FINAL

Preliminary Assessment Report

Kalaeloa Army Aviation Support 

Facility #1-JRF

Hawai’i Army National Guard, 

O’ahu, Hawai’i

Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic Acid 

(PFOA) Impacted Sites

ARNG Installations, Nationwide

October 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Kalaeloa AASF #1-JRF, O’ahu, Hawai’i

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Table of Contents

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

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

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

1.2 Preliminary Assessment Methods ............................................................................. 5

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

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

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

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

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

1.5.3 Hydrology ....................................................................................................... 7

1.5.4 Climate ........................................................................................................... 8

1.5.5 Current and Future Land Use ......................................................................... 8

2. Fire Training Areas ........................................................................................................... 12

3. Non-Fire Training Areas ................................................................................................... 13

3.1 Former Fuel Farm Area ........................................................................................... 13

3.2 Hangar Suppression System and Storage .............................................................. 13

4. Emergency Response Areas ............................................................................................ 16

5. Adjacent Sources ............................................................................................................. 17

5.1 Kalaeloa Airport ...................................................................................................... 17

6. Conceptual Site Model ..................................................................................................... 19

6.1 AOI 1: Former Fuel Farm Area ................................................................................ 19

6.2 AOI 2: Hangar Suppression System and Storage ................................................... 19

7. Conclusions ..................................................................................................................... 23

7.1 Findings .................................................................................................................. 23

7.2 Uncertainties ........................................................................................................... 23

7.3 Potential Future Actions .......................................................................................... 24

8. References ...................................................................................................................... 26
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Tables

Table ES-1 AOIs at Kalaeloa AASF #1-JRF

Table 7-1 AOIs at Kalaeloa AASF #1-JRF

Table 7-2 Summary of Uncertainties

Table 7-3 PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, Kalaeloa AASF #1-JRF, HI

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-2 Preliminary Conceptual Site Model, Kalaeloa AASF #1-JRF, HI

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Conceptual Site Model Information

Appendix C Photographic Log
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Acronyms and Abbreviations

°F degrees Fahrenheit

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI area of interest

ARFF aircraft rescue and firefighting

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CFR Code of Federal Regulations

CSM conceptual site model

DON Department of the Navy

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

HA Health Advisory

HDOT Hawai’i Department of Transportation

HIARNG Hawai’i Army National Guard

mg/l Milligrams per liter

NAS Naval Air Station

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

UCMR 3 Unregulated Contaminant Monitoring Rule 3

UIC underground injection control

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency
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Executive Summary

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

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

Impacted Sites at ARNG Facilities Nationwide. A PA for per- and polyfluoroalkyl substances

(PFAS) containing materials was completed for Kalaeloa Army Aviation Support Facility (AASF)

#1-JRF (also referred to as the “facility”) in, O’ahu, Hawai’i to assess potential PFAS release areas

and exposure pathways to receptors. Occupation of the property by Hawai’i ARNG (HIARNG)

began in 1999.

The performance of this PA included the following tasks:

 Reviewed available administrative record documents and Environmental Data Resources,

Inc. (EDR)TM report packages to obtain information relevant to potential PFAS releases, such

as: drinking water well locations, historical aerial photographs, Sanborn maps, and

environmental compliance actions in the area surrounding the facility;

 ARNG conducted a 1⁄2 -day site visit on 2 May 2019 and completed visual site inspections at

locations where PFAS-containing materials were suspected of being stored, used, or

disposed;

 Interviewed current Kalaeloa and Hawai’i Department of Transportation (HDOT) fire

personnel during the site visit, including a Fire Captain;

 Identified Area(s) of Interest (AOIs) and developed a preliminary conceptual site model (CSM)

to summarize potential source-pathway-receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI.

Two AOIs related to a potential PFAS release were identified at Kalaeloa AASF #1-JRF during

preparation of this PA report. The potential releases are associated with a known release at a

former fuel farm in 2017 and the presence and storage of aqueous film forming foam (AFFF) in

the hangar. The AOIs are shown on Figure ES-1 and described in Table ES-1 below.

Table ES-1: AOIs at Kalaeloa AASF #1-JRF

Area of

Interest

Name Used by Release Date

AOI 1 Former Fuel Farm

Area HDOT Confirmed release: October 2017; unknown historical pump test frequency

AOI 2

Hangar

Suppression

System and

Storage

HIARNG Unknown; no documented releases

Based on the documented release and storage of AFFF at the facility, there is potential for

exposure to PFAS contamination in media at or near the facility. The preliminary CSM for the

Kalaeloa AASF #1-JRF, which presents the potential receptors and media impacted, is shown on

Figure ES-2. Kalaeloa Municipal Airport is located immediately south of the identified AOIs at

Kalaeloa AASF #1-JRF; a section of the northeastern runway is located cross-gradient to the

southern portion of the facility boundary and may be a potential off-facility source of PFAS.

Because this source is located cross-gradient of the facility, it is unknown how much of an impact

the source would have on Kalaeloa AASF #1-JRF. Based on the United States (US)

Environmental Protection Agency (USEPA) Unregulated Contaminant Monitoring Rule 3

(UCMR3) data, it was indicated that no PFAS were detected in a public water system above the
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USEPA’s lifetime Health Advisory (HA) within 20 miles of the facility. The HA is 70 parts per trillion

for PFOS and PFOA, individually or combined. PFAS analyses performed in 2016 had method

detection limits that were higher than currently achievable. Thus, it is possible that low

concentrations of PFAS were not detected during the UCMR3 but might be detected if analyzed

today.
AOI 1

AOI 2

Former Fuel Farm Area

Kalaeloa

Airport

Hangar Suppression

System and Storage

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Summary of Findings

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Feet

Legend

Area of Interest

Potential PFAS Release

Facility Boundary

3
SOURCE PATHWAY RECEPTOR

AOI 1

AOI 2

AFFF 

releases 

during HDOT 

pump testing 

and AFFF 

Storage

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

 Shallow

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site 

Worker

Construction 

Worker Resident Trespasser/

Recreational User

Site 

Worker

Construction 

Worker Resident Trespasser

/ / /

LEGEND

/

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WƌĞůŝŵŝŶĂƌLJŽŶĐĞƉƚƵĂů^ŝƚĞDŽĚĞů

<ĂůĂĞůŽĂ^&ηϭͲ:Z&͕,/

/

/

/

PFAS in 

Surface Soil/ 

Groundwater

Notes:

1. The resident and recreational user

receptors refer to an off-site resident

and recreational user.

2. Dermal contact exposure pathway

is incomplete for PFAS

/ /

/

/ /

/ /

/

/ /

/ / /

4
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1. Introduction

1.1 Authority and Purpose

The Army National Guard (ARNG) G9 is the lead agency in performing Preliminary Assessments

(PAs) and Site Inspections (SIs) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic

acid (PFOA) at Impacted Sites at ARNG Facilities Nationwide. This work is supported by the

United States (US) Army Corps of Engineers (USACE) Baltimore District and their contractor

AECOM Technical Services, Inc. (AECOM) under Contract Number W912DR-12-D-0014, Task

Order W912DR17F0192, issued 11 August 2017.

The ARNG is assessing potential effects on human health related to processes at facilities that

used per- and poly-fluoroalkyl substances (PFAS) (a suite of related chemicals), primarily in the

form of aqueous film forming foam (AFFF) released as part of firefighting activities, although other

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

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

PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing

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

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

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

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

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

national standards regulating PFAS in drinking water. The HA is 70 parts per trillion for PFOS and

PFOA, individually or combined.

This report presents findings of a PA for PFAS-containing materials at Kalaeloa Army Aviation

Support Facility (AASF) #1-JRF (also referred to as the “facility”) in Kalaeloa, O’ahu, Hawai’i in

accordance with the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA), as amended, the National Oil and Hazardous Substances Pollution Contingency Plan

(40 Code of Federal Regulations [CFR] Part 300), and Army requirements and guidance.

This PA documents potential locations where PFAS may have been released into the environment

at Kalaeloa AASF #1-JRF. The term PFAS will be used throughout this report to encompass all

PFAS chemicals being evaluated, including PFOS and PFOA, which are key components of

AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks:

 Reviewed available administrative record documents and Environmental Data Resources,

Inc. (EDR)TM report packages to obtain information relevant to potential PFAS releases, such

as: drinking water well locations, historical aerial photographs, Sanborn maps, and

environmental compliance actions in the area surrounding the facility;

 ARNG conducted a 1⁄2 -day site visit on 2 May 2019 and completed visual site inspections at

locations where PFAS-containing materials were suspected of being stored, used, or

disposed;

 Interviewed current Kalaeloa and Hawai’i Department of Transportation (HDOT) fire

department personnel during the site visit, including a Fire Captain;
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 Identified Area(s) of Interest (AOIs) and developed a preliminary conceptual site model (CSM)

to summarize potential source-pathway-receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI.

1.3 Report Organization

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

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

of each are as follows:

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

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

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

identified during the site visit.

 Section 3 – Non-Fire Training Areas: describes other locations of potential PFAS releases

at the facility identified during the site visit.

 Section 4 – Emergency Response Areas: describes areas of potential PFAS release at the

facility, specifically in response to emergency situations.

 Section 5 – Adjacent Sources: describes sources of potential PFAS release adjacent to the

facility that are not under the control of ARNG.

 Section 6 – Preliminary Conceptual Site Model: describes the pathways of potential PFAS

transport and receptors at the facility.

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

uncertainties of the PA.

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

 Appendix A – Data Resources

 Appendix B – Preliminary Assessment Documentation

 Appendix C – Photographic Log

1.4 Facility Location and Description

Kalaeloa AASF #1-JRF is located on a portion of Former Naval Air Station (NAS) Barbers Point

that was closed on 2 July 1999 as part of the Base Realignment and Closure Act. Kalaeloa AASF

#1-JRF is located at Midway Street in Kapolei, Hawai’i on the island of O’ahu, (Figure 1-1). In

July 2016, HIARNG began leasing approximately 17 acres of adjacent land from HDOT for a term

of 30 years. This additional parcel is located along the southeastern boundary of the facility and

includes a former fuel farm area (approximately 7 acres) and access apron (approximately 10

acres). The facility is bordered by Campbell Industrial Park to the west, the city of Kapolei to the

north, Ewa Beach residential communities to the east, and the Kalaeloa Airport (operated by

HDOT) to the south.

Kalaeloa AASF #1-JRF provides training, maintenance, and flight operations for the various

aviation units that support the Hawai’i ARNG (HIARNG). AASF #1-JRF consists of office areas,

hangars, aircraft parking area, maintenance bays, and storages bays. The Kalaeloa AASF #1-

JRF formally opened in 2018.
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1.5 Facility Environmental Setting

The facility is located on the southern shore of O’ahu, approximately 5 miles west of the entrance

to Pearl Harbor. The natural terrain in the area slopes gently southward, ranging from a maximum

elevation of 0 to 65 feet above mean sea level over a distance of about 2 miles.

1.5.1 Geology

The near-surface geologic units encountered at Kalaeloa AASF #1-JRF are predominantly marine

with minor terrestrial and fill sediments. Major units include coralline limestone, carbonate clastics,

and construction fill material. The coral limestone is of Pleistocene age and was deposited in a

shoreline or in shallow-water, near-shore environments. Within the carbonate clastics unit are

minor layers of darker carbonate mud and reworked coralline rubble and sand (Figure 1-2)

(Department of the Navy [DON], 2008).

1.5.2 Hydrogeology

The shallow groundwater beneath Kalaeloa AASF #1-JRF is perched and occurs within the

caprock. The caprock consists of alternating layers of permeable marine sedimentary rock and

alluvial deposits that overlie the basal volcanic aquifer. Caprock pore water is largely separate

from the deeper basal groundwater, occurring above and frequently within caprock sediments and

extending from the ocean edge to approximately 1 mile inland (Earth Tech and Tetra Tech, 2005).

This type of groundwater is usually connected with the ocean and therefore has high

concentrations of total dissolved solids and is considered non-potable. Depth to groundwater at

Former NAS Barbers Point was measured at approximately 36 to 39 feet below ground surface

(bgs), and groundwater has a south-southeasterly gradient (Earth Tech and Tetra Tech, 2005).

The hydrologic and geologic classification of the upper aquifer in the Ewa aquifer system (Aquifer

Code 3-02-04-116, Status Code 23321) describes the aquifer as a basal, unconfined aquifer in

sedimentary or non-volcanic lithology. The groundwater status for the upper aquifer is classified

as: neither a drinking water source nor ecologically important; moderate salinity level of 1,000 to

5,000 milligrams per liter (mg/L) chloride; replaceable in uniqueness; and highly vulnerable to 

contamination (Mink and Lau, 1990).

An EDRTM report conducted a well search for a 1-mile radius surrounding the facility (Appendix

A). Using additional online resources, such as state and local Geographic Information System

databases, wells were researched to a 4-mile radius of the facility. Several irrigation and industrial

wells lie in the inferred upgradient and cross-gradient pathway to the facility. The USEPA

Unregulated Contaminant Monitoring Rule 3 (UCMR3) data indicate that PFOS/PFOA were not

detected in a public water system above the USEPA HA within a 20-mile radius of the facility. The

HA is 70 parts per trillion for PFOS and PFOA, individually or combined. PFAS analyses

performed in 2016 had method detection limits that were higher than currently achievable. Thus,

it is possible that low concentrations of PFAS were not detected during the UCMR3 but might be

detected if analyzed today. Groundwater features are presented in Figure 1-2.

1.5.3 Hydrology

No perennial streams or drainage ways exist on Kalaeloa AASF #1-JRF due to relatively low

precipitation (20 inches/year) and highly permeable coralline limestone. Storm water runoff

follows the topography (Figure 1-3), flowing south toward the Pacific Ocean until it percolates

(DON, 2002). Local drainage diversions also convey runoff into a series of dry wells (Earth Tech

and Tetra Tech, 2005). An underground injection control (UIC) well (Well #73) is located at the

southern border of the facility, in the vicinity of the former fuel farm. Details regarding the UIC well

were not available at the time of the PA.
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1.5.4 Climate

O’ahu is located in the tropics, with a climate characterized by mild temperatures, northeasterly

trade winds year-round, and moderate humidity. Hawai’i has two seasons: summer (between May

and October) and winter (between October and April). The average coastal temperature is

approximately 79 degrees Fahrenheit (°F), with temperatures decreasing at higher elevations.

The coldest temperatures are in January (72°F) and the warmest temperatures are in August

(89°F). Humidity on O’ahu ranges from approximately 30 to 90 percent. Precipitation

predominantly occurs when the island’s mountain masses capture and cool the rising, warm,

moist ocean air, producing higher rainfall in the windward and mountain areas and lower rainfall

in the leeward and coastal zones. Annual rainfall ranges from 20 inches in the leeward coastal

areas to 250 inches on the Ko’olau mountain peaks (Macdonald, Abbott, and Peterson 1983).

Kalaeloa HIARNG has a mean annual rainfall of approximately 20 inches (National Oceanic and

Atmospheric Administration [NOAA], 2019).

1.5.5 Current and Future Land Use

Current Kalaeloa AASF #1-JRF operations include training and maintenance for the various

aviation units, which support the HIARNG. In addition to aircraft maintenance and aircraft support

for HIARNG, periodic training exercises and course work for the National Guard/Army Reserve

units are conducted at the facility’s training facility. AASF #1-JRF shares tarmac space with the

neighboring Kalaeloa Airport to the south. Portions of the eastern and western borders of Kalaeloa

AASF #1-JRF are abutted primarily by commercial properties. Residential homes border the

northeastern border of the facility.

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

described above.
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Facility Location

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Intermap, INCREMENT P, NRCan, Esri Japan, METI,

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^_

012 0.5

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Legend

Facility Boundary

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Legend

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Pipeline

Inferred Groundwater Flow Direction

Geology

Beach Deposits

Lagoon and Reef Deposits

Manmade Fill

Alluvium

Older Alluvium

Koolan Basalt 

Kolekole Volcanics; Lava Flows

Kolekole Volcanics; Vent Deposits

Waianae Volcanics, Palehua member; Lava Flows

Waianae Volcanics, Palehua member; Vent Deposits

Waianae Volcanics – Kamaileunu member

Waianae Volcanics – Lualualei member 

Wells

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Groundwater Features

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Surface Water Features

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Surface Water Flow

Direction

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2. Fire Training Areas

No FTAs were identified within the facility during the PA through interviews (Appendix B), EDRTM

reports (Appendix A), or observations made by ARNG personnel during a brief visual site

inspection. The personnel interviewed had institutional knowledge spanning from 2014 to present.
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3. Non-Fire Training Areas

In addition to FTAs, the PA evaluated areas where PFAS-containing materials may have been

broadly used, stored, or disposed. This may include buildings with fire suppression systems, paint

booths, AFFF storage areas, and areas of compliance demonstrations. Information on these

features obtained during the PA is included in Appendices A and B. Two non-FTAs were identified

during the PA. A description of each non-FTA is presented below, and the non-FTAs are shown

on Figure 3-1. Photographs taken during the site visit appear in Appendix C.

3.1 Former Fuel Farm Area

HIARNG began leasing a portion of HDOT property that contains a former fuel farm area in July

2016. HDOT operates the adjacent Kalaeloa Airport and maintains an aircraft rescue and

firefighting (ARFF) unit, hereafter referred to as HDOT Kalaeloa ARFF Unit. During the PA,

interviewees indicated that the HDOT Kalaeloa ARFF Unit conducts pump tests of their firetrucks

at random locations surrounding the adjacent airport runway. Pump testing is sometimes

conducted with AFFF mixed into the water tank of the trucks.

On 12 October 2017, HIARNG personnel observed an unknown foam-like substance present on

a walkway located within the former fuel farm area near UIC well #73. As documented in the

subsequent spill report (Appendix A) and confirmed by an interview with the unit fire chief, it was

determined that the HDOT Kalaeloa ARFF Unit discharged the contents of a firetruck’s water tank

during pump testing/repair. The water tank reportedly contained 25-gallons of 1.6% AFFF mixed

with water. Tank contents flowed onto the former fuel farm area leased by HIARNG from the point

of release along the fence line that separates HDOT-controlled property from the former fuel farm.

HDOT Kalaeloa ARFF Unit personnel were unaware that the former fuel farm area was no longer

under HDOT control. Unit personnel were following the historical practice of performing pump

testing over the fence line that separates the former fuel farm from the active runway. HIARNG

personnel did not participate in pump testing activities.

In addition to the foam observed on the walkway, HIARNG personnel observed flattened

vegetation among the surrounding areas, indicating that the foam mixture likely affected a larger

area. The spill report notes that based on the direction of flattened vegetation adjacent to UIC

Well #73, it is suspected some of the AFFF mixture may have also entered the UIC well.

3.2 Hangar Suppression System and Storage

The hangar at Kalaeloa AASF #1-JRF was constructed in 2017 and is equipped with an AFFF fire

suppression system. The system consists of an 800-gallon tank that contains approximately 440-

gallons of Ansulite AFC-3MS 3% AFFF (NSN 4210-01-144-0291) concentrate. The AFFF tank is

located within the mechanical room of the hangar. An additional, eight 55-gallon drums of the

same Ansulite 3% AFFF are stored on secondary containment pallets within the facility’s hangar.

The drums of AFFF are reportedly moved within the hangar as needed and have temporarily been

stored outside the hangar on at least one occasion.

The hangar suppression system is supplied water by an external aboveground storage tank and

associated Fire Pump Building located northeast of the hangar. The Fire Pump Building contains

the diesel-powered water pump system that services the hangar building (Amec Foster Wheeler

Environment & Infrastructure, Inc., 2019). AFFF is not currently or historically stored within the

Fire Pump Building.

The hangar was not inspected during the visual site inspection. Information provided by HIARNG

indicates that the system has never been tested, and there have been no known instances of

leaks or spills from either the system or the drums of AFFF. However, because AFFF is stored at

the facility, there is potential for it to have been incidentally released to the environment during
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handling or via leaks. If a spill or system release occurred within the hangar or mechanical room,

it would likely flow into floor drains that connect to an oil/water separator and subsequently

discharge to the sanitary sewer. Incidental spills that may have occurred or been tracked outside

the hangar would travel via stormwater as sheet flow across impervious pavement to areas of

crushed concrete that surround the hangar and subsequently to drainage pits and/or UIC wells.
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4. Emergency Response Areas

Emergency responses to crashes sometimes require flame suppression, which may result in the

release of PFAS to the environment in the form of AFFF. No emergency response areas were

identified at Kalaeloa AASF #1-JRF during the PA based on interviews, and online research. The

facility relies on Honolulu Fire Department for emergency needs (Appendix B.1).
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5. Adjacent Sources

One off-facility source of PFAS (the Kalaeloa Airport) located adjacent to the Kalaeloa AASF #1-

JRF was identified during PA interviews (Appendix B.1). A description of the adjacent source is

presented below, and the adjacent source is shown on Figure 5-1.

5.1 Kalaeloa Airport

No visual site inspection was performed at the adjacent Kalaeloa Airport during the PA. However,

the Kalaeloa Airport is considered an adjacent PFAS source, as runways are typically the location

of crash sites requiring the usage of AFFF in emergency response, and aviation hangars may

have fire suppression systems charged with AFFF. Additionally, personnel interviewed during the

PA stated that pump testing of HDOT Kalaeloa ARFF Unit firetrucks was conducted on the empty

areas controlled by the HDOT and around the airstrip. One such pump testing location was a

former fuel farm that was previously controlled by HDOT until July 2016 when HIARNG began

leasing the property, described in Section 3.1. Previous pump testing may have also occurred at

the former fuel farm area while it was under HDOT control. The exact locations of all pump testing

areas at Kalaeloa Airport are unknown. Although the pump testing was typically conducted with

water, AFFF was sometimes mixed in the water tank; thus, residual PFAS may have been

released from the previous testing of equipment with AFFF. Pump testing began at an unknown

time and is conducted once a month. Review of the EDRTM reports did not reveal other likely

PFAS sources near the facility.
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6. Conceptual Site Model

Based on the PA findings, one AOI was identified at Kalaeloa AASF #1-JRF. The AOI is shown on

Figures 6-1. The following sections describe the CSM components and the specific preliminary

CSMs developed for each AOI. The CSM identifies the three components necessary for a

potentially complete exposure pathway: (1) source, (2) pathway, and (3) receptor. If any of these

elements are missing, the pathway is considered incomplete.

In general, the potential PFAS exposure pathways are ingestion and inhalation. 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 PFAS toxicological study (National Ground Water Association, 2018).

Receptors at Kalaeloa AASF #1-JRF include site workers, construction workers, and trespassers.

The preliminary CSM for the AOI indicates which specific receptors could potentially be exposed

to PFAS. Kalaeloa Airport is an adjacent source of PFAS located immediately downgradient of

the AOI (Figure 6-1).

6.1 AOI 1: Former Fuel Farm Area

AFFF was released within the AOI 1 area during pump testing activities at the Former Fuel Farm

Area. The area of the AOI is mostly vegetated or paved. Ground-disturbing activities in release

areas could result in site worker, construction worker, and trespasser exposure to potential PFAS

contamination via inhalation of dust or ingestion of surface soil. Ground-disturbing activities to

subsurface soil could result in site and construction worker exposure.

Because AFFF was released directly to the surface at the AOI, surface soil is considered a

potentially complete pathway to site workers, construction workers, and trespassers via ingestion

and inhalation of soil particulates. PFAS may have also infiltrated from surface soil to the

subsurface, and ground-disturbing activities within the AOI may expose construction workers to

potential PFAS in subsurface soil via ingestion and inhalation. Based on the spill incident report

(Appendix A), AFFF likely also drained into UIC Well #73, which may also potentially expose

construction workers to PFAS through ingestion of subsurface soil.

PFAS are water soluble and can migrate readily from soil to groundwater via leaching; however, 

drinking water at Kalaeloa AASF #1-JRF is resourced from public drinking water wells. No drinking

water wells exist at the facility, and no private supply wells exist downgradient. Furthermore,

groundwater in the upper, unconfined aquifer is not used for drinking water purposes due to the

salinity levels and high vulnerability to contamination (Mink and Lau, 1990). Groundwater is

approximately 36 to 39 feet bgs in the area of AOI 1 (Earth Tech and Tetra Tech, 2005). As such,

groundwater is not considered a complete pathway via drinking water ingestion for any receptor

nor via incidental ingestion during excavation activities by construction workers.

The surface water/ sediment pathway is considered incomplete, since there are no surface water

bodies at the facility, and storm water runoff from the facility is captured in dry wells, UIC Well

#73, or is conveyed to open areas for percolation (Earth Tech and Tetra Tech, 2005). Although

there is a hydraulic connection to the Pacific Ocean, approximately 1 mile downgradient of the

facility, any PFAS in groundwater that discharges to the ocean is largely diluted and is unlikely to

present a complete pathway to recreational users.

6.2 AOI 2: Hangar Suppression System and Storage

AOI 2 is the location of the hangar and the surrounding area at Kalaeloa AASF #1-JRF. Although

there have been no known incidences of AFFF release, the hangar and the surrounding area are
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conservatively considered a potential PFAS release area based on the presence of the AFFF

charged fire suppression system and the storage of eight 55-gallon drums of 3% AFFF.

Potential AFFF releases would have occurred either inside the enclosed mechanical room within

the hangar or where the drums of AFFF are stored. The hangar and mechanical room are

constructed with floor drains that lead to an OWS that subsequently discharges to the sanitary

sewer. If AFFF was rinsed into the floor drains, any cracks or leaks are present within the drainage

system may have facilitated the movement of PFAS into the subsurface.

The area within and surrounding AOI 2 is a combination of impervious paved areas and crushed

concrete laid over soil substrate (Amec Foster Wheeler Environment & Infrastructure, Inc., 2019).

Although the topography at the facility is relatively level, stormwater is anticipated to generally

flow to the south-southwest and is directed to UIC wells, drainage pits, and detention basins that

are located at numerous points across the apron. Any AFFF that may have exited the hangar (i.e.,

via tracking or outdoor storage) would have likely been washed into the surrounding areas of

crushed concrete via sheet flow and infiltrated to the underlying soil. Significant rainfall could carry

PFAS to detention basins to the south and southwest of the hangar and subsequently to UIC wells

for subsurface infiltration.

For the above reasons, there is a potentially complete pathway for subsurface soil to construction

workers. Because it is possible that PFAS could have been washed into the surrounding areas of

crushed concrete, surface soil is considered a potentially complete pathway to site workers,

construction workers, and trespassers via ingestion and inhalation of soil particulates.

Like AOI 1 (Section 6.1), groundwater pathways are also considered incomplete for all receptors

because there are no drinking water intakes at or downgradient of the facility and the depth to

groundwater is anticipated to be approximately 36 to 39 feet bgs. The surface water/sediment

pathway is also considered incomplete because there are no surface water bodies at the facility

and storm water runoff is captured in dry wells. The preliminary CSM for AOI 2 is the same as for

AOI 1 and is shown on Figure 6-2.
!5

!5

!5!5

A!

!5!5

!5

!5

!5 !5

!5!5

!5

!5

!5

Pacific Ocean

Kaloi Gulch-Frontal

Pacific Ocean Watershed

Mamala Bay-Pacific

Ocean Watershed

Former Fuel Farm Area

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Airport

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System and Storage

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AOI 2

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Area of Interest

Potential PFAS Release

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Water Body

River/Stream

Canal/Ditch

Surface Water Flow

Direction

Inferred Groundwater

Flow Direction

Wells

!5 Industrial Well

!5 Irrigation Well

A! Other Well

21
SOURCE PATHWAY RECEPTOR

AOI 1

AOI 2

AFFF 

releases 

during HDOT 

pump testing 

and AFFF 

Storage

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

 Shallow

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site 

Worker

Construction 

Worker Resident Trespasser/

Recreational User

Site 

Worker

Construction 

Worker Resident Trespasser

/ / /

LEGEND

/

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<ĂůĂĞůŽĂ^&ηϭͲ:Z&͕,/

/

/

/

PFAS in 

Surface Soil/ 

Groundwater

Notes:

1. The resident and recreational user

receptors refer to an off-site resident

and recreational user.

2. Dermal contact exposure pathway

is incomplete for PFAS

/ /

/

/ /

/ /

/

/ /

/ / /

22
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7. Conclusions

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

and storage of AFFF at the Kalaeloa AASF #1-JRF. The PA findings are based on the information

presented in Appendix A and Appendix B.

7.1 Findings

Two AOIs related to potential PFAS releases were identified at the Kalaeloa AASF #1-JRF during

the PA. Figure 7-1 and Table 7-1 present a summary of PA findings.

Kalaeloa Municipal Airport is located immediately to the south of the identified AOI, at Kalaeloa

HIARNG Facility, and is a potential off-facility source of PFAS.

Table 7-1: AOIs at Kalaeloa AASF #1-JRF

Area of Interest Name Used by Release Dates

AOI 1 Former Fuel Farm

Area

HDOT Confirmed release: 12 October

2017; unknown historical pump

test frequency

AOI 2 Hangar Suppression

System and Storage

HIARNG Unknown; no documented 

releases

Based on the known or potential PFAS releases at the AOIs, there is potential for exposure to

PFAS contamination in media at or near the facility. The preliminary CSM for the AOI at Kalaeloa

AASF #1-JRF details the specific pathways and receptors for the AOI and are shown on Figures

6-2.

7.2 Uncertainties

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

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

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

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

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

The conclusions of this PA are based on all available information, including: previous

environmental reports, EDRsTM, observations made during the visual site inspection, and

interviews. Interviews of personnel with direct knowledge of a facility generally provided the most

useful insights regarding a facility's historical and current PFAS-containing materials. Gathered

information has a degree of uncertainty due to the absence of written documentation, the limited

number of personnel with direct knowledge due to staffing changes, the time passed since PFAS

were first used (1969 to present), and a reliance on personal recollection. Inaccuracies may arise

in potential PFAS release locations, dates of release, volume of releases, and the concentration

of AFFF used. Comprehensive information on all industrial practices that may potentially be

sources of PFAS is incomplete. Therefore, this PA may not identify all potential PFAS sources.

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

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

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

Interviews were not conducted with municipal airport staff, and the site visit did not include visiting

municipal airport assets and hangars because the focus of the assessment was to evaluate
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potential PFAS related activities and sources at HIARNG properties, not formally assess adjacent

sources. AFFF storage or use is commonly associated with such municipal airport facilities. Table

7-2 summarizes the uncertainties associated with the PA.

Table 7-2: Summary of Uncertainties

Location Source of Uncertainty

AOI 1 – Former

Fuel Farm Area

Fuel Farm: While a spill report was available, records documenting

the frequency that pump tests were conducted in the area were not

available. It is possible that release of AFFF during pump tests have

occurred in the past prior to interviewees’ knowledge.

HDOT Kalaeloa

ARFF Unit pump

testing (unknown

locations)

PA interviewees stated that monthly pump tests occur at random

locations across Kalaeloa Airport. The exact locations are unknown. It

is possible there are other locations of releases within the AASF #1-

JRF that are not documented.

AOI 2 – Hangar

Suppression

System and

Storage

The hangar was not inspected at the time of the site visit. There are

no documented tests or releases of the suppression system.

However, it is not known if any incidental releases occurred during

AFFF handling.

7.3 Potential Future Actions

The degree of uncertainties associated with the interviews and data collected during the PA

indicates that current or former HDOT Kalaeloa ARFF Unit activities may have resulted in potential

PFAS releases at the one AOI identified during the PA. Based on the preliminary CSM developed

for the AOI, there is potential for receptors to be exposed to PFAS contamination in soil,

subsurface soil, and groundwater at this AOI. Table 7-3 summarizes the rationale used to

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

and undergo an SI.

Table 7-3: PA Findings Summary

Area of Interest AOI Location Rational Potential Future

Action

AOI 1 – Former

HDOT Fuel Farm

Area

21°19'0.02"N,

158° 3'41.81"W

HDOT Kalaeloa

ARFF Unit released

AFFF during water

pump testing

Proceed to an SI;

focus on soil

AOI 2 – Hangar

Suppression System

and Storage

21°19'11.67"N,

158° 3'30.09"W

Potential PFAS

release a result of

AFFF system and

storage

Proceed to an SI;

focus on soil

ARNG is evaluating an SI at Kalaeloa AASF #1-JRF based on the potential receptors, the

potential migration of PFAS contamination off the facility, and the availability of resources.
AOI 1

AOI 2

Former Fuel Farm Area

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Summary of Findings

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8. References

Amec Foster Wheeler Environment & Infrastructure, Inc., 2019. Spill Prevention, Control, and

Countermeasure Plan, Hawaii Army National Guard - Kalaeloa Facility. February 2018, Amended

January 2019).

DON, Department of the Navy (DON). 2002. Sampling and Analysis Plan, Site Investigation,

National Guard Property, Former Naval Air Station Barbers Point, Oahu, Hawaii. Prepared by

Earth Tech, Inc. and Tetra Tech EM Inc. Pearl Harbor, HI: Naval Facilities Engineering Command,

Hawaii. September.

DON, Department of the Navy (DON). 2008. Site Investigation Report Addendum Revetments

Site, Former Naval Air Station Barbers Point, Oahu, Hawaii. Prepared by Earth Tech, Inc. Pearl

Harbor, HI: Naval Facilities Engineering Command, Hawaii. September.

Earth Tech, Inc. and Tetra Tech EM Inc. (Earth Tech and Tetra Tech). 2005. Site Investigation

Report, National Guard Property, Former Naval Air Station, Barbers Point, Hawaii. March.

Macdonald, G.A, A.T. Abbott, and F.L. Peterson.1983. Volcanoes in the Sea: The Geology of

Hawaii. 2nd ed. Honolulu, HI: University of Hawaii Press

Mink, J. F., and L. S. Lau. 1990. Aquifer Identification and Classification for Oahu: Groundwater

Protection Strategy for Hawai’i. Revised. Tech. Report No. 179. Honolulu: Univ. of Hawai’i, Water

Resources Research Center. February.National Ground Water Association, 2018. Groundwater

and PFAS: State of Knowledge and Practice. January.National Oceanic and Atmospheric

Administration. 2019. Climate Data Online Database. https://www.ncdc.noaa.gov/cdo-web/

(Accessed June 2019).

National Oceanic Atmospheric Administration (NOAA), 2019. U.S. Normals Data (1981-2010)

Map. https://gis.ncdc.noaa.gov/maps/ncei/normals (Data accessed July 13, 2019)

United States Environmental Protection Agency (USEPA). 1991. Guidance for Performing

Preliminary Assessments under CERCLA. EPA/540/G-91/013. September 1991