) is warranted in a 

Remedial Investigation (RI) for the area upgradient of AOI 1. The detections in the groundwater 

at locations upgradient of AOI 1 may be related to the former leach field (AOI 2), an unidentified 

on-Facility source, or a potential off-Facility source not under control of ARNG. Potential 

upgradient sources will be investigated as part of the RI. No further action is warranted for AOI 

1. 

Table ES-1. Screening Levels (Soil and Groundwater)

Analyte1,2

Residential

(Soil)

(μg/kg)1

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg) 1

Tap Water

(Groundwater)

(ng/L)1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and 

Soil using United States Environmental Protection Agency’s (USEPA’s) Regional 

Screening Level Calculator. Hazard Quotient (HQ)=0.1. May 2022.

2. Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA 

(commonly referred to as GenX) was not included as an analyte at the time of this SI. Based 

on the CSM developed during the PA and revised based on SI findings, the presence of 

HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a component 

of MIL-SPEC AFFF and based on its history including distribution limitations that restricted 

use of GenX, it is generally not a component of other products the military used. In addition, 

it is unlikely that GenX would be an individual chemical of concern in the absence of other 

PFAS

Abbreviations:

μg/kg = microgram(s) per kilogram

bgs = below ground surface

ng/L = nanogram(s) per liter
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Table ES-2. Summary of Site Inspection Findings and Recommendations

AOI

Potential Release 

Area

Soil – 

Source Area

Groundwater –

Source Area Future Action

1 Current Leach Field

No Further 

Action

Source Upgradient 

of AOI 1

TBD Proceed to RI

2 Former Leach Field TBD TBD Proceed to RI

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
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1. INTRODUCTION

1.1 PROJECT AUTHORIZATION

The Army National Guard (ARNG) G-9 is the lead agency in performing Preliminary 

Assessments (PAs) and Site Inspections (SIs) at ARNG facilities nationwide based on the current 

or potential historical use of per- and polyfluoroalkyl substances (PFAS) with a focus on the six 

compounds presented in the memorandum regarding Investigating Per- and Polyfluoroalkyl 

Substances within the Department of Defense Cleanup Program (Assistant Secretary of Defense, 

2022) from the Office of the Secretary of Defense (OSD) dated 6 July 2022. The six compounds 

listed in the OSD memorandum are referred to as “relevant compounds” throughout this 

document and include perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), 

perfluorobutanesulfonic acid (PFBS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic 

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1. The ARNG performed 

this SI at the New Hampshire National Guard Training Site (NHNGTS) in Center Strafford, New 

Hampshire. The NHNGTS is also referred to as the “Facility” throughout this report.

The SI project elements were performed in accordance with the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA) (U.S. Environmental

Protection Agency [EPA], 1980), as amended, the National Oil and Hazardous Substances

Pollution Contingency Plan (40 Code of Federal Regulations Part 300; EPA, 1994), and in 

compliance with U.S. Department of Army (DA) requirements and guidance for field 

investigations.

1.2 SITE INSPECTION PURPOSE

A PA was performed at the NHNGTS (AECOM Technical Services, Inc. [AECOM], 2019) that 

identified one Area of Interest (AOI) where PFAS-containing materials were used, stored, and/or 

disposed, or released historically. The objective of the SI is to identify whether there has been a 

release to the environment from the AOI identified in the PA and determine whether further 

investigation is warranted, a removal action is required to address immediate threats, or no 

further action is required based on screening levels (SLs) for the relevant compounds.

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as 

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS.
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2. FACILITY BACKGROUND

2.1 FACILITY LOCATION AND DESCRIPTION

The NHNGTS occupies approximately 104.7 acres of land in Center Strafford in the Lakes 

Region of New Hampshire (Figure 2-1). Center Strafford is located approximately 7.5 miles 

southwest of Rochester, New Hampshire, and 24 miles northwest of Portsmouth, New 

Hampshire. Parker Mountain of the Blue Hill Range is located north of the Facility and Bow 

Lake is located several miles to the southwest. The Isinglass River is located several miles 

southeast. The Facility is accessible from Austin Cate Drive from the south, off Parker Mountain 

Road (Route 126).

The Facility was originally developed in 1833 as a boarding school under the name Strafford 

Union Academy. In the early 1900s, the school changed its name to the Austin Cate Academy 

and underwent several improvements over the course of the century. In 1985, the property was 

sold to the State of New Hampshire. Currently, the NHNGTS property is owned by the State of 

New Hampshire and operated by both the New Hampshire Army National Guard (federal 

technicians), and state employees who are personnel of the State of New Hampshire Department 

of Military Affairs and Veterans Services. 

2.2 FACILITY ENVIRONMENTAL SETTING

The approximate center of the Facility is located at 43°16'42.6" North latitude and 71°07'16.1" 

West longitude at 500 feet (ft) above mean sea level (amsl). The Facility topography is 

dominated by a ridge that separates the Facility into northern and southern drainage areas. The 

crest of the ridge lies northeast of the cantonment area and runs across the Facility. Agricultural 

lands border the Facility to the southeast and northwest. The northeast portion of the Facility and 

beyond is forested (AECOM, 2019).

Center Strafford is a rural residential community with a total population of approximately 4,114. 

Strafford County is primarily agricultural and forested land with a total population of 

approximately 130,090 (US Census Bureau, 2018; AECOM, 2019).

The following sections include information on geology, hydrogeology, hydrology, climate, and 

current and future land use. The topography at the Facility is shown on Figure 2-2. The regional 

geology and groundwater features are shown on Figure 2-3. The regional surface water features 

are shown on Figure 2-4. Groundwater elevations and contours are presented on Figure 2-5. 

2.2.1 Geology

Strafford County is situated within the New England Physiographic Province of the Appalachian

Highlands (Billings, 1980; AECOM, 2019). The Facility is underlain by Late Devonian Binary 

Granite. This medium-grained, gray granite is part of the Hampshire Plutonic series. The 

surrounding metamorphic bedrock is part of the Jenness Pond Schist of the Littleton Formation. 

Pleistocene deposits overlying igneous and metamorphic bedrock consist of glacial till, sand, 

gravel, and clay. Depth to bedrock is approximately 20 ft on the ridge just northeast of the 

cantonment area. Bedrock in the northeastern section of the Facility is identified as occurring 12 
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ft below ground surface (bgs) (Jacobs Engineering Group, 2013; AECOM, 2019). Data on depth 

to bedrock in the lower elevations of the Facility (near the wetlands in the northeastern portion of 

the Facility) are not available (NHARNG, 2014; AECOM, 2019). During the SI, depth to 

bedrock was observed from 5 to 14 ft bgs. 

During the SI, nine borings were advanced between 9 and 30 ft bgs. The soil was classified as 

well graded sand with varying levels of fines overlying low to medium plasticity silt at seven of 

the nine boring locations. The grain size analysis conducted on the soil sample collected from the 

AOI confirms the field observation of well graded sand and silt.

2.2.2 Hydrogeology

The shallow glacial stratified-drift aquifers, made up of layers of sand, gravel, clay, and silt 

overlying bedrock, are the primary source of groundwater in this region of New Hampshire.

Groundwater within the shallow overburden aquifer has been measured at varying depths across 

the Facility, likely due to variations in lithology and temporal variations in groundwater level. A 

hardpan soil layer is found just below the surface in the unforested parts of the Facility, which 

impacts vertical mobility of water; therefore, the infiltration of precipitation to recharge the 

shallow aquifer is limited. Groundwater flow in the overburden aquifer is presumed to follow the 

slope of the topography. There are no confining layers between the shallow aquifer and the 

bedrock aquifer below (Nobis Engineering, 2006; AECOM, 2019), providing a potential 

pathway for vertical migration from the overburden aquifer. The regional groundwater flow is to 

the east (ERT, 2008; AECOM, 2019). 

Static depth to groundwater measured during the May 2022 SI ranged from 7.93 to 17.18 ft bgs. 

Groundwater elevation contours from the SI are presented on Figure 2-5 and indicate the 

groundwater flow direction at AOI 1 is primarily to the northeast, following the topography.

Because the current leach field is designed as an infiltration area, localized mounding may occur 

resulting in radial flow away from the leach field (AECOM, 2019).

Groundwater is the primary source of drinking water in the Center Strafford area. Most, if not 

all, drinking water wells penetrate and derive water from the bedrock. NHNGTS is currently 

served by drinking water supply wells. There are institutional wells in Center Strafford less than 

one mile southeast of the Facility boundary and numerous private domestic drinking water wells 

surrounding the Facility (AECOM, 2019). Groundwater features in the vicinity of the Facility are 

shown on Figure 2-3.

The NHARNG sampled the private water supply wells at the NHNGTS (Well #1 and Well #4) 

for PFAS in March 2017. Two pre-treatment (pre-filtration) samples were collected, one from 

each well, and one post-treatment sample was collected, which consisted of water from both 

Well #1 and Well #4. Nine of the 18 PFAS compounds analyzed were detected in Well #4 pretreatment, with PFOS and PFOA detected at 5.12 and 9.38 parts per trillion (ppt), respectively. 

Only one PFAS compound, 6:2 fluorotelomer sulfonate (FTS), was detected in Well #1 pretreatment. All detected compounds were below the New Hampshire Ambient Groundwater 

Quality Standards (AGQS) and the United States Environmental Protection Agency (USEPA) 

Health Advisories (HAs) (Tetra Tech, 2017). The NHNGTS Well #5 was sampled for PFAS in 
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June 2020. None of the 18 PFAS compounds analyzed were detected in the Well #5 water 

sample (Bureau Veritas Laboratories, 2020). 

2.2.3 Hydrology

The Facility lies within the Nippo Brook - Isinglass River sub-watershed of the Cocheco River 

watershed. Surface water from the southern portion of the Facility flows south-southwest 

towards the Cocheco River, which eventually joins the Isinglass River (Nobis Engineering, 2006; 

AECOM, 2019). The elevation of the Mohawk River, located north of the Facility, is below the 

elevation of the surface of the groundwater near the Facility. Therefore, groundwater flow from 

the Facility is likely to flow into the Mohawk River, which acts as boundary preventing 

groundwater from the Facility interacting with drinking water wells east of the Mohawk River 

(ERT, 2008; AECOM, 2019). Surface water features in the vicinity of the Facility are shown on 

Figure 2-4.

Topography at the NHNGTS is dominated by a ridge that separates the Facility into a northern 

and southern drainage patterns. The crest of this ridge lies northeast of the cantonment area at the 

edge of the parade field and runs northwest to southeast. Based on topography and newly 

installed drainage, parts of the cantonment area likely drain to the southeast and southwest, and 

the operational ranges drain to the northeast. A hardpan layer is found below the surface of the 

unforested parts of the Facility. This low permeability layer restricts vertical movement of water, 

creating an erosion potential for the Facility during rain events (ERT, 2008; AECOM, 2019).

The wetland resources are situated on the northern end of the Facility at the base of a rather steep 

hill. The dominant wetland consists of a large scrub shrub and emergent beaver influenced 

wetland associated with an unnamed stream flowing roughly west to east across the Facility. 

Several intermittent streams flow out of this large wetland under the woods road through culverts 

and connect to other forested wetland areas. The flow in these streams appears to vary depending 

on water levels and beaver activity. Several intermittent streams, originating as hillside seeps, 

also flow in the wetland system from the south. A number of wetlands have been identified on 

and off the Facility as part of the National Wetlands Inventory Field, and delineation by the 

NHARNG further identified freshwater wetlands on the Facility. These wetlands include vernal 

ponds and both intermittent and permanent water bodies. Additionally, a small pond is located on 

the northern end of the NHNGTS (NHARNG, 2014; AECOM, 2019).

Stormwater flow within the cantonment area generally flows in a southerly direction toward New 

Hampshire Route 126. There are several storm drain structures, including small diameter cross 

culverts, under driveways and drainage pipes exiting isolated catch basins. Stormwater flowing 

off the Facility to the south disperses into drainage channels parallel to New Hampshire Route 

126. The remainder of the Facility consists of primarily pervious land cover, allowing for 

infiltration of precipitation. Stormwater runoff for the northern tier of the NHNGTS (beyond the 

cantonment area) generally flows in a northerly direction, draining to the wetland complex or the 

tributary to the Mohawk River (EA, 2018; AECOM, 2019).
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2.2.4 Climate

The Facility lies within the humid continental climate zone, which is characterized by long, cold, 

snowy winters, very warm (and at times humid) summers, and relatively brief autumns and 

springs. The average maximum temperature ranges from 83°Fahrenheit (°F) in July to 31°F in 

January. The average minimum temperature ranges from 58°F in July to 14°F in January. In 

winter, successive storms deliver light to moderate snowfall amounts, contributing to the 

relatively reliable snow cover. Summer can bring stretches of humid conditions, as well as 

thunderstorms. Average annual rainfall is 46 inches (US Climate Data, 2019; AECOM, 2019).

2.2.5 Current and Future Land Use

The NHARNG uses the NHNGTS for federal small arms and maneuver training. Facilities at the 

NHNGTS include a kitchen and dining hall, a drill hall, a running track, barracks buildings, and 

multiple-use operational range areas. The entire Facility, including all ranges, is also open for 

public recreational use and hunting. The NHARNG does not regulate hunting on the Facility but 

estimates that there are less than 20 hunters per year (ERT, 2008; AECOM, 2019). The Facility 

is not fenced and is open to the public.

Future land use will intensify over the next few years under a newly proposed Master Plan which 

will maximize development at the NHNGTS. New barracks and training ranges are part of the 

proposed facilities. Future land use in the immediate area is not expected to change and will 

remain rural in character.

2.2.6 Sensitive Habitat and Threatened/Endangered Species

A number of wetlands have been identified at the northern end of the Facility as part of the 

National Wetlands Inventory (AECOM, 2019), however, a wildlife survey of the Facility was not 

available. Sensitive habitat includes the exemplary natural community of the black gum-red 

maple swamp at the far northeast of the property. The following species are listed as federally 

endangered, threatened, proposed, and/or candidate species in Strafford County, New Hampshire 

(U.S. Fish and Wildlife Service, 2022):

Birds: Roseate Tern, Sterna dougallii (endangered).

Insects: Monarch Butterfly, Danaus plexippus (candidate)

Mammals: Northern Long-eared Bat, Myotis septentrionalis (threatened).

Flowering Plants: Small Whorled Pogonia, Isotria medeoloides (threatened).

2.3 HISTORY OF PFAS USE

The NHNGTS currently uses a single common leach field (constructed in 1993) for wastewater 

disposal for the entire Facility. Septic tanks are located outside each building, and then individual 

building sewage is collected by gravity sewers and conveyed to the leach field via a single pump 
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station and twin force mains. The leach field piping is located below ground surface. Engineering 

drawings reviewed during the PA indicated that the current leach field was built in the same 

location as the former leach field (AECOM, 2019), however, after the SI fieldwork was 

completed, information was provided by NHARNG indicating that the former leach field was 

located southwest (and upgradient) of the current leach field. The approximate geographic 

coordinates for the current leach field are 43°16'31.9"N; 71°07'28.8"W (AECOM, 2019).

The former leach field was constructed prior to the NHNGTS occupying the property. The 

former leach field was utilized by the Austin Cate Academy, and by the NHNGTS from 1985 

until 1993, when the new leach field was constructed. Based on information provided by 

NHARNG after the SI, the location of the former leach field was southwest (and upgradient) of 

the current leach field. 

In the PA, the current and former leach fields were thought to be in the same location and were

identified as an AOI (AOI 1) due to discharges of floor polish, which potentially contain PFAS, 

to drains connected to the Facility’s septic system. According to NHNGTS personnel, the floors 

in the kitchen and drill hall are polished with Centi Finish floor polish. The floor polish is mixed 

with water in a bucket, and after polishing is complete, the unused mixture is discharged to the 

drain in each respective building. The mixture is subsequently transported through the Facility’s 

septic system to the leach field and released to the subsurface (AECOM, 2019). The Centi Finish 

bottle and Safety Data Sheet (SDS) maintained by the NHNGTS indicate the formula is 

proprietary; however, some floor polishes are known to contain PFAS. The SDS was dated 2012, 

but interviewees were unaware of when use of the Centi Finish began. It is likely that floor 

polish (Centi Finish or possibly other brands) has been used in buildings since the NHARNG 

occupied the buildings (AECOM, 2019).

During preparation of the SI Report, it was discovered that the current leach field was not 

constructed in the same location as the former leach field. AOI 1, which was investigated during 

the SI, is the location of the current leach field. The former leach field was located southwest 

(and upgradient) of the current leach field and was not investigated as part of the SI. Following 

the SI, the former leach field was identified as a second AOI (AOI 2) due to the potential 

discharge of floor polish while it was in use. AOI 2 will be investigated as part of the RI. 

A description of the AOI is presented in Section 3. 
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Figure 2-1

Facility Location

3

0 1

Miles

Data Sources:

ESRI 2020

AECOM 2019

Date:...................September 2022

Prepared By:........................WSP

Prepared For:.....................USACE

)

NH

Facility Data

Facility Boundary

New Hampshire

National Guard

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Figure 2-2

Facility Topography

3

0 1

Miles

Data Sources:

ESRI 2020

AECOM 2019

Date:...................September 2022

Prepared By:........................WSP

Prepared For:.....................USACE

)

NH

New Hampshire

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Facility Data

Facility Boundary

Note:

Contour elevation recorded in ft. asml.
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Figure 2-3

Groundwater Features

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Data Sources: 

NHDES 2021

ESRI 2020

AECOM 2019

Note:Certain features digitized from

georeferenced AECOM Preliminary

Assessment Report (2019) figures.

Geology

Concord Granite

Perry Mountain

Formation

Date:....................September 2022

Prepared By:........................WSP

Prepared For:.....................USACE

Domestic wells, institutional wells, NHNGTS water supply wells. and unkown wells digitized from AECOM 2019 Preliminary Assessment Report.

Water wells digitized from NHDES One Stop online data mapper, accessed on 10/14/2021.

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0 0.5

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River/Stream

Water Body

Wetland

Hydrology/Hydrogeology

Local Groundwater Flow Direction

Inferred Local Groundwater Flow

Direction

Regional Groundwater Flow Direction
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Figure 2-4

Surface Water Features

Big River

Watershed

Nippo

Brook-Isinglass

River Watershed

Long Pond

Watershed

Unnamed Tributary

Mohawk River

Cochec o Rive r

0 3 2,400

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ESRI 2020

AECOM 2019

National Hydrography Dataset

Date:...................September 2022

Prepared By:........................WSP

Prepared For:.....................USACE

Facility Data

Facility Boundary

Hydrology/Hydrogeology

General Surface Water Flow Direction

River/Stream

Water Body

Wetland

Watershed

)

NH

Data Sources:

Note: Certain features digitized from

georeferenced AECOM Preliminary

Assessment Report (2019) figures.
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Figure 2-5 

Groundwater Elevations

May 2022

!(

!(

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NHNGTS Current

Leach Field

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AOI01-04

586.45

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610

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3

0 200

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Date:........................March 2022

Prepared By:........................WSP

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Facility Data

Area of Interest

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Note: Certain features digitized

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Preliminary Assessment Report

(2020) figures.

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Hydrology/Hydrogeology

Local Groundwater Flow Direction

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3. SUMMARY OF AREAS OF INTEREST

The PA evaluated areas where PFAS-containing materials may have been used, stored, disposed, 

or released historically. Based on the PA findings, one potential release area was identified at 

NHNGTS and identified as: AOI 1 Current and Former Leach Field. During preparation of the SI

Report, it was discovered that the current leach field was not constructed in the same location as 

the former leach field. AOI 1, which was investigated during the SI, is the location of the current 

leach field. The former leach field was located southwest (and upgradient) of the current leach 

field and was not investigated as part of the SI. Following the SI, the former leach field was 

identified as a second AOI (AOI 2) due to the potential discharge of floor polish while it was in 

use. AOI 2 will be investigated as part of the RI. The AOIs are shown on Figure 3-1.

3.1 AOI 1 – CURRENT LEACH FIELD

AOI 1 is the current leach field. According to interviews with NHNGTS personnel, floor polish 

is used in the kitchen and drill hall, and after polishing is complete, the unused polish mixture is 

poured into the drain in each respective building (AECOM, 2019). Although the brand used by 

the NHNGTS has a proprietary formula, and therefore PFAS content cannot be confirmed, some 

floor polishes are known to contain PFAS (Interstate Technology Regulatory Council [ITRC],

2017). Drains in the buildings lead to septic tanks located outside each building, and then 

individual building sewage is conveyed to the leach field. The current leach field was 

constructed in 1993, prior to which, the former leach field was used (See Section 3.2). 

Because liquids potentially containing PFAS were discharged into the wastewater system which 

flows to the leach field, and the piping for the leach field was below the ground surface, there is 

the potential for PFAS to have been released directly to the subsurface soil (AECOM 2019). 

Groundwater is the primary source of drinking water in the Center Strafford area. Most, if not 

all, drinking water wells penetrate and derive water from the bedrock. NHNGTS is currently 

served by three private, ARNG-owned drinking water supply wells, there are two municipal 

wells in Center Strafford less than one mile southeast of the Facility boundary, and there are 

numerous domestic drinking water wells surrounding the Facility (Figure 2-3). Additionally, 

there are agricultural areas in the vicinity that may produce products for human consumption. 

Regional groundwater flow is to the east and local groundwater flow follows the topography, 

which is toward the northeast at AOI 1. Because the leach field is designed as an infiltration area, 

localized mounding may occur resulting in radial flow away from the leach field (AECOM,

2019). There are no confining layers between the shallow aquifer and the bedrock aquifer below 

(Nobis Engineering, 2006; AECOM, 2019), providing a potential pathway between AOI 1 and 

the bedrock aquifer below. 

PFAS are water soluble and can migrate readily from soil to groundwater. Because potential 

PFAS releases to subsurface soil at AOI 1 may have occurred, PFAS may migrate from the 

subsurface soil to the groundwater via leaching. 
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3.2 AOI 2 – FORMER LEACH FIELD

Following the SI fieldwork, new information was provided by NHARNG indicating that the 

current leach field had not been constructed in the location of the former leach, as was previously 

noted in the PA. The former leach field was located southwest and upgradient of the current 

leach field. The former leach field was used by the Austin Cate Academy and was also used by 

the NHNGTS from 1985 to 1993.

Regional groundwater flow is to the east and local groundwater flow is assumed to follow the 

topography. Groundwater elevations were not measured in the location of AOI 2 during the SI;

however, the groundwater flow is likely north/northeast based on the topography. There are no 

confining layers between the shallow aquifer and the bedrock aquifer below (Nobis Engineering,

2006; AECOM, 2019), providing a potential pathway between AOI 2 and the bedrock aquifer 

below. 

PFAS are water soluble and can migrate readily from soil to groundwater. Because potential 

PFAS releases to subsurface soil at AOI 2 may have occurred, PFAS may migrate from the 

subsurface soil to the groundwater via leaching. 

3.3 ADJACENT SOURCES

The Strafford Fire and Rescue Station is located approximately two miles south of the NHNGTS 

and could be a potential off-Facility source of PFAS. The Strafford Fire and Rescue Station has 

the potential for current or historical use of AFFF, but this was not confirmed during the PA. 

Based on the topography of the Facility, this source is not expected to impact PFAS 

concentrations in shallow groundwater at the Facility. However, the groundwater gradient for the 

bedrock aquifer is largely influenced by fractures in crystalline bedrock and drinking water wells 

in the vicinity of the NHNGTS vary considerably in depth. While the regional groundwater flow 

is to the east, it is unclear if potential PFAS sources adjacent to the Facility are located 

hydraulically downgradient, or upgradient, of the NHNGTS bedrock water supply wells 

(AECOM, 2019).

The potential off-Facility source is shown on Figure 3-1.
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Figure 3-1

Areas of Interest

Nippo

Brook-Isinglass

River Watershed

Town of Strafford

Fire and

Rescue Station

Drake Hill Rd

E Province Rd

Meetinghouse Rd

Drake Hill Rd

Roller Coaster Rd

Meetinghouse Rd

Province Rd

Nippo

Brook-Isinglass

River Watershed

AOI 1 NHNGTS 

Current Leach Field

AOI 2 NHNGTS 

Former Leach Field

Roller Coaster Rd

Strafford Rd

Scribner Rd

Parker Mountain Rd

Parker Mountain Rd

)

NH

Date:..........................March 2023

Prepared By:........................WSP

Prepared For:.....................USACE

Note: Certain features digitized from

georeferenced AECOM Preliminary

Assessment Report (2019) figures.

Well Type

!( Water Well

&( Domestic Well

!. Institutional Well

A! Unknown Well

Facility Data

Area of Interest

Potential PFAS Release

Facility Boundary

Hydrology/Hydrogeology

River/Stream

Water Body

Wetland

Local Groundwater Flow Direction

Inferred Local Groundwater Flow Direction

Regional Groundwater Flow Direction

Surface Water Flow Direction

0 1,200

Feet

0 200

Feet

1 2

Domestic wells, institutional wells, 

NHNGTS water supply wells. 

and unkown wells digitized from 

AECOM 2019 Preliminary Assessment Report.

Water wells digitized from NHDES One Stop 

online data mapper, accessed on 10/14/2021.

3 3

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4. PROJECT DATA QUALITY OBJECTIVES

As identified during the Data Quality Objective (DQO) process and outlined in the SI Uniform 

Federal Policy (UFP)-Quality Assurance Project Plan (QAPP) Addendum (EA Engineering, 

Science, and Technology, Inc., PBC [EA]/Wood, 2022), the objective of the SI is to identify 

whether there has been a release to the environment at the AOIs identified in the PA. For each

AOI, ARNG determines if further investigation is warranted, a removal action is required to 

address immediate threats, or whether no further action is warranted. This SI evaluated 

groundwater and soil for the presence or absence of relevant compounds at the sampled AOI.

4.1 PROBLEM STATEMENT

ARNG will recommend AOIs for remedial investigation (RI) if site-related soil and groundwater 

samples have concentrations of the relevant compounds above the OSD risk-based screening 

levels. The SLs are presented in Section 6.1 of this Report.

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for NHNGTS (AECOM, 2019);

• Analytical data from groundwater and soil samples collected as part of this SI in 

accordance with the site-specific UFP –QAPP Addendum (EA/Wood, 2022); and

• Field data collected during the SI, including groundwater elevation and water quality 

parameters measured at the time of sampling.

4.3 STUDY BOUNDARIES

The scope of the SI was bounded horizontally by the property limits of the Facility (Figures 2-1 

and 2-2). The scope of the SI was bounded vertically by the depth of temporary monitoring wells 

installed within groundwater, where encountered (maximum depth of 30 ft bgs). Off-Facility

sampling was not included in the scope of this SI. If future off-Facility sampling is required, the 

proper stakeholders will be notified, and necessary rights of entry will be obtained by ARNG 

with property owner(s). Temporal boundaries were limited to the earliest available time field 

resources were available to complete the study.

4.4 ANALYTICAL APPROACH

Samples were analyzed by Eurofins, accredited under the DoD Environmental Laboratory 

Accreditation Program (DoD ELAP; Accreditation Number 1.01) and the National 

Environmental Laboratory Accreditation Program (NELAP; Certificate Number 021). Data were 

compared to applicable SLs and decision rules as defined in the UFP-QAPP Addendum 

(EA/Wood, 2022). 
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4.5 DATA USABILITY ASSESSMENT

The Data Usability Assessment (DUA), which is provided in Appendix A, is an evaluation at the 

conclusion of data collection activities that uses the results of both data verification and 

validation in the context of the overall project decisions or objectives. Using both quantitative 

and qualitative methods, the assessment determines whether project execution and the resulting 

data have met installation specific DQOs. Both sampling and analytical activities are considered 

to assess whether the collected data are of the right type, quality, and quantity to support the 

decision-making (DoD, 2019a; DoD, 2019b; USEPA, 2017).

Based on the DUA, the environmental data collected during the SI were found to be acceptable 

and usable for this SI evaluation with the qualifications documented in the DUA and its 

associated data validation reports. These data are of sufficient quality to meet the objectives and 

requirements of the UFP-QAPP (EA, 2020).
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5. SITE INSPECTION ACTIVITIES

This section describes the environmental investigation and sampling activities that occurred as 

part of the SI. The SI sampling approach was based on the findings of the PA and was 

implemented in accordance with the following approved documents. 

• Final Preliminary Assessment Report, New Hampshire National Guard Training 

Site, New Hampshire, dated December 2019 (AECOM, 2019)

• Final Programmatic Uniform Federal Policy-Quality Assurance Project Plan,

Site Inspections for Per- and Polyfluoroalkyl Substances Impacted Sites, ARNG 

Installations, Nationwide, dated December 2020 (EA, 2020)

• Final Site Inspection Uniform Federal Policy-Quality Assurance Project Plan 

Addendum, New Hampshire National Guard Training Site, New Hampshire dated

May 2022 (EA/Wood, 2022)

• Final Programmatic Accident Prevention Plan, dated October 2021 (EA, 2021)

• Final Site Safety and Health Plan, New Hampshire National Guard Training Site, 

New Hampshire, dated October 2021 (EA/Wood, 2021). 

The SI field activities were conducted from 9 to 23 May 2021 and consisted of utility 

clearance, direct-push technology (DPT) and hollow stem auger (HSA) boring

installation and soil sample collection, temporary monitoring well installation, grab 

groundwater sample collection, and land surveying. Field activities were conducted in 

accordance with the UFP-QAPP Addendum (EA/Wood, 2022), except as noted in 

Section 5.8.

The following samples were collected during the SI and analyzed for 24 compounds via 

liquid chromatography/tandem mass spectrometry (LC/MS/MS) compliant with QSM 

Version 5.3 Table B-15 to fulfill the project DQOs:

• Seven (7) soil samples from three locations (AOI01-01, AOI01-02, and AOI01-

03);

• Six (6) grab groundwater samples from temporary well locations (AOI01-04 

through AOI01-09);

• Fifteen (15) quality assurance (QA)/QC samples.

Figure 5-1 provides the sample locations for all media across the Facility. Table 5-1

presents the list of samples collected for each medium. Field documentation is provided 

in Appendix B. A log of Daily Notice of Field Activity was completed throughout the SI 

field activities, which is provided in Appendix B1. Sampling forms are provided in 

Appendix B2, and land survey data are provided in Appendix B3. Investigation-derived 

waste (IDW) placement locations are shown in Appendix B4. Additionally, a 

photographic log of field activities is provided in Appendix C.
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5.1 PRE-INVESTIGATION ACTIVITIES

In preparation for the SI field activities, project team members participated in Technical Project 

Planning (TPP) meetings, performed utility clearance, and sampled decontamination source 

water. Details of these activities are presented below.

5.1.1 Technical Project Planning

The U.S. Army Corps of Engineers (USACE) TPP Process, Engineers Manual (EM) 200-1-2 

(DA 2016a) defines four phases to project planning: (1) defining the project phase; (2)

determining data needs; (3) developing data collection strategies; and (4) finalizing the data

collection plan. The process encourages stakeholder involvement in the SI, beginning with 

defining overall project objectives, including DQOs, and formulating a sampling approach to 

address the AOI identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 18 March 2022, prior to SI field activities.

Meeting minutes are provided in Appendix D. The combined TPP Meeting 1 and 2 was 

conducted in general accordance with EM 200-1-2. The stakeholders for this SI include, ARNG, 

USACE, NHARNG, NHDES, and representatives familiar with the Facility, the regulations, and 

the community. Stakeholders were provided the opportunity to make comments on the technical 

sampling approach and methods at the combined TPP Meeting 1 and 2. The outcome of the 

combined TPP Meeting 1 and 2 was memorialized in the UFP-QAPP Addendum (EA/Wood, 

2022). 

A TPP Meeting 3 was held after the field event to discuss the results of the SI. Meeting minutes 

for TPP 3 are included in Appendix D of this report. Future TPP meetings will provide an 

opportunity to discuss results and findings, and future actions, where warranted. 

5.1.2 Utility Clearance

WSP USA Environment & Infrastructure, Inc. (WSP), formerly doing business as Wood

Environment & Infrastructure Solutions, Inc. (Wood), contacted DigSafe to notify them of 

intrusive work at the Facility. WSP contracted Corbuilt, LLC, a private utility location service, to 

perform utility clearance at the Facility. Utility clearance was performed at each of the proposed

boring locations on 9 May 2022 with input from the WSP field team. General locating services

and ground-penetrating radar (GPR) were used to complete the clearance. Additionally, an 

attempt was made to pre-clear the first 5 ft of each boring using a hand auger by WSP’s drilling

subcontractor, Parratt-Wolff, Inc. Due to shallow hard pan, hand auger refusal occurred 

shallower than 5 ft bgs at all locations. Concurrence from stakeholders was received on 10 May

2022 to deviate from the UFP-QAPP requirement to hand auger the first 5 ft at each boring and 

proceed with DPT methods based on the results of the Dig Safe and results from the private

utility locating. 
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5.1.3 Source Water and PFAS Sampling Equipment Acceptability

The potable water source used for decontamination of drilling equipment was confirmed to meet 

acceptability criteria, as defined in the UFP-QAPP Addendum, prior to the start of field 

activities. A sample from a potable water source at the NHNGTS, was collected on 8 April 2022, 

prior to mobilization, and analyzed for PFAS by LC/MS/MS compliant with QSM 5.3 Table B15 (DoD, 2020). The results of the sample of the potable water source used for decontamination 

of drilling equipment during the SI are provided in Appendix F. A discussion of the results is 

presented in the DUA (Appendix A).

Materials that were used within the sampling zone were confirmed as acceptable for use in the

PFAS sampling environment. The checklist of acceptable materials for use in the PFAS sampling 

environment was provided in the Standard Operating Procedures appendix to the Programmatic 

UFP-QAPP (PQAPP) (EA, 2020). 

5.2 SOIL BORINGS AND SOIL SAMPLING

Soil samples were collected via DPT drilling methods in accordance with Standard Operating 

Procedure 047 Direct-Push Technology Sampling (EA, 2020). A Geoprobe® 7822DT dual-tube 

sampling system was used to collect continuous soil cores to the target depth. An attempt was 

made to use a hand auger to clear the top 5 ft of each boring in compliance with utility clearance 

procedures; however, hand auger refusal occurred shallower than 5 ft bgs at all locations. As the 

locations had all been pre-cleared for utilities, drilling proceeded using DPT methods (see 

Section 5.1.2). The soil boring locations are shown on Figure 5-1, and boring sample depths are 

provided in Table 5-1. Several boring locations were adjusted within a 50-ft offset for reasons 

including drill rig access, utility avoidance and bias toward sampling within observed drainage 

features.

Discrete soil samples were collected for chemical analysis at three locations in the vicinity of the 

current leach field: AOI01-01, AOI01-02, and AOI01-03. At each of these locations, one shallow 

subsurface soil sample was collected (3 to 5 ft bgs) and one deeper subsurface soil samples was 

collected at approximately 1 foot above the groundwater table (5 to 9 ft bgs). Additionally, one 

soil sample was collected at the mid-point between the surface and the groundwater table at 

AOI01-01 (5 to 7 ft bgs). Due to shallow groundwater, midpoint samples were not collected at 

AOI01-02 and AOI01-03. Groundwater was encountered at depths ranging from 8.6 to 29 ft bgs 

during drilling. Total boring completion depths, to accommodate temporary well installation, 

ranged from 15 to 30 ft bgs.

During the drilling, the soil cores were continuously logged for lithological descriptions by a 

field geologist using the Unified Soil Classification System. A photoionization detector (PID) 

was used to screen the breathing zone during boring activities as a part of personal safety 

requirements. Observations and measurements were recorded on sampling forms (Appendix B2) 

and in a non-treated field logbook. Depth interval, recovery thickness, PID concentrations, 

moisture, relative density, Munsell color, and Unified Soil Classification System texture were 

recorded. The boring logs are provided in Appendix E. 
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Soil borings completed during the SI classified the soil as sand with varying levels of fines 

overlying a layer of low to medium plasticity silt with varying levels of clay and sand as the 

lithology of the unconsolidated sediments below the NHNGTS. Bedrock was identified at depths 

between 5 and 14 ft bgs. The borings were completed at depths between 9 and 30 ft bgs. These 

observations are consistent with the understood depositional environment of the region.

Each sample was collected into a laboratory-supplied PFAS-free high-density polyethylene 

(HDPE) bottle and labeled using a PFAS-free marker or pen. Samples were packaged on ice and 

transported via Federal Express (FedEx) under standard chain-of-custody (COC) procedures to 

the laboratory and analyzed for PFAS (LC/MS/MS compliant with QSM Version 5.3 Table B15), total organic carbon (TOC) (EPA Method 9060A), pH (EPA Method 9045D), and grain size 

(ASTM Method D-422) in accordance with the UFP-QAPP Addendum (EA/Wood, 2022). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. Matrix Spike/Matrix Spike Duplicates (MS/MSDs) were collected at 

a rate of 5% and analyzed for the same parameters as the accompanying samples. In instances 

when non-dedicated sampling equipment was used, such as a hand auger for the shallow soil 

samples, one equipment blank (EB) was collected per day and analyzed for the same parameters 

as the soil samples. A temperature blank was placed in each cooler for use in confirming that 

samples were preserved at or below 6 degrees Celsius (°C) during shipment. 

DPT borings were converted to temporary wells, which were subsequently abandoned after 

sampling and surveying in accordance with the UFP-QAPP Addendum (EA/Wood 2022). After 

removal of the casings, boreholes were abandoned using bentonite chips. 

5.3 TEMPORARY WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Temporary monitoring wells were installed using a Geoprobe® 7822DT drill rig using both 

direct-push and HSA drilling methods, supplemented with an air hammer where groundwater 

was encountered deeper than top of bedrock. Once the borehole was advanced to the desired 

depth, a temporary well was constructed of a 5-ft section of 1-inch Schedule 40 poly-vinyl 

chloride (PVC) screen with sufficient casing to reach the ground surface. New PVC pipe and 

screen were used at each location to avoid cross contamination between locations. The screen 

intervals for the temporary wells are provided in Table 5-2.

Groundwater samples were collected, using a peristaltic pump with PFAS-free HDPE tubing. 

Samples were collected after a period of time following well installation to allow groundwater to 

infiltrate and recharge the temporary well intervals. The temporary wells were purged at a rate 

determined in the field to reduce turbidity and draw down prior to sampling. Water quality 

parameters (e.g., temperature, specific conductance, pH, dissolved oxygen, and oxidationreduction potential) were measured using a water quality meter and recorded on the field 

sampling form (Appendix B2) before each grab sample was collected in a separate container. 

Additionally, a subsample of each groundwater sample was collected in a separate container, and 

a shaker test was completed to identify if there were any foaming. No foaming was noted in any 

of the groundwater samples.
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Each sample was collected in laboratory-supplied PFAS-free HDPE bottles and labeled using a 

PFAS-free marker or pen. Samples were packaged on ice and transported via FedEx under 

standard COC procedures to the laboratory and analyzed for PFAS by LC/MS/MS compliant 

with QSM Version 5.3 Table B-15 in accordance with the UFP-QAPP Addendum (EA/Wood,

2022). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. MS/MSDs were collected at a rate of 5% and analyzed for the same 

parameters as the accompanying samples. Six field blanks (FBs) were collected in accordance 

with the UFP-QAPP Addendum (EA/Wood, 2022). A temperature blank was placed in each 

cooler for use in confirming that samples were preserved at or below 6°C during shipment. 

Following well surveying (described below in Section 5.7), temporary wells were abandoned in 

accordance with the SI UFP-QAPP Addendum (EA/Wood, 2022) by removing the PVC and 

backfilling the hole with soil cuttings and bentonite chips. 

5.4 SYNOPTIC WATER LEVEL MEASUREMENTS

Synoptic water level elevation measurements were collected from the newly installed temporary 

monitoring wells prior to sampling. Water level measurements were taken from the survey mark 

on the northern side of the well casing. Groundwater elevation data is provided in Table 5-3. A 

groundwater flow contour map is provided as Figure 2-5.

5.5 SURVEYING

The northern side of each new temporary well casing was surveyed following guidelines 

provided in the SOPs provided in the SI QAPP Addendum (EA/Wood, 2022). Positions were 

collected in the applicable Universal Transverse Mercator zone projection with World Geodetic 

System 1984 datum (horizontal) and North American Vertical Datum 1988 (vertical). Surveying 

data were collected on 20 May 2022 and are provided in Appendix B3. 

5.6 INVESTIGATION-DERIVED WASTE

As of the date of this report, the disposal of PFAS IDW is not regulated federally. IDW 

generated during the SI is considered non-hazardous waste and was managed in accordance with 

the UFP-QAPP Addendum (EA/Wood, 2022). 

Soil IDW (i.e., soil cuttings) generated during the SI activities were returned to the borehole 

from which they originated. The soil IDW was not sampled and assumes the characteristics of 

the associated soil samples collected from that source location.

Liquid IDW generated during SI activities (purge water, decontamination fluids) were treated 

using granular activated carbon (GAC) and contained in two labeled, 55-gallon Department of 

Transportation (DOT)-approved steel drums and left onsite as directed by Facility personnel. The 

liquid IDW was sampled following the SI fieldwork and is awaiting disposal. The status of the 

IDW disposal will be added to this report before it is finalized. 
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Geographic coordinates were collected using a Global positioning system (GPS) at each location 

where IDW was placed (i.e., boreholes). The IDW placement locations are displayed on the 

figure in Appendix B4.

Other solids such as spent personal protective equipment, plastic sheeting, tubing, rope, unused 

monitoring well construction materials, and other environmental media generated during the 

field activities were disposed of off-Facility at a licensed solid waste landfill. 

5.7 LABORATORY ANALYTICAL METHODS

Samples were analyzed by LC/MS/MS, compliant with QSM Version 5.3 Table B-15, at 

Eurofins in Lancaster, Pennsylvania, a DoD ELAP and NELAP-certified laboratory. 

Soil samples were also analyzed for TOC using EPA Method 9060A, pH by EPA Method 

9045D, and grain size using ASTM Method D-422.

5.8 Deviations from SI UFP-QAPP Addendum

Deviations from the UFP-QAPP Addendum occurred based on conditions encountered during 

field activities. These deviations were discussed with the project delivery team. The deviations 

from the UFP-QAPP Addendum are noted below: 

Borings were unable to be pre-cleared to 5’ using a hand auger by WSP’s drilling subcontractor 

due to shallow hardpan. 

Soil sample locations AOI01-01, AOI01-02, AOI01-03, and AOI01-06 were adjusted within a 

50-ft offset for reasons including drill rig access, utility avoidance and bias toward sampling 

within observed drainage features.

Due to shallow groundwater at locations AOI01-02 and AOI01-03, no midpoint subsurface soil 

samples were collected.
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Table 5-1. Site Inspection Samples by Medium

New Hampshire National Guard Training Site, Center Strafford, New Hampshire

Site Inspection Report

Sample Identification

Sample 

Collection 

Date

Sample Depth

(ft bgs)

PFASLC/MS/MS compliant with QSM 5.3 Table B-15)TOC(EPA Method 9060A)pH (EPA Method 9045D)Grain Size (ASTM D422)

Comments

Soil Samples

AOI01-01-SB-(3-5) 5/17/22 3-5 X Parent Sample of DUP-02

AOI01-01-SB-(3.0-3.5) 5/10/22 3.0-3.5 X X

AOI01-01-SB-(5-7) 5/17/22 5-7 X MS/MSD Collected

AOI01-01-SB-(7-9) 5/17/22 7-9 X

AOI01-02-SB-(3-5) 5/10/22 3-5 X

AOI01-02-SB-(5-9) 5/10/22 5-9 X

AOI01-03-SB-(3-5) 5/10/22 3-5 X

AOI01-03-SB-(5-8) 5/10/22 5-8 X

AOI01-03-SB-(8.6-12) 5/10/22 8.6-12 X

DUP-02 5/17/22 3-5 X Field Duplicate

Groundwater Samples

AOI01-04-GW-(14) 5/14/22 14 X

AOI01-05-GW-(19) 5/17/22 19 X

AOI01-06-GW-(14) 5/17/22 14 X

AOI01-07-GW-(20) 5/13/22 20 X

AOI01-08-GW-(13) 5/19/22 13 X

AOI01-09-GW-(28) 5/12/22 28 X Parent Sample of DUP-01

DUP-01 5/12/22 28 X MS/MSD Collected 

Field Duplicate

Blank Samples

(NHNGTS)-EB-01 5/10/22 - X Equipment Blank Collected 

from Hand Auger

(NHNGTS)-EB-02 5/10/22 - X Equipment Blank Collected 

from Driller’s Water Tank

(NHNGTS)-EB-03 5/11/22 - X Equipment Blank Collected 

from Water Level Meter

(NHNGTS)-EB-04 5/12/22 - X Equipment Blank Collected 

from Dedicated Tubing

(NHNGTS)-EB-05 5/13/22 - X Equipment Blank Collected 

from Water Level Meter

(NHNGTS)-EB-06 5/17/22 - X Equipment Blank Collected 

from Water Level Meter

(NHNGTS)-EB-07 5/17/22 - X Equipment Blank Collected 

from Water Level Meter

(NHNGTS)-FB-01 5/10/22 - X

(NHNGTS)-FB-02 5/11/22 - X

(NHNGTS)-FB-03 5/12/22 - X

(NHNGTS)-FB-04 5/13/22 - X

(NHNGTS)-FB-05 5/17/22 - X
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Sample Identification

Sample 

Collection 

Date

Sample Depth

(ft bgs)

PFASLC/MS/MS compliant with QSM 5.3 Table B-15)TOC(EPA Method 9060A)pH (EPA Method 9045D)Grain Size (ASTM D422)

Comments

(NHNGTS)-FB-06 5/19/22 - X

Notes:

NHNGTS = New Hampshire National Guard Training Site

ASTM = American Society for Testing and Materials

bgs = below ground surface

EB = equipment blank

FB = field blank

ft = feet

MS/MSD = matrix spike/ matrix spike duplicate

QSM = Quality Systems Manual

TOC = total organic carbon

USEPA = United States Environmental Protection Agency
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Table 5-2. Soil Boring Depths and Temporary Well Screen Intervals

New Hampshire National Guard Training Site, Center Strafford, New Hampshire

Site Inspection Report

Area of Interest Boring Location

Soil Boring Depth

(ft bgs)

Temporary Well 

Screen Interval

(ft bgs)

1

AOI01-01 9.0 -

AOI01-02 13.0 -

AOI01-03 12.0 -

AOI01-04 15.0 10.0-15.0

AOI01-05 21.5 16.5-21.5

AOI01-06 16.0 11.0-16.0

AOI01-07 22.0 17.0-22.0

AOI01-08 15.0 10.0-15.0

AOI01-09 30.0 25.0-30.0

Notes:

bgs = below ground surface

ft = feet
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Table 5-3. Groundwater Elevation

New Hampshire National Guard Training Site, Center Strafford, New Hampshire

Site Inspection Report

Monitoring Well 

ID

Top of Casing Elevation

(ft NAVD88)

Depth to Water

(ft btoc)

Depth to Water

(ft bgs)

Groundwater Elevation

(ft NAVD 88)

AOI01-04 595.30 8.85 7.96 586.45

AOI01-05 602.34 15.45 13.70 586.89

AOI01-06 613.57 7.93 6.81 605.64

AOI01-07 635.90 13.38 11.99 622.52

AOI01-08 602.44 8.92 8.56 593.52

AOI01-09 566.17 17.18 15.78 548.99

Notes:

bgs = below ground surface

btoc = below top of casing

ft = feet

NAVD88 = North American Vertical Datum 1988
Army National Guard Site Inspections

Site Inspection Report

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Figure 5-1

Site Inspection Sample Locations

!( !(

!(

*#

*#

*#

*#

*#

NHNGTS Current *#

Leach Field

AOI 1

NHNGTS Former 

Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

AOI01-04 AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Parker Mountain Rd

Austin Cate

3

0 200

Feet

Date:....................September 2022

Prepared By:........................WSP

Prepared For:....................USACE

Facility Data

Area of Interest

Potential PFAS

Release

Facility Boundary

Sample Type

!( Soil Boring

*# Monitoring Well

Note: Certain features digitized from

georeferenced AECOM Preliminary

Assessment Report (2020) figures.

)

NH

Hydrology/Hydrogeology

Local Groundwater Flow Direction

Inferred Local Groundwater Flow

Direction

Regional Groundwater Flow

Direction

Surface Water Flow Direction

Water Body

Wetland

Document Path: P:\Army National Guard PFAS Maps\Strafford National Guard Training Site\Strafford National Guard Training Site\MXDs\Site Inspection Report\Figure 5-1 Site Inspection Sample Locations.mxd
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6. SITE INSPECTION RESULTS

This section presents the analytical results of the SI. The SLs used in this evaluation are 

presented in Section 6.1 and Table 6-1. A discussion of the results for the AOI is provided in 

Section 6.3. Tables 6-2 through 6-5 present results in soil or groundwater for the relevant 

compounds. Tables that contain all results are provided in Appendix F, and the laboratory 

reports are provided in Appendix G. 

6.1 SCREENING LEVELS

The SLs established in the OSD memorandum apply to the five compounds presented on Table 

6-1.

Table 6-1. Screening Levels (Soil and Groundwater)

Analyte1,2

Residential 0-2 ft bgs

(Soil)

(μg/kg)1

Industrial / Commercial

Composite Worker 2-15 ft bgs

(Soil)

(μg /kg) 1

Tap Water

(Groundwater)

(ng/L) 1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and Soil using 

U.S. Environmental Protection Agency’s (EPA’s) Regional Screening Level Calculator. Hazard Quotient 

(HQ)=0.1. May 2022. 

2. Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly 

referred to as GenX) was not included as an analyte at the time of this SI. Based on the CSM developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility 

because HFPO-DA is generally not a component of military specification MIL-SPEC AFFF and based on 

its history including distribution limitations that restricted use of GenX, it is generally not a component of 

other products the military used. In addition, it is unlikely that GenX would be an individual chemical of 

concern in the absence of other PFAS

Abbreviations:

μg/kg = microgram(s) per kilogram

bgs = below ground surface

ng/L = nanogram(s) per liter

The data in the subsequent sections are compared against the SLs presented in Table 6-1. The 

SLs for groundwater are based on direct ingestion. The SLs for soil are based on incidental 

ingestion and are applied to the depth intervals reasonably anticipated to be encountered by the 

receptors identified at the Facility: the residential scenario is applied to surface soil results (0 to 2 

ft bgs) and the industrial/commercial worker scenario is applied to shallow subsurface soil 

results (2 to 15 ft bgs). The SLs are not applied to deep subsurface soil results (>15 ft bgs) 

because 15 ft is the anticipated limit of construction activities.
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6.2 SOIL PHYSICOCHEMICAL ANALYSES

To provide basic soil parameter information, soil samples were analyzed for TOC, pH, and grain 

size, which are important for evaluating transport through the soil medium. Appendix E contains 

the results of the TOC, pH, and grain size sampling. 

The data collected in this investigation will be used in subsequent investigations, where 

appropriate, to assess fate and transport. According to the ITRC, several important PFAS 

partitioning mechanisms include hydrophobic and lipophobic effects, electrostatic interactions, 

and interfacial behaviors. At relevant environmental pH values, certain PFAS are present as 

organic anions, and are therefore relatively mobile in groundwater (Xiao et al., 2015) but tend to 

associate with the organic carbon fraction that may be present in soil or sediment (Higgins and 

Luthy, 2006; Guelfo and Higgins, 2013). When sufficient organic carbon is present, organic 

carbon normalized distribution coefficients (Koc values) can help in evaluating transport 

potential, though other geochemical factors (for example, pH and presence of polyvalent cations) 

may also affect PFAS sorption to solid phases (ITRC, 2018). 

6.3 AOI 1 – CURRENT LEACH FIELD

This section presents the analytical results for soil and groundwater in comparison to SLs for 

AOI 1: Current Leach Field. The soil and groundwater results are summarized in Table 6-2

through Table 6-5. Soil and groundwater results are presented on Figures 6-1 through Figure 6-

7.

This section also presents the analytical results for groundwater in comparison to SLs for 

locations AOI01-06 and AOI01-07, which were located upgradient of AOI 1. The purpose of 

these locations was to determine if there were potential sources upgradient of AOI 1. AOI01-07 

is situated just below the ridge (topographic high) that separates the Facility into two drainage 

areas, whereas AOI01-06 is located closer to AOI 1. 

6.3.1 AOI 1 Soil Analytical Results

Soil samples were collected from three boring locations associated with AOI 1 during the SI. 

Figure 6-1 through Figure 6-3 show the ranges of detections in soil in figure format. Tables 6-2

through Table 6-4 summarize the soil results in table format.

Three borings were installed as close as possible to the leach field (AOI01-01, AOI01-02, and 

AOI01-03). Shallow subsurface soil samples were collected at the approximate depth of the 

wastewater distribution box (3 to 5 ft bgs). A midpoint subsurface soil sample was collected at 

the midpoint between the ground surface and the groundwater table (5 to 7 ft bgs) at AOI01-01.

Due to the shallow groundwater at locations AOI01-02 and AOI01-03, no midpoint subsurface 

soil samples were collected at those locations. Deep subsurface soil samples were collected 

approximately 1 ft above the groundwater table (5 to 9 ft bgs). 

There were no exceedances of screening levels in shallow soils (3 to 5 ft bgs), midpoint soils (5 

to 7 ft bg), or deeper soils (5 to 9 ft bgs).
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PFOA was detected in shallow subsurface soil at one of three locations at a concentration of 

0.23 J μg/kg (AOI01-01). PFOS, PFBS, PFNA, and PFHxS were not detected in the shallow 

subsurface soil samples. 

PFOS, PFOA, PFBS, PFNA, and PFHxS were not detected in the midpoint subsurface soil 

sample taken at AOI01-01. 

PFOS, PFOA, PFBS, PFNA, and PFHxS were not detected in the deep subsurface soil samples.

6.3.2 AOI 1 Groundwater 

Only one AOI 1 groundwater sample had an exceedance of a screening level. The upgradient 

sample location positioned furthest from the leach field (AOI01-07), shown in Figure 6-6,

exceeded the screening level for one constituent, PFOA, at 6.1 J+ ng/L, suggesting a release 

unrelated to the AOI 1. 

6.3.2.1 AOI 1 – Current Leach Field Groundwater Analytical Results 

Groundwater samples were collected from four temporary wells associated with AOI 1 during

the SI (AOI01-04, AOI01-05, AOI01-08, and AOI01-09). Synoptic water level measurements 

taken in the temporary monitoring wells during the SI indicate that groundwater flows towards 

the northeast in the area of the leach field. Groundwater samples were collected from two 

locations downgradient of AOI 1; AOI01-04 and AOI01-09, with a duplicate sample collected at 

AOI01-09. Two groundwater samples were collected at locations cross-gradient of AOI 1; 

AOI01-05 and AOI01-08. Figure 6-4 through Figure 6-7 shows the ranges of detections in 

groundwater in figure format. Table 6-5 summarizes the groundwater results in table format.

PFOA and PFOS were detected at concentrations below their respective SLs in groundwater 

samples taken downgradient and cross-gradient of AOI 1. PFOA was detected in groundwater in 

three of the four locations (AOI01-05, AOI01-08, and AOI01-09), with concentrations ranging 

from 1.8 J+ to 4.9 J ng/L. PFOS was detected in groundwater at one of four locations (AOI01-

04), with a concentration of 3.3 J+ ng/L. PFHxS, PFBS, and PFNA were not detected in 

groundwater. 

6.3.2.2 AOI 1 - Upgradient Source Area Groundwater Analytical Results 

Two groundwater samples were collected upgradient of AOI 1: AOI01-06 and AOI01-07. PFOA 

was detected in groundwater with a concentration exceeding the SL at the most upgradient 

location (AOI01-07) at a concentration of 6.1 J+ ng/L. PFBS was also detected in groundwater at 

AOI01-07 below the SL, with a concentration of 2.0 J+ ng/L. PFOA and PFOS were detected at 

concentrations below their respective SLs in groundwater at AOI01-06. PFOA was detected in 

groundwater at AOI01-06 with a concentration of 3.9 J+ ng/L, and PFOS was detected in 

groundwater at AOI01-06 with concentration of 2.9 J+ ng/L. PFOS was not detected in 

groundwater at AOI01-07. PFHxS and PFNA were not detected in either of the upgradient 

groundwater samples. The detections in the groundwater at locations upgradient of AOI 1 may 

be related to the former leach field (AOI 2, see Section 6.4) an unidentified on-Facility source, 
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or a potential off-Facility source not under control of ARNG. Potential upgradient sources will 

be investigated as part of the RI. 

6.3.3 Conclusions

PFOA and PFOS were detected in groundwater below their respective SLs at temporary

monitoring well locations down-gradient and cross-gradient of AOI 1. While no soil samples 

exceeded the SLs, PFOA was detected in one shallow subsurface soil sample taken from as close 

as possible to the leach field (AOI01-01). Based on these results, no further action is warranted 

for AOI 1. 

Two groundwater samples were collected upgradient of AOI 1: AOI01-06 and AOI01-07. PFOA 

was detected in groundwater with a concentration exceeding the SL at the most upgradient 

location (AOI01-07). The detections in the groundwater at locations upgradient of AOI 1 may be 

related to the former leach field (AOI 2, see Section 6.4), an unidentified on-Facility source, or a 

potential off-Facility source not under control of ARNG. Potential upgradient sources will be 

investigated as part of the RI. Based on these results, further evaluation is warranted for the area 

upgradient of AOI 1 in an RI. 

6.4 AOI 2 – FORMER LEACH FIELD

Following the SI fieldwork, information was provided by NHARNG indicating that the current 

leach field had not been constructed in the location of the former leach, as was previously noted 

in the PA. The former leach field was located southwest and upgradient of the current leach field. 

Investigation of AOI 2 was not conducted during the SI and will be investigated as part of the RI. 
Table 6-2

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil

Site Inspection Report

New Hampshire National Guard Training Site

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual R

PFBS 25000 ND U ND U ND U PFHxS 1600 ND U ND U ND U PFNA 250 ND U ND UJ ND U PFOA 250 0.23 J ND UJ ND U PFOS 160 ND U ND U ND U 

Notes Chemical AbbreviaGray Fill Detected concentration exceeded OSD Screening Levels PFBS 

PFHxS 

References PFNA 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated PFOA 

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s PFOS 

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil arebased on Industrial/Commercial Composite Worker scenario for direct ingestion of contaminated soil.Interpreted Qualifiers

J = The result is an estimated quantity.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)NHNGTS New Hampshire National Guard Training SiteOSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

DUP-02 AOI01-02-SB-(3-5)

Sample Date 5/17/2022 5/17/2022 5/10/2022 

Soil, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)

Area of Interest

Depth

AOI01

3 - 5 ft 3 - 5 ft 3 - 5 ft 

Location ID AOI01-01 AOI01-01-Duplicate AOI01-02 

Sample ID AOI01-01-SB-(3-5)

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Table 6-3

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Midpoint Subsurface Soil

Site Inspection Report

New Hampshire National Guard Training Site

Analyte OSD Screening Level 1 Result Qual

PFBS 25000 ND UPFHxS 1600 ND UPFNA 250 ND UJPFOA 250 ND UJPFOS 160 ND U

Notes Chemical AbbreviationsGray Fill Detected concentration exceeded OSD Screening Levels PFBS perfl

PFHxS perfl

References PFNA perfl

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated PFOA perfl

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s PFOS perfl

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil arebased on Industrial/Commercial Composite Worker scenario for direct ingestion of contaminated soil.Interpreted Qualifiers

U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)NHNGTS New Hampshire National Guard Training SiteOSD Office of the Secretary of the DefenseQSM Quality Systems Manual

PFAS per- and polyfluoroalkyl substancesSB soil boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Soil, PFAS by LCMSMS compliant with QSM 5.3 Table 

Area of Interest

Depth 5 - 7 ft

Sample Date

Location ID

AOI01

AOI01-01

AOI01-01-SB-(5-7)

5/17/2022

Sample ID

EA Engineering, Science, and Technology, Inc., PBC 
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New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-8

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Table 6-4

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Deep Subsurface Soil

Site Inspection Report

New Hampshire National Guard Training Site

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual

PFBS 25000 ND U ND U ND UPFHxS 1600 ND U ND U ND UPFNA 250 ND UJ ND U ND U

PFOA 250 ND UJ ND U ND UPFOS 160 ND U ND U ND U

Notes Chemical AbbreviationsGray Fill Detected concentration exceeded OSD Screening Levels PFBS p

PFHxS p

References PFNA p

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated PFOA p

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s PFOS p

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil arebased on Industrial/Commercial Composite Worker scenario for direct ingestion of contaminated soil.Interpreted Qualifiers

U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)NHNGTS New Hampshire National Guard Training SiteOSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Soil, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)

Area of Interest

Depth

AOI01

7 - 9 ft 5 - 9 ft 5 - 8 ft

Sample Date 5/17/2022 5/14/2022 5/10/2022

Location ID AOI01-01 AOI01-02 AOI01-03

Sample ID AOI01-01-SB-(7-9) AOI01-02-SB-(5-9) AOI01-03-SB-(5-8)

EA Engineering, Science, and Technology, Inc., PBC 
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-10

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Table 6-5

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

New Hampshire National Guard Training Site

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual Result Qual Resul

PFBS 601 ND U ND U ND UJ 2.0 J+ ND PFHxS 39 ND U ND U ND UJ ND UJ ND PFNA 6 ND U ND U ND UJ ND U ND PFOA 6 ND U 3.4 J+ 3.9 J+ 6.1 J+ 1.8 PFOS 4 3.3 J+ ND U 2.9 J+ ND U ND 

Notes Gray Fill Detected concentration exceeded OSD Screening Levels References 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated  for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1 . May 2022. Groundwater screening levelsbased on residential scenario for direct ingestion of groundwater.Interpreted Qualifiers

J = Estimated concentration.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and AbbreviationsAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)ng/L New Hampshire National Guard Training SiteNHNGTS nanogram(s) per literOSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date 5/19/2022 5/17/2022 5/17/2022 5/13/2022 

AOI01-06 AOI01-07 

Area of Interest AOI01

Water, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

Sample ID AOI01-04-GW-(14) AOI01-05-GW-(19) AOI01-06-GW-(14) AOI01-07-GW-(20) AOI0

Location ID AOI01-04 AOI01-05

EA Engineering, Science, and Technology, Inc., PBC 
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-12

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Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :........................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Army National Guard Site Inspections

Site Inspection Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Figure 6-1

PFOS Detections in Soil

!( !(

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Homestead

Austin Cate

Parker Mountain Rd

!( !(

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Homestead

Austin Cate

Parker Mountain Rd

0 200

Fe e t

Sha llow (3-5') De e p (5-9')

PFOS Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 13

!!( >13 -160

!!( >160 - 1,600

!!( >1,600

3

)

NH

Hydrology/Hydrogeology

Loca l Ground w a te r Flow Dire ction

Infe rre d Loca l Ground w a te r Flow Dire ction

Re g iona l Ground w a te r Flow Dire ction

Surfa ce W a te r Flow Dire ction

NOTES:

PFAS - Pe r- a nd Polyfluoroa lkyl Substa nce s

PFOS = pe rfluoroocta ne sulfonic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m(s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re d e picte d w ith a ye llow ha lo.

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-01

Homestead

Austin Cate

Parker Mountain Rd

0 200

Fe e t

0 200

Fe e t

Intermediate (5-7')
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-14

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Data Sourc e s: 

ESRI 2020

AECOM 2020

Date :........................Oc tob e r 2022

Pre pare d By:........................W SP

Pre pare d For:....................U SACE

Army National Guard Site Inspections

Site Inspection Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Figure 6-2

PFOA Detections in Soil

)

NH

NOTES:

PFAS = Pe r- and Polyfluoroalkyl Sub stanc e s

PFOA = pe rfluorooc tanoic ac id

ND = Non-De te c t

(μg/Kg) = M ic rogram (s) pe r Kilogram

Exc e e d anc e s of The Offic e of the Se c re tary of De fe nse (OSD)

Sc re e ning Le ve l (SL) are d e pic te d with a ye llow halo.

!( !(

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Homestead

Austin Cate

Parker Mountain Rd

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

!(

AOI01-01

Homestead

Austin Cate

Parker Mountain Rd

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

Homestead

Austin Cate

Parker Mountain Rd

Shallow (3-5') Intermediate (5-7') De e p (5-9')

0 200

Fe e t

0 200

Fe e t

0 200

Fe e t

Doc um e nt Path: P:\Arm y National Guard PFAS M aps\Strafford National Guard Training Site \Strafford National Guard Training Site \M X Ds\Site Inspe c tion Re port\Figure 6-2 PFOA De te c tions in Soil.m xd

Hydrology/Hydrogeology

Loc al Ground wate r Flow Dire c tion

Infe rre d Loc al Ground wate r Flow

Dire c tion

Re gional Ground wate r Flow Dire c tion

Surfac e W ate r Flow Dire c tion

Facility Data

Are a of Inte re st

Pote ntial PFAS Re le ase

Fac ility Bound ary

PFOA Results (μg/kg)

!( ND (Non-De te c t)

!( >ND - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-16

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Data Sourc e s: 

ESRI 2020

AECOM 2020

Date :.....................Oc tob e r 2022

Pre pare d By:......................W SP

Pre pare d For:..................U SACE

Ar m y Nation al Gu ard Site In s pection s

Site In s pection Report

New Ham ps hire Nation al Gu ard Train in g Site

Cen ter Strafford , New Ham ps hire

Figu re 6-3

PFBS Detection s in Soil

!( !(

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

!( !(

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

0 200

Fe e t

3

)

NH

NOTES:

PFAS = Pe r- and Polyfluoroalkyl Sub stanc e s

PFBS = pe rfluorob utane sulfonic ac id

ND = Non-De te c t

(μg/Kg) = M ic rogram (s) pe r Kilogram

Exc e e d anc e s of The Offic e of the

Se c re tary of De fe nse (OSD) Sc re e ning Le ve l (SL)

are d e pic te d with a ye llow halo.

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

Shallow (3-5') Intermediate (5-7') De e p (5-9')

0 200

Fe e t

0 200

Fe e t

Doc um e nt Path: P:\Arm y National Guard PFAS M aps\Strafford National Guard Training Site \Strafford National Guard Training Site \M X Ds\Site Inspe c tion Re port\Figure 6-3 PFBS De te c tions in Soil (AOI 1).m xd

Hyd rology/Hyd rogeology

Loc al Ground wate r Flow Dire c tion

Infe rre d Loc al Ground wate r Flow Dire c tion

Re gional Ground wate r Flow Dire c tion

Surfac e W ate r Flow Dire c tion

Facility Data

Are a of Inte re st

Pote ntial PFAS Re le ase

Fac ility Bound ary

PFBS Res u lts (μg/kg)

!( ND (Non-De te c t)

!( >ND - 10

!( >10 - 1,900

!!( >1,900 - 25,000

!!( >25,000
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-18

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Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :........................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Ar m y Nation al Gu ard Site In s pection s

Site In s pection Report

New Ham ps hire Nation al Gu ard Train in g Site

Cen ter Strafford , New Ham ps hire

Figu re 6-4

PFHxS Detection s in Soil

!( !(

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

!( !(

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

0 200

Fe e t

3

)

NH

PFHxS Res u lts (μg/kg)

!( ND (Non-De te ct)

!( >ND - 13

!( >13 -160

!!( >160 - 1,600

!!( >1,600

NOTES:

PFAS - Pe r- a nd Polyfluoroa lkyl Substa nce s

PFHxS = pe rfluorohe xa ne sulfonic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m(s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of

De fe nse (OSD) Scre e ning Le ve l (SL)

a re d e picte d w ith a ye llow ha lo.

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

0 200

Fe e t

Sha llow (3-5') Intermediate (5-7') De e p (5-9')

0 200

Fe e t

Facility Data

Are a of Inte re st

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Hyd rology/Hyd rogeology

Loca l Ground w a te r Flow Dire ction

Infe rre d Loca l Ground w a te r Flow Dire ction

Re g iona l Ground w a te r Flow Dire ction

Surfa ce W a te r Flow Dire ction
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-20

This page intentionally left blank
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :....................Octob e r 2022

Pre pa re d By:......................W SP

Pre pa re d For:.................USACE

Facility Data

Are a of Inte re st

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Ar m y Nation al Gu ard Site In s pection s

Site In s pection Report

New Ham ps hire Nation al Gu ard Train in g Site

Cen ter Strafford , New Ham ps hire

Figu re 6-5

PFNA Detection s in Soil

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

!( !(

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

AOI01-02

AOI01-03Hom es tead

Au s tin Cate

Parker Mou n tain Rd

3

)

N H

NOTES:

PFAS - Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFN A = pe rflu oronona noic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e

Se cre ta ry of De fe nse (OSD) Scre e ning Le ve l (SL)

a re de picte d w ith a ye llow h a lo.

PFNA Res u lts (μg/kg)

!( N D (N on-De te ct)

!( >N D - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500

!(

NHNGTS

Cu rren t Leach Field 

AOI 1

NHNGTS

For m er Leach Field 

AOI 2

AOI01-01

Hom es tead

Au s tin Cate

Parker Mou n tain Rd

0 200

Fe e t

0 200

Fe e t

0 200

Fe e t

Sh a llow (3-5') Intermediate (5-7') De e p (5-9')

Hyd rology/Hyd rogeology

Loca l Grou ndw a te r Flow Dire ction

Infe rre d Loca l Grou ndw a te r Flow Dire ction

Re g iona l Grou ndw a te r Flow Dire ction

Su rfa ce W a te r Flow Dire ction
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-22

This page intentionally left blank
Data Sources:

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:.........................WSP

Prepared For:....................USACE

Facility Data

Area of Interest

Potential PFAS Release

Facility Boundary

Army National Guard Site Inspections

Site Inspection Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Figure 6-6

PFOS, PFOA, and PFBS Detections in Groundwater

!(

!(

!(

!(

!(

!(

NHNGTS

Current Leach Field

AOI 1

NHNGTS

Former Leach Field

AOI 2

AOI01-04 AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Homestead

Austin

Cate

Parker Mountain Rd

!(

!(

!(

!(

!(

!(

NHNGTS

Current Leach Field

AOI 1

NHNGTS

Former Leach Field

AOI 2

AOI01-04 AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Homestead

Austin

Cate

Parker Mountain Rd

0 200

Feet

PFOS

3

PFBS (ng/L)

!( ND (Non-Detect)

!( >ND - 100

!( >100 - 601

!!( >601 - 1,000

!!( >1,000

)

NH

!(

!(

!(

!!(

!(

!(

NHNGTS

Current Leach Field

AOI 1

NHNGTS

Former Leach Field

AOI 2

NHNGTS

Current Leach Field

AOI 1

NHNGTS

Former Leach Field

AOI 2

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Homestead

Austin

Cate

Parker Mountain Rd

0 200

Feet

0 200

Feet

PFOS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 4

!!( >4 - 40

!!( >40 - 70

!!( >70

PFOA PFBS

PFOA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

NOTES:

PFAS - Per- and Polyfluoroalkyl Substances

PFOS = perfluorooctanesulfonic acid

PFOA = perfluorooctanoic acid

PFBS = perfluorobutanesulfonic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD)

Screening Level (SL) are depicted with a yellow halo.

Hydrology/Hydrogeology

Local Groundwater Flow Direction

Inferred Local Groundwater Flow Direction

Regional Groundwater Flow Direction

Surface Water Flow Direction

Document Path: P:\Army National Guard PFAS Maps\Strafford National Guard Training Site\Strafford National Guard Training Site\MXDs\Site Inspection Report\Figure 6-6 PFOS, PFOA, and PFBS Detections in Groundwater.mxd
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-24

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:....................October 2022

Prepared By:......................WSP

Prepared For:.................USACE

Facility Data

Area of Interest

Potential PFAS Release

Facility Boundary

Army National Guard Site Inspections

Site Inspection Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Figure 6-7

PFHxS and PFNA Detections in Groundwater

!(

!(

!(

!(

!(

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Homestead

Austin Cate

Parker Mountain Rd

!(

!(

!(

!(

!(

!(

NHNGTS

Current Leach Field 

AOI 1

NHNGTS

Former Leach Field 

AOI 2

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI01-09

Homestead

Austin Cate

Parker Mountain Rd

0 400

Feet

0 400

Feet

PFHxS PFNA 3

)

NH

NOTES:

PFAS - Per-and Polyfluoroalkyl Substances

PFHxS = Perfluorohexanesulfonic acid

PFNA = Perfluorononanoic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the

Secretary of Defense (OSD) Screening Level (SL) are depicted with a yellow halo.

PFNA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 100

!!( >100 - 1000

!!( >1000

PFHxS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 39

!!( >39 - 100

!!( >100 - 1000

!!( >1,000

Hydrology/Hydrogeology

Local Groundwater Flow Direction

Inferred Local Groundwater Flow Direction

Regional Groundwater Flow Direction

Surface Water Flow Direction

Document Path: P:\Army National Guard PFAS Maps\Strafford National Guard Training Site\Strafford National Guard Training Site\MXDs\Site Inspection Report\Figure 6-7 PFHxS and PFNA Detections in Groundwater.mxd
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-26

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Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-1

7. EXPOSURE PATHWAYS

The Conceptual Site Model (CSM) for AOI 1, revised based on the SI findings, is presented on 

Figure 7-1. Additionally, preliminary CSMs for a potentially unidentified upgradient source 

(Figure 7-2) and for AOI 2 are included (Figure 7-3).

Please note that while the CSM discussion assists in determining if a receptor may be impacted, 

the decision to move from SI to RI or interim action is determined based upon exceedances of 

the SLs for the relevant compounds and whether the release is more than likely attributable to the 

DoD. A CSM presents the current understanding of the Facility conditions with respect to known 

and suspected sources, potential transport mechanisms and migration pathways, and potentially 

exposed human receptors. A human exposure pathway is considered potentially complete when 

the following conditions are present:

1. Contaminant source;

2. Environmental fate and transport;

3. Exposure point;

4. Exposure route; and

5. Potentially exposed populations. 

If any of these elements are missing, the pathway is incomplete. The CSM figures use an empty 

circle symbol to represent an incomplete exposure pathway. Areas with no identified complete 

pathway generally warrant no further action. However, the pathway is considered potentially 

complete if the relevant compounds are detected, in which case the CSM figure uses a half-filled 

circle symbol to represent a potentially complete exposure pathway. Additionally, a completely 

filled circle symbol is used to indicate when a potentially complete exposure pathway has 

detections of the relevant compounds above the SLs. Areas with an identified potentially 

complete pathway and a complete pathway may warrant further investigation. Although the 

CSMs indicate whether potentially complete exposure pathways may exist, the recommendation 

for future study in a RI or no action at this time is based on the comparison of the SI analytical 

results for the relevant compounds to the SLs and whether the release is more than likely 

attributable to the DoD.

In general, the potential routes of exposure to the relevant compounds are ingestion and 

inhalation. Human exposure via the dermal contact pathway may occur, and current risk practice 

suggests it is an insignificant pathway compared to ingestion; however, exposure data for dermal 

pathways are sparse and continue to be the subject of toxicological study. The receptors 

evaluated are consistent with those listed in EPA guidance for risk screening (EPA 2001). 

Receptors at the Facility include Facility workers (e.g., Facility staff and visiting soldiers), 

construction workers, trespassers, recreational users, and off-Facility residents.

7.1 SOIL EXPOSURE PATHWAY

The SI results in soil were used to determine whether a potentially complete pathway exists 

between the source and potential receptors at each AOI based on the aforementioned criteria. 
Site Inspection Report

New Hampshire National Guard Training Site, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-2

7.1.1 AOI 1 – Current Leach Field

AOI 1 is the current leach field. Liquids potentially containing PFAS were discharged to the 

wastewater system which flows to the current leach field. The piping for the leach field is below 

the ground surface; therefore, there is the potential for PFAS to have been released directly to the 

subsurface soil. Due to potential releases occurring only below the ground surface, no surface 

soil samples were collected as part of the SI. The human exposure pathway via surface soil is 

considered incomplete. PFOA was detected in soil just below the surface (3 to 5 ft bgs) at AOI 1. 

Construction workers could contact constituents in subsurface soil via incidental ingestion and 

inhalation of dust; therefore, the subsurface soil exposure pathway for construction workers is 

potentially complete. The CSM is presented in Figure 7-1.

7.1.1.1 AOI 1 – Upgradient Source Area

No soil samples were collected in the area upgradient of AOI 1. Due to the detection of PFOA in 

groundwater that exceeded the SL at a sample location upgradient of AOI 1, further assessment 

of the area upgradient of AOI 1 will be conducted during the RI. The detections in the 

groundwater at locations upgradient of AOI 1 may be related to the former leach field (AOI 2, 

see Section 7.1.2) an unidentified on-Facility source, or a potential off-Facility source not under 

control of ARNG. Further assessment of potential exposure pathways will be conducted during 

the RI. As the source is unknown, the surface soil exposure pathways are potentially complete 

for the Facility worker, construction worker, and recreational user/trespasser, and the soil 

exposure pathways is potentially complete for the construction worker. The preliminary CSM 

for a potential unidentified on-Facility source presented in Figure 7-2.

7.1.2 AOI 2 – Former Leach Field

AOI 2 is the former leach field. During preparation of the SI Report, it was discovered that the 

current leach field was not constructed in the same location as the former leach field. The former 

leach field was located southwest (and upgradient) of the current leach field and was not 

investigated as part of the SI. Following the SI, the former leach field was identified as a second 

AOI (AOI 2) due to the potential use of floor polish while it was in use. Liquids potentially 

containing PFAS were discharged to wastewater system which flowed to the former leach field. 

The piping for the former leach field was below the ground surface; therefore, there is the 

potential for PFAS to have been released directly to the subsurface soil. Due to potential releases 

occurring only below the ground surface, the human exposure pathway via surface soil is 

considered incomplete. Further assessment of potential exposure pathways will be conducted 

during the RI. The preliminary CSM for AOI 2 is presented in Figure 7-3.

7.2 GROUNDWATER EXPOSURE PATHWAY

The SI results in groundwater were used to determine whether a potentially complete pathway 

exists between the source and potential receptors at each AOI based on the aforementioned 

criteria. 
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7.2.1 AOI 1 – Current Leach Field

PFOS and PFOA were detected in the groundwater at AOI 1 at concentrations below their 

respective SLs. Due to these detections of PFOS and PFOA in wells associated with AOI 1 and 

the detections of PFAS in water samples taken from NHNGTS water supply wells (Well #1 and 

Well #4) in 2017 (see Section 2.2.2), the pathway for exposure to Facility workers is considered 

potentially complete. The concentration at the potential point of exposure for off-Facility 

residents is not known, therefore, the exposure pathway for ingestion is potentially complete for 

off-Facility residential receptors. Depths to groundwater measured at AOI 1 in May 2022 during 

the SI ranged from 7.93 to 17.18 ft bgs. Therefore, the ingestion exposure pathway for 

construction workers is considered potentially complete. It is unknown if recreational users are 

using the onsite water supply, therefore, the ingestion pathway for the recreational user is 

considered potentially compete. The CSM is presented on Figure 7-1. 

7.2.1.1 AOI 1 – Upgradient Source Area

PFOA was detected in groundwater in both sample locations upgradient of AOI 1. The 

concentration of PFOA exceeded the SL at one upgradient location. PFOS and PFBS were both

detected below their respective SL in the upgradient sample locations. These results, in 

conjunction with the Facility topography, may indicate a potential source upgradient of the 

current leach field. The detections in the groundwater at locations upgradient of AOI 1 may be 

related to the former leach field (AOI 2, see Section 7.2.2), an unidentified on-Facility source, or 

a potential off-Facility source not under control of ARNG.

Due to the detections of PFOA (exceeding the SL), PFOS, and PFBS (below their respective 

SLs) in wells located upgradient of AOI 1 and the detections of PFAS in water samples taken

from NHNGTS water supply wells (Well #1 and Well #4) in 2017 (see Section 2.2.2), the 

pathway for exposure to Facility workers is considered potentially complete. The concentration 

at the potential point of exposure for off-Facility residents is not known, therefore, the exposure 

pathway for ingestion is potentially complete for off-Facility residential receptors. Depths to 

groundwater measured at AOI 1 in May 2022 during the SI ranged from 7.93 to 17.18 ft bgs. 

Therefore, the ingestion exposure pathway for future construction workers is considered 

potentially complete. It is unknown if recreational users are using the onsite water supply, 

therefore, the ingestion pathway for the recreational user is considered potentially compete.

Further assessment will be conducted during the RI. The preliminary CSM is presented on 

Figure 7-2.

7.2.2 AOI 2 – Former Leach Field

Following the SI fieldwork, new information was provided by NHARNG indicating that the 

current leach field had not been constructed in the location of the former leach field, as was 

previously noted in the PA. The former leach field was located southwest and upgradient of the 

current leach field. Investigation of AOI 2 was not conducted during the SI and will be 

investigated as part of the RI. 

Due to the detections of PFOA (exceeding the SL), PFOs, and PFBS (below their respective 

SLs) in wells located upgradient of AOI 1 and the detections of PFAS in water samples taken
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from NHNGTS water supply wells (Well #1 and Well #4) in 2017 (see Section 2.2.2), the 

pathway for exposure to Facility workers is considered potentially complete. The concentration 

at the potential point of exposure for off-Facility residents is not known, therefore, the exposure 

pathway for ingestion is potentially complete for off-Facility residential receptors. Depths to 

groundwater measured at AOI 1 in May 2022 during the SI ranged from 7.93 to 17.18 ft bgs. 

Therefore, the ingestion exposure pathway for future construction workers is considered 

potentially complete. It is unknown if recreational users are using the onsite water supply, 

therefore, the ingestion pathway for the recreational user is considered potentially compete.

Further assessment will be conducted during the RI. The preliminary CSM is presented on 

Figure 7-3.

7.3 SURFACE WATER AND SEDIMENT EXPOSURE PATHWAY

The elevation of the Mohawk River, located north of the Facility, is below the elevation of the 

surface of the groundwater near the Facility. Therefore, groundwater flow from the Facility is 

likely to flow into the Mohawk River. Additionally, several intermittent streams, originating as 

hillside seeps, also flow into the wetland system (on and off Facility) to the north. The ingestion 

exposure pathway for offsite surface water and sediment is considered potentially complete for 

recreational users of these rivers. Human consumption of fish potentially affected by PFAS from 

the rivers is also possible. No surface water or sediment samples were collected as part of the SI. 

7.3.1 AOI 1 – Current Leach Field

PFOS and PFOA were detected in the groundwater at AOI 1 at concentrations below their 

respective SLs. As AOI 1 is located on the north portion of the Facility, groundwater may flow 

into the Mohawk River and expose the potential off-Facility recreational user of the river by 

ingestion of surface water and/or fish potentially affected by PFAS.

7.3.1.1 AOI 1 – Upgradient Source Area

PFOA was detected in groundwater in both sample locations upgradient of AOI 1. The 

concentration of PFOA exceeded the SL at one upgradient location. PFOS and PFBS were both 

detected below their respective SL in the upgradient sample locations. These results, in 

conjunction with the Facility topography, may indicate a potential source upgradient of the 

current leach field. The detections in the groundwater at locations upgradient of AOI 1 may be 

related to the former leach field (AOI 2, see Section 7.3.2), an unidentified on-Facility source, or 

a potential off-Facility source not under control of ARNG.

PFOA was detected in groundwater in both sample locations upgradient of AOI 1. The 

concentration of PFOA exceeded the SL at one upgradient location. PFOS and PFBS were both 

detected below their respective SL in the upgradient sample locations. As the area upgradient of 

AOI 1 is located on the north portion of the Facility, groundwater may flow into the Mohawk 

River and expose the potential off-Facility recreational user of the river by ingestion of surface 

water and/or fish potentially affected by PFAS.
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7.3.2 AOI 2 – Former Leach Field

Following the SI fieldwork, new information was provided by NHARNG indicating that the 

current leach field had not been constructed in the location of the former leach field, as was 

previously noted in the PA. The former leach field was located southwest and upgradient of the 

current leach field. Investigation of AOI 2 was not conducted during the SI and will be 

investigated as part of the RI. 

PFOA was detected in groundwater in both sample locations upgradient of AOI 1. The 

concentration of PFOA exceeded the SL at one upgradient location. PFOS and PFBS were both 

detected below their respective SL in the upgradient sample locations. As the area upgradient of 

AOI 1 is located on the north portion of the Facility, groundwater may flow into the Mohawk 

River and expose the potential off-Facility recreational user of the river by ingestion of surface 

water and/or fish potentially affected by PFAS.
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REC

Huma

Curr

Human 

Activities

Precipitation/

Run-Off

Leaching/Infiltration

Inhalation of 

Dust

AOI 1

(Current 

Leach Field)

Potential 

releases from 

leach field

PFAS in 

Subsurface 

Soil

AOI 2 (Figure 2-3)

or

Potential Unidentified OnFacility Source (Figure 7-2)

or 

Potential Off-Facility 

Source Not Under Control 

of ARNG

Airborne 

Soil 

Particulate

Surface 

Soil at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

SOURCE

Source Release Mechanism Media

PATHWAY

Transport

and Migration Media Exposure Routes

LEGENDFlow Chart StopsFlow Chart ContinuesIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Notes:1. The resident refers to off-site receptors2. Inhalation of dust for off-site receptors is likely 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS4. No current active construction at the Facility5. The only exceedances of the SL were in groundwater 

samples upgradient from AOI 1, suggesting a release unrelated to AOI 1.

Figure 7-1

Conceptual Site Model

NHNGTS

Site 

Worker3,5

Construction 

Worker3,4,5 

Site 

Worker3,5

Construction 

Worker3,4,5 
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`

REC

Huma

Curr

Human 

Activities

Precipitation/

Run-Off

Leaching/Infiltration

Inhalation of 

Dust

Potential 

Unidentified 

On-Facility 

Source 

Unknown 

Release 

Mechanism

PFAS in 

Subsurface 

Soil

AOI 2 (Figure 7-3)

ot

Potential Off-Facility 

Source Not Under 

Control of ARNG

Airborne 

Soil 

Particulate

Surface 

Soil at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

SOURCE

Source Release Mechanism Media

PATHWAY

Transport

and Migration Media Exposure Routes

LEGENDFlow Chart ContinuesIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Notes:1. The resident refers to off-site receptors2. Inhalation of dust for off-site receptors is likely 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS4. No current active construction at the Facility

Figure 7-2

Conceptual Site 

Potentially Unidentifie

NHNGTS

Site 

Worker3,5

Construction 

Worker3,4,5 

Site 

Worker3,5

Construction 

Worker3,4,5 
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REC

Huma

Curr

Human 

Activities

Precipitation/

Run-Off

Leaching/Infiltration

Inhalation of 

Dust

AOI 2

(Former 

Leach Field)

Potential 

releases from 

leach field

PFAS in 

Subsurface 

Soil

Potential Unidentified 

On-Facility Source 

(Figure 7-2)

or 

Potential Off-Facility 

Source Not Under 

Control of ARNG

Airborne 

Soil 

Particulate

Surface 

Soil at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

SOURCE

Source Release Mechanism Media

PATHWAY

Transport

and Migration Media Exposure Routes

LEGENDFlow Chart StopsFlow Chart ContinuesIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Notes:1. The resident refers to off-site receptors2. Inhalation of dust for off-site receptors is likely 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS4. No current active construction at the Facility

Figure 7-3

Conceptual Site Mod

NHNGTS

Site 

Worker3,5

Construction 

Worker3,4,5 

Site 

Worker3,5

Construction 

Worker3,4,5 
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8. SUMMARY AND OUTCOME

This section summarizes SI activities and findings. The most significant findings are summarized 

in this section and are reproduced directly or abstracted from information contained in this 

report. The outcome provides general and comparative interpretations of the findings relative to 

the SLs. 

8.1 SI ACTIVITIES

The SI field activities at the Facility were conducted from 9 to 23 May 2022. The SI field 

activities included soil and groundwater. Field activities were conducted in accordance with the 

UFP-QAPP Addendum (EA/Wood 2022), except as previously noted in Section 5.8.

To fulfill the project DQOs set forth in the approved SI UFP-QAPP Addendum (EA, 2021), 

samples were collected and analyzed for a subset of PFAS by LC/MS/MS compliant with QSM 

5.3 Table B-15 as follows. 

• Seven (7) soil samples from three locations (AOI01-01, AOI01-02, and 

AOI01-03);

• Six (6) grab groundwater samples from temporary well locations;

• Fifteen (15) QA/QC samples.

An SI is conducted when the PA determines an AOI exists based on probable use, storage, and/or 

disposal of PFAS-containing materials. The SI includes multi-media sampling at AOIs to 

determine whether or not a release has occurred. The SI may conclude further investigation is 

warranted, a removal action is required to address immediate threats, or no further action is 

required. Additionally, the CSMs were refined to assess whether a potentially complete pathway 

exists between the source and potential receptors for potential exposure at the AOIs, which are 

described in Section 7. 

8.2 OUTCOME

Based on the results of this SI, further evaluation is warranted for a potential source upgradient 

of AOI 1. Based on the CSMs developed and revised based on the SI findings, there is potential 

for exposure to receptors from sources upgradient of AOI 1 on the Facility resulting from 

historical DoD activities.

Sample chemical analytical concentrations collected during the SI were compared against the 

project SLs in soil and groundwater, as described in Table 6-1. The following bullets summarize 

the SI results relative to the SLs: 

At AOI 1 – Current Leach Field:

o PFOS, PFOA, and PFBS were detected in groundwater below their respective SLs at AOI 1. 

o PFOA was detected in soil at AOI 1 at a concentration that is several orders of magnitude

below the SL. 
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o Based on the results of this SI, no further evaluation is warranted for AOI 1.

At Potential Source Area Upgradient of AOI 1

o PFOA exceeded the SL in groundwater in a temporary well located upgradient of AOI 1 (on 

the Facility) with a maximum concentration of 6.1 J+ ng/L. These results, in conjunction 

with the Facility topography, may indicate a potential source upgradient of the current leach 

field. The detections in the groundwater at locations upgradient of AOI 1 may be related to 

the former leach field (AOI 2), an unidentified on-Facility source, or a potential off-Facility 

source not under control of ARNG. Potential upgradient sources will be investigated as part 

of the RI. 

o Based on the results of this SI, further evaluation is warranted for a potential source 

upgradient of AOI 1.

At AOI 2 – Former Leach Field:

o During preparation of the SI report, information was provided from NHARNG indicating 

that the former leach field had not been in the same location as the current leach field, as was 

previously identified, and the location had been upgradient to the southwest. Based on this 

information, the former leach field was designated as AOI 2 and will also be investigated as 

part of the RI.

Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA 

(commonly referred to as GenX) was not included as an analyte at the time of this SI. Based on 

the CSM developed during the PA and revised based on SI findings, the presence of HFPO-DA 

is not anticipated at the facility because HFPO-DA is generally not a component of MIL-SPEC 

AFFF and based on its history including distribution limitations that restricted use of GenX, it is 

generally not a component of other products the military used. In addition, it is unlikely that 

GenX would be an individual chemical of concern in the absence of other PFAS.

Table 8-1 summarizes the SI results for soil and groundwater and the rationale used to determine 

if an AOI should be considered for further investigation under CERCLA and undergo an RI. 
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Table 8-1. Summary of Site Inspection Findings and Recommendations

AOI

Potential Release 

Area

Soil – 

Source Area

Groundwater –

Source Area Future Action

1 Current Leach Field No Further Action

Source Upgradient of 

AOI 1

TBD Proceed to RI

2 Former Leach Field TBD Proceed to RI

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected

TBD = to be determined
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