FINAL

Preliminary Assessment Report

Army Aviation Support Facility

Reno, Nevada

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

July 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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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 ....................................................................................................... 8

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

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

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

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

3.1 Former Firetruck Bay .............................................................................................. 14

3.2 Rotary Wing Parking Apron Area............................................................................. 14

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

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

5.1 Former Stead Air Force Base (Currently Reno-Stead Airport) ................................. 17

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

6.1 AOI 1: Former Firetruck Bay and Rotary Wing Parking Apron Area ......................... 19

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

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

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

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

8. References ...................................................................................................................... 26
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model for AOI 1

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 6-1 Area of Interest

Figure 6-2 Preliminary Conceptual Site Model for AOI 1

Figure 7-1 Summary of Findings

Tables

Table ES-1: Areas of Interest

Table 7-1: Areas of Interest

Table 7-2: Sources of Uncertainty

Table 7-3: PA Findings Summary

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

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Acronyms and Abbreviations

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI

ARNG

Area of Interest

Army National Guard

ANG Air National Guard

bgs below ground surface

CERCLA

CFR

Comprehensive Environmental Response, Compensation, and

LiabilityAct

Code of Federal Regulations

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.TM

°F degrees Fahrenheit

FTA Fire Training Area

HA Health Advisory

NDEP Nevada Department of Environmental Protection

NVARNG Nevada Army National Guard

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Investigation

TMWA Truckee Meadows Water Authority

UCMR3 Unregulated Contaminant Monitoring Rule

US United States

USACE United States Army Corps of Engineers

USDA United States Department of Agriculture

USEPA United States Environmental Protection Agency
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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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 PFAS at the Reno Army Aviation Support Facility

(AASF; also referred to as the “facility”) in Reno, Nevada, to identify areas of known or suspected

releases known as Areas of Interest (AOIs) and possible exposure pathways to receptors. The

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;

· Conducted a 1-day PA site visit on 18 September 2019 and completed visual site inspections

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

disposed;

· Interviewed current AASF Nevada ARNG (NVARNG) personnel during the site visit including

environmental managers and operations staff;

· Identified 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.

One AOI related to a potential PFAS release was identified at the Reno AASF based on PA data.

The AOI is shown on Figure ES-1 and described in the Table ES-1 below:

Table ES-1: Areas of Interest

Area of

Interest Name Used by Potential Release Dates

AOI 1 Former Firetruck Bay and Rotary

Wing Parking Area NVARNG 1980s-mid 2000s

Based on the potential for AFFF releases and or leaks at this AOI, there is potential for exposure

to PFAS contamination in airborne soil particulate and ingestion of surface soil to site and

construction workers, and subsurface soils to construction workers via inhalation and ingestion.

Given the relatively arid climate, surface water is not a likely exposure medium; however, any soil

in drainage ditches (on- and off-facility) could contain residual PFAS. There are no drinking water

wells located at the facility; therefore, groundwater is an incomplete pathway to site workers,

construction workers, and trespassers. However, there is the potential for exposure to PFAS

contamination migrating from AOI 1 in groundwater via ingestion for off-facility residents using

private domestic and public wells. 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 USEPA lifetime Health Advisory

(HA) within 20 miles of the facility. The HA is 70 parts per trillion for PFOA and PFOS, 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.
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Army Aviation Support Facility Reno, Nevada

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One adjacent off-facility potential PFAS release area was identified that includes a fire training

area, flight line, hangars, and several other maintenance and storage areas. As a result of

adjacent PFAS releases, it is possible PFAS is in site media surrounding the AASF. The

preliminary CSM for the Reno AASF is shown on Figure ES-2.
Former 

Firetruck Bay

Reno Stead

Airport

Trimax Storage Area

AOI 1

0 0.25 0.5 1

Miles

Legend

Area of Interest

Potential Release Area

Facility Boundary

Wetland

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

HO

LS

3/19/2020

3/19/2020

NOTES Preliminary Assessment for PFAS at Reno AASF, NV

3/19/2020 ­ Figure ES-1

PM RG 3/19/2020

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NV\RenoAASF\FigES-1_RenoAASF_Summary.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:36,000

3
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – 

Former Fire

Truck Bay

and Rotary

Wing

Parking

Area

Accidental

Firetruck or

Trimax fire

extinguisher

releases or

leaks

PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure ES-2

Preliminary Conceptual Site Model

Reno AASF, Reno, NV

Potential

Off-Facility

Source Not

under

Control of

ARNG

Trespasser

Trespasser

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.

Flow-Chart Stops

4
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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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. The US

Environmental Protection Agency (USEPA) issued lifetime Drinking Water Health Advisories

(HAs) for PFOA and PFOS in May 2016, but there are currently no promulgated national

standards regulating PFAS. The HA is 70 parts per trillion for PFOA and PFOS, individually or

combined.

This document presents the findings of a PA for PFAS-containing materials at the current Army

Aviation Support Facility Reno (AASF; also referred to as the “facility”), Nevada, 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 the known fire training areas (FTAs) as well as other locations where PFAS

may have been released into the environment at the AASF. 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. If a known or suspected discharge of AFFF or other

PFAS-containing material has occurred, that location is designated an Area of Interest (AOI).

1.2 Preliminary Assessment Methods

The following tasks were performed as part 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;

· Conducted a 1-day PA site visit on 18 September 2019 and completed visual site inspections

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

disposed;

· Interviewed current AASF Nevada ARNG (NVARNG) personnel during the site visit including

environmental managers and operations staff;
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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· Identified 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 FTAs at the facility identified during the site

visit;

· Section 3 – Non-Fire Training Areas: describes other locations of suspected PFAS releases

at the facility identified during the site visit;

· Section 4 – Emergency Response Areas: describes areas of suspected AFFF discharge

at the facility, specifically in response to emergency situations;

· Section 5 – Adjacent Sources: describes sources of suspected PFAS release adjacent to

the facility that are not under the control of ARNG;

· Section 6 – Preliminary Conceptual Site Model: describes the pathways of suspected

PFAS transport and receptors at the facility;

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

PA;

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

Reno AASF is located at the Harry Reid Readiness Training Center and occupies approximately

63 acres in the southwest portion of Washoe County, Nevada, about 13 miles northwest of

downtown Reno, and is directly adjacent to Reno-Stead Airport (Figure 1-1). The facility and

properties immediately surrounding the AASF are owned by the Reno-Tahoe Airport Authority,

with Army Aviation Drive to the west, and Reno-Stead Airport to the south and east of the facility

(Broadbent & Associates, 2014).

NVARNG rented hangars and operated helicopters from 1972 to 1984 at the former Stead Air

Force Base, which is now the Reno-Stead Airport. In 1984, the NVARNG facility was constructed

on land leased to the NVARNG by the Reno Tahoe Airport Authority and currently exists and

operates as part of the Harry Reid Readiness Training Center. The lease agreement can be found

in Appendix A. The facility includes multiple buildings, parking lots, and a rotary wing parking

apron.
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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1.5 Facility Environmental Setting

The AASF is located in the southwestern portion of Washoe County, Nevada and is approximately

4,987 feet above mean sea level. The approximate geographic coordinates for the center of the

property are 39°40’22.10”N; 119°53’29.52”W. The majority of the facility is developed with

buildings, concrete, and asphalt features.

The facility and neighboring City of Reno is located within the Truckee Meadows, which is a basin

bounded by the Sierra Nevada on the western edge of the Great Basin. Truckee Meadows covers

approximately 94 square miles in western Nevada and is bounded on the west by the Carson

Range, on the east by the Virginia Range and Pine Nut Mountains, and on the south by the

Steamboat hills and Peavine Peak (Cohen 2016).

Based on the soil survey maps published by the US Department of Agriculture (USDA) Soil

Conservation Service, the facility is predominately mapped as “Greenbrae”, which is sandy loam.

The facility soil hydrologic group classification is Class C – Slow infiltration rates. Class C soils

are described as, “soils with layers impeding downward movement of water, or soils with

moderately fine or fine textures.” (Broadbent & Associates, 2014). According to information found

in the EDRTM Radius Map Report (Appendix A), soils on the property are listed as Doten silty

clay with very slow infiltration rates and moderately well drained textures (AMEC, 2010).

1.5.1 Geology

Reno AASF is located in the northern portion of the Lemmon Valley. The primary structural

indicators in the Lemmon Valley area are north-to-northeast-trending valleys between mountain

ranges. A major fault in the area, the Airport fault, divides the valley into two structural areas. The

fault also approximates the divide between two hydrologic subareas in the valley: the East

Lemmon subarea is in the eastern section of the valley, and the Silver Lake subarea is to the west

(Schaefer 1981). The USGS describes the shallow geological deposits of this region as stratified

sequences of quaternary alluvium.

1.5.2 Hydrogeology

The AASF is located within the Lemmon Valley Hydrographic Basin. These two hydrographic

basins that comprise Lemmon Valley represent two separate groundwater reservoirs. In each

basin, groundwater resources exist in both fractured consolidated rocks in the uplands adjacent

to and at depth beneath valley fill and in valley-fill alluvium that partly fills the structural depression

underlying Lemmon Valley. The valley-fill alluvium represents the more productive and most

important aquifers in both hydrographic basins due to its overall transmissivity, permeability, and

extent. The thickness of the alluvial deposits is roughly 200 to 400 feet thick before bedrock is

encountered. According to the Nevada Division of Water Resources online database,

groundwater flow in the region flows southwest and the groundwater depth is approximately 30

to 50 feet below ground surface (bgs) (Nevada Department of Environmental Protection [NDEP]

2015).

Groundwater sources and storage provide between 5 and 15% of the Truckee Meadows Water

Authority (TMWA) water supply. TMWA owns 33 production wells that have a combined capacity

of 63 million gallons per day. The wells are used for summer peak times and provide off-river

reliability. In winter months, the wells are used to recharge treated water (TMWA, 2016). TMWA

operates an aquifer storage and recovery program in Lemmon Valley – Western Part (Basin

092A). This project is associated with Nevada State Engineer’s Recharge Permit R15. The
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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recharge permit was issued on November 19, 2008 and allows for the recharge of up to 1,000

acre-feet annually of Truckee River surface water imported to Lemmon Valley from Truckee

Meadows (Hydrographic Basin 6-087). Permit R-15 also provides for four injection/recovery wells

in the system located near the former Stead Air Force Base (NDEP 2015).

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. According to data received

from the EDRTM report for the facility, three monitoring wells were located on site, and several

dozen are located within a 1-mile radius of the facility. A large number of wells are also classified

as either domestic, public water supply, or unspecified wells (Figure 1-2). Information regarding

the general depth of the public supply wells was not available in either the EDRTM or state well

database. Three monitoring wells located on the facility were part of a previous remedial

investigation that concluded in 2018 and were abandoned on 5 September 2018 (driller’s

abandonment logs appear in Appendix A).

1.5.3 Hydrology

The AASF has an approximate elevation of 5,000 feet above mean sea level. The area is relatively

flat, and the immediate vicinity has a shallow slope to the southeast. Surface water runoff from

the facility drains to the west. Storm water runoff is generated by snow melt and rainfall.

Stormwater is channeled from the pavement surfaces of the facility into two underground

stormwater interceptors that discharge to open flow channels on the west side of Army Aviation

drive. Other drainage features located on the facility include open swales, gutters in the parking

lot, gutters on the helicopter tarmac on the east side of the AASF, and drop inlets (Broadbent &

Associates, 2014). Surface water within the basin in which the facility is located generally flows in

a southern direction towards nearby playas.

Since 1944, surface water from the Truckee River has been imported from the TMWA through a

pipeline to serve the former Stead Air Force Base. In the 1960s, importation of Truckee River

water into Lemmon Valley was expanded to serve the area of Raleigh Heights in the southern

part of the Lemmon Valley. Currently, TMWA continues to import Truckee River water into

Lemmon Valley each year, a portion of which serves their customers directly, with the remainder

being stored in the groundwater aquifer in Lemmon Valley – Western Part (NDEP 2015). While

the TMWA obtains its water supply from both surface water and groundwater, surface water

sources and storage provide between 85 and 95 percent of the TMWA water supply. Surface

water is treated at Chalk Bluff and Glendale Treatment Plants before distribution into the system,

and the groundwater is pumped from wells throughout the service territory (TMWA, 2016).

The City of Reno operates a wastewater treatment plant in Lemmon Valley – Eastern Part,

southeast of the Reno-Stead Airport, near Swan Lake. The Reno-Stead Water Reclamation

Facility is located adjacent to the basin boundary with Lemmon Valley – Western Part and treats

wastewater received primarily from residential properties, along with some commercial and

industrial properties, and the AASF. The plant has a treatment capacity up to 2 million gallons per

day, with planned improvements to accommodate up to 4 million gallons per day. Treated effluent

is pumped from the treatment plant to various locations for reuse within Lemmon Valley. Reuse

of effluent from the Reno Stead Water Reclamation Facility is authorized by the Nevada State

Engineer under Permit 4541S05 and by the Nevada Division of Environmental Protection under

Permit NS2008500. Permitted use of the treated effluent includes irrigation of Sierra Sage Golf

Course, North Valleys Sports Complex, and Mayors Park. On-site reuse of effluent at the RenoStead Water Reclamation Facility is also permitted for landscape irrigation and for an onsite
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

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effluent truck fill station for construction water. Delivery of effluent is also permitted to nearby

Swan Lake to support wildlife habitat under an agreement with the US Bureau of Land

Management. Washoe County also operates a smaller capacity wastewater treatment plant in

Lemmon Valley – Eastern Part. The Lemmon Valley Wastewater Reclamation Facility operates at

approximately 300,000 gallons per day, and effluent reuse from this facility does not occur.

Several times per year, polished effluent is discharged to Lemmon Lake Playa (Swan Lake),

where it rapidly evaporates (NDEP 2015). Surface water features in the region are shown in

Figure 1-3.

Based on the USEPA UCMR3 data, it was indicated that no PFAS were detected in a public water

system above the HA within 20 miles of the facility. The HA is 70 parts per trillion for PFOA and

PFOS, 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.

1.5.4 Current and Future Land Use

Presently, the AASF is a fully developed NVARNG active military training facility comprised of

three large structures, four small structures, a helicopter landing pad, a large paved parking area

west of the armory, and a large gravel lot to the east of the armory building used for equipment

parking and storage. Building structures on the facility include an Armory Building, AASF, Field

Maintenance Shop, Operational Support Airlift, Hazardous Materials Storage Building, Fire Pump

House, and Gymnasium. The current land use is listed as General Industrial. Future land use is

not anticipated to change (Broadbent & Associates, 2014).

1.5.5 Climate

Reno AASF is situated in western Nevada and in the rain shadow of the Sierra Nevada mountain

range (O’Hara, 2006). Being in the high desert of the Great Basin, the area experiences large

temperature ranges on both a diurnal and annual scale. During the summer, afternoon highs are

often above 90 degrees Fahrenheit (°F), but at night, the air mass can cool down to about 50 °F.

This area experiences a typical four seasons, though spring and fall can be short, as is common

for mid-latitude dry climates. Reno receives an average of 11.12 inches of precipitation per

calendar year, which primarily occurs between the months of November and March. The warm

half of the year is relatively dry, with a secondary precipitation maximum in May. An average of

23.5 inches of snow falls in Reno annually, also occurring primarily between November and March

(National Oceanic and Atmospheric Administration [NOAA], 2019).
Army Aviation

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11/4/2019

11/4/2019

NOTES Preliminary Assessment for PFAS at Reno AASF, NV

11/4/2019 ­ Figure 1-1

PM RG 11/4/2019

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NV\Fig1-1_RenoAASF_SiteLocation.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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NOTES Preliminary Assessment for PFAS at Reno AASF, NV

2/17/2020 ­ Figure 1-2

PM RG 2/17/2020

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NV\RenoAASF\Fig1-2_RenoAASF_Groundwater.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:64,728

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11
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REVISED

SCALE

ARNG

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NOTES Preliminary Assessment for PFAS at Reno AASF, NV

3/11/2020 ­ Figure 1-3

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12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:126,720

Swan Lake

12
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

13

2. Fire Training Areas

No FTAs were identified during the PA. According to historical research and interviews conducted

with facility personnel, any fire training completed on base was over 20 years ago with dish soap

on the parking apron near the drain racks. Personnel indicated that any fire training activities

historically and presently occur at the former Stead Air Force Base, currently the Reno-Stead

Airport adjacent to the AASF facility. The City of Reno Fire Department handles aviation

emergencies. Interview records appear in Appendix B.
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

14

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 are included in Appendices A and B. Two non-FTAs where AFFF

was stored were identified during the PA. A description of each non-FTA is presented below, and

the non-FTAs are shown on Figure 3-1. Interview records with relevant information appear in

Appendix B, and photographs appear in Appendix C.

3.1 Former Firetruck Bay

The South Hangar, located centrally on site, formerly housed a single standard crash fire rescue

truck and related equipment until the late 1980s, when the truck was returned or sold due to the

lack of trained personnel to operate the truck. Since AFFF use was not recorded on site, it is

unclear if AFFF was ever stored on the truck. There are no records or recollection of the truck

ever being used for fire training or emergency response.

Presently, the South Hangar is fitted with an AFFF foam deluge fire protection system, which

features a fire suppression system throughout the hangar, and a large AFFF storage tank housed

where the firetruck formerly sat. The large fire suppression tank, according to the label found on

said tank, is a model CCS3-704VA tank built in 1990 by Arrow Tank & Engineering Company. The

tank is good condition, has a rubber diaphragm, and shows no signs of past or present leakage

(Appendix C). There are no drains in the room that houses the AFFF storage tank; however,

drains do exist in the main portion of the South Hangar, which leads to a sand and oil separator

on site. All drains within the facility at the AASF are routed to the local water treatment plant, Stead

Treatment Plant, located approximately 5 miles southeast of the facility. There are no records or

recollection from interviewees of any incident in which the fire suppression system was used or

tested.

3.2 Rotary Wing Parking Apron Area

Portable Tri-MaxTM hand-truck fire extinguishers containing AFFF were previously stored in various

places on and near the parking apron from approximately the mid-1990s through the early 2000s.

These extinguishers were serviced regularly by ABC Fire and turned into the Carson City

Warehouse Defense Reutilization and Marketing Office in the early 2000s. There is no record of

these hand-trucks being used in training or emergency situations. The Tri-MaxTM units were

replaced with two different types of extinguishers, one that contains AFFF, and one that does not

contain AFFF. Only one unit containing AFFF exists on base and is located in the C12 hangar

immediately adjacent to the Rotary Wing Parking Apron (Figure 3-1). The remaining fire

extinguishers, which do not contain AFFF, continue to be moved around various places on the

Rotary Wing Parking Apron Area. Photos and additional information on the types of fire

extinguishers that currently exist on the facility can be found in Appendix C.
Former

Firetruck Bay

Trimax

Storage

Area

0 250 500 1,000

Feet

Legend

Potential PFAS Release Area

Facility Boundary

Wetland

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

LS

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NOTES Preliminary Assessment for PFAS at Reno AASF, NV

3/19/2020 ­ Figure 3-1

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12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:6,000

15
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

16

4. Emergency Response Areas

No emergency response areas were identified within the boundaries of the AASF facility during

the PA through interviews, previous investigations, online research, and the EDRTM report

(Appendix A). Personnel interviewed during the PA site visit stated that no incidents have

occurred on site that required fire suppression (Appendix B), though it was noted that plane

crashes have occurred in areas adjacent to the facility. Interviewee knowledge dates from 1987

to present. The City of Reno Fire Department provides emergency response to Reno AASF.
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

17

5. Adjacent Sources

One off-facility PFAS source was identified adjacent to Reno AASF during the PA and is discussed

below. Figure 5-1 presents the location of the suspected adjacent PFAS sources.

5.1 Former Stead Air Force Base (Currently Reno-Stead Airport)

Reno-Stead Airport began in 1942 as the Reno Army Airport, an air base built by the Army Air

Corps. In 1951, the air base was renamed Stead Army Airbase. From 1954 to1964, the air base

served as a training center for Army, Navy, Marine, Air Force, and foreign officers, as well as most

of the pre-1965 astronauts. In 1966, the Stead Army Airbase was transferred to the City of Reno,

and in June 1966, it began operating as Reno-Stead Airport (Reno Tahoe Airport Authority, 2019).

Reno-Stead Airport currently covers an area of 5,000 acres and has two asphalt paved runways.

There have been several crashes at Reno-Stead airport throughout its long history, though it is

unknown whether AFFF were used as an emergency response measure for these incidents. A

fire academy exists at Reno-Stead Airport where, according to interviewee knowledge, fire training

has historically and currently occurred on base using AFFF foam. Before Reno AASF was

constructed, hangars located on Stead Air Force Base were used by the ARNG to store

helicopters from 1972-1984, and any firefighting activities that occurred during this time were via

airport firefighters (Appendix A).
Reno Stead

Airport

0 0.25 0.5 1

Mile

Legend

Potential Release Area

Facility Boundary

River/Stream

Wetland

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REVISED

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12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:36,000

18
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

19

6. Preliminary Conceptual Site Model

Based on the PA findings, one potential release area was identified at Reno AASF and is

considered an AOI. The AOI location is shown on Figure 6-1. The following section describes the

CSM components and the specific preliminary CSM developed for the AOI. A CSM includes three

components necessary for potentially complete exposure pathways related to a site: (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 a negligible

pathway compared to ingestion; however, exposure data for dermal pathways are sparse and

continue to be the subject of PFAS toxicological study. Receptors for Reno AASF include site

workers, construction workers, and off-site residents. Trespassers are not anticipated at this

facility as the perimeter is secured with a fence. The CSM indicates which specific receptors could

potentially be exposed to PFAS.

6.1 AOI 1: Former Firetruck Bay and Rotary Wing Parking Apron

Area

AOI 1 encompasses the South Hangar and surrounding parking apron. The former firetruck bay,

located in the South Hangar, previously housed a standard crash fire rescue truck and related

equipment until the late 1980s. It is unknown exactly how long the firetruck was stored in the

firetruck bay and if AFFF were ever stored on the truck or used in an emergency response. The

former firetruck bay does not contain any drains and presently houses an AFFF storage tank for

the fire suppression system for the South Hangar. Portable Tri-MaxTM hand-truck fire extinguishers

containing AFFF had been stored on the adjoining parking apron and moved to various places on

and near the apron from about the mid-1990s through the early 2000s. There are no records or

recollection of these hand-trucks leaking or being used in training or emergency situations.

On the parking apron, AFFF from a Tri-MaxTM release or flowing out of the hangar could be washed

into surrounding soil and infiltrate the subsurface via cracks or joint in the pavement. If AFFF were

released from the storage tank or suppression system, it is possible that the material could have

flowed out of the hangar doors or into the hangar floor drains that connect to the local wastewater

treatment plant. A visual summary of the AOI is shown on Figure 6-1. Photographs of points of

interest at the AOI appear in Appendix C.

Ground disturbing activities in the area could result in construction worker and site worker

exposure to possible PFAS contamination via inhalation of dust or ingestion of surface soil, and

subsurface soil exposure for the construction worker. Given the relatively arid climate, surface

water is not a likely exposure medium; however, any soil within drainage ditches (on- and offfacility) could contain residual PFAS.

PFAS are water soluble and can migrate readily from soil to groundwater. Groundwater beneath

the facility ranges from 30 to 50 feet bgs. While the city sources 85 to 95% of its drinking water

from surface water, the remaining 5 to 15% comes from groundwater. There are no drinking water

wells located at the facility; therefore, groundwater is an incomplete pathway to site workers,

construction workers, and trespassers. There are several public and domestic water wells listed

in the Nevada database within a 1-mile radius of the facility, with many of these wells located

downgradient of the facility, which could provide drinking water to the surrounding areas (Figure

1-2). As such, the pathway for off-facility resident exposure to PFAS in groundwater is considered
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

20

potentially complete for residents depending on where the wells are screened. The preliminary

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

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0 250 500 1,000

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REVISED

SCALE

ARNG

GIS BY

CHK BY

SK

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3/19/2020 ­ Figure 6-1

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Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NV\RenoAASF\Fig6-1_RenoAASF_AOIs.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Areas of Interest

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:6,000

21
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – 

Former Fire

Truck Bay

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Parking

Area

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Firetruck or

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Worker

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LEGEND

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Figure 6-2

Preliminary Conceptual Site Model

Reno AASF, Reno, NV

Potential

Off-Facility

Source Not

under

Control of

ARNG

Trespasser

Trespasser

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.

Flow-Chart Stops

22
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

23

7. Conclusions

This document presents a summary of information on known or suspected management of AFFF

at Reno AASF. The PA findings are based on personnel interviews, environmental investigations

and reports, historical documents, and the VSI. The PA findings are based on the information

presented in Appendix A, Appendix B, and Appendix C.

7.1 Findings

One AOI related to potential PFAS release was identified at the Reno AASF based on PA data

(Figure 7-1) and is described in Table 7-1 below:

Table 7-1: Areas of Interest

Area of

Interest Name Used by Potential Release Dates

AOI 1 Former Firetruck Bay and Rotary

Wing Parking Apron NVARNG 1980s-mid 2000s

Because there is some uncertainty regarding possible AFFF releases, there is potential for

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

AASF is shown on Figure 6-2, which presents the potential receptors and media impacted.

An adjacent potential PFAS release area was also identified. The Reno-Stead Airport, formerly

Stead Air Force Base, includes a fire academy that hosts regular fire training activities using AFFF.

Additionally, several aviation incidents have occurred on the site throughout its long history,

though it is unknown whether AFFF were used in response.

7.2 Uncertainties

A number of information sources were evaluated 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, other non-traditional activities, or on its disposition. There is no historically

documented use of PFAS containing materials at Reno AASF by NVARNG staff.

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

environmental reports, EDRsTM, observations made during the VSI, 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. Sometimes, the provided information

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

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

the time passed since AFFF were first used, and a reliance on personal recollection. Inaccuracies

may arise in suspected AFFF discharge locations, discharge dates, discharge volumes, and PFAS

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

how PFAS may enter the environment continually evolves.

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

of PFAS were reviewed, current personnel were interviewed from NVARNG and NVANG, multiple
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

24

persons were interviewed for the same potential source area, and potential source areas were

visually inspected.

Table 7-2 summarizes the uncertainties associated with the PA:

Table 7-2: Sources of Uncertainties

Area of Interest Source of Uncertainty

AOI 1 Former Firetruck

Bay and Rotary Wing

Parking Area

It is unknown if the firetruck previously stored in the former

firetruck bay held AFFF and for how long. If the firetruck did

store AFFF, it is uncertain if any releases or leaks occurred. If a

leak or release did occur, the timeframe and volume released

is unknown.

There are no records of the Tri-MaxTM hand-truck units

previously stored on the rotary wing parking apron being used,

tested or leaking. If a leak or release did occur, the timeframe

and volume released is unknown.

Fire Suppression System

in South Hangar

It is unknown if the fire suppression system were tested when

first installed in 1984. Direct knowledge from interviewees

spans from 1987 to present, and fire suppression system was

likely installed in 1984, when the building was constructed.

7.3 Potential Future Actions

Table 7-3 summarizes the rationale used to determine if the AOI should be considered for further

investigation under the CERCLA process and undergo a SI.

Table 7-3: PA Findings Summary

Area of Interest AOI Location Rationale Potential Future

Action

AOI 1 Former

Firetruck Bay and

Rotary Wing Parking

Area

39°40'31.02"N; 

119°53'31.81"W

Potential AFFF release / leak

from firetruck, fire suppression

system and Tri-MaxTM hand

trucks

Proceed to an SI,

focus on soil and

groundwater

ARNG will evaluate the need for an SI at AOI 1 at the Reno AASF based on the potential

receptors, the potential migration of PFAS contamination off the facility, and the availability of

resources.
Former

Firetruck Bay

Reno Stead

Airport

Trimax Storage Area

AOI 1

0 0.25 0.5 1

Miles

Legend

Area of Interest

Potential Release Area

Facility Boundary

Wetland

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

HO

LS

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3/19/2020 ­ Figure 7-1

PM RG 3/19/2020

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NV\RenoAASF\Fig7-1_RenoAASF_Summary.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

1:36,000

25
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

26

8. References

AMEC. December 2010. Final Phase I Site Assessment for The Nevada Army National Guard

Harry Reid Training Center 20,000 Army Aviation Drive Reno, Nevada. Nevada Army

National Guard. AMEC Project Number: 10-417-00946.

Broadbent & Associates, Inc. September 2014. Phase 1 Environmental Site Assessment Nevada

Army National Guard – Harry Reid Training Center. Nevada Army National Guard. APN

Number: 086-850-03. Project Number: 14-02-115.

Cohen, Philip. 2016. Evaluation of hydrogeology and hydrogeochemistry of Truckee Meadows

area, Washoe County, Nevada. USGS Publications Warehouse.

National Oceanic and Atmospheric Administration. 2019. Climate Data Online Database.

https://www.ncdc.noaa.gov/cdo-web/datatools/normals

Nevada Department of Environmental Protection (NDEP). 2015. Lemmon Valley Hydrographic

Basins 7-092A and 7-092B Groundwater Pumpage Inventory Water Year 2015. Nevada

Department of Conservation and Natural Resources Division of Water Resources.

O’Hara, Brian. October 2006. NOAA Techincal Memorandum NWS WR-276, Climate of Reno,

Nevada. National Oceanic and Atmospheric Administration.

Reno-Tahoe Airport Authority. 2019. History of Reno-Stead Airport. Reno-Tahoe Airport Authority.

Accessed November 2019. https://www.renoairport.com/airport-authority/reno-steadairport-rts/history-reno-stead-airport

Schaefer, Donald H., & Maurer, Douglas K. 1981. Geophysical Reconnaissance of Lemmon

Valley, Washoe County, Nevada. Water-Resources Investigations Open-File Report 80-

1123. Nevada Division of Water Resources. United States Department of the Interior

Geological Survey.

Truckee Meadows Water Authority (TMWA). 12 October 2016. Where does TMWA get their water

supply? Truckee Meadows Water Authority. Accessed 12 December 2019.

https://tmwa.com/article/where-does-tmwa-get-their-water-supply/

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

Assessments under CERCLA. EPA/540/G91/013.
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix A

Data Resources
PFAS Preliminary Assessment Report

Reno AASF, Reno, Nevada

Data Resources will be provided separately on CD. Data Resources for Reno AASF facility 

include:

Reno AASF Previous Investigations

· 2010 AMEC. Final Phase 1 Site Assessment for the NVARNG Harry Reid Training Center

· 2014 Broadbent. Phase 1 Environmental Site Assessment. NVARNG Harry Reid Training

Center

Reno AASF Facility Information

· 2008 State of Nevada – Office of the Military Nevada National Guard. Senator Harry Reid

Readiness and Training Center Facility Condition Analysis Site Number: 9920. State of

Nevada Public Works Board

· 2014 Airport Joint Use Agreement

· 2014 Reno Tahoe Airport Authority Land Lease Agreement Nevada State Lands NVARNG.

· 2018 Nevada Division of Environmental Protection. NVARNG Well Closure Packet. State of

Nevada Department of Conservation & Natural Resources.

· 2018 Nevada Division of Environmental Protection. NVARNG Well Closure NFA –

Groundwater Exemption, PCE in Groundwater. State of Nevada Department of

Conservation & Natural Resources.

Reno AASF EDRTM Report

· 2019 Reno AASF Environmental Data Resource Report
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix B.1

Interview Records


PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix B.2

Visual Site Inspection Checklists

PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

Army Aviation Support Facility Reno, Nevada

Appendix C

Photographic Log
Preliminary Assessment Report

Army Aviation Support Facility Reno

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Army Aviation Support Facility Reno Reno, Nevada

Photograph No. 1

Description:

Facing West. Fire suppression 

tank in South Hangar.

Photo Date: 09/18/2019 0945 

Photograph No. 2

Description:

Facing West. Fire suppression 

tank in South Hangar.

Photo Date: 09/18/2019 0945
Preliminary Assessment Report

Army Aviation Support Facility Reno

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Army Aviation Support Facility Reno Reno, Nevada

Photograph No. 3

Description:

Facing South. Drain line 

direction through the flight 

line and ramps.

Photo Date: 09/18/2019 0951

Photograph No. 4

Description:

Facing North. Oil/sand 

separator and drain line.

Photo Date: 09/18/2019 0953
Preliminary Assessment Report

Army Aviation Support Facility Reno

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Army Aviation Support Facility Reno Reno, Nevada

Photograph No. 5

Description:

Facing North. New fire

extinguishers on flight line.

Photo Date: 09/18/2019 0956

Photograph No. 6

Description:

Facing North. New fire 

extinguishers which have 

AFFF. 

Callouts contain detailed 

information on specs.

Photo Date: 09/18/2019 1001