Final

Preliminary Assessment Report

1109th TASMG-Groton, 

Groton, Connecticut

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic Acid 

(PFOA) Impacted Sites

ARNG Installations, Nationwide

June 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

U.S. Army Corps of Engineers, Baltimore District

2 Hopkins Plaza

Baltimore, MD 21201

Prepared by:

AECOM

12420 Milestone Center Drive, Suite 150

Germantown, MD 20876

aecom.com

Contract Number: W912DR-12-D-0014

Delivery Order: W912DR17F0192
PFAS Preliminary Assessment Report

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Table of Contents

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

1. Introduction ........................................................................................................................4

1.5.1 Geology .........................................................................................................6

1.5.2 Hydrogeology .................................................................................................6

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

1.5.4 Climate ...........................................................................................................7

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

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

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

4. Emergency Response Areas ............................................................................................18

5. Adjacent Sources .............................................................................................................20

6. Preliminary Conceptual Site Model ..................................................................................25

7. Conclusions .....................................................................................................................31
PFAS Preliminary Assessment Report

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8. References ...................................................................................................................... 35

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model TASMG-Groton, CT

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 4-1 Emergency Response Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model AOI 1 - AOI 2

Figure 6-3 Preliminary Conceptual Site Model AOI 3

Figure 7-1 Summary of Findings

Tables

Table ES-1: AOIs at TASMG-Groton

Table 7-1: AOIs at TASMG-Groton

Table 7-2: No Suspected Release Areas

Table 7-3: Sources of Uncertainties

Table 7-4: 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

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI Area of Interest

ARFF Aircraft Rescue and Firefighting

ARNG Army National Guard

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CFR Code of Federal Regulations

CSM conceptual site model

CTARNG Connecticut Army National Guard

CTDEEP Connecticut Department of Energy and Environmental Protection

EDR Environmental Data Resources, Inc.

FTA fire training area

GSE Ground Support Equipment

NAVFAC Naval Facilities Engineering Command

NOAA National Oceanic and Atmospheric Administration

OWS Oil-water separator

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

SUBASENLON Naval Submarine Base New London

TASMG Theatre Aviation Sustainment Management Group

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VSI visual site inspection

WWTP Wastewater treatment plant

WPCF Water Pollution Control Facility
PFAS Preliminary Assessment Report

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Executive Summary

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

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

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

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

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

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

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

activities, although other PFAS sources are possible.

 AECOM completed a PA for PFAS at 1109th Theatre Aviation Sustainment Management Group

(TASMG-Groton; also referred to as the “facility”), in Groton, Connecticut, to assess potential

PFAS release areas and exposure pathways to receptors. The performance of this PA included

the following tasks:

· Reviewed data resources to obtain information relevant to suspected PFAS releases;

· Conducted a site visit on 10 December 2019;

· Interviewed current Connecticut ARNG (CTARNG) personnel during the site visit, including

the Facility Administrative Officer, the Facility Environmental Supervisor, a Fire and Life

Safety Program Officer, and a member of the Groton-New London Airport Fire Department;

· Completed visual site inspections at suspected PFAS release locations and documented

with photographs;

· Developed a preliminary conceptual site model (CSM) to outline the potential release and

pathway of PFAS for the Area(s) of Interest (AOIs) and the facility (Figure ES-1).

Three AOIs related to potential PFAS release were identified at TASMG-Groton based on PA

data (Figure ES-1) and are summarized in Table ES-1 below:

Table ES-1: AOIs at TASMG-Groton

Area of Interest Name Used by Potential Release Dates

AOI 1 Building 320 CTARNG 2008-Present

AOI 2 Building 323 CTARNG 2010-2012 and 2014

AOI 3 Building 325 CTARNG 2008-Present

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

contamination in environmental media at the facility to site workers, construction workers,

trespassers and off-facility recreational users of the surrounding water bodies. The preliminary

CSM for TASMG-Groton, which presents the potential receptors and media impacted, is shown

on Figure ES-2.

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

Monitoring Rule 3 data, it was indicated that no PFAS were detected in a public water system

above the USEPA’s Lifetime Health Advisory level within 20 miles of the facility.
Building 325 - 

State Equip ment 

Storage Building

Building 320 

- Main Hangar

Fire Dep ar tment

AFFF Training Area

Fire Dep ar tment

AFFF Nozzle Chec k

Testing Area

Groton-New London Air p or t 

Fire Dep ar tment

Fire Dep ar tment

AFFF Training Area

Groton WCPF

2003 Learjet

35A Ac c ident

Building 323 – 

Engine Shop

Runw ay 5/23

Runw ay 15/33

Gun Butt/Nozzle Chec k

Testing Area

Building 350 Flight - TASMG 2

Test

Ramp

Building 324 – 

Paint Strip p ing 

Building

Building 338 -

Cold Storage

Building

Groton-New London Air p or t

Mystic 

Jet 

Center

Lanmar

Aviation

Building 324

Boiler Room Fire

Former Administrative

Building Fire

Building 322 -

GSE Building

Building 321

- TASMG Gym

Building

323 Fire

Long Island Sound

Long

Island

Sound

Long

Island

Sound

Fort Hill Brook

Poquonnock R iver

AOI 2

AOI 1

AOI 3

Pfizer

Industrial

Camp us

General Dynamic

Elec tric Boat

Industrial Camp us

Naval Submarine

Base New London

Rock Pond

Groton

Reservoir

Groton

Reservoir

Goss Cove

Long

Cove

Latham

Reservoir

Latham

Bog

Morgan Pond

Reservoir

Ledyard

Reservoir

Buddington

Pond

Long Island Sound

Long Island

Sound

Smith Pond

Warren

Millpond

Birch Plain

Creek Tidal Marsh

Trails Pond

Long

Cove

Beaverd am B rook

o

Pqu onn ock

Rive r

Th ompson Brook

Grea t Brook

He mpst ead

Brook

Brig g sBrook

F lat Brook

Thames River

0 2,100 4,200 8,400

Feet

0 500 1,000 2,000

Feet

­ Figure ES-1

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Area of Interest

Potential PFAS Release

No Suspected Release

Facility Location

Water Body

Wetland

River/Stream

Summar y of Findings

12420 Milestone Center Drive

Germantown, MD 20876

1 2

1

2

2
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – AOI 3

AFFF 

releases from 

Building 320 

and Building 

323 fire 

suppression 

systems

PFAS in 

Surface 

Soil / Paved 

Surfaces

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

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

TASMG-Groton, CT

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Tresspasser/ Recreational User

Tresspasser/ Recreational User 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

3
PFAS Preliminary Assessment Report

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1. Introduction

Authority and Purpose

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

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

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

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

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

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

on human health related to processes at 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.

This report presents the findings of a PA for PFAS at 1109th Theatre Aviation Sustainment 

Management Group (TASMG-Groton; also referred to as the “facility”), in Groton, Connecticut, 

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 USACE requirements and 

guidance. 

This PA documents locations where PFAS-containing materials may have been released into 

the environment at TASMG-Groton. 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 data resources to obtain information relevant to suspected PFAS releases;

· Conducted a site visit on 10 December 2019;

· Interviewed current Connecticut ARNG (CTARNG) personnel during the site visit including 

the Facility Administrative Officer, the Facility Environmental Supervisor, a Fire and Life 

Safety Program Officer, and a member of the Groton-New London Airport Fire Department;

· Completed visual site inspections (VSIs) at suspected PFAS release locations and 

documented with photographs;

· Developed a preliminary conceptual site model (CSM) to outline the potential release and 

pathway of PFAS for the Area(s) of Interest (AOIs) and the facility.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

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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 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

TASMG-Groton is located in the city of Groton, in New London County, Connecticut (Figure 1-

1). The facility is located on the Groton-New London Airport property, which is situated on a 

peninsula between the Poquonnock River, Baker Cove, Birch Plain Creek, and the Long Island 

Sound. TASMG-Groton comprises several buildings, including multiple hangars, office spaces, 

material storage areas, and a flight test ramp. The facility provides testing, repairs, and 

maintenance for CTARNG equipment and aircrafts. The facility also provides services to aircraft 

at the Groton-New London Airport and services ARNG operations in 14 northeastern states and 

the District of Columbia.

TASMG-Groton is located on state-owned property. The CTARNG established its presence on 

the property in the 1950s. The facility transitioned from an Aviation Classification and Repair 

Depot to the TASMG-Groton in 2012 and expanded upon its mission capabilities. A 2012 

memorandum for the request of a temporary aviation unit facility to accommodate the expanded 

mission capabilities, as well as other real property documents, are included in Appendix A. 

TASMG-Groton occupies approximately 16 acres of the northwest corner of the airport. There 

are two guarded entranceways for vehicle traffic to access the facility. A chain link fence 

provides security along the north, east, and south sides of the facility. The southwest corner is 

open to the Groton-New London Airport, which maintains its own security for the area 

(CTARNG, 2019). Real estate documents were requested but not available at the time this 

report was prepared.
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Groton-New London Airport was established in 1929; it was designated as a major training 

center for pilots and aircrews during World War II and was later transferred for operation to the 

Navy. The State of Connecticut resumed airport ownership and operations in 1949. In 1984, the 

airport was approved to operate commercial air service. The Connecticut Airport Authority 

maintains the Groton-New London Airport. 

Facility Environmental Setting

TASMG-Groton and the larger Groton-New London Airport are located on a peninsula bordered 

by the Poquonnock River to the east, Baker Cove to the west and Long Island Sound to the 

south. Bluff Point and Bushy Point Beach form a breakwater-like barrier, separating the facility 

and airport property from Long Island Sound. Topography across the facility is generally flat, and 

topography across the larger airport area generally slopes radially away on the edges of the 

peninsula towards the surrounding water bodies. The facility is zoned for industrial/commercial 

use and is surrounded by properties zoned for commercial, industrial, and residential use. 

(CTARNG, 2019).

1.5.1 Geology

According to the 2005 Quaternary Geologic Map of Connecticut and Long Island Sound Basin, 

the facility and surrounding airport property is underlain by Poquonnock River deposits. These 

deposits are ice-marginal, fluviodeltaic sediments of the Long Island Sound Basin. Glacial 

sediments in the area are measured at thicknesses between 50-100 feet. The USGS 

generalized bedrock lithologic map indicates that bedrock beneath the facility is comprised of 

undivided schists and gneisses. The bedrock is mostly light-gray to medium-gray 

metasedimentary and metaigneous aluminous, felsic intermediate and mafic rocks of 

Proterozoic to Devonian age (US Geological Survey [USGS], 2005). Geologic materials are 

shown on Figure 1-2.

Virtually all areas at the Groton-New London airport are underlain with artificial fill. Perimeter 

soils on the edge of the peninsula are tidal and inland wetlands (DeCarlo & Doll, Inc. 1996).

1.5.2 Hydrogeology

The majority of the Connecticut coastline, including the town of Groton, lies within the Long 

Island Sound Basin and the much larger Long Island Sound Basin. These basins are principally 

drained by the Long Island Sound. TASMG-Groton and the larger surrounding airport property 

are underlain by groundwater that is designated as “class GB” by the Connecticut Department 

of Energy and Environmental Protection (CTDEEP), which indicates that the area has a long 

history of urban or industrial activity. Class GB groundwater is assumed to be degraded due to 

likely pollution sources, and it is presumed not to be suitable for human consumption without 

treatment (Connecticut Airport Authority, 2013). Due to the groundwater designation as class 

GB, the airport property including TASMG-Groton is supplied water drinking water by the Groton 

Utilities Water Operations. Groton Utilities Water Operations sources its water from a variety of 

groundwater wells and surface water reservoirs, some of which are located within 4 miles north 

and upgradient of the facility.

According to the USGS National Water Information System Mapper, a groundwater well (USGS 

CT-GT 19) is located approximately 800 feet northwest of TASMG-Groton. Data collected from 

the well in 2019, which is included in Appendix A, indicate that the depth to groundwater at the 

well location is approximately 15 feet below ground surface (USGS, 2019). Data for 

groundwater depth directly beneath TASMG-Groton is unavailable, but the depth to groundwater 
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

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beneath the facility is presumed to be similar to the depth to water measured at the nearby

groundwater well.

Groundwater flow direction at the facility is unknown, but groundwater in the area generally

flows south towards the Long Island Sound (Figure 1-2). Although no information was provided

during this PA that stated groundwater depth at the facility, CTARNG personnel stated during

interviews that groundwater is approximately 8-9 feet below ground surface at TASMG-Groton.

Based on the USEPA Unregulated Contaminant Monitoring Rule 3 data, it was indicated that no

PFAS were detected in a public water system above the HA within 20 miles of TASMG-Groton.

1.5.3 Hydrology

There are no surface water bodies on the TASMG-Groton property; however, there are several

surface water bodies immediately surrounding the property, and the airport lies on a coastal

peninsula. The airport is located within the Southeast Costal Drainage Basin (Connecticut

Airport Authority, 2013) and falls within the 100-year floodplain of the town of Groton. The area

is subject to occasional flooding events during hurricanes and major nor’easters. During these

events, floodwaters may extend onto areas surrounding the southern end of the airport runway

and taxiway edges. During heavy rainfall events, localized flooding may also occur on the

airplane parking ramps (Connecticut Airport Authority, 2013).

A small intermittent stream borders the northwest boundary of the CTARNG property and flows

southwest into Birch Plain Creek and Baker Cove. A freshwater pond and forested wetland are

present northeast of the parking lot northeast of the facility main gate (Figure 1-3) (US Fish and

Wildlife Service, 2019). TASMG-Groton generally drains via surface drainage from the east to

west. Stormwater runoff is also collected by catch basins throughout the facility. These catch

basins channel flow west towards two main outlets near the northwestern portion of the facility

that discharge into the small intermittent stream. Runoff entering the stream discharges to Baker

Cove and ultimately into the Long Island Sound, directly south of the Groton-New London

Airport. Any runoff entering the stormwater drainage system or the intermittent stream has the

potential of migrating to the Long Island Sound and wetlands associated with the intermittent

stream (CTARNG, 2019).

Additionally, discharge from a stormwater outlet pipe located behind Building 322 flows across a

stretch of grass prior to entering an area filled with cattails and other vegetation associated with

wetlands. This area, located along the fence line behind the building, has not been delineated or

identified by USFWS as a wetland (CTARNG, 2019). Several oil-water separators (OWSs) are

also positioned throughout the facility. The OWSs connect to municipal sanitary sewer pipes,

which ultimately discharged to the Groton Water Pollution Control Facility (WPCF). All OWSs

are permitted with CTDEEP under the General Permit for the Discharge of Wastewaters

Associated with Vehicle Maintenance activities #GVM-000179 (CTARNG, 2019).

1.5.4 Climate

Data from Groton-New London Airport, Connecticut, indicate that the annual average

temperature between 1981 and 2010 in was 50.4 degrees Fahrenheit (oF) (National Oceanic

and Atmospheric Administration [NOAA], 2019). The warmest months are July and August, with

normal daily average temperatures of 70.6oF and 70.4oF, respectively. January is the coldest

month, with an average temperature of 29.5oF. Average annual precipitation at the airport

measured from 1981 to 2010 was 46.49 inches. Average monthly precipitation ranges from 2.86

inches in February to 4.41 inches in April. The average annual snowfall is approximately 24

inches, with January and February usually experiencing the most snow (NOAA, 2019).
PFAS Preliminary Assessment Report

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1.5.5 Current and Future Land Use

TASMG-Groton currently supports ARNG operations across northeastern states and the District

of Columbia, as well as the Groton-New London Airport. Future land use at TASMG-Groton and

the surrounding airport property is anticipated to remain the same.
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Facility Location

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

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^_

0 0.25 0.5 1

Miles

TASMG Groton

9
AA!!

A!

A!

A! A!

A!

Groton

Reservoir

Long

Island

Sound

Long Island

Sound

Long Island

Sound

Birch Plain

Creek Tidal

Marsh

Trails

Pond

B irch P al in C reek

Poquonnock River

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Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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Facility Location

Water Body

Wetland

River/Stream

Geology

gneiss

granite

granitic gneiss

Wells

A! Other/Unknown Well

0 750 1,500 3,000

Feet

10
Poquonock

RiverWatershed

Coastal drainages-Pawcatuck

Point to Eastern

PointWatershed

Groton

Reservoir

Long

Island

Sound

Long Island

Sound

Long Island

Sound

Birch Plain

Creek Tidal

Marsh

Trails

Pond

B irch P al in C reek

Poquonnock River

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Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\CT\CT_Figures\TASMG_Groton_Figures\Fig_1-3_TASMG_Groton_Surface_Water.mxd

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Water Body

Wetland

River/Stream

0 750 1,500 3,000

Feet

11
PFAS Preliminary Assessment Report

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2. Fire Training Areas

FTAs are considered areas where deliberate discharge of AFFF or other firefighting materials is

performed for purposes of training personnel. No FTAs were identified at TASMG-Groton during

the PA through interviews, review of the Environmental Data Resources, Inc. (EDR) report for a

1-mile radius surrounding the facility (Appendix A), and historical document review. According

to interviewees whose collective tenure span 1985 to present, joint fire training events are

performed at the facility with the Groton-New London Fire Department; however, the training is 

simulated and does not involve discharge of water or AFFF.

The Groton-New London Airport Fire Department performs fire training within the airport

property, but outside the CTARNG facility boundary. FTAs located within the airport property but

outside the TASMG-Groton boundary are considered adjacent sources and are discussed in

Section 5.
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3. Non-Fire Training Areas

Several non-FTAs where AFFF could have been potentially stored and/or released were 

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

are shown on Figure 3-1. 

Building 320 – Main Hangar

Building 320 is the main hangar at TASMG-Groton and is located at the center of the CTARNG 

property; it is divided into Building 320 North and Building 320 South, and includes 

administrative areas, the mess hall, maintenance shops, and equipment storage rooms in 

addition to the hangar space. According to facility staff, Building 320 South comprises the 

original building footprint and was built in 1977. In 1998, the building was renovated, and 

Building 320 North was constructed as an addition to the hangar. Interviewees, whose collective 

tenure span 1985-present, stated that the AFFF fire suppression system that serves Building 

320 was installed during the 1998 renovation.

The Building 320 AFFF fire suppression system is supplied by a 1,000-gallon AFFF tank that 

contains Ansul Thunderstorm F-601A 3% AFFF and is stored in the hangar tank room. The tank 

connects to ceiling sprinklers in the hangar space, as well as two hoses that may be used to 

direct flow, and test ports located on the building perimeter. A 5-gallon bucket of National Foam 

Aer-O-Lite 3% AFFF concentrate is also stored within the tank room. It is unknown whether the 

suppression system was tested after installation in 1998, but interviewees confirmed that the 

system was tested in 2008. The 2008 test involved a complete discharge of the AFFF system 

through a system hose that connected directly to a tanker truck provided by a private contractor. 

Although the system test was completely enclosed, residual AFFF remained in the fire 

suppression system piping as a result.

Scheduled fire suppression system testing has occurred between 2008 and 2014 at an irregular 

frequency following the 2008 system test. Since 2014, fire suppression system testing has 

occurred on a quarterly schedule. System testing involves the discharge of water through test 

ports located on the building perimeter. Although no AFFF is released during the testing, the 

water is presumed to contain residual AFFF as a result of the full system test in 2008. According 

to the facility Environmental Supervisor, barrels are placed beneath the perimeter test ports to 

collect water that is discharged during the system testing. The barrels are then moved via fork 

lift to a temporary storage area adjacent to Building 325 until a private contractor removes and 

disposes of the water. Although the water is captured in barrels during system testing, small 

releases of PFAS-laden water are suspected at each test port as a result of incidental spillage.

Sanitary system sewers and trench drains are located near several of the test ports. It is 

possible that PFAS-laden water has entered sanitary system sewers as a result of regular 

system testing. Sanitary sewers transport water to the Groton WPCF. It is also possible that 

surface water runoff has transported PFAS away from Building 320 and towards surface soil 

within the facility. 

Building 321 – TASMG Gym

Building 321 serves as the TASMG-Groton gym and is located in the north-central portion of the 

facility. The building is not plumbed and does not include a fire suppression system. According 

to facility staff, no AFFF has ever been stored or used at the gym. No evidence indicates that 

any activities that may have resulted in PFAS releases to the environment have occurred at 

Building 321; the gym is not considered a potential PFOSPFOA release area.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

14

Building 322 – Ground Support Equipment Building

Building 322 is the Ground Support Equipment (GSE) building and is used for the repair of 

facility ground equipment. The building is located on the western edge of the facility, near the 

perimeter fence, and was formerly used as a cold storage building. The building does not have 

a fire suppression system of any kind. According to facility staff, no AFFF has ever been stored 

or used at Building 322. No evidence indicates that any activities that may have resulted in 

PFAS releases to the environment have occurred at Building 322; the GSE building is not 

considered a potential PFOS/PFOA release area.

Building 323 – Engine Shop

Building 323 is facility Engine Shop, which is used for the cleaning and rebuilding of engines. 

The building is located on the western edge of the facility, near the perimeter fence. According 

to interviewees, the building was constructed in 1998, and the building AFFF fire suppression 

system was installed in 2004. The majority of the building relies on a water-only fire suppression 

system, but the engine shop portion of Building 323 uses an AFFF fire suppression system. The 

AFFF fire suppression system is supplied by a 270-gallon 3% AFFF concentrate tank containing 

Ansul Thunderstorm F-601A 3% AFFF.

According to interviewees, AFFF suppression system releases have occurred at Building 323; 

however, the number of releases is unclear. Two AFFF system releases (one occurring between 

2010 and 2012, and one in 2014) were recounted by interviewees, although some personnel 

believe only one release occurred. 

The first AFFF system release occurred between 2010 and 2012, when a contractor accidentally 

triggered the water suppression system, covering the building interior in rust-colored water. 

During cleanup, a contractor power washing the walls accidentally sprayed the AFFF system 

trigger and released the full 270-gallon AFFF system tank. According to staff present during the 

release, all of the building doors were closed, and the foam was guided towards the sanitary 

system drain at the center of the engine shop. The drain connects to an OWS that flows offfacility to the Groton WPCF and is located adjacent to the building. AFFF in the OWS was 

vacuumed out by a contractor and disposed of off-facility.

On 31 December 2014, the AFFF fire suppression system was also accidentally triggered, 

resulting in the release of the full 270-gallon AFFF system tank. During this release, the garage 

door was open, and AFFF flowed west outside the building, towards the facility perimeter fence. 

The CTDEEP responded to the facility and deemed the private contractor that triggered the 

release the responsible party for cleanup. The contractor vacuumed the visible AFFF that 

escaped the garage doors as well as AFFF that escaped via the floor drain to the OWS.

AFFF released during both events escaped to the adjacent OWS, which connects to Groton 

WPCF. AFFF released during the 2014 event also escaped westward via the open garage door 

across pavement towards surface soil and may have flowed towards a wetland located 

approximately 180 feet northeast. Additionally, space was observed between the bottom of the 

engine shop doors and the floor during the VSI, indicating that AFFF could have potentially 

escaped the building even during the 2010-2012 release, when all doors were closed. The 

majority of surface water at TASMG-Groton ultimately flows towards Birch Stream, so it is also 

possible that AFFF releases at Building 323 have resulted in PFAS migration to surface water.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

15

Building 324 – Paint Stripping Building

Building 324 is the Paint Stripping Building at TASMG-Groton and is used to strip exterior and 

interior paint from aircrafts prior to painting. The building is located on the western edge of the 

facility, near the western property boundary fence. According to interviewees, the building fire 

suppression system uses only water. The building also includes a wash rack; however, no 

vehicles at TASMG-Groton use or carry AFFF so no releases of AFFF at the wash rack are 

expected to have occurred. According to interviewees, a fire occurred between 2013 and 2014 

in the boiler room within Building 324; however, only water was used in response to the fire. No 

evidence indicates that any activities that may have resulted in PFAS releases to the 

environment have occurred at Building 324; the Paint Stripping building is not considered a 

potential PFOS/PFOA release area.

Building 325 – State Equipment Storage Building

Building 325 is located on the western edge of the facility, near the western perimeter fence, 

and is used for CTARNG equipment storage. The building was constructed in 1954 and is the 

oldest building on the property. Although AFFF has never been used at Building 325, barrels of 

PFAS-laden water are stored next to the building following the quarterly Building 320 fire 

suppression system testing. The barrels that are used to collect Building 320 test port water are 

transported to a storage area adjacent to Building 325 until they can be emptied by a private 

contractor via vacuum truck. The water is then disposed of off-facility. The disposal of PFASladen water is performed in an enclosed manner by using a hose to connect the truck tank to a 

port on each barrel. Although the disposal of PFAS-laden water is performed in an enclosed 

manner, it is possible that spillage may occur. Additionally, the storage area is unsheltered and 

barrels are subject to corrosion due to the elements. Evidence does not indicate that PFAS 

releases to the environment have occurred at Building 325; however, there is uncertainty 

regarding the potential for spills to occur. As such, the State Equipment Storage Building area is 

considered a potential PFOS/PFOA release area. 

Building 338 – Cold Storage Building

Building 338 is used for equipment storage and as a temporary staging area. The footprint of 

the building was previously excavated to remediate soils impacted by hydrocarbons. The Cold 

Storage Building was constructed following the remediation. The use of the building prior to its 

use as a cold storage building is unknown. According to interviewees, the building does not 

have an AFFF fire suppression system. No evidence indicates that any activities that may have 

resulted in PFAS releases to the environment have occurred at Building 338; the Cold Storage 

Building is not considered a potential PFOS/PFOA release area.

Building 350 – TASMG 2 Hangar

Building 350 comprises the TASMG 2 Hangar and is the eastern-most building associated with 

TASMG-Groton located on the Groton-New London airport property. The hangar was formerly 

leased for commercial purposes and is currently leased by the CTARNG for aircraft 

maintenance and repair support activities. According to interviewees, the building uses a wateronly fire suppression system. No evidence indicates that any activities that may have resulted in 

PFAS releases to the environment have occurred at Building 350; the TASMG 2 Hangar is not 

considered a potential PFOS/PFOA release area.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

16

Flight Test Ramp

The Flight Test Ramp is located south of Building 320 and adjacent to Groton-New London 

Runway 15/33. The ramp is used for aircraft maintenance as well as fueling and defueling. 

According to interviewees, no incidents have occurred on the Flight test Ramp requiring AFFF 

use in response. Fuel spills are not responded to with precautionary AFFF discharge at TASMGGroton. 

A total of six to eight wheeled mobile fire extinguishers are staged between the Flight Test Ramp 

and a shed located on the ramp. The fire extinguishers contain Purple K extinguishant, which 

does not contain PFAS. According to interviewees, the Purple K fire extinguishers replaced 

extinguishers that contained Halon. It is unknown whether mobile fire extinguishers stored at 

TASMG-Groton have ever stored AFFF. No evidence indicates that any activities that may have 

resulted in PFAS releases to the environment have occurred at the Flight Test Ramp; the ramp 

is not considered a potential PFOS/PFOA release area.
Buildin g

350 -

Flight TASMG 2

Test Ramp

Buildin g 324 –

Pain t Strippin g

Buildin g

Buildin g 338

- Cold Storage

Buildin g

Buildin g 321

- TASMG Gym

Buildin g 322 -

GSE Buildin g

Buildin g 325 -

State Equipmen t

Storage Buildin g

Buildin g 320

- Main Han gar

Buildin g 323 –

En gin e Shop

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3/31/2020 ­ Figure 3-1

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12420 Milestone Center Drive

Germantown, MD 20876

Non -Fire Train in g Areas

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PFAS Preliminary Assessment Report

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4. Emergency Response Areas

CTARNG staff described several known incidents requiring emergency response at the TASMGGroton facility during their collective tenure (spanning 1985-present). Emergency response 

areas are described below and shown on Figure 4-1.

Building 324 Boiler Room Fire

According to interviewees, a fire occurred between 2013 and 2014 in the boiler room within 

Building 324; however, the Groton-New London Airport Fire Department used only water in 

response to the fire. No evidence indicates that emergency response activities resulted in PFAS 

releases to the environment. Building 324 is not considered a potential PFAS release area.

Former Administrative Building Fire

According to interviewees, a structure fire occurred in the former administrative building 

between 1985 and 1992. The former administrative building was located adjacent to the current 

TASMG Gym. The Groton-New London Airport Fire Department used only water in response to 

the fire. No evidence indicates that emergency response activities resulted in PFAS releases to 

the environment. The former administrative building area is not considered a potential PFAS 

release area.

Building 323 Fire

A fire occurred in the Building 323 engine shop as a result of engine maintenance between 2004 

and 2006. According to interviewees, the Groton-New London Airport Fire Department used only 

water in response to the fire. No evidence indicated that emergency response activities resulted 

in PFAS releases to the environment. The building is not considered a potential PFAS release 

area as a result of the fire; however, known AFFF system releases have occurred at Building 

323, and the area is considered a potential PFAS release area as a result.
Building

323 Fire

Building

324 Boiler

Room Fire

Former

Administrative

Building Fire

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3/11/2020 ­ Figure 4-1 PM RG 3/11/2020

12420 Milestone Center Drive

Germantown, MD 20876

Emergency Response Areas

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\CT\CT_Figures\TASMG_Groton_Figures\Fig_4-1_TASMG_Groton_Emergency_Response_Areas.mxd

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Facility Location

Water Body

Wetland

River/Stream

0 150 300 600

Feet

19
PFAS Preliminary Assessment Report

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5. Adjacent Sources

Several potential off-facility sources of PFAS adjacent to the TASMG-Groton, not under the 

control of the CTARNG, were identified during the PA through interviews, review of the EDR 

report for a 1-mile radius surrounding the facility (Appendix A), and historical document review. 

A description of each potential adjacent source is presented below, and the sources are shown 

on Figure 5-1

Groton-New London Airport 

TASMG-Groton is located on the larger Groton-New London Airport property. Groton-New 

London Airport is a public-use, publicly-owned general aviation airport comprising 489 acres and 

includes Runway 5/23 and Runway 15/33. The airport has numerous tenant facilities, including 

the CTARNG TASMG-Groton facility, and was established in 1929. The Groton-New London 

Airport Fire Department responds to emergencies on the airport property, and from airport 

tenants, including the TASMG-Groton. According to interviewees, no known crashes that have 

required the use of AFFF in response have occurred on the airport property; however, several 

areas of the airport have been used for fire training and nozzle checks by the fire department.

According to Groton-New London Fire Department staff, one area near the north end of Runway 

5/23, and one area near the south end of Runway 5/23, have been used for Federal Aviation 

Administration-required annual fire training that involved the discharge of AFFF. The events 

occurred circa 2011 and 2017 and involved the discharge of approximately 100-150 gallons of 

3% AFFF solution. Other annual training events used only water. 

Nozzle check testing has also resulted in the discharge of AFFF to the airport property. 

According to fire department staff, nozzle check testing that involved the release of AFFF has 

occurred at the parking apron located west of Runway 15/33 and at the former shooting range 

colloquially referred to as the “Gun Butt”. Nozzle check testing also occurs on various runway 

areas but usually involves the discharge of only water. Because the water is sprayed through 

the same equipment used to spray AFFF, it is possible that this water contains residual AFFF. 

As a result of fire training and nozzle check testing at the airport property, several areas are 

considered potential PFAS release areas. The airport also occasionally hosts dignitaries and 

holds formal events. During these events, local fire departments may provide firefighting 

vehicles known to carry AFFF. According to interviewees, no AFFF releases have occurred at 

any such events. Fire department staff also stated that the airport terminal is used for the 

storage of extra AFFF in 5-gallon buckets and 55-gallon drums. The total volume stored at the 

terminal fluctuates, but approximately 500 gallons were stored at the terminal during PA 

interviews. No known releases have occurred at the airport terminal.

Groton-New London Airport Fire Department

The Groton-New London Airport Fire Department is located adjacent to the TASMG-Groton 

facility to the northwest and responds to emergencies at the airport and from airport tenants, 

including CTARNG. Aircraft rescue and firefighting (ARFF) training is required under the current 

lease with the CTARNG, according to the airport Master Plan (Connecticut Airport Authority, 

2013; Appendix A). 

The fire department occupied another building within the airport property until the previous 

facility was damaged in a structure fire in 2011. The former fire department was located adjacent 

to the private aviation hangars next to Runway 5/23, approximately 1,000 feet east of TASMGGroton. During the 2011 structure fire, the AFFF tank on a 1998 E One Titan 4x4 ARFF truck 
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

21

stored at the station was damaged, resulting in the release of 250 gallons of 3% AFFF 

concentrate. As a result, the former fire station location is considered a potential PFAS release 

area. The former fire station was repaired and is currently used for the storage of materials, 

including AFFF in 5-gallon buckets and in 55-gallon drums. 

The fire department currently stores two firefighting vehicles: one 2010 Ford Crash Rescue 

Equipment Services Renegade, and one 1995 T-1500 Oshkosh ARFF Truck. The former stores 

40 gallons of AFFF 3% concentrate, which produces 1,200 gallons of foam solution, and the 

latter stores 208 gallons of 3% AFFF concentrate, which produces 6,000 gallons of foam 

solution. The two vehicles are typically kept at the current fire department location. The fire 

department also formerly stored the aforementioned 1998 E One Titan 4x4 ARFF truck, which 

stored 250 gallons of AFFF concentrate, and a 1990 Oshkosh T-300 ARFF Truck, which went 

out of service prior to 2013 and stored 360 gallons of AFFF concentrate.

Nozzle check testing and fire training are performed by the fire department on airport property, 

but staff also confirmed that nozzle check testing is performed at the current fire station. Runoff 

from the fire station connects to sanitary sewers, which connects to the Groton WPCF. It is 

possible that residual AFFF has been released as a result of nozzle check testing at the current 

fire station. The current fire department location is considered a potential PFAS release area.

Private Aviation Companies at Groton-New London Airport

Several private aviation companies maintain spaces on the northwest side of Groton NewLondon Airport Runway 5/23, between 0.1 and 0.3 miles east of the TASMG-Groton facility.

Lanmar Aviation maintains hangar space on the northwestern-most end of the runway. Hangar 

space is available for rent at the Lanmar Aviation location, and the company also provides 

aircraft washing and detailing services for their customers. It is unknown whether AFFF is used 

or stored at the Lanmar Aviation facility, or whether emergency responses that used AFFF have 

occurred at the location.

Columbia Air Services is a fixed-base operator at the Groton-New London Airport that operates 

out of the Mystic Jet Center on the northwestern side of Runway 5/23. Through the Mystic Jet 

Center, Columbia Air Services is granted the right to operate at the airport and provide 

aeronautical services such as fueling, aircraft storage, aircraft rental, aircraft maintenance, flight 

instruction, and other services. It is unknown whether AFFF is used or stored at the Columbia 

Air Services/Mystic Jet Center facility, or whether emergency responses using AFFF have 

occurred at the location.

Naval Submarine Base New London

Naval Submarine Base New London (SUBASENLON) is a 687-acre facility located on the east 

bank of the Thames River, approximately 4.2 miles northwest of TASMG-Groton. The Naval 

facility has been active since 1867 and currently provides support for Navy submarine forces 

and other naval organizations and tenants. Due to historical use of AFFF at the facility, the Navy 

has identified fifteen areas where PFAS releases occurred, or potentially occurred (Naval 

Facilities Engineering Command [NAVFAC], 2019).

The Navy has initiated PFAS sampling at three private wells located outside of the Navy 

property in the area surrounding SUBASENLON. Data from the three wells indicate that 

concentrations of PFOS and PFOA in groundwater do not exceed the HA. The investigation of 

potential PFAS release areas within the Navy property is anticipated to begin in Spring 2020. 

The Navy PA report for the investigation of PFAS at SUBASENLON has not been approved by 
PFAS Preliminary Assessment Report

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22

CTDEEP at the time of this PA report (NAVFAC, 2019). The SUBASENLON Drinking Water 

Investigation Fact Sheet is included in Appendix A.

2003 Learjet 35A Accident

On 4 August 2003, a Learjet 35A crashed into a residential neighborhood approximately 0.75 

miles northeast of the north end of Groton-New London Airport Runway 5/23, and approximately 

1.2 miles northeast of TASMG-Groton. The aircraft struck several residential homes, a line of 

trees, and ultimately came to rest in the Poquonnock River. The post-impact fires destroyed two 

residential homes, two automobiles, and five vessels on the river. Staff from the Groton-New 

London Fire Department stated that AFFF was likely used in response to the post-crash fires; 

however, the exact location of the fires and response is unknown. The National Transportation 

Safety Board Aviation Accident Final Report (Accident Number NYC03FA173) does not specify 

which entities responded to the post-impact fires or whether AFFF were used in that response. 

The general area where the crash took place, including the Poquonnock River, is considered a 

potential PFAS release.

General Dynamics Electrical Boat Industrial Campus

The General Dynamics Electric Boat industrial campus occupies 118 acres along the Thames 

River, approximately 1.7 miles northwest of TASMG-Groton. The campus supports engineering 

and design work as well as new construction and maintenance activities. Electric Boat was 

established at the Groton location in 1911, and has been a long-time supporter of the nearby 

naval base (General Dynamics, 2019). According to TASMG-Groton and Groton-New London 

Airport Fire Department personnel, fires have occurred at the campus that have required AFFF 

fire suppression. The locations and dates of fires, as well as the volume of AFFF used in 

response, are unknown. Due to the campus’s proximity to the Thames River, it is possible that 

any PFAS releases on the campus may have migrated into the river.

Pfizer Industrial Campus

The pharmaceutical corporation Pfizer occupies a 160-acre industrial campus along the Thames 

River, approximately 1.3 miles west of TASMG-Groton. The campus supports research and 

development laboratories for Pfizer (Pfizer, 2019). According to TASMG-Groton and Groton-New 

London Airport Fire Department personnel, fires have occurred at the campus that have 

required AFFF fire suppression; however, no records of these fires or responses were provided 

during PA efforts. The locations and dates of fires, as well as the volume of AFFF used in 

response, are unknown. It is possible that PFAS releases on the campus may have migrated 

into the river.

Groton WPCF

There are no wastewater treatment plants (WWTPs) located at TASMG-Groton. The Groton 

WPCF is the nearest WWTP and is located approximately 1.5 miles to the east. WWTPs are not 

usually a primary potential release area of PFAS, but sludges and liquids from areas of potential 

release that are treated at WWTPs may create a secondary source of contamination. Known 

PFAS releases have occurred at TASMG-Groton that could have resulted in the migration of 

PFAS in water to the Groton WPCF.

Wastewater at the WPCF is treated using an activated sludge process. Solids are collected, 

dewatered, and shipped for disposal. Nitrogen is removed from the liquid in a two-step aerobic 
PFAS Preliminary Assessment Report

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23

and anaerobic process by beneficial bacteria. The wastewater is disinfected with sodium

hypochlorite before being released to the Thames River (Town of Groton, 2019).
Fire Department

AFFF Training Area

Fire Department

AFFF Nozzle Check

Testing Area

Groton-New

London Airport

Fire Department

Groton-New

London Airport

Fire Department

Fire Department

AFFF Training Area

Groton WCPF

2003 Learjet

35A Accident

Runway 5/23 Runway 15/33

Gun Butt/Nozzle

Check Testing Area

GrotonNew London 

Airport

Mystic Jet Center

Lanmar Aviation

Long Island

Sound

Long

Island

Sound

Long

Island

Sound

Fort Hill Brook

Poquonnock R iver

Pfizer

Industrial

Campus

General Dynamic

Electric Boat

Industrial Campus

Naval Submarine

Base New London

Rock Pond

Groton

Reservoir

Pohegnut Reservoir

Goss Cove

Long

Cove

Latham

Reservoir

Latham

Bog

Morgan Pond

Reservoir

Ledyard

Reservoir

Smith Lake

Buddington

Pond

Long Island

Sound

Long Island

Sound

Long

Island Sound

Warren

Millpond

Birch Plain

Creek Tidal Marsh

Long

Cove

Beaverdam B rook

Birch

Plain

Cre ek

Thompson

Brook

Po quonnock R vi er

Br ig gs Brook

He mp st ead

Brook

F lat Brook

Grea t

Brook

Poquonnock River

Thames River

0 2,100 4,200 8,400

Feet

0 500 1,000 2,000

Feet

­ Figure 5-1

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1 2

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6. Preliminary Conceptual Site Model

Based on the PA findings, two AOIs were identified at TASMG-Groton: AOI 1 Building 320 and 

AOI 2 Building 323. The AOI locations are shown on Figure 6-1. The following sections describe 

the CSM components and the specific preliminary CSM developed for each AOI. The CSM 

identifies the three components necessary for a potentially complete exposure pathway: (1) 

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

considered incomplete.

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

exposure via the dermal contact pathway may occur, and current risk practice suggests it is an 

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

sparse and continue to be the subject of PFAS toxicological study (National Ground Water 

Association, 2018). Receptors at the TASMG-Groton include site workers, construction workers, 

trespassers, and off-facility recreational users of the surrounding water bodies. The preliminary 

CSM diagram for the TASMG-Groton indicates which specific receptors could potentially be 

exposed to PFAS. 

AOI 1 Building 320

AOI 1 comprises Building 320, the main hangar, and its immediately surrounding areas where 

known PFAS releases have occurred. PFAS releases are suspected to have occurred during 

the AFFF fire suppression system test events between 2008 the present. System tests involved 

the discharge of water suspected to contain residual AFFF through test ports located on the 

building perimeter.

PFAS-laden water released from the test ports is collected in barrels; however, it is possible that 

water has been spilled during the many test events. Test ports are located over paved surfaces, 

but trench drains and catch basins were observed near the test ports during the VSI. The trench 

drains and catch basins connect to municipal sanitary sewers that discharge to the WPCF. 

Additionally, surface runoff at the facility generally drains from east to west. Stormwater catch 

basins channel flow west towards a small intermittent stream that enters Baker Cove and 

ultimately the Long Island Sound. Although surface water catch basins are not located 

immediately beneath or adjacent to the building test ports, it is possible that runoff transported 

PFAS-laden water into the surface water bodies described. As such, surface water and 

sediment are considered a potentially complete pathway for recreational users of the surface 

water bodies surrounding TASMG-Groton, and for site workers/construction workers entering 

the small wetland area within the facility. 

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

TASMG-Groton and surrounding areas are provided municipal water by the Groton Utilities 

Water Operations. No drinking water wells exist at the facility. Groundwater is considered an 

incomplete pathway for PFAS exposure to site workers and residents via ingestion. 

Groundwater in the area generally flows south and discharges to the Long Island Sound. It is 

possible that PFAS infiltrating groundwater at the facility are discharging to surface water that is 

used recreationally south of the facility.

Landscaped areas exist adjacent to Building 320. Surface soil in the landscaped areas near 

Building 320 may have received surface water runoff containing PFAS as a result of spillage at 

the test ports during system testing. Surface soil is considered a potentially complete pathway 

for PFAS exposure to site workers, construction workers, and trespassers via ingestion and 

inhalation. 
PFAS Preliminary Assessment Report

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26

AFFF releases at AOI 1 may also have infiltrated subsurface soil via cracks in pavement, joints 

between areas that are paved with different materials, and the nearby landscaped areas. If 

AFFF released at the AOI infiltrated the subsurface, then ground-disturbing activities may result 

in PFAS exposure to construction workers via ingestion and inhalation. Accidental ingestion of 

groundwater is also considered a potentially complete pathway for exposure to PFAS during 

construction activities due to the presumed 8- to 9-foot depth to groundwater. The preliminary 

CSM diagram for AOI 1 is shown in Figure 6-2.

AOI 2 Building 323

AOI 2 comprises Building 323, the Engine Shop, and the area between its garage door and the 

perimeter fence, where known PFAS releases have occurred. PFAS releases to the 

environment are suspected to have occurred during the AFFF fire suppression system 

discharges circa 2010-2012, and 2014. During the events, AFFF escaped the building to floor 

drains that connect to an OWS and sanitary system sewers, and also out of the open garage 

door. AFFF may have also escaped beneath entryway doors that appeared to have space 

between the floor and the bottom of the doors even when closed; this was observed during the 

VSI.

AFFF that was contained within the building drained to an OWS and possibly municipal sanitary 

sewers that discharge to the WPCF. Surface runoff escaping the building; however, potentially 

drained towards a wetland located approximately 180 feet northeast. Elsewhere, surface runoff 

may have traveled west towards Birch Stream, which drains to Baker Cove and the Long Island 

Sound. Surface water and sediment are considered a potentially complete pathway for 

recreational users of the surface water bodies surrounding TASMG-Groton, and for site 

workers/construction workers entering the small wetland area within the facility as a result of 

AFFF releases at AOI 2. 

Groundwater is considered an incomplete pathway for PFAS exposure to site workers and 

residents via ingestion due to the lack of drinking water wells at the facility and surrounding 

area.

Landscaped and wooded areas exist adjacent to Building 323. Surface soil in these may have 

received AFFF flowing outwardly from the building or surface water runoff containing PFAS as a 

result of the releases. Surface soil is considered a potentially complete pathway for PFAS 

exposure to site workers, construction workers, and trespassers via ingestion and inhalation. 

AFFF releases at AOI 2 may also have infiltrated subsurface soil in the landscaped and wooded 

areas. As such, ground-disturbing activities may result in PFAS exposure to construction 

workers via ingestion and inhalation. Accidental ingestion of groundwater during construction is 

also considered a potentially complete pathway. The preliminary CSM diagram for AOI 2 is 

shown in Figure 6-2.

AOI 3 - Building 325 Storage Area

AOI 3 comprises Building 325 and its adjacent storage area where potentially PFAS-laden water 

is stored in barrels prior to disposal by a private contractor. Although the disposal of PFAS-laden 

water is performed in an enclosed manner, it is possible that spillage may occur. Additionally, 

the storage area is unsheltered and barrels are subject to corrosion due to the elements.

According the facility Spill Prevention, Control and Countermeasure Plan, the barrels are stored 

on spill control pallets, and any liquid spilled is collected in the pallets. If any spills occur outside 

of the pallets, liquid will flow to the surrounding impervious surfaces. Surface runoff may flow 

southeast or northwest depending on the location of the spill. Grassy surfaces surround the 
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

27

storage area to the south, west, and north, and precipitation may facilitate runoff of any PFAS

spills to those areas. Surface runoff to the northwest may have traveled west towards the Birch

Stream. It is not expected that runoff travels to the wetland to the northeast. Thus, surface

water and sediment are considered a potentially complete pathway for recreational users of the

surface water bodies surrounding TASMG-Groton.

As previously stated, groundwater is considered an incomplete pathway for all receptors.

Surface soil surrounding AOI3 may have received surface water runoff containing PFAS. As

such, it is considered a potentially complete pathway for PFAS exposure to site workers,

construction workers, and trespassers via ingestion and inhalation. Additionally, grounddisturbing activities may result in PFAS exposure to construction workers via ingestion and

inhalation of subsurface soil, and ingestion of groundwater. The preliminary CSM diagram for

AOI 3 is shown in Figure 6-3.
Building 320 

- Main Hangar

Fire Dep ar tment

AFFF Training Area

Fire Dep ar tment

AFFF Nozzle Chec k

Testing Area

Groton-New London Air p or t 

Fire Dep ar tment

Fire Dep ar tment

AFFF Training Area

Groton WCPF

2003 Learjet

35A Ac c ident

Building 323 – 

Engine Shop

Runw ay 5/23

Runw ay 15/33

Gun Butt/Nozzle Chec k

Testing Area

Building 350 

- TASMG 2

Flight

Test

Ramp

Building 324 – 

Paint Strip p ing 

Building

Building 338 -

Cold Storage

Building

Groton-New London Air p or t

Mystic 

Jet 

Center

Lanmar

Aviation

Building 324

Boiler Room Fire

Former Administrative

Building Fire

Building 322 -

GSE Building

Building 321

- TASMG Gym

Building

323 Fire

Building 325 -

State Equip ment

Storage Building

Poquonnoc k

RiverWater shed

Coastal drainages-Paw c atuc k

Point to Eastern

PointWatershed

Coastal drainages-Paw c atuc k

Point to Eastern

PointWatershed

AOI 2

AOI 1

AOI 3

Fort Hill Brook

Birch Plain Creek

Poquonnock River

0 500 1,000 2,000

Feet

­ Figure 6-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at TASMG Groton, CT

3/31/2020

3/31/2020

3/31/2020

MS

JW

RG

GIS BY

CHK BY

PM

Base Map: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus

DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

3/31/2020

1:12,000

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\CT\CT_Figures\TASMG_Groton_Figures\Fig_6-1_TASMG_Groton_AOIs.mxd

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Location

River/Stream

Areas of Interest

12420 Milestone Center Drive

Germantown, MD 20876

28
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – AOI 2

AFFF 

releases from 

Building 320 

and Building 

323 fire 

suppression 

systems

PFAS in 

Surface 

Soil / Paved 

Surfaces

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site 

Worker

Construction 

Worker Resident

Site 

Worker

Construction 

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure 6-2

Preliminary Conceptual Site Model

AOI 1 (Building 320) – AOI 2 (Building 323)

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Tresspasser/

Recreational User

Tresspasser/

Recreational User

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

29
Media

SOURCE PATHWAY RECEPTOR

AOI 3

Potential 

PFAS-laden 

water spills

PFAS in 

Surface 

Soil / Paved 

Surfaces

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site Worker Construction Worker Resident

Site Worker Construction Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure 6-3

Preliminary Conceptual Site Model

AOI 3 (Building 325 Storage Area)

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Tresspasser/ Recreational User

Tresspasser/ Recreational User 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

30
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

31

7. Conclusions

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

storage of AFFF and other PFAS-related activities at TASMG-Groton. The PA findings are based 

on personnel interviews, environmental investigations and reports, historical documents, and 

the VSI (Appendix A and Appendix B).

Findings

Three AOIs related to potential PFAS releases were identified at TASMG-Groton based on PA 

data (Figure 7-1) and are summarized in Table 7-1 below:

Table 7-1: AOIs at TASMG-Groton

Area of Interest Name Used by Potential Release Dates

AOI 1 Building 320 CTARNG 2008-Present

AOI 2 Building 323 CTARNG 2010-2012 and 2014

AOI 3 Building 325 CTARNG 2008-Present

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

contamination in environmental media at the facility to site workers, construction workers, 

trespassers and off-facility recreational users of the surrounding water bodies. The preliminary 

CSM for TASMG-Groton, which presents the potential receptors and media impacted, is shown 

on Figure 6-2 and Figure 6-3.

The following areas, which were discussed in Section 3 through Section 5, were determined to 

have no suspected PFAS releases to the environment (Table 7-2):

Table 7-2: No Suspected Release Areas

No Suspected 

Release Area Used by Rationale for No Suspected Release Determination

Building 321 –

TASMG Gym CTARNG Readily available information indicates no evidence of 

AFFF stored or use at this location.

Building 322 – GSE 

Building CTARNG Readily available information indicates no evidence of AFFF stored or use at this location.

Building 324 – Paint 

Stripping Building CTARNG Readily available information indicates no evidence of AFFF stored or use at this location.

Building 338 – Cold 

Storage Building CTARNG Readily available information indicates no evidence of AFFF stored or use at this location.

Building 35 – TASMG 

2

CTARNG Readily available information indicates no evidence of 

AFFF stored or use at this location.

Flight Test Ramp CTARNG Readily available information indicates no evidence of 

AFFF stored or use at this location.

Uncertainties

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

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

documentation of PFAS use was not required because PFAS were considered benign. 
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

32

Therefore, records were not typically kept by the CTARNG on the storage, use, or disposition of 

AFFF. 

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

interviews with personnel who had direct knowledge of PFAS use and storage at the facility. 

Sometimes, the provided information was vague or conflicted with other information sources. 

For example, the number of AFFF release events recalled by interviewees at Building 323 

varied, as did whether the garage door were open during one of the events. Gathered 

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

number of personnel with direct knowledge, the time passed since PFAS were first used by the 

ARNG (1969 to present), and a reliance on personal recollection. Inaccuracies may arise in 

potential PFAS storage locations. 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 storage of PFAS 

were reviewed, tenured 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: Sources of Uncertainties

Location Source of Uncertainty

Building 320 –

Main Hangar

It is unknown whether the AFFF system test following the 1998 

installation involved AFFF. The frequency of fire suppression system 

testing between 2008-2014 is unknown. It is unclear if water spilled from 

the system test ports on the perimeter of the building during AFFF 

system testing, and if so, how much water was spilled. The exact 

drainage pattern from each system test port is also unknown.

Building 323 -

Engine Shop

It is unclear how many independent AFFF fire suppression system 

releases have occurred at this location. Interviewee-provided information 

is conflicting. It is also unclear whether the garage door were open during 

one of the releases. The exact drainage pattern for surface water exiting 

the building is unknown.

Building 325 –

State Equipment 

Storage Building

Information about the contractor that provides disposal of the barrels 

staged in this area was not available during the site visit. It is unknown if 

PFAS releases have ever occurred as a result of draining barrels at this 

location.

Potential Future Actions

Interviews with CTARNG staff, whose first-hand knowledge of the facility span 1985-present, 

indicate that ARNG activities may have resulted in the release of AFFF and residual AFFF in 

water at two AOIs identified during the PA. Based on the preliminary CSMs developed for the 

AOIs, there is potential for PFAS to be exposed to human receptors (see Section 7.1). 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. 
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

33

Table 7-4: PA Findings Summary

Area of

Interest AOI Location Rationale Potential Future Action

AOI 1

Building 320

41°20'1.84"N; 

72°2'55.63"W

Multiple releases of residual

AFFF in water building

perimeter between 2008-

present

Proceed to an SI, focus on

soil, groundwater, surface

water and sediment

AOI 2

Building 323

41°20'4.84"N; 

72°3'2.61"W

Potentially two AFFF system

releases to sanitary sewers and

surfaces surrounding the

building

Proceed to an SI, focus on

soil, groundwater, surface

water and sediment

AOI 3

Building 325

41°20'3.30"N; 

72°3'5.94"W

Potential PFAS releases during

drum content disposal

Proceed to SI, focus on soil

and groundwater

ARNG will evaluate the need for an SI at TASMG-Groton based on the potential receptors, the

potential migration of PFAS contamination off the facility, and the availability of resources.
Building 325 - 

State Eq uipment 

Sto rage Building

Building 320 

- Main Hangar

Fire Department

AFFF Training Area

Fire Department

AFFF No zzle Check

Testing Area

Gro to n-New Lo ndo n Airpo rt 

Fire Department

Fire Department

AFFF Training Area

Gro to n WCPF

2003 Learjet

35A Accident

Building 323 – 

Engine Sho p

Runw ay 5/23

Runw ay 15/33

Gun Butt/No zzle Check

Testing Area

Building 350 Flight - TASMG 2

Test

Ramp

Building 324 – 

Paint Stripping 

Building

Building 338 -

Co ld Sto rage

Building

Gro to n-New Lo ndo n Airpo rt

Mystic 

Jet 

Center

Lanmar

Aviatio n

Building 324

Bo iler Ro o m Fire

Fo rmer Administrative

Building Fire

Building 322 -

GSE Building

Building 321

- TASMG Gym

Building

323 Fire

Long Island Sound

Long

Island

Sound

Long

Island

Sound

Fort Hill Brook

Poquonnock R iver

AOI 2

AOI 1

AOI 3

Pfizer

Industrial

Campus

General Dynamic

Electric Bo at

Industrial Campus

Naval Sub marine

Base New Lo ndo n

Rock Pond

Groton Reservoir

Groton

Reservoir

Pohegnut

Reservoir

Goss Cove

Long

Cove

Latham

Reservoir

Latham

Bog

Morgan Pond

Reservoir

Ledyard

Reservoir

Buddington

Pond

Long

Island Sound

Long Island

Sound

Warren Millpond

Birch Plain

Creek Tidal Marsh

Trails Pond

Long

Cove

Beaver dam Brook

Poquonnoc k Riv er

Thompson Brook

Grea t

Brook

He mpst ead

Brook

Brigg s Bro ok

F lat Brook

Thames River

0 2,100 4,200 8,400

Feet

0 500 1,000 2,000

Feet

­ Figure 7-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at TASMG Groton, CT

3/31/2020

3/31/2020

3/31/2020

MS

JW

RG

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

3/31/2020

1:12,000

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\CT\CT_Figures\TASMG_Groton_Figures\Fig_7-1_TASMG_Groton_Summary.mxd

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Location

Water Body

Wetland

River/Stream

Summary o f Findings

12420 Milestone Center Drive

Germantown, MD 20876

1 2

1

2

34
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

35

8. References

CTARNG, 2019. Final Spill Prevention, Control and Countermeasures Plan; Including 

Hazardous Waste Contingency Response Actions. January 2019.

Connecticut Airport Authority, 2013. Groton-New London Airport Master Plan. May 2013.

https://ctairports.org/airports/groton-newlondon/planning-engineering/. Accessed December

2019.

DeCarlo & Doll, Inc. 1996. Final Environmental Assessment for Improvements to Aviation

Facilities; Groton/New London Airport, Groton, Connecticut; CTARNG No. 090034. August

1996.

General Dynamics, 2019. Electric Boat Groton, CT Website.

http://www.gdeb.com/about/locations/groton/. Accessed December 2019.

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

Practice. January.

National Oceanic and Atmospheric Administration, 2019. Data Tools: 1981-2010 Normals.

https://www.ncdc.noaa.gov/cdo-web/datatools/normals. Accessed December 2019.

NAVFAC, 2019. Naval Submarine Base New London Environmental Restoration Program

Public Website.

https://www.navfac.navy.mil/products_and_services/ev/products_and_services/env_restoration/i

nstallation_map/navfac_atlantic/midlant/new_london/pfas.html. Accessed December 2019.

Pfizer, 2019. Pfizer Groton, CT Website. https://www.pfizer.com/science/researchdevelopment/centers/ct_groton. Accessed December 2019.

Town of Groton, 2019. Water Pollution Control Website. http://www.grotonct.gov/depts/pubwks/wpcf.asp. Accessed December 2019.

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

Preliminary Assessments under CERCLA. September.

United States Fish and Wildlife Service (USFWS), 2019. National Wetlands Inventory Mapper.

https://www.fws.gov/wetlands/data/mapper.html. (Accessed December 2019).

USGS, 2019. National Water Information System: Mapper.

https://maps.waterdata.usgs.gov/mapper/index.html. Accessed December 2019.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix A

Data Resources
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, CT

Data resources will be provided separately on CD. Data resources for TASMG-Groton include:

Facility Real Property Documents

• 1996 Lease and Operating Agreement for the State of Connecticut Military Department Use 

and Occupancy of Parcel 1, Parcel 2, and Parcel 3 at Groton-New London Airport

• 2012 Memorandum for the Request for Temporary Aviation Unit Facility Lease and 

Corresponding Funding

• 2014 TASMG Certificate of Title

• 2014 TASMG Certificate of Title Lease Supplement: Exhibit A

• 2018 Department of the Army License for National Guard Purposes: DACA33-3-18-094

• 2018 Property Map provided by CTARNG

Background Information Sources

• 2005 Quaternary Geologic Map of Connecticut and Long Island Sound Basin

• 2017 Groton-New London Airport Master Plan Update

• 2019 EDR Report for TASMG-Groton

Adjacent Source Information

• 2003 National Transportation Safety Board Aviation Accident Final Report; Accident 

Number NYC03FA173

• 2019 Naval Submarine Base New London, Groton, Connecticut PFAS Drinking Water 

Investigation Fact Sheet
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix B.1

Interview Records





Additional notes:

While walking to different locations on the property during the site visit, an intervieweerecounted a story in which teenagers accidentally trespassed onto the property by bywalking through the woods to the west of TASMG-Groton and around the fence linenear Long Island Sound. When the teenagers returned north towards the facility, theyaccidentally walked onto airport/CTARNG property. They were escorted offsite by facility staff.





PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix B.2

Visual Site Inspection Checklists
Visual Site Inspection Checklist

Names(s) of people performing VSI:

Recorded by:

ARNG Contact:

Date and Time:

Method of visit (walking, driving, adjacent):

Source/Release Information

Site Name / Area Name / Unique ID:

Historic Site Use (Brief Description):

Current Site Use (Brief Description):

Physical barriers or access restrictions:

1. Was PFAS used (or spilled) at the site/area? Y / N

1a. If yes, document how PFAS was used and usage time (e.g., fire fighting training 2001 to 2014):

2. Has usage been documented? Y / N

2a. If yes, keep a record (place electronic files on a disk):

3. What types of businesses are located near the site? Industrial / Commercial / Plating / Waterproofing / Residential

3a. Indicate what businesses are located near the site

4. Is this site located at an airport/flightline? Y / N

4a. If yes, provide a description of the airport/flightline tenants:

Site / Area Acreage:

Page 1 of 4

December 10, 2019; 12:00pm

Walking

TASMG-Groton Building 320

3.2 acres (based on Google Earth aerial imagery)

TASMG/AVCRAD

TASMG

Facility perimeter fence / airport fence

Yes, PFAS-laden water may be released during quarterly testing of fire suppression system. Water may spill onto ground outside building during testing.

No documents have been made available recording system testing.

Airport tenants, industrial campuses nearby (Pfizer, General Dynamic Electric

Boat), Naval Submarine Base

Yes
Visual Survey Inspection Log

1. Does the facility have a fire suppression system? Y / N

1a. If yes, indicate which type of AFFF has been used:

1b. If yes, describe maintenance schedule/leaks:

1c. If yes, how often is the AFFF replaced:

1d. If yes, does the facility have floor drains and where do they lead? Can we obtain an as built drawing?

Transport / Pathway Information

1. Does site/area drainage flow off installation? Y / N

1a. If so, note observation and location:

2. Is there channelized flow within the site/area? Y / N

2a. If so, please note observation and location:

3. Are monitoring or drinking water wells located near the site? Y / N

3a. If so, please note the location:

4. Are surface water intakes located near the site? Y / N

4a. If so, please note the location:

5. Can wind dispersion information be obtained? Y / N

5a. If so, please note and observe the location.

6. Does an adjacent non-ARNG PFAS source exist? Y / N

6a. If so, please note the source and location.

6b. Will off-site reconnaissance be conducted? Y / N

Other Significant Site Features:

Migration Potential:

Page 2 of 4

Yes, the Building 320 fire suppression system is supported by a 5,000 gallon

AFFF tank.

The system was installed in 1998, and tested in 2008. The test in 2008 was enclosed and no leaks occurred. Quarterly system testing has occurred ever since.

The AFFF is not used during the quarterly testing. Only water is released; however, the water may contain residual PFAS. AFFF is not replaced.

Floor drains connect to sanitary system sewers for the town of Groton. Stormwater

runoff flows towards Birch Stream.

Yes, via sanitary system sewers to Groton WWTP, and via runoff/stormwater catch

basins to an intermittent stream that connects to Birch Stream/Long Island Sound

No surface channels. Below ground channelization via stormwater catch basins

towards intermittent stream.

No drinking water wells. According to interviewees, monitoring wells exist at

Building 338 due to previous hydrocarbon remediation.

Yes, intermittent stream to Birch Stream to Birch Cove to Long Island Sound.

Also a small wetland on the facility, and the Poquonnock River to the east.

No

Yes, multiple. Airport fire department, private tenants, airport runways, industrial

campuses, crash location.
Visual Survey Inspection Log

1. Has the infrastructure changed at the site/area? Y / N

1a. If so, please describe change (ex. Structures no longer exist):

2. Is the site/area vegetated? Y / N

2a. If not vegetated, briefly describe the site/area composition:

3. Does the site or area exhibit evidence of erosion? Y / N

3a. If yes, describe the location and extent of the erosion: 

4. Does the site/area exhibit any areas of ponding or standing water? Y / N

4a. If yes, describe the location and extent of the ponding: 

Receptor Information

1. Is access to the site restricted? Y / N

1a. If so, please note to what extent:

2. Who can access the site?

2a. Circle all that apply, note any not covered above:

3. Are residential areas located near the site? Y / N

3a. If so, please note the location/distance:

4. Are any schools/day care centers located near the site? Y / N

4a. If so, please note the location/distance/type:

5. Are any wetlands located near the site? Y / N

5a. If so, please note the location/distance/type:

Significant Topographical Features:

Site Workers / Construction Workers / Trespassers / Residential / Recreational

Users / Ecological

Page 3 of 4

No

Building 320 is not vegetated, but some landscaped areas exist near it. PFASladen water runoff may reach landscaped areas.

No

No, but a wetland exists nearby.

Yes, perimeter fence and airport fence.

Site workers/construction workers/trespassers/ecological receptors

Yes, to the northwest

West Side Middle School is 0.9 miles northwest. Susan's Family Daycare

located 0.4 miles northwest.

Yes, approximately 600 ft northwest
Visual Site Inspection Checklist

Names(s) of people performing VSI:

Recorded by:

ARNG Contact:

Date and Time:

Method of visit (walking, driving, adjacent):

Source/Release Information

Site Name / Area Name / Unique ID:

Historic Site Use (Brief Description):

Current Site Use (Brief Description):

Physical barriers or access restrictions:

1. Was PFAS used (or spilled) at the site/area? Y / N

1a. If yes, document how PFAS was used and usage time (e.g., fire fighting training 2001 to 2014):

2. Has usage been documented? Y / N

2a. If yes, keep a record (place electronic files on a disk):

3. What types of businesses are located near the site? Industrial / Commercial / Plating / Waterproofing / Residential

3a. Indicate what businesses are located near the site

4. Is this site located at an airport/flightline? Y / N

4a. If yes, provide a description of the airport/flightline tenants:

Site / Area Acreage:

Page 1 of 4

December 10, 2019; 12:00pm

Walking

TASMG-Groton Building 323

0.24 acres (based on Google Earth aerial imagery)

Engine shop

Engine shop

Facility perimeter fence / airport fence

Yes, AFFF releases occurred in 2010-2012 and 2014 during accidental fire suppression

system releases. AFFF may have escaped the building to the west during releases.

No documents have been made available recording system testing. Records requested.

Airport tenants, industrial campuses nearby (Pfizer, General Dynamic Electric

Boat), Naval Submarine Base

Yes
Visual Survey Inspection Log

1. Does the facility have a fire suppression system? Y / N

1a. If yes, indicate which type of AFFF has been used:

1b. If yes, describe maintenance schedule/leaks:

1c. If yes, how often is the AFFF replaced:

1d. If yes, does the facility have floor drains and where do they lead? Can we obtain an as built drawing?

Transport / Pathway Information

1. Does site/area drainage flow off installation? Y / N

1a. If so, note observation and location:

2. Is there channelized flow within the site/area? Y / N

2a. If so, please note observation and location:

3. Are monitoring or drinking water wells located near the site? Y / N

3a. If so, please note the location:

4. Are surface water intakes located near the site? Y / N

4a. If so, please note the location:

5. Can wind dispersion information be obtained? Y / N

5a. If so, please note and observe the location.

6. Does an adjacent non-ARNG PFAS source exist? Y / N

6a. If so, please note the source and location.

6b. Will off-site reconnaissance be conducted? Y / N

Other Significant Site Features:

Migration Potential:

Page 2 of 4

Yes, the Building 323 fire suppression system is supported by a 270 gallon

AFFF tank.

The system was installed in 2004. No known releases occur during maintenance

or testing.

The AFFF is not used and thus not replaced.

Floor drains connect to sanitary system sewers for the town of Groton. Stormwater

runoff flows towards Birch Stream.

Yes, via sanitary system sewers to Groton WWTP, and via runoff/stormwater catch

basins to an intermittent stream that connects to Birch Stream/Long Island Sound

No surface channels. Below ground channelization via stormwater catch basins

towards intermittent stream.

No drinking water wells. According to interviewees, monitoring wells exist at

Building 338 due to previous hydrocarbon remediation.

Yes, intermittent stream to Birch Stream to Birch Cove to Long Island Sound.

Also a small wetland on the facility, and the Poquonnock River to the east.

No

Yes, multiple. Airport fire department, private tenants, airport runways, industrial

campuses, crash location.
Visual Survey Inspection Log

1. Has the infrastructure changed at the site/area? Y / N

1a. If so, please describe change (ex. Structures no longer exist):

2. Is the site/area vegetated? Y / N

2a. If not vegetated, briefly describe the site/area composition:

3. Does the site or area exhibit evidence of erosion? Y / N

3a. If yes, describe the location and extent of the erosion: 

4. Does the site/area exhibit any areas of ponding or standing water? Y / N

4a. If yes, describe the location and extent of the ponding: 

Receptor Information

1. Is access to the site restricted? Y / N

1a. If so, please note to what extent:

2. Who can access the site?

2a. Circle all that apply, note any not covered above:

3. Are residential areas located near the site? Y / N

3a. If so, please note the location/distance:

4. Are any schools/day care centers located near the site? Y / N

4a. If so, please note the location/distance/type:

5. Are any wetlands located near the site? Y / N

5a. If so, please note the location/distance/type:

Significant Topographical Features:

Site Workers / Construction Workers / Trespassers / Residential / Recreational

Users / Ecological

Page 3 of 4

No

Landscaped areas exist on the southwest side, and nearby to the west and

north. AFFF runoff may have reach landscaped areas.

No

No, but a wetland exists approximately 250 ft to the northeast

Yes, perimeter fence and airport fence.

Site workers/construction workers/trespassers/ecological receptors

Yes, to the northwest

West Side Middle School is 0.9 miles northwest. Susan's Family Daycare

located 0.4 miles northwest.

Yes, approximately 250 ft northeast
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix B.3

Conceptual Site Model Information
Preliminary Assessment – Conceptual Site Model Information

Site Name:

Why has this location been identified as a site?

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

Training Events

Have any training events with AFFF occurred at this site?

If so, how often?

How much material was used? Is it documented?

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

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

pathways to larger water bodies?

Surface Water:

Surface water flow direction?

Average rainfall?

Any flooding during rainy season?

Direct or indirect pathway to ditches?

Direct or indirect pathway to larger bodies of water?

Does surface water pond any place on site?

Any impoundment areas or retention ponds?

Any NPDES location points near the site?

How does surface water drain on and around the flight line?

TASMG-Groton

The site is located on an airport and has a history of aircraft use and maintenance that is

typically associated with AFFF.

Yes, airport activities (fire department, crashes, training, private tenants), industrial activities (Pfizer, General Dynamic), and DoD (Naval Submarine Base)

No at the facility, but it has at the airport

2 known events during annual training. Nozzle check testing also occurs on airport.

100-150 gallons of AFFF concentrate

Generally east to west

46.49 inches annually

Facility is in a 100-yr floodplain

Direct pathway to wetland, Birch Stream

Yes, direct to Birch Stream

Wetland exists in northwest corner of property

No impoundment areas

Unknown

Unknown; flightline is not on property
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction?

Depth to groundwater?

Uses (agricultural, drinking water, irrigation)?

Any groundwater treatment systems? 

Any groundwater monitoring well locations near the site?

Is groundwater used for drinking water?

Are there drinking water supply wells on installation?

Do they serve off-post populations?

Are there off-post drinking water wells downgradient 

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present?

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

Do we understand the fate of sludge waste?

Is surface water from potential contaminated sites treated?

Equipment Rinse Water

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

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

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

3. Other?

Generally north to south towards Long Island Sound

8-9 ft according to facility personnel

No known use of groundwater

No

Near Cold Storage Building

No

No, provided by Groton Municipal Water Department

No

No; none known

No, the Groton WWTP treats sanitary system water

Information available online

No

Runoff from potential releases may reach the Groton

WWTP

No firefighting equipment at the facility is washed on facility

Fire department nozzle testing occurs on the airport, off-property
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker 

Construction Worker 

Recreational User

Residential 

Child 

Ecological

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

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur?

Nearest school/daycare is 0.9 and 0.4 miles away, respectively.

Trespassers are also a potential receptor

for exposure at TASMG-Groton.
PFAS Preliminary Assessment Report

TASMG-Groton, Groton, Connecticut

Appendix C

Photographic Log
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 1

Description:

5,000-gallon tank of Ansulite 

3% AFFF concentrate stored 

in the tank room within 

Building 320.

Orientation:

NA

Date 12/10/2019

Time 11:10

Photograph No. 2

Description:

Nested AFFF system test

ports used during the

quarterly system testing 

of Building 320.

Orientation:

Northwest

Date 12/10/2019

Time 11:37

AECOM Page 1 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 3

Description:

Piping supporting AFFF

system test ports at Building 

320 used during the quarterly 

system testing. "Foam" labels 

visible on system piping.

Orientation:

East

Date 12/10/2019

Time 11:39

Photograph No. 4

Description:

AFFF system release button in 

Building 323. This was 

accidentally triggered during 

the known AFFF system 

releases within the Engine 

Room.

Orientation:

Southwest

Date 12/10/2019

Time 12:01

AECOM Page 2 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 5

Description:

Space visible between the

floor and the bottom of the

door in Engine Room in 

Building 323.

Orientation:

Northeast

Date 12/10/2019

Time 12:09

Photograph No. 6

Description:

270-gallon AFFF concentrate

tank stored in the Engine

Room - Building 323.

Orientation:

Northeast

Date 12/10/219

Time 12:10

AECOM Page 3 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 7

Description:

TASMG-Groton fence north 

of Building 323. Wetland 

visible in the foreground 

within the fenced area.

Orientation:

Northeast

Date 12/10/2019

Time 12:15

Photograph No. 8

Description:

Mobile fire extinguisher 

staged on the Flight Ramp 

adjacent to a storage shed 

which is sometimes used to 

store more mobile fire 

extinguishers.

Orientation:

Southwest

Date 12/10/2019

Time 12:29

AECOM Page 4 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 9

Description:

5-gallon bucket of National 

Foam Aer-O-Lite 3% AFFF 

concentrate stored within the 

Building 320 tank room.

Orientation:

NA

Date 12/10/2019

Time 11:10

Photograph No. 10

Description:

5,000-gallon AFFF 

concentrate tank and 5-gallon 

bucket of AFFF concentrate 

stored within the Building 

320 tank room.

Orientation:

NA

Date 12/10/2019

Time 11:11

AECOM Page 5 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 11

Description:

Ceiling sprinklers connected 

to the AFFF fire suppression 

system in the Building 320 

hangar.

Orientation:

NA

Date 12/10/2019

Time 11:18

Photograph No. 12

Description:

Building 320 AFFF suppression system hose that was 

used during the 2008 system 

test to discharge AFFF 

straight into the vac-truck of 

a private contractor.

Orientation:

NA

Date 12/10/2019

Time 11:22

AECOM Page 6 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 13

Description:

AFFF system test port used

during the quarterly system

testing of Building 320. 

During testing, a barrel is 

placed beneath the port to 

catch potentially PFASladen water.

Orientation:

Northwest

Date 12/10/2019

Time 11:25

Photograph No. 14

Description:

AFFF system test port used

during the quarterly system

testing at Building 320.

Sanitary drain visible beyond the test port.

Orientation:

Northwest

Date 12/10/2019

Time 11:27

AECOM Page 7 of 8
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

TASMG-Groton Groton, Connecticut

Preliminary Assessment Report

TASMG-Groton

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 15

Description:

AFFF system test port used

during the quarterly system

testing at Building 320.

Orientation:

Southeast

Date 12/10/2019

Time 11:33

Photograph No. 16

Description:

AFFF system test port used 

during the quarterly system 

testing.

Orientation:

East

Date 12/10/2019

Time 11:34

AECOM Page 8 of 8