FINAL

Preliminary Assessment Report

Army Aviation Support Facility #2,

Wheeling, West Virginia

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

August 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

i

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 ................................................................................... 6

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

2.1 Hangar Ramp FTA .................................................................................................. 12

2.2 Wash Pad FTA ........................................................................................................ 12

2.3 Helicopter FTA ........................................................................................................ 13

3. Non-Fire Training Areas ................................................................................................... 15

3.1 HAZMAT Room ....................................................................................................... 15

3.2 Kitchen Hood Fire Suppression System .................................................................. 15

3.3 Tri-MaxTM Fill Area 1 ................................................................................................ 15

3.4 AFFF Storage Shed ................................................................................................ 15

3.5 Tri-MaxTM Fill Area 2 ................................................................................................ 15

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

5. Adjacent Sources ............................................................................................................. 18

5.1 Plane Crash Site 1 .................................................................................................. 18

5.2 Plane Crash Site 2 .................................................................................................. 18

5.3 Short Creek Landfill ................................................................................................ 18

5.4 Wheeling Ohio County Airport ................................................................................. 18

6. Preliminary Conceptual Site Model .................................................................................. 20

6.1 AOI 1: FTAs, Surface Drainage Path, HAZMAT Room, and Tri-MaxTM Fill Area

2 ............................................................................................................................. 20

6.2 AOI 2: AFFF Storage Shed and Tri-MaxTM Fill Area 1 .............................................. 21

7. Conclusions ..................................................................................................................... 26

7.1 Findings .................................................................................................................. 26

7.2 Uncertainties ........................................................................................................... 26

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

8. References ...................................................................................................................... 30
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

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Tables

Table ES-1 AOIs at Wheeling AASF #2

Table 7-1 AOIs at Wheeling AASF #2

Table 7-2 No Suspected Release Areas

Table 7-3 Uncertainties

Table 7-4 PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, Wheeling AASF #2, West Virginia

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 2-1 Fire Training Areas

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model, AOI 1: FTAs, Surface Drainage Path,

HAZMAT Room, and Tri-MaxTM Fill Area 2

Figure 6-3 Preliminary Conceptual Site Model, AOI 2: AFFF Storage Shed and Tri-MaxTM Fill

Area 1

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

iii

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

ARNG Army National Guard

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CFR Code of Federal Regulations

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

HA Health Advisory

HAZMAT hazardous materials

NGWA National Ground Water Association

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

ppt parts per trillion

SI Site Inspection

UCMR3 Unregulated Contaminant Monitoring Rule 3

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

USPFO United States Property and Fiscal Office

WVARNG West Virginia Army National Guard

WVDEP West Virginia Department of Environmental Protection

WVGES West Virginia Geological and Economic Survey
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

1

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 Wheeling Army Aviation Support Facility (AASF)

#2 (also referred to as the “facility”) in Wheeling, West Virginia, to assess potential PFAS release

areas and exposure pathways to receptors. AASF #2 is constructed on a parcel of land owned by

the Ohio County Commission and leased to the West Virginia ARNG (WVARNG). According to

the lease document, the lease began on 14 December 1988 and is eligible for a term of 99 years,

until 13 December 2087.

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; 

· Conducted a site visit on 3 October 2019 and completed visual site inspections at locations

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

· Interviewed current and retired AASF #2 personnel including the facility commander,

operations staff, and personnel who are also local volunteer firefighters; and

· Identified areas of interest (AOIs) and developed a preliminary conceptual site model (CSM)

to summarize potential PFAS source-pathway-receptor linkages for each AOI.

Two AOIs (referred to as “AOI 1” and “AOI 2”) related to potential PFAS release were identified at

AASF #2 during the PA. The AOIs are shown on Figure ES-1 and described in Table ES-1 below.

Table ES-1: AOIs at Wheeling AASF #2

Area of Interest Name Used by Potential Release Date

AOI 1 FTAs, Surface

Drainage Path,

HAZMAT Room,

and Tri-MaxTM Fill

Area 2

AASF #2 Personnel,

Airport Employees, Local

Fire Department

Personnel, and Visiting

Drill Soldiers

 2000-2013

AOI 2 AFFF Storage

Shed and TriMaxTM Fill Area 1

AASF #2 Personnel 2000-2013

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

contamination in media at or near the facility. The preliminary CSM for AASF #2, which presents

the potential receptors and media impacted, is shown on Figure ES-2. The Short Creek Landfill

and the Wheeling Ohio County Airport were identified as potential off-facility, adjacent sources of

PFAS.

Based on the US Environmental Protection Agency’s (USEPA) Unregulated Contaminant

Monitoring Rule 3 (UCMR3) data, no PFAS were detected in a public water system above the

USEPA lifetime Health Advisory within 20 miles of the facility (USEPA, 2017). 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
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

2

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

today.
AOI 1

AOI 2

Tri-Max

Fill Area 1

Kitchen

Hood System

Tri-Max

Fill Area 2

Helicopter

FTA

Hangar Ramp

FTA

Wash Pad FTA

HAZMAT

Room

AFFF

Storage Shed

0 175 350 700

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected PFAS Release

Facility Boundary

Stormwater Inlet

Stormwater Drainage Pathway

Open Stormwater Drain

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

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NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

6/8/2020 ­ Figure ES-1

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Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:4,200

3
Media

SOURCE PATHWAY RECEPTOR

AOI 1

&

AOI 2

FTAs, AFFF

Storage, Refill of

Tri-MaxTM Units

PFAS in

Concrete,

Drainage

System, and

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

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser

Site

Worker

Construction

Worker Resident Trespasser

/ / /

/ / /

LEGEND

/ / / /

/ / / /

/ / /

Figure ES-2

Preliminary Conceptual Site Model

Wheeling AASF #2, West Virginia

Notes:

1. The residential receptor refers to an off-facility

receptor.

2. Human consumption of agricultural products or

fish potentially affected by PFAS is possible.

/

/

/

4
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

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1. Introduction

Authority and Purpose

The Army National Guard (ARNG) G9 Division 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), 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 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 drinking water lifetime Health 

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

national standards regulating PFAS in drinking water (USEPA, 2016a; USEPA, 2016b). The HA 

is 70 parts per trillion (ppt) for PFOS and PFOA, individually or combined. 

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

Support Facility (AASF) #2 (also referred to as the “facility”) in Wheeling, West Virginia, in 

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

(CERCLA; USEPA, 1980), as amended, the National Oil and Hazardous Substances Pollution 

Contingency Plan (40 Code of Federal Regulations [CFR] Part 300; USEPA, 1994), and Army 

requirements and guidance. 

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

at AASF #2. 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.

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;

· Conducted a site visit on 3 October 2019 and completed visual site inspections (VSIs) at 

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

disposed;

· Interviewed current and retired AASF #2 personnel including the facility commander, 

operations staff, and personnel who are also local volunteer firefighters during the site visit; 

and

· Identified areas of interest (AOIs) and developed a preliminary conceptual site model (CSM) 

to summarize potential PFAS source-pathway-receptor linkages for each AOI.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

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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 PFAS transport 

and receptors for the AOIs and 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

Facility Location and Description

AASF #2 occupies 38.14 acres in Wheeling, West Virginia (Figure 1-1). The facility is located 

adjacent to the Wheeling Ohio County Airport, east of Runway 34. Aside from the airport and 

runways to the northwest, AASF #2’s immediate surroundings are primarily forest and agricultural 

land. The nearest urban area is the city of Wheeling, located 8.5 miles southwest of the facility.

AASF #2 is located on a portion of land the West Virginia National Guard leased from the Ohio 

County Commission for a term of 99 years, beginning 14 December 1988. The facility was fully 

operational starting in 1996.

Facility Environmental Setting

Wheeling AASF #2 is located in Ohio County, West Virginia, directly south of the Brooke County 

border. The facility is located northeast of the city of Wheeling and southeast of the residential 

community, Windsor Heights. The facility is approximately 643 feet above mean sea level (US 

Climate Data, 2019). This area of West Virginia is considered part of the Allegheny Plateau, which 

formed during the last glacial recession through the levelling of terrain beneath the retreating ice 

sheet. Typical surface features in the surrounding area include steep hillslopes and ravines 

formed through post-glacial erosional processes (US Geological Survey [USGS], 1981). The 

facility and Wheeling-Ohio County Airport sit atop one of these plateaus. 
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

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1.5.1 Geology

The facility is located in a region where the soil is shallow and acidic, with a pH range of 4.5 to 5

(USGS, 1981). Soil is described as well drained, with immediate water holding capacity and

primarily composed of silt loam (EDRTM, 2019). The exposed geologic group in this portion of Ohio

county is from the Paleozoic era, specifically, the Pennsylvanian period. The primary rock types

are sandstone, shale, clay, coal, and limestone (West Virginia Geological and Economic Survey

[WVGES], 2011). To the west of the facility, approaching the Ohio River, alluvial deposits are the

primary geologic feature (USGS, 1981).

1.5.2 Hydrogeology

Sands and gravel form an alluvial aquifer above bedrock in Wheeling, West Virginia (National

Ground Water Association [NGWA], 2018). The depth to water in this area is approximately 30

feet below ground surface (USGS, 2019). Beneath the alluvial aquifer is the Upper Pennsylvanian

Sedimentary Bedrock Aquifer (USGS, 2001). The hydraulic gradient is such that groundwater

flows west from the surrounding hills and valleys in Ohio County toward the Ohio River, as shown

on Figure 1-2 (USGS, 1997).

In the Upper Ohio South Watershed, where AASF #2 is located, both groundwater and surface

water are used for public water supply in Ohio, Brooke, Marshall, and Wetzel counties. 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 GIS databases, wells were researched to a

4-mile radius of the facility. According to the EDRTM Radius Map Report, there are two wells of

unknown type within 1 mile of the facility; one located northwest of AASF #2 and the other located 

south of the facility, near a residential property (Figure 1-2). It is unknown if these wells are

potable, domestic, or non-potable (EDRTM, 2019). According to the USGS National Water

Information System Mapper, there are two active USGS monitoring wells located within a 4-mile

radius of the facility; one 3.8 miles north of the AASF and the other 2.7 miles northeast (USGS,

2020). Additional inactive USGS monitoring wells were identified within 4 miles and are shown on

Figure 1-2. GIS data for wells within a 4-mile radius of the facility was unavailable at the city,

county, state, and national levels. Therefore, it is possible that additional unidentified public or

private wells may be located within 4 miles of the facility.

Based on the USEPA’s Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, no PFAS

were detected in a public water system above the HA within 20 miles of the facility (USEPA, 2017).

The HA is 70 ppt 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.

1.5.3 Hydrology

The major water feature near the facility is the Ohio River, which is located approximately 2 miles

west of the facility boundary. The Ohio River is used for recreational activities and public water

supply. The Ohio River begins in Pittsburgh, Pennsylvania, at the union of the Allegheny and

Monongahela Rivers. From its origin in Pittsburgh, the river flows southwest, ending at the borders

of Kentucky, Illinois, and Missouri, when it meets with the Mississippi River. Wheeling, West

Virginia is within the Upper Ohio South Watershed, one of many watersheds of the Ohio River.

The Upper Ohio South Watershed extends from Brooke County to the south through Ohio and

Marshall Counties, ending in Wetzel County (West Virginia Department of Environmental

Protection [WVDEP], 2013). Around the facility, water flows downhill to ravines, joining the primary

tributary for the area, Short Creek. Short Creek is approximately 1 mile south of the facility and

flows northwest, where it joins the Ohio River (Figure 1-3).
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

8

1.5.4 Climate

Wheeling, West Virginia has a continental climate (USGS, 1981). As such, Wheeling gets four

distinct seasons, with moderately severe winters and warm, rainy summers. The amount of

precipitation between the seasons is about equal (USGS, 1981). Climate data for Wheeling

records the average annual high temperature as 63.2 degrees Fahrenheit (°F), the average

annual low temperature as 42.7°F, and the average annual rainfall as 40.4 inches (US Climate

Data, 2019).

1.5.5 Current and Future Land Use

AASF #2 currently resides on a portion of land leased from the Ohio County Commission under

the terms of a 99-year lease. The facility has been an operational military facility for an active

ARNG unit since 1996, following the completion of construction. The unit at this facility provides

support for helicopter operation and maintenance. Future land use is not anticipated to change.
Wheeling

AASF #2

0 0.5 1 2

Miles

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Facility Boundary

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12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

Base Map: Sources: Esri, HERE, Garmin, USGS,

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

1:63,360

9
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Waddl es Run

Hukill Run

Grog Run

Stotts Run

Hogtan Run

Mingo Run

Short C reek

Williamson

Run

Weidman Run

North F ork ShortCree k

Girty Run

Rush Run

HuffRun

Batt el Run

Souttell Ru n

LittleRush Run

Short Cre e k

Short Creek

Bl ues Run Long

Run

Ohio

River

G lenns Run

Newland s Run

Ferry Run

Spr ing R un

Buffalo Creek

Ohio River

0 0.5 1 2

Miles

Legend

Facility Boundary

River/Stream

Water Body

Wetland

Inferred Groundwater Flow Direction

Geology

Alluvium

Sandstone

Shale

Mudstone

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Wells

A! USGS Active Monitoring Well

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A! Other/Unknown Well

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Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:63,360

10
W addl es

Run

Girty Run

Huff Run

Hog tan Run

Souttel l Run

North Fork Short Creek

Short Creek

Short Creek

Newland s Run

Ohio River

Sugarcamp

Run-Buffalo

Creek Watershed

Salt

Run-Ohio River

Watershed

Short

Creek

Watershed

0 0.25 0.5 1

Miles

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Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow Direction

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Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:31,680

11
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

12

2. Fire Training Areas

Three FTAs were identified at AASF #2 during the PA through interviews. The exact dates of the 

fire training activities are unknown because interviewee recollection varied, but there was general 

consensus that training events using AFFF occurred at the facility. Tri-MaxTM was acquired by the 

facility around 2000 and was utilized until about 2013. According to a 2005 ARNG survey on fire 

extinguishing foam use at AASF #2 in Appendix A, there were ten Tri-MaxTM extinguishers at the 

facility. One interviewee recalls Tri-MaxTM being removed when Purple K fire extinguishers were 

introduced in 2013/2014, and the removed AFFF likely being turned in to the US Property and 

Fiscal Office (USPFO). A description for each FTA is presented below, and the areas are shown 

in Figure 2-1.

Hangar Ramp FTA

During the time AFFF was kept on-site, annual fire training was conducted with extinguishers 

equipped with AFFF on the ramp in front of the hangar doors. On one occasion, shortly after AFFF 

was brought on by the Guard, there was a brief demonstration held at AASF #2 along the wall of 

the hangar. AFFF was sprayed on the wall to demonstrate how the foam sticks to surfaces during 

firefighting activities. Following this event, foam was left to dissipate on its own without being 

washed away. Interviewees present for the demonstration recalled the foam dissipating on the 

wall and paved ground before it could reach a drain. Though this demonstration was only held on 

one occasion, since foam was left to dissipate on its own, the foam may have leeched into the 

wall or pavement where it was sprayed at AASF #2.

This location, shown on Figure 2-1, is also where the annual barrel burn trainings took place. To 

interviewee recollection, barrel burn training at this location may date back to 2005. During these 

trainings, there were occasional outside participants from the airport, local fire departments, as 

well as drill soldiers sent to AASF #2 for drill around the time of the Safety Stand-Down. One such 

event was held in September 2010, as seen in the invitation email presented in Appendix A. 

During these annual trainings, a 55-gallon drum that had been cut in half was filled with water and 

JP8 fuel. This jet fuel was then ignited, and AFFF foam was used to extinguish the flames. At least 

one tank of AFFF was used in each training, and up to 50 soldiers, including drill soldiers at the 

facility for safety day, participated at once. After training was over, foam would be allowed to 

dissipate on its own without being rinsed away. The foam released likely infiltrated surface soils 

in the area, as it would collect in the grass or travel down one of the stormwater inlets in the grass 

on either side of the ramp. The hangar ramp FTA is considered a potential PFAS release area.

Wash Pad FTA

The wash pad at AASF #2 is one of two areas where Tri-MaxTM extinguishers were refilled with 

AFFF. Buckets of AFFF were stored in spill containment buckets at collection points but were 

occasionally brought to the wash pad when refilling was necessary. If AFFF was spilled during 

refills, it would have been sprayed with water and washed down the wash pad drain. There is no 

interviewee recollection of spills at the location. The wash pad location is shown on Figure 2-1.

Interviewees could not recall the timeframe; however, for two years, the wash pad was used for 

fire training activities with AFFF. During these exercises, an ARNG truck would be parked on the 

wash pad and sprayed down with AFFF to demonstrate how the foam sticks to surfaces and how 

to properly use the extinguisher. During these events, the foam was contained to the wash pad. 

Prior to 2006, drainage from the wash pad went to the oil-water separator and then to a surface 

water outflow on-site. After 2006, the AASF #2 wash pad was connected to municipal sewage; 

therefore, AFFF released at the wash pad would have gone to the municipal water treatment 

plant, located approximately 9 miles southwest of the facility, if the drainage valve were in proper 
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

13

operating position. Due to a lack of information on when these two fire training activities occurred 

and uncertainty whether the valve were in the correct position to direct liquids to municipal 

sewage, the path AFFF would have taken is uncertain. Therefore, it is equally likely the AFFF 

would have infiltrated surface water via outflow from the site prior to 2006, or that it would have 

made its way to the municipal water treatment plant. Therefore, the wash pad FTA is a potential 

PFAS release area.

Helicopter FTA

On one occasion, a fire training exercise was conducted where AFFF was sprayed on the tail of 

a helicopter to familiarize personnel with the process of using Tri-MaxTM extinguishers. This training 

occurred in the center of the landing pads at AASF #2 (Figure 2-1). Aircraft were relocated for the 

duration of the exercise, and approximately one Tri-MaxTM unit was expended. Following training, 

foam was rinsed off the helicopter’s tail, then left to dissipate on its own. It is possible that foam 

from this FTA traveled to a grassy area and infiltrated the surface soil or followed on-site drainage 

pathways to stormwater inlets in the grass. Therefore, the helicopter FTA is considered a potential 

PFAS release area. Based on interviewee recollection, it is believed this event occurred in the 

early 2000s, prior to 2006.
Helicopter FTA

Hangar

Ramp FTA

Wash Pad FTA

Wadd el s Run

0 250 500 1,000

Feet

Legend

Potential PFAS Release

Facility Boundary

River/Stream

Water Body

Wetland

Stormwater Drainage Pathway

Open Stormwater Drain

Stormwater Inlet

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MM

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5/28/2020

NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

5/28/2020 ­ Figure 2-1

PM RG 5/28/2020

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12420 Milestone Center Drive

Germantown, MD 20876

Fire Training Areas

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:6,000

14
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

15

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. Five non-FTAs were 

identified during the PA. Descriptions of the non-FTAs are presented below, and the non-FTAs 

are shown on Figure 3-1.

HAZMAT Room

While AFFF was in-use at AASF #2, 5-gallon buckets of Tri-MaxTM were stored in the facility’s 

HAZMAT room. The location of this room is shown on Figure 3-1. To interviewee knowledge, no 

spills occurred in this location; however, due to the potential for unintended spills or releases, this 

location is considered a potential PFAS release area.

Kitchen Hood Fire Suppression System

In a separate building at the facility, adjacent to the administrative building (Figure 3-1), there is 

a kitchen containing a fire suppression hood. The contents of this hood have never been released 

in response to a fire or otherwise, and the fire suppressant is not believed to contain PFAS. 

Therefore, this area has no suspected PFAS release.

Tri-MaxTM Fill Area 1

In the southeast corner of the hangar (Figure 3-1), an area that was used for filling Tri-MaxTM

extinguishers inside the hangar is marked out. Interviewees do not recall any instances of spills 

during the time AFFF was in use at the facility. However, due to the potential for unintended spills 

or releases, this area is considered a potential PFAS release area.

AFFF Storage Shed

While AFFF was kept at the facility, a small storage shed was also used to store 5-gallon buckets 

of AFFF (Figure 3-1). The shed is located within a fenced area adjacent to the parking lot. There 

is no knowledge of any spills or expended AFFF in this area. However, due to the potential for 

unintended spills or releases, this location is considered a potential PFAS release area.

Tri-MaxTM Fill Area 2

Tri-MaxTM units were filled in the wash pad area, shown on Figure 3-1. There is no record or 

recollection of a spill at this location throughout the time AFFF was kept at the AASF. However, 

due to the potential for unintended spills or releases, this area is considered a potential PFAS 

release area. 
Tri-Max

Fill Area 1

Kitchen

Hood System

AFFF Storage Shed

Tri-Max

Fill Area 2

HAZMAT Room

0 250 500 1,000

Feet

Legend

Potential PFAS Release

No Suspected PFAS Release

Facility Boundary

River/Stream

Water Body

Wetland

Stormwater Inlet

Stormwater Drainage Pathway

Open Stormwater Drain

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MM

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NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

5/28/2020 ­ 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

16
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

17

4. Emergency Response Areas

No emergency response areas were identified within AASF #2 during the PA through interviews.

Firsthand knowledge of interviewees extends prior to AASF #2 being operational.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

18

5. Adjacent Sources

Four potential off-facility sources of PFAS located adjacent to AASF #2, not under the control of 

ARNG, were identified during the PA through interviews. A description of each adjacent source is 

presented below, and the adjacent sources are shown on Figure 5-1.

Plane Crash Site 1

Between the years 2009 and 2012, there was a civilian plane crash near a runway of the adjacent 

airport at the northeast corner of airport property (Figure 5-1). Interviewees recalled the municipal 

fire department responding to the scene and determining there was no firefighting action 

necessary. There was no fire resulting from the crash, and interviewees who were present at the 

crash recalled that no foam or water were sprayed in response. Due to no known use of AFFF at 

this location, there is no suspected PFAS release.

Plane Crash Site 2

Another crash occurred adjacent to AASF #2 between the years 1996 and 2005 (Figure 5-1). A 

civilian plane crashed west of the adjacent airport’s runways. However, according to interviewees 

who were present at this incident, there was no fire, and therefore, no AFFF response necessary 

by the municipal fire department responding to the scene. Due to no known use of AFFF at this 

location, there is no suspected PFAS release.

Short Creek Landfill

Short Creek Landfill is located approximately 1.7 miles downgradient of the facility and is currently 

active (Figure 5-1). Landfills are not typically a primary potential release area of PFAS, but 

materials disposed of in landfills may create a secondary source of contamination. Such materials 

may include sludge from wastewater treatment plants that process PFAS-laden water or products 

associated with waterproofing uniforms or boots. The exact materials disposed of at Short Creek 

Landfill are unknown. Due the potential that PFAS-containing materials were disposed of in the 

landfill, the Short Creek Landfill is considered a potential adjacent source of PFAS. However, 

because the landfill is located downgradient, it is unlikely that PFAS contamination from the landfill 

would migrate to the facility.

Wheeling Ohio County Airport

The Wheeling Ohio County Airport sits approximately 0.6 miles northwest of the facility (Figure 

5-1). Secondary information from an airport employee contacted by West Virginia ARNG 

(WVARNG) personnel asserts that there are no AFFF-equipped firetrucks at the airport, and no 

annual fire training with AFFF. However, due to a lack of robust information on the history of use 

of AFFF at the airport, there may have been releases at the airport outside of the employee’s 

knowledge. For this reason, the airport is considered a potential adjacent source of PFAS.
Airplane

Crash Site 2

Airplane

Crash Site 1

Short Creek

Landfill

Wheeling Ohio

County Airport

Wa ddle s

Run

North Fork S hort Creek

Short Creek

Girty Run

Huff Run

Soutte l l Run

Short Creek

0 1,000 2,000 4,000

Feet

Legend

Potential PFAS Release

No Suspected PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MM

4/17/2020

4/17/2020

NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

4/17/2020 ­ Figure 5-1

PM RG 4/17/2020

C:\Users\samir.khadka\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\WV\Wheeling_AASF\Fig5-1_Wheeling_AdjacentSources.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:24,000

19
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

20

6. Preliminary Conceptual Site Model

Based on the PA findings, two AOIs were identified at AASF #2; AOI 1 is the area encompassing 

the hangar ramp, wash pad, and helicopter FTAs, HAZMAT Room, and Tri-MaxTM Fill Area 2 as 

well as their surface drainage pathways. AOI 2 includes the AFFF Storage Shed and Tri-MaxTM

Fill Area 1. The AOIs and potential PFAS release areas are shown on Figure 6-1. The following 

section describes the CSM components and the specific preliminary CSM developed for AOIs 1 

and 2. The CSM identifies the three components necessary for a potentially complete exposure 

pathway: (1) source, (2) pathway, (3) receptor. If any of these elements are missing, the pathway 

is considered incomplete.

In general, the potential PFAS exposure pathways are ingestion and inhalation. 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. Receptors at AASF #2 include site workers, 

construction workers, trespassers, and off-site residents. Although Wheeling AASF #2 is a secure 

facility and trespassers are generally not anticipated, the trespasser exposure pathway is 

considered in the preliminary CSMs as a conservative measure. The preliminary CSMs for 

Wheeling AASF #2 indicate which specific receptors could potentially be exposed to PFAS 

(Figure 6-2 and Figure 6-3).

AOI 1: FTAs, Surface Drainage Path, HAZMAT Room, and TriMaxTM Fill Area 2

AOI 1 consists of the locations of the hangar ramp, the wash pad, the HAZMAT Room, the 

helicopter FTAs, Tri-MaxTM Fill Area 2, and their respective potential surface drainage pathways. 

First-hand knowledge from interviewees noted that training with AFFF occurred annually for the 

duration of time AFFF was kept at AASF #2. Interviewees recalled AFFF use at the facility dating 

prior to 2001 and ending between 2011 and 2013.

Barrel burn fire trainings were conducted annually at the hangar ramp FTA. On one occasion, 

AFFF was sprayed on a wall of the administrative building adjacent to the hangar. The FTA is 

located on the paved ramp leading to the facility’s hangar. On occasions of barrel burn trainings, 

AFFF was released to the barrel and surrounding pavement and not rinsed away. Similarly, after 

AFFF was sprayed on the administrative building’s wall, it was not rinsed away, but left to dissipate 

on the wall and pavement below. Following both of these events, some AFFF likely soaked into 

the pavement. Foam that did not dissolve into the pavement likely followed on-site surface water 

pathways across grassy surface drainage path to a stormwater drop inlet 180 feet northwest of 

the FTA. From the inlet, AFFF would have followed on-facility subsurface drainage to an outfall 

leading to off-facility surface water drainage. 

AFFF from hangar ramp and potential HAZMAT Room releases may have infiltrated surface and 

subsurface soils along the drainage pathway, leading to a potentially complete pathway for site 

workers, construction workers, and trespassers in this area of the facility. In addition, PFAS are 

water soluble; therefore, they may have migrated from subsurface soil to groundwater in the area, 

leading to a potentially complete pathway for off-facility residents, or construction workers at the 

facility. AFFF that traveled to the stormwater inlet would have traveled off-facility through pipes 

and released to surface water drainage. Surface drainage from the facility meets with surrounding 

water features leading to Short Creek, and eventually the Ohio River. AFFF may have infiltrated 

stream sediment along these drainage pathways. The surface water and sediment pathways are 

therefore potentially complete for off-facility residents and recreational users. Human 

consumption of agricultural products and fish potentially affected by PFAS is possible.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

21

The wash pad FTA is where a truck was sprayed with AFFF on two occasions. During these 

events, the truck was parked on the wash pad, sprayed with AFFF, and the foam was rinsed off 

and down the wash pad drain (Figure 2-1). Due to the unknown timeframe of these two training 

events, and uncertainty whether the diversion valve in the wash pad was in the proper position to 

divert to municipal water treatment, the released AFFF could have followed two separate 

pathways. One pathway is to the municipal water treatment plant, and one is to the surface water 

outfall leading from the facility to the east (Figure 2-1). As both pathways are possible, in the 

interest of being conservative, both will be considered as potential exposure pathways in this 

CSM.

If the wash pad releases occurred prior to 2006, the foam drainage would have been directed 

through a drain and subsurface drainage paths to an oil-water separator. Since PFAS are water 

soluble, the water exiting the oil-water separator would still have PFAS contamination and would 

follow the same path as described for surface water drainage from the hangar ramp release. If 

one or both releases occurred before 2006, the surface water and sediment pathways would be 

potentially complete for off-facility residents. If wash pad releases occurred after 2006, and the 

diversion valve was in the correct position, the foam drainage would have been directed through 

the wash pad drain and to the municipal water treatment plant. If the valve was not in proper 

operating position, AFFF would have followed the same path it took prior to the 2006 renovations. 

If AFFF went to the water treatment plant, pathways for soils, sediment, surface water, and 

groundwater for site workers, construction workers, off-facility residents, and trespassers would 

be considered incomplete.

Tri-MaxTM Fill Area 2 was also located on the wash pad. There is a potential that PFAS were 

released while filling Tri-MaxTM extinguishers at this location during the time AFFF was stored at 

the facility. If a spill had occurred, foam would have followed the same release pathway as 

described for the wash pad FTA.

Following the helicopter fire training event, AFFF could have followed the same paths as 

described previously for the wash pad FTA and hangar ramp FTA. The foam could have traveled 

either across paved and unpaved surfaces to the stormwater drain inlets east of the landing pad, 

flowed down the wash pad drain, or both (Figure 2-1).

If the foam had traveled across the grassy surface drainage path to the stormwater inlet, it may 

have infiltrated surface and subsurface soils before continuing through subsurface drainage to 

off-facility surface drainage. From the drainage pathway, PFAS could be introduced to off-facility 

surface water and sediment. If AFFF followed this path, the pathways for surface water and 

sediments would be potentially complete for off-facility residents and recreational users, surface 

soil would be potentially complete for site workers, construction workers, and trespassers, and 

the subsurface soil path would be potentially complete for construction workers.

Since interviewee recollection dates the helicopter fire training prior to 2006, if the foam entered 

the wash pad drain, it would have been released to off-facility surface water drainage, then 

followed surface water pathways to adjacent creeks and the Ohio River. The potential for AFFF 

to take this path results in a potentially complete pathway for surface water and sediments to offfacility residents. The preliminary CSM for AOI 1 is shown in Figure 6-2.

AOI 2: AFFF Storage Shed and Tri-MaxTM Fill Area 1

AOI 2 consists of an AFFF storage shed and Tri-MaxTM fill area 1 on the eastern side of the 

property near the parking lot. During the time AASF #2 had Tri-MaxTM extinguishers at the facility, 

some 5-gallon AFFF buckets were kept in this shed (Figure 6-1). While there were no spills or 

leaks to interviewee knowledge, this location is considered a potential PFAS release area due to 

the potential for undocumented spills or releases.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

22

If AFFF leaked from the storage shed, it likely would have either been directed through the facility’s

stormwater drainage pathway or infiltrated soil at that location. Had the foam entered the

stormwater drainage path from an inlet near its location, the AFFF would have traveled through a

subsurface pipe to the east, and off the property. From there, the AFFF would follow nearby

surface water pathways leading to Short Creek, then the Ohio River. AFFF may have infiltrated

stream sediments along these drainage pathways. The surface water and sediment pathways are

therefore potentially complete for off-facility residents and recreational users. Human

consumption of agricultural products and fish potentially affected by PFAS is possible. AFFF may

have infiltrated surface and subsurface soil from a leak or spill in this location, therefore the

pathway for surface soil and airborne soil particulates as a result of human activities is potentially

complete for site workers, construction workers, and trespassers. Subsurface soil infiltration

would mean a potentially complete pathway for construction workers. PFAS may have also

migrated from subsurface soil to shallow groundwater resulting from a potential spill or leak of

AFFF from the storage shed. The potential for this infiltration of groundwater leads to a potentially

complete shallow groundwater pathway for off-facility residents and construction workers. The

preliminary CSM for AOI 2 is shown in Figure 6-3.
A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

Tri-Max Fill Area 1

Airplane

Crash Site 2

Airplane

Crash Site 1

Kitchen Hood System

Tri-Max Fill Area 2

Helicopter FTA

Hangar Ramp FTA

Wash Pad FTA

HAZMAT Room

Short Creek

Landfill

AFFF Storage Shed

Wheeling Ohio

County Airport

AOI 1 AOI 2

Wa ddle s

Run

Girty Run

Girty Run

Short Creek

Souttell Run

Huff Run

North Fork S hort Creek

Short Creek

Watershed

0 1,000 2,000 4,000

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected PFAS Release

Facility Boundary

River/Stream

Water Body

Surface Water Flow Direction

Inferred Groundwater Flow Direction

Wells

A! USGS Inactive Monitoring Well

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MM

6/16/2020

6/16/2020

NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

6/16/2020 ­ Figure 6-1

PM RG 6/16/2020

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12420 Milestone Center Drive

Germantown, MD 20876

Areas of Interest

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:24,000

23
Media

SOURCE PATHWAY RECEPTOR

AOI 1

FTAs, AFFF

Storage, Refill of

Tri-MaxTM Units

PFAS in

Concrete

and 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

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser

Site

Worker

Construction

Worker Resident Trespasser

/ / /

/ / /

LEGEND

/ / / /

/ / / /

/ / /

Figure 6-2

Preliminary Conceptual Site Model

AOI 1: FTAs, Surface Drainage Path, HAZMAT Room,

and Tri-MaxTM Fill Area 2

Notes:

1. The residential receptor refers to an off-facility

receptor.

2. Human consumption of agricultural products or

fish potentially affected by PFAS is possible.

/

/

/

24
Media

SOURCE PATHWAY RECEPTOR

AOI 2

AFFF Storage,

Refill of Tri-MaxTM

Units

PFAS in

Drainage

System and

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

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser

Site

Worker

Construction

Worker Resident Trespasser

/ / /

/ / /

LEGEND

/ / / /

/ / / /

/ / /

Figure 6-3

Preliminary Conceptual Site Model

AOI 2: AFFF Storage Shed and Tri-MaxTM Fill Area 1

Notes:

1. The residential receptor refers to an off-facility

receptor.

2. Human consumption of agricultural products or

fish potentially affected by PFAS is possible.

/

/

/

25
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

26

7. Conclusions

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

AFFF at AASF #2. The PA findings are based on the information presented in Appendix A and 

Appendix B.

Findings

Two AOIs related to potential PFAS release (Table 7-1) were identified at AASF #2 during the PA 

through interviews with facility personnel (Figure 7-1).

Table 7-1 AOIs at Wheeling AASF #2

Area of Interest Name Used by Potential Release Dates

AOI 1

FTAs, Surface 

Drainage Path, 

HAZMAT Room, 

and Tri-MaxTM Fill 

Area 2

AASF #2 Personnel, 

Airport Employees, 

Local Fire 

Department 

Personnel, and 

Visiting Drill Soldiers

2000-2013

AOI 2

AFFF Storage 

Shed and TriMaxTM Fill Area 1AASF #2 Personnel 2000-2013

Based on potential PFAS release at the AOIs, there is a potential for exposure to PFAS 

contamination in media at or near the facility. The preliminary CSM for AASF #2, which presents 

the potential receptors and media impacted, is shown on Figure ES-2.

The following areas shown in Table 7-2 and discussed in Section 3 were determined to have no 

suspected release.

Table 7-2 No Suspected Release Areas

No Suspected 

Release Area Used by Rationale for No Suspected Release Determination

Kitchen Hood Fire 

Suppression System AASF #2

The suppression system is not believed to contain 

PFAS and there is no recollection of releases since 

its installation.

Two potential adjacent sources of PFAS, the Short Creek Landfill and the Wheeling Ohio County 

Airport, were identified near AASF #2. Additionally, two historical plane crash areas were 

identified; however, the crash areas are not considered potential adjacent PFAS releases because 

there is no recollection of PFAS being expended in response to those events. 

Uncertainties

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

environmental reports, EDRTM Reports, 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. A number of 

information sources were investigated during this PA to determine the potential for PFAScontaining 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, 
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

27

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. 

Sometimes, the provided information was vague. Gathered information has a degree of 

uncertainty due to the absence of written documentation, the limited number of personnel with 

direct knowledge due to staffing changes, the time passed since PFAS 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. 

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, retired and current personnel were interviewed, multiple persons were 

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

inspected. Table 7-3 summarizes the uncertainties associated with the PA.

Table 7-3 Uncertainties

Area of Interest Source of Uncertainty

AOI 1: FTAs, Surface Drainage Path, 

HAZMAT Room, and Tri-MaxTM Fill Area 

2

Interviewees do not recall the exact timeframe 

of these training events.

AOI 2: AFFF Storage Shed and Tri-MaxTM

Fill Area 1

Uncertainty of personal recollection and lack of 

documentation.

General Limited documentation of PFAS use at the 

facility

It is also unknown whether or to what degree the identified potential off-facility PFAS release areas 

may affect AASF #2.

Potential Future Actions

Interviews and records indicate that former activities at Wheeling AASF #2 may have resulted in 

potential PFAS releases at two AOIs identified during the PA. Based on the preliminary CSMs 

developed for the AOIs, there is potential for receptors to be exposed to PFAS contamination in 

soil, groundwater, surface water, and sediment at or near the facility. Table 7-4 summarizes the 

rationale used to determine if the AOIs should be considered for further investigation under the 

CERCLA process and undergo an SI.

ARNG will evaluate the need for an SI at Wheeling AASF #2 based on the potential receptors, 

the potential migration of PFAS contamination off the facility, and the availability of resources.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

28

Table 7-4 PA Findings Summary

Area of Interest AOI Location Rationale Potential Future

Action

AOI 1 FTAs,

Surface

Drainage Path,

HAZMAT Room,

and Tri-MaxTM

Fill Area 2

40°10'27.069"N

80°38'26.929"W

AFFF was used within

this AOI for fire training

activities; storage of AFFF

Proceed to an SI, focus

on soil, surface water,

sediment, and

groundwater

AOI 2: AFFF

Storage Shed

and Tri-MaxTM

Fill Area 1

40°10'25.991"N

80°38'23.846"W

Storage of 5-gallon

buckets of AFFF; refilling 

of Tri-MaxTM units

Proceed to an SI, focus

on soil, surface water,

sediment, and

groundwater
AOI 1

AOI 2

Tri-Max

Fill Area 1

Kitchen

Hood System

Tri-Max

Fill Area 2

Helicopter

FTA

Hangar Ramp

FTA

Wash Pad FTA

HAZMAT

Room

AFFF

Storage Shed

0 175 350 700

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected PFAS Release

Facility Boundary

Stormwater Inlet

Stormwater Drainage Pathway

Open Stormwater Drain

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MM

5/28/2020

5/28/2020

NOTES Preliminary Assessment for PFAS at Wheeling AASF #2, WV

5/28/2020 ­ Figure 7-1

PM RG 5/28/2020

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\WV\Wheeling_AASF\Fig7-1_Wheeling_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,

1:4,200

29
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

30

8. References

EDRTM. 2019. The EDR Radius MapTM Report with GeoCheck®; Aerial Photo Decade Package; 

and Certified Sanborn® Map Report. 8 October.

NGWA. 2018. West Virginia Groundwater Map Accessed 5 November 2019).

https://www.ngwa.org/images/default-source/default-album/state/WestVirginia.jpg.

US Climate Data. 2019. Climate Wheeling – West Virginia. Accessed 4 November 2019 at

https://www.usclimatedata.com/climate/wheeling/west-virginia/united-states/uswv0799.

USEPA. 1980. Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA).

USEPA. 1991. Guidance for Performing Preliminary Assessments under CERCLA.

EPA/540/G91/013.

USEPA. 1994. National Oil and Hazardous Substances Pollution Contingency Plan (Final Rule).

40 CFR Part 300; 59 Federal Register 47384. September.

USEPA. 2016a. Drinking Water Health Advisory for Perfluorooctanoic Acid (PFOA). Office of

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. EPA

Document Number: 822-R-16-005. May.

USEPA. 2016b. Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS). Office of

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. EPA

Document Number: 822-R-16-004. May.

USEPA. 2017. UCMR 3 (2013-2015) Occurrence Data by State. Occurrence Data for the

Unregulated Contaminant Monitoring Rule. Accessed 9 July 2019 at

https://www.epa.gov/dwucmr/occurrence-data-unregulated-contaminant-monitoringrule. January

USGS. 1981. Hydrology of Area 4, Eastern Coal Province, Pennsylvania, Ohio, and West Virginia.

Accessed 5 November 2019 at https://pubs.usgs.gov/of/1981/0343/report.pdf.

USGS. 1997. Ground-Water Hydrology of the Area Bordering the Ohio River between Chester

and Waverly, West Virginia. Accessed 4 November 2019 at

https://pubs.usgs.gov/of/1995/0710/report.pdf.

USGS. 2001. Aquifer-Characteristics Data for West Virginia. Accessed 5 November 2019 at

https://pubs.usgs.gov/wri/wri01-4036/pdf/aquifer_report.pdf.

USGS. 2019. Groundwater Levels for the Nation. Accessed 12 November 2019 at

https://nwis.waterdata.usgs.gov/usa/nwis/gwlevels/?site_no=400955080393901.

USGS. 2020. National Water Information System: Mapper. Accessed 11 June 2020 at

https://maps.waterdata.usgs.gov/mapper/index.html.

WVDEP. 2013. West Virginia Watersheds: A Closer Look. Accessed 4 November 2019 at

https://dep.wv.gov/WWE/wateruse/WVWaterPlan/Documents/WatershedACloserLookN

ovember2013.pdf. November.

WVGES. 2011. Geologic Map of West Virginia. Accessed 5 November 2019 at.

https://upload.wikimedia.org/wikipedia/commons/7/7e/Geologic_Map_of_West_Virginia.

jpg. 16 May.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

31

WVDEP. 2013. West Virginia Water Resources Management Plan. Accessed 22 October 2019

at http://dep.wv.gov/WWE/wateruse/WVWaterPlan/Documents/WV_WRMP.pdf. 22

November.
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix A

Data Resources
Data Resources will be provided separately on CD. Data Resources for Wheeling AASF #2

include:

Wheeling AASF #2 Site Background Documents

· 2005, Fire Foam ASO List Server Survey, 5 January 2005

· 2010, Training Invitation to Local Fire Departments, 31 August 2010

Wheeling AASF #2 Site Property Documents

· 1988, Wheeling AASF #2 Lease Document, 14 December 1988

· 2008, Army Aviation Support Facility #2 Wastewater Re-route: Modified Site plan and

Details, Ohio County, West Virginia, July 2008

· 2014, Stormwater Pollution Prevention Plan, December 2014

· 2015, National Pollutant Discharge Elimination System Approval, 12 August 2015

· National Pollutant Discharge Elimination System Monitoring Report

· Wheeling AASF #2 National Pollutant Discharge Elimination System Permit-Annual

Certification

Environmental Data Resources, Inc. (EDR)TM Reports

· 2019, Aerial Photo Decade Package, EDRTM, 8 October 2019

· 2019, Certified Sanborn Map Report, EDRTM, 8 October 2019

· 2019, Radius Map Report with Geocheck, EDRTM, 8 October 2019
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix B.1

Interview Records












PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix B.2

Visual Site Inspection Checklists



PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

Wheeling AASF #2, Wheeling, West Virginia

Appendix C

Photographic Log
Preliminary Assessment Report

Wheeling AASF #2 

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 1

Description:

Wheeling AASF #2 Ansul fire 

suppression system in the 

kitchen. 

Photo Date: 10/3/2019 

Photograph No. 2

Description:

Storage shed that previously 

held 5-gallon buckets of 

AFFF.

Photo Date: 10/3/2019 
Preliminary Assessment Report

Wheeling AASF #2 

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 3

Description:

Hangar’s water deluge fire 

suppression system

Photo Date: 10/3/2019 

Photograph No. 4

Description:

View of Wheeling AASF from 

surface water outfall offproperty. Photograph shows 

location of surface water 

outfall. 

Photo Date: 10/3/2019 
Preliminary Assessment Report

Wheeling AASF #2 

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 5

Description:

Drains at the hangar doors

Photo Date: 10/3/2019 

Photograph No. 6

Description:

Purple K fire extinguishers 

that replaced Tri-MaxTM at 

AASF #2.

Photo Date: 10/3/2019 
Preliminary Assessment Report

Wheeling AASF #2 

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 7

Description:

Tri-MaxTM fill area inside 

hangar (striped yellow/black 

marked out area).

Photo Date: 10/3/2019 

Photograph No. 8

Description:

Wash pad at AASF #2 

Photo Date: 10/3/2019 
Preliminary Assessment Report

Wheeling AASF #2

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 9

Description:

Hangar ramp FTA. Barrel 

burn trainings occurred on the 

concrete in the foreground. 

AFFF was sprayed on the wall 

facing the camera.

Photo Date: 10/3/2019

Photograph No. 10

Description:

Helicopter FTA in the center 

of the landing pad.

Photo Date: 10/3/2019
Preliminary Assessment Report

Wheeling AASF #2

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 11

Description:

Hazmat room where AFFF 

was stored.

Photo Date: 10/3/2019

Photograph No. 12

Description:

Stormwater intake closest to 

FTAs on the facility.

Photo Date: 10/3/2019
Preliminary Assessment Report

Wheeling AASF #2

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Wheeling AASF #2 Wheeling, West Virginia

Photograph No. 7

Description:

Surface water drainage 

pathway leading to stormwater 

intake outside of the fence

Photo Date: 10/3/2019