FINAL 

Site Inspection Report 

Rio Rancho Training Site 

Rio Rancho, New Mexico 

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

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

oxide dimer Acid (HFPO-DA) and Perfluorobutanesulfonic Acid (PFBS) 

ARNG Installations, Nationwide

February 2023

Prepared for:

Army National Guard Headquarters 

111 S. George Mason Drive 

Arlington, VA 22204 

Contract No. W912DR-19-D-0005 

UNCLASSIFIED
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TABLE OF CONTENTS

Page

LIST OF APPENDICES ................................................................................................................ iii

LIST OF FIGURES ....................................................................................................................... iv

LIST OF TABLES .......................................................................................................................... v

LIST OF ACRONYMS AND ABBREVIATIONS ...................................................................... vi

EXECUTIVE SUMMARY ...................................................................................................... ES-1

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

1.1 PROJECT AUTHORIZATION ............................................................... 1-1

1.2 SITE INSPECTION PURPOSE .............................................................. 1-1

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

2.1 FACILITY LOCATION AND DESCRIPTION ..................................... 2-1

2.2 FACILITY ENVIRONMENTAL SETTING .......................................... 2-1

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

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

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

2.2.4 Climate ...................................................................................... 2-3

2.2.5 Current and Future Land Use .................................................... 2-3

2.2.6 Sensitive Habitat and Threatened/Endangered Species ............ 2-3

2.3 HISTORY OF PFAS USE ....................................................................... 2-4

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

3.1 AOI 1 – HAZARDOUS MATERIALS STORAGE LOCKERS 2 AND 

3/WASH RACKS/EVAPORATION LAGOON ..................................... 3-1

3.1.1 Hazardous Materials Storage Lockers 2 and 3 ......................... 3-1

3.1.2 Wash Racks and Evaporation Lagoon ...................................... 3-1

3.1.3 Tri-MaxTM 30 .......................................................................... 3-2

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

4.1 PROBLEM STATEMENT ...................................................................... 4-1

4.2 INFORMATION INPUTS ...................................................................... 4-1

4.3 STUDY BOUNDARIES ......................................................................... 4-1

4.4 ANALYTICAL APPROACH ................................................................. 4-1

4.5 DATA USABILITY ASSESSMENT ...................................................... 4-2

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

5.1 PRE-INVESTIGATION ACTIVITIES ................................................... 5-2
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5.1.1 Technical Project Planning ....................................................... 5-2

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

5.1.3 Source Water and PFAS Sampling Equipment Acceptability.. 5-2

5.2 HAND AUGER SOIL SAMPLING........................................................ 5-3

5.3 SOIL BORINGS AND SOIL SAMPLING............................................. 5-3

5.4 MONITORING WELL INSTALLATION AND GROUNDWATER 

GRAB SAMPLING................................................................................. 5-4

5.5 SYNOPTIC WATER LEVEL MEASUREMENTS ............................... 5-4

5.6 SURVEYING .......................................................................................... 5-4

5.7 INVESTIGATION-DERIVED WASTE................................................. 5-4

5.8 LABORATORY ANALYTICAL METHODS ....................................... 5-5

5.9 DEVIATIONS FROM UFP-QAPP ADDENDUM................................. 5-5

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

6.1 SCREENING LEVELS ........................................................................... 6-1

6.2 SOIL PHYSICOCHEMICAL ANALYSES............................................ 6-2

6.3 AOI 1 – HAZARDOUS WASTE STORAGE SHEDS 2 AND 3/WASH 

RACKS/CONCRETE LAGOON ............................................................ 6-2

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

6.3.2 AOI 1 – Groundwater Analytical Results................................. 6-3

6.3.3 AOI 1 – Conclusions................................................................. 6-3

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

7.1 SOIL EXPOSURE PATHWAY.............................................................. 7-1

7.1.1 AOI 1 – Hazardous Waste Storage Sheds 1 and 2/Wash 

Racks/Evaporation Lagoon....................................................... 7-1

7.2 GROUNDWATER EXPOSURE PATHWAY........................................ 7-2

7.3 SURFACE WATER/ SEDIMENT EXPOSURE PATHWAY ............... 7-2

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

8.1 SITE INSPECTION ACTIVITIES SUMMARY .................................... 8-1

8.2 OUTCOME.............................................................................................. 8-1

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

Appendix A. Data Usability Assessment and Data Validation Reports

Appendix B. Field Documentation

B1. Logs of Daily Notice of Field Activities

B2. Sampling Forms 

B3. Survey Data

B4. Field Change Request Form

Appendix C. Photographic Log

Appendix D. Technical Project Planning Meeting Minutes

Appendix E. Boring Logs

Appendix F. Analytical Results

Appendix G. Laboratory Reports
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LIST OF FIGURES

Figure 2-1. Facility Location

Figure 2-2. Topography

Figure 2-3. Groundwater Features

Figure 2-4. Surface Water Features

Figure 3-1. Area of Interest

Figure 5-1. Site Inspection Sample Locations

Figure 6-1. AOI 1 PFOS Detections in Soil

Figure 6-2. AOI 1 PFOA Detections in Soil

Figure 6-3. AOI 1 PFBS Detections in Soil

Figure 6-4. AOI 1 PFHxS Detections in Soil

Figure 6-5. AOI 1 PFNA Detections in Soil

Figure 7-1. Conceptual Site Model, AOI 1 Rio Rancho Training Site
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LIST OF TABLES

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

Table ES-2. Summary of Site Inspection Findings and Recommendations

Table 5-1. Samples by Medium, Rio Rancho Training Site, New Mexico, Site Inspection 

Report

Table 5-2. Soil Boring Depths and Temporary Well Screen Intervals, Rio Rancho Training 

Site, New Mexico, Site Inspection Report

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

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

Inspection Report, Rio Rancho Training Site

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

Site Inspection Report, Rio Rancho Training Site

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

Inspection Report, Rio Rancho Training Site

Table 8-1. Summary of Site Inspection Findings and Recommendations
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vi

LIST OF ACRONYMS AND ABBREVIATIONS

°C Degrees Celsius

°F Degrees Fahrenheit

μg/kg Microgram(s) per kilogram

% Percent

AECOM AECOM Technical Services, Inc. 

AFFF Aqueous film-forming foam

AOI Area of Interest

ARNG Army National Guard

bgs Below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

City City of Rio Rancho

CSM Conceptual site model

CST Civil Support Team

DoD Department of Defense

DPT Direct-push technology

DQO Data Quality Objectives

DUA Data Usability Assessment

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

EDR Environmental Data ReportTM

ELAP Environmental Laboratory Accreditation Program

EM Engineer Manual

EB Equipment blank 

FB Field blank

FD Field duplicate

FedEx Federal Express

FMS Facility Maintenance Shop

ft Foot (feet)

gal Gallon(s)

GPS Global positioning system

HDPE High-density polyethylene

HFPO-DA Hexafluoropropylene oxide dimer acid

IDW Investigation-derived waste

in. Inch(es)

ITRC Interstate Technology Regulatory Council
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vii

LIST OF ACRONYMS AND ABBREVIATIONS (continued)

LC/MS/MS Liquid chromatography with tandem mass spectrometry

MS Matrix spike

MSD Matrix spike duplicate

NEtFOSAA N-ethyl perfluorooctane sulfonamidoacetic acid 

ng/L Nanogram(s) per liter

NMARNG New Mexico Army National Guard

NMeFOSAA N-methyl perfluorooctane sulfonamidoacetic acid

No. Number

OSD Office of the Secretary of Defense

PA Preliminary Assessment

PFAS Per- and polyfluoroalkyl substances

PFBS Perfluorobutanesulfonic acid

PFHxS Perfluorohexanesulfonic acid

PFNA Perfluorononanoic acid 

PFOA Perfluorooctanoic acid

PFOS Perfluorooctanesulfonic acid

PID Photoionization detector

POD Point of diversion

QAPP Quality Assurance Project Plan

QSM Quality Systems Manual

RI Remedial investigation 

SI Site Inspection

SL Screening level

TOC Total organic carbon

TPP Technical Project Planning

TS Training Site

UFP Uniform Federal Policy 

USACE U.S. Army Corps of Engineers

USEPA U.S. Environmental Protection Agency
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EA Engineering, Science, and Technology, Inc., PBC ES-1

EXECUTIVE SUMMARY

The Army National Guard (ARNG) G9 is performing Preliminary Assessments (PAs) and Site 

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

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

memorandum from the Office of the Secretary of Defense (OSD) (Assistant Secretary of 

Defense) dated 6 July 2022. The six compounds listed in the OSD memorandum include 

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

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

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA). These compounds are 

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

screening levels (SL) are provided below in Table ES-1.

The PA identified one Area of Interest (AOI) where PFAS-containing materials may have been

used, stored, disposed, or released historically (see Table ES-2). The objective of the SI is to 

identify whether there has been a release to the environment from the identified in the PA and 

determine whether further investigation is warranted, a removal action is required to address

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

the relevant compounds. This SI was completed at the Rio Rancho Training Site (TS) in Rio 

Rancho, New Mexico, and determined further investigation is not warranted for Rio Ranch TS. 

Rio Rancho TS will be referred to as the “Facility” throughout this document. 

The Facility, operated by the New Mexico ARNG (NMARNG), encompasses approximately 

120 acres in the north-central portion of the Albuquerque Metropolitan Statistical Area of New 

Mexico in Sandoval County. The land was acquired by the State Armory Board in 1987 through 

a special warranty deed with the NMARNG. The Readiness Center and FMS-3 buildings were 

constructed and opened in 1994. Rio Rancho TS is located in the Albuquerque Basin, within the 

Santa Fe Group aquifer system. 

The PA identified one AOI for investigation during the SI phase. SI sampling results from the 

AOI were compared to OSD SLs. Table ES-2 summarizes the SI results for the AOI. Based on 

the results of this SI, no further evaluation under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) is warranted for the identified AOI. 
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ES-2 

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

Analyte1,2 

Residential

(Soil)

(μg/kg)

 1,2

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg)

 1,2

Tap Water

(Groundwater) 

(ng/L) 1,2

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

1. Office of the Assistant Secretary of Defense. July 2022. Risk Based Screening Levels

Calculated for Groundwater and Soil using U.S. Environmental Protection Agency’s

Regional Screening Level Calculator. Hazard Quotient =0.1. May 2022.

2. Screening values for HFPO-DA were established after SI planning and execution and thus

not included as an analyte. Future CERCLA phases will include HFPO-DA

if warranted.

μg/kg = Microgram(s) per kilogram

ng/L = Nanogram(s) per liter

Table ES-2. Summary of Site Inspection Findings and Recommendations

AOI

Potential 

Release Area

Soil 

Source Area

Groundwater

Source Area

Groundwater 

Facility Boundary Future Action

1 

Hazardous Materials

Storage Lockers/Wash 

Racks/Evaporation 

Lagoon

Not Applicable Not Applicable No Further Action

Legend:

 = Detected; exceedance of SLs

 = Detected; no exceedance of SLs

 = Not detected
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1. INTRODUCTION

1.1 PROJECT AUTHORIZATION

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

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

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

compounds presented in the memorandum from the Office of the Secretary of Defense (OSD) 

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

memorandum will be referred to as “relevant compounds” throughout this document and include 

perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), perfluorobutanesulfonic 

acid (PFBS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic acid (PFHxS), and 

hexafluoropropylene oxide-dimer acid (HFPO-DA)1 at ARNG facilities nationwide. The ARNG 

performed this SI at the Rio Rancho Training Site (TS) in Rio Rancho, New Mexico. The Rio 

Rancho TS will be referred to as the “Facility” throughout this report. 

The SI project elements were performed in accordance with the Comprehensive

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

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

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

compliance with Army requirements and guidance for field investigations.

1.2 SITE INSPECTION PURPOSE

A PA was performed at the Rio Rancho TS (AECOM Technical Services, Inc. [AECOM] 2020) 

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

and/or disposed, or areas where known or suspected releases to the environment occurred. The 

objective of the SI is to identify whether there has been a release to the environment from the 

AOI identified in the PA and determine whether further investigation is warranted, a removal 

action is required to address immediate threats, or no further action is required based on

screening levels (SLs) for the relevant compounds.

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

GenX) was not included as an analyte at the time of this SI, as screening values were established after SI planning 

and execution. However, ARNG will add HFPO-DA to the list of constituents sampled during the next phase of 

CERCLA if warranted.
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2. FACILITY BACKGROUND

2.1 FACILITY LOCATION AND DESCRIPTION

The New Mexico Army National Guard NMARNG) Rio Rancho TS facility encompasses 

approximately 120 acres of land located in the north-central portion of Albuquerque, 

approximately 25 miles north of downtown Albuquerque, in Sandoval County, which is near the 

center of New Mexico. The land was acquired in 1987 by the State Armory Board through a 

special warranty deed with the NMARNG and was used as a training site and Hawk Battalion 

between 1987 and 1995. Additional structures (the Readiness Center and FMS-3 buildings) were 

constructed and opened in 1994, as the HAWK Missile System was phased out (Figure 2-1). 

The facility contains the Facility Maintenance Shop (FMS)-3, a readiness center, the 64th Civil 

Support Team (CST), and areas used for tactical training (AECOM 2020).

2.2 FACILITY ENVIRONMENTAL SETTING

The Rio Rancho TS is approximately 5,300 feet (ft) above mean sea level (amsl) (Figure 2-2). 

The Facility consists of three buildings, a readiness center, the FMS-3 building, the CST, a 

training area, and a ROPES obstacle course (AECOM 2020). The ground surface within the 

facility is covered by buildings, asphalt, or concrete in some areas, while other areas are gravelcovered dirt lots or unpaved desert.

2.2.1 Geology

The facility lies in the Albuquerque Basin, one of the largest and deepest basins in the Rio 

Grande rift. The fill material in the Albuquerque Basin is mostly Cenozoic fill deposits of the 

Santa Fe Group. The Santa Fe Group was deposited during the middle Miocene to early 

Pleistocene epochs. During that time, the Albuquerque Basin received alluvial sediment from the 

adjacent highlands and fluvial sediments from Northern New Mexico and southern Colorado. 

For the Albuquerque area, alluvial deposits came from the Sandia Mountains providing 

weathered granitic and limestone material. The fluvial deposits from the north consisted of 

volcanic rock fragments. Volcanic material was also deposited by wind and basalt flows from 

nearby volcanoes, just to the west of Albuquerque, in late the Pleistocene and Holocene epochs. 

These processes resulted in thousands of feet of sediment that lay under Albuquerque, providing 

a porous space for water to accumulate (AECOM 2020).

Observations from drilling at the Facility are consistent with regional geology. Soils were observed 

to be dominated by poorly graded sand and silty sand. Samples for grain size analyses were 

collected at two locations, AOI101-01 and AOI01-02, and analyzed via American Society for 

Testing and Materials (ASTM) Method D-422. The results indicate that the soil samples are 

comprised primarily of sand (30.5% to 50.3%) and silt (57.3% to 41.3%). These results and facility 

observations are consistent with the reported depositional environment of the region. Soil pH was 

analyzed at one location, AOI01-02, and had a pH of 9.2. 
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2.2.2 Hydrogeology

The Rio Rancho TS resides within the Santa Fe Group aquifer system of the Albuquerque Basin.

The groundwater has been deposited in three main phases. The lower Santa Fe group was created

by dune fields and small streams draining into playa lakes and mud flats. The sediments in this

group yield low volumes of poor-quality water. Deposits in the upper Santa Fe group come from

drainage of the ancestral Rio Grande and its tributaries. Most of the potable water in the region 

comes from these later deposits, which lie within 1.2 miles of the eastern boundary of the basin. 

Finally, the modern Rio Grande cuts down into the Santa Fe group sediments to create the

present river valley. Groundwater depth in the area is approximately 1,000 ft below ground

surface (bgs). Groundwater flow direction is generally to the southeast (AECOM 2020). An 

Environmental Data Resources (EDR)TM report, along with other resources, was used to conduct 

a well search for a 1-mile radius surrounding the facility. Using additional online resources, such 

as state and local geographic information system databases, wells were researched to a 4-mile 

radius of the facility. Wells are displayed on Figure 2-3. No groundwater wells have been 

installed at the Rio Rancho TS. 

The City of Rio Rancho (City) water supply consists entirely of groundwater withdrawn from the 

Santa Fe Group aquifer and has 17 wells currently in operation and diverts about 13,000 acre-ft 

per year. Three of these municipal wells are located within 1-mile west and upgradient of the 

facility. The city wells are considered points of diversion (PODs) by the New Mexico Office of 

the State Engineer (NMOSE), and have been designated as POD 38, POD 39, and POD 40. They 

are drilled into the Rio Grande POD Basin, and Middle Rio Grande POD Subbasin; no 

information about their total depths was available in the EDRTM report or the online well 

database maintained by the NMOSE (NMOSE 2021). The remaining city wells used for 

municipal water are located several miles south of the facility. Because the City pulls the water 

from deep wells, the supply is not as susceptible to climate change, drought, or human-caused 

degradation as a surface water supply. The City of Rio Rancho has been working to expand its 

water resources since 2001. The Aquifer Injection Project, the first of its kind in New Mexico, 

allows the city to inject purified water back into the aquifer and store it for future use. This water 

recharges the aquifer to maintain it as a drinking water source now and for future generations.

The City has an emergency water shortage ordinance for times of drought or limited supply and 

can presently store up to 41 million gallons of water. The City has a 26,039 acre-ft per year water 

rights diversion permit. As part of the pumping permit, the City is required to purchase 728 acreft of water per 5-year period. To date, the City has purchased more water rights than required for 

the current timeframe (AECOM 2020).

2.2.3 Hydrology

The Rio Grande is the largest water body in the region and is approximately 8 miles east of the 

Facility. The inner valley of the Rio Grande contains a complex network of irrigation canals,

ditches, and drains. In general, the Rio Grande flows from north to south through Sandoval

County. The cities of Bernalillo, Rio Rancho, Albuquerque, Los Lunas, and Belen discharge

treated effluent directly into the river. Surface water features at and near the Facility are shown 

in Figure 2-4 (AECOM 2020).
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At Rio Rancho TS, a drainage channels runoff from nearby paved surfaces to a stormwater 

retention pond. Additionally, there is an evaporation lagoon which receives discharge from the 

facility wash racks.

2.2.4 Climate

The climate in north-central New Mexico is categorized as semi-arid, receiving about 12 inches

(in.) of precipitation per year. The highest rainfall (about 2 in. per month) usually occurs in 

August. Most of the moisture that Rio Rancho receives comes from the Gulf of Mexico during 

the North American Monsoon season. July is the hottest month averaging 78.1 degrees 

Fahrenheit (°F), while January is the coldest month, averaging 34.3°F. There is a diurnal 

temperature difference greater than 25°F for every month of the year. The immediate 

Albuquerque metro area receives an average of 9.6 in. of snowfall per winter, which can increase 

considerably in surrounding higher elevations (AECOM 2020).

2.2.5 Current and Future Land Use

Presently, the Rio Rancho TS is a NMARNG facility consisting of three buildings: a readiness

center, the FMS-3 building, and CST, as well as a training area and a ROPES obstacle course. A 

fence surrounds the facility. The area is zoned as rural residential/agricultural (Sandoval County 

2021). Future land use is not anticipated to change (AECOM 2020). Additionally, there are not 

any proposed significant changes to the mission of the Rio Rancho TS in the foreseeable future 

(EA Engineering, Science, and Technology, Inc., PBC [EA] 2021a).

2.2.6 Sensitive Habitat and Threatened/Endangered Species

A wildlife survey has not occurred at the facility, and the facility does not have any significant 

areas of habitat. The following species have not been identified at the facility but may be present 

in the surrounding area.

The following species are listed as federally endangered, threatened, proposed, and/or candidate 

species in Sandoval County, New Mexico (U.S. Fish and Wildlife Service 2022):

• Birds: Mexican Spotted Owl (Strix occidentalis lucida) – Federally Threatened; 

Southwestern Willow Flycatcher (Empidonax traillii extimus) – Federally Endangered; 

Yellow-billed Cuckoo (Coccyzus Americanus) – Federally Threatened

• Amphibians: Jemez Mountains Salamander (Plethodon neomexicanus) – Federally 

Endangered

• Fishes: Rio Grande Cutthroat Trout (Oncorhynchus clarkia virginalis) – Federal 

Candidate; Rio Grande Silvery Minnow (Hybognathus amarus) – Federally Endangered

• Insects: Monarch Butterfly (Danaus plexippus) – Federal Candidate 
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• Mammal: New Mexico Meadow Jumping Mouse (Zapus hudsonius luteus) – Federally 

Endangered.

2.3 HISTORY OF PFAS USE

Interviews and records obtained during the PA/SI indicate that aqueous film-forming foam 

(AFFF) has been stored at the Facility within the Hazardous Materials Storage Lockers

(AECOM 2020). Additionally, a Tri-MaxTM 30 extinguisher was stored at the FMS-3 building in 

an office (Room 110) that functioned as a storage space, but interviews indicate the extinguisher 

was never used or serviced and it was taken off-facility for decommissioning and disposal in 

Summer 2020 (EA 2021a). Prior PFAS sampling results indicate there has been a release of 

PFAS at the Rio Rancho TS. A description of the AOI and its potential release areas are

presented in Section 3.
Rio Rancho

Training Site

^_

NM

Facility Data

Facility Boundary

3

0 2

Miles

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-1

Facility Location

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Rio Rancho

Training Site

^_

NM

Facility Data

Facility Boundary

3

0 2

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-2

Topography

Army National Guard Site Inspections

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Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N
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Data Sources:

ESRI 2020

AECOM 2020

Figure 2-3

Groundwater Features

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Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N
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Jemez River

Arroyo Venada

Arroyo de las

Lomitas Negras

Arroyo Baranca

Arroyo de los

MontoyasWatershed

Town of Santa

Ana Pueblo-Jemez

RiverWatershed

Arroyo de la

Baranca-Rio

GrandeWatershed

Jemez Canyon

Dam-Jemez

RiverWatershed

Arroyo Venada-Rio

GrandeWatershed

^_

NM

Facility Data

Facility Boundary

Hydrology

Surface Water Flow Direction

Perennial Creek/Stream

Intermittent Creek/Stream

Waterbody

Wetlands

Watershed Boundary

3

0 1

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-4

Surface Water Features

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Drainage

Evaporation

Lagoon

Stormwater

Retention

Pond

Drainage

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N
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3. SUMMARY OF AREAS OF INTEREST

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

or released historically. Based on the PA findings, three potential release areas were identified at 

the Rio Rancho TS and grouped into one AOI identified as AOI 1 Hazardous Materials Storage 

Lockers 2 and 3/Wash Racks/Evaporation Lagoon. The potential AOIs are shown on Figure 3-1.

3.1 AOI 1 – HAZARDOUS MATERIALS STORAGE LOCKERS 2 AND 3/WASH 

RACKS/EVAPORATION LAGOON

The AOI encompasses the hazardous materials lockers, adjacent wash racks, and evaporation

lagoon (Figure 3-1). These features are located in the southern portion of the Facility and are 

described below.

3.1.1 Hazardous Materials Storage Lockers 2 and 3

The hazardous materials storage lockers, located in the southern portion of the facility, housed

two 10-gallon (gal) containers of an unknown type of AFFF for an unknown period of time. The

lockers are located in the segment of the facility designated as FMS-3. According to personnel 

interviews, two 10-gal containers of AFFF were found in Hazardous Waste Storage Locker 2 

sometime in early 2019. The containers were found half-empty with evidence of a small amount 

of product around the cap. No leaks or spills of AFFF have been reported. The containers were 

described as small high-density polyethylene (HDPE) “poly” 10-gal closed head drums by 

interviewed personnel and were noted to be stored in a hazardous materials storage locker that 

was in good condition, with no evidence of corrosion or damage that would compromise the 

integrity of the locker. After these containers were discovered, they were moved to an adjacent 

hazardous materials storage locker (Hazardous Waste Storage Locker 3) designated for transport 

through the Defense Logistics Agency as non- Resource Conservation and Recovery Act nonhazardous waste. This secondary storage locker was also in good condition, with no evidence of 

corrosion or damage that would compromise the integrity of the locker. The containers of AFFF 

were dispatched via a third-party carrier (Envirokleen – USEPA ID No. TXR000084068), with 

the waste code N/H Out54091, on 8 April 2019. Both containers were classified as fiberboard or 

plastic drums, barrels, or kegs in the Uniform Hazardous Waste Manifest. The weight of the 

product listed on the Uniform Hazardous Waste Manifest is 60 pounds.

3.1.2 Wash Racks and Evaporation Lagoon

Wash racks are located adjacent to, and to the north of, the hazardous waste storage sheds. The 

wash racks discharge to an oil/water separator and eventually to a concrete evaporation lagoon. 

As noted in Section 2.4, a water sample was collected from the lagoon in March 2021 and was 

analyzed for PFAS in accordance with the discharge permit issued by the State of New Mexico. 

Several PFAS chemicals were detected and PFOA was detected at a concentration of 41.2 ng/L. 

As a result, the wash racks and lagoon were added as potential PFAS release areas during the SI 

scoping process and are considered potential PFAS release areas (EA 2021a).
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3.1.3 Tri-MaxTM 30

A Tri-MaxTM 30 extinguisher was stored at the FMS-3 building in an office (Room 110) that 

functioned as storage space. There was no evidence of PFAS-containing substances ever having 

been used within the building. The FMS-3 building is not included as an AOI due to a lack of a 

complete exposure pathway. According to staff interviews, the Tri-MaxTM was not used or 

serviced, and evidence of a leak was not observed. The unit was found with a full tank. As 

determined during reconnaissance, the storage location does not have floor drains, eliminating

the potential transport of AFFF from the storage area to the environment. In Summer 2020, the 

Tri-MaxTM unit was taken off-facility for decommissioning and proper disposal (EA 2021a). 

3.2 ADJACENT SOURCES

No potential Facility-adjacent sources were identified.
AOI 1

Haz Mat

Storage Lockers

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

Wash Rack

^_

NM

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

3

0 200

Feet

Data Sources:

ESRI 2020

AECOM 2020

Figure 3-1

Area of Interest

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Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N
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4. PROJECT DATA QUALITY OBJECTIVES

As identified during the data quality objective (DQO) process and outlined in the SI Uniform 

Federal Policy- (UFP) Quality Assurance Project Plan (QAPP) Addendum (EA 2021a), the 

objective of the SI is to identify whether there has been a release to the environment at the AOIs 

identified in the PA. For each AOI, ARNG determines if further investigation is warranted, a 

removal action is required to address immediate threats, or whether no further action is 

warranted. This SI evaluated soil for presence or absence of relevant compounds at each of the 

sampled AOIs.

4.1 PROBLEM STATEMENT

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

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

SLs. The SLs are presented in Section 6.1 of this report. 

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for the Rio Rancho TS

• Analytical data collected during other environmental sampling efforts at each ARNG 

installation

• Analytical data from soil samples collected as part of this SI in accordance with the 

Facility specific UFP-QAPP Addendum (EA 2021a).

4.3 STUDY BOUNDARIES

The scope of the SI was bounded horizontally by the property limits of the Facility (Figure 2-2). 

Off-facility sampling was not included in the scope of this SI. The scope of the SI was vertically 

bounded as follows: soil from direct-push technology (DPT) borings installed to 15 ft bgs. 

Temporal boundaries were limited to the earliest available time field resources were available to 

complete the study.

4.4 ANALYTICAL APPROACH

Samples were analyzed in accordance with the Department of Defense (DoD) Quality Systems 

Manual (QSM) Version 5.3 by Eurofins Lancaster Laboratories Env, LLC, accredited under the 

DoD Environmental Laboratory Accreditation Program (DoD Environmental Laboratory 

Accreditation Program (ELAP), Accreditation No. 1.01. PFAS data underwent 100 percent (%)

Stage 2B validation in accordance with the DoD General Data Validation Guidelines (2019) and 

DoD Data Validation Guidelines Module 3: Data Validation Procedure of Per- and 

Polyfluoroalkyl Substances Analysis by QSM Table B-15 (2020).
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Data were compared to applicable SLs and decision rules as defined in the UFP-QAPP 

Addendum (EA 2021a). 

4.5 DATA USABILITY ASSESSMENT

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

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

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

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

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

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

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

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

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

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

requirements of the UFP-QAPP (EA 2021a).
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5. SITE INSPECTION ACTIVITIES 

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

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

and the sampling was implemented in accordance with the following approved documents. 

• Final Preliminary Assessment Report, Rio Rancho, Rio Rancho, New Mexico, dated 

August 2020 (AECOM 2020)

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

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

Nationwide, dated December 2020 (EA 2020a)

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

Addendum, Rio Rancho Training Site, Rio Rancho, New Mexico, dated November 2021 

(EA 2021a)

• Final Programmatic Accident Prevention Plan, Revision 1, dated November 2020 (EA 

2020b)

• Accident Prevention Plan / Site Safety and Health Plan Addendum, Revision 0, Rio 

Rancho Training Site, New Mexico, dated August 2021 (EA 2021b). 

The SI field activities were conducted from 20 to 21 December 2021 and consisted of hand auger 

surface soil sample collection and DPT boring and subsurface soil sample collection. Field 

activities were conducted in accordance with the UFP-QAPP Addendum (EA 2021a), except as 

noted in Section 5.9.

The following samples were collected during the SI and analyzed for a subset of 24 compounds 

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

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

• Six (6) surface soil samples from five locations including a duplicate sample (hand auger

boring locations)

• Twenty-one (21) soil samples from six locations including three duplicate samples (DPT 

boring locations).

• One (1) field blank sample (FB).

• Two (2) equipment rinsate samples. 

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

list of samples collected. Field documentation is provided in Appendix B. A log of Daily Notice 

of Field Activity was completed throughout the SI field activities, which is provided in 

Appendix B1. Field notes are provided in Appendix B2. Survey data is presented in Appendix 
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B3. Field change request forms are provided in Appendix B4. Additionally, a photographic log 

of field activities is provided in Appendix C. 

5.1 PRE-INVESTIGATION ACTIVITIES

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

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

water. Details of these activities are presented below. 

5.1.1 Technical Project Planning

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

(Department of the Army 2016) defines four phases to project planning: (1) defining the project 

phase; (2) determining data needs; (3) developing data collection strategies; and (4) finalizing the 

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

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

address the AOIs identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 10 August 2021, prior to SI field activities. 

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

conducted in general accordance with EM 200-1-2. 

The stakeholders for this SI include ARNG, USACE, and the New Mexico Environment 

Department, representatives familiar with the facility, the regulations, and the community. 

Stakeholders were provided the opportunity to make comments on the technical sampling 

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

TPP Meeting 1 and 2 was memorialized in the UFP-QAPP Addendum (EA 2021a). Future 

TPP meetings will provide an opportunity to discuss results and findings, and future actions, 

where warranted. 

5.1.2 Utility Clearance

EA contracted MT Private Utility Locating Services, LLC, a private utility location service, to 

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

boring locations on 13 December 2021 with input from the EA field team, New Mexico 

Environment Department, and ARNG. General locating services and ground-penetrating radar 

were used to complete the clearance. Additionally, the first 5 ft of each boring were pre-cleared 

by EA’s drilling subcontractor, JR Drilling, using a hand auger to verify utility clearance in 

shallow subsurface where utilities would typically be encountered. 

5.1.3 Source Water and PFAS Sampling Equipment Acceptability

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

PFAS-free prior to the start of field activities. A sample from the yard hydrant located adjacent 

to the middle wash rack at the Rio Rancho TS was collected on 22 October 2021, prior to 

mobilization, and analyzed for PFAS by LC/MS/MS compliant with QSM Version 5.3

Table B-15. The yard hydrant is connected to the City of Rio Rancho public water supply.
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Materials that were used within the sampling zone were confirmed as acceptable for use in the

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

environment was provided in the Standard Operating Procedures provided as Appendix B to the

Programmatic UFP-QAPP (EA 2020a). 

5.2 HAND AUGER SOIL SAMPLING

Six soil samples were collected from five locations near the wash racks for chemical analysis 

from 0 to 2 ft bgs using a hand auger. Asphalt and/or concrete were cut to allow hand auger 

access. All soil sample locations are shown on Figure 5-1. The hand auger location was selected 

based on the AOI information provided in the PA (AECOM 2020) and as agreed upon by 

stakeholders during the TPP and review of the UFP-QAPP Addendum (EA 2021a). Nondedicated sampling equipment (i.e., hand auger) was decontaminated between sampling 

locations. 

Each sample was collected into a laboratory-supplied PFAS-free HDPE bottle and labeled using 

a PFAS-free marker or pen. Samples were packaged on ice and transported via Federal Express 

(FedEx) under standard chain-of-custody procedures to the laboratory and analyzed for PFAS 

(LC/MS/MS compliant with QSM Version 5.3 Table B-15) in accordance with the UFP-QAPP 

Addendum. Quality control samples and analysis were performed as described in the UFP-QAPP 

Addendum (EA 2021a).

5.3 SOIL BORINGS AND SOIL SAMPLING

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

Procedure 047 Direct-Push Technology Sampling (EA 2021a). A Geoprobe® 7822D dual-tube 

sampling system was used to collect continuous soil cores to the target depth. A hand auger was 

used to collect soil from the top 5 ft of the boring in compliance with utility clearance 

procedures.

Three discrete soil samples were collected for chemical analysis from six soil borings: one 

sample at the surface (0 to 2 ft bgs) and two subsurface soil samples. One shallow subsurface soil 

sample was collected at 6–8 ft bgs, and one deep subsurface sample was collected at 13–15 ft.

Additionally, three field duplicates were collected. Borings were drilled to a total depth of 15 ft 

bgs. Groundwater is present at an estimated depth of 1,000 ft bgs, and as a result was not 

encountered during drilling.

All soil sample locations are shown on Figure 5-1, and boring sample depths are provided in 

Table 5-2. The soil boring locations were selected based on the AOI information provided in the 

PA (AECOM 2020) and as agreed upon by stakeholders during the TPP and review of the 

UFP-QAPP Addendum (EA 2021a). 

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

by a field geologist using the Unified Soil Classification System. A photoionization detector 

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

requirements. Observations and measurements were recorded on sampling forms and in a 

non-treated field logbook. Depth interval, recovery thickness, PID concentrations, moisture, 
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relative density, Munsell color, and Unified Soil Classification System texture were recorded. 

Boring logs are provided in Appendix E. 

Each sample was collected into a laboratory-supplied PFAS-free HDPE bottle and labeled using 

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

standard chain-of-custody procedures to the laboratory and analyzed for PFAS (LC/MS/MS 

compliant with QSM Version 5.3 Table B-15), total organic carbon (TOC) (USEPA Method 

9060A) and pH (USEPA Method 9045D) in accordance with the UFP-QAPP Addendum (EA 

2021a). 

Field duplicate (FD) samples were collected at a rate of 10% and analyzed for the same 

parameters as the accompanying samples. Matrix spike (MS)/matrix spike duplicates (MSDs)

were collected at a rate of 5% and analyzed for the same parameters as the accompanying 

samples. In instances when non-dedicated sampling equipment was used, such as a hand auger 

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

the same parameters as the soil samples. A temperature blank was placed in each cooler to 

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

removal of the drilling equipment, boreholes were abandoned using bentonite chips. In borings 

installed on paved surfaces, the borings were abandoned by backfilling with bentonite chips to 

approximately 6 in. bgs and by filling the remainder of the borehole with concrete or asphalt to

match the surrounding area.

5.4 MONITORING WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Existing wells were not present at Rio Rancho TS. Given the depth to groundwater (greater than 

1,000 ft bgs) wells were not installed at the Rio Rancho TS in accordance with the UFP-QAPP 

(EA 2021a). No groundwater grab samples were collected.

5.5 SYNOPTIC WATER LEVEL MEASUREMENTS

Temporary wells were not installed, and no existing wells were present at the Facility. As a 

result, water level measurements were not taken.

5.6 SURVEYING

Soil boring locations were recorded with a Trimble Geo 7x global positioning system (GPS) unit. 

Positions were collected in the applicable Universal Transverse Mercator zone projection with 

World Geodetic System 1984 datum (horizontal) and North American Vertical Datum 1988 

(vertical). Surveying data were collected on 25 March 2022 and are provided in Appendix B3. 

5.7 INVESTIGATION-DERIVED WASTE

As of the date of this report, the disposal of PFAS investigation-derived waste (IDW) is not 

regulated federally. PFAS IDW generated during the SI is considered non-hazardous waste and 

was managed in accordance with the UFP-QAPP Addendum (EA 2021a). 
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Soil IDW (i.e., soil cuttings) generated during the SI activities were contained in labeled, 55-

gallon Department of Transportation (DOT)-approved steel drums and left at the Facility in the 

designated hazardous waste storage lockers. The soil IDW was not sampled and assumes the 

characteristics of the associated soil samples collected from that source location. 

Liquid IDW generated during SI activities (i.e., decontamination fluids) were contained in 

labeled, 55-gallon DOT-approved steel drums, and left at the Facility in the designated 

hazardous waste storage lockers. The liquid IDW was not sampled.

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

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

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

5.8 LABORATORY ANALYTICAL METHODS

Soil samples were also analyzed for TOC using USEPA Method 9060A and pH by USEPA 

Method 9045D.

5.9 DEVIATIONS FROM UFP-QAPP ADDENDUM

The following deviations from the UFP-QAPP Addendum occurred based on conditions

encountered during the field investigation activities. These deviations were discussed between 

EA, ARNG, USACE, and the New Mexico Environment Department and are documented in a

Field Change Request Form (Appendix B4). Deviations from the UFP-QAPP Addendum (EA 

2021a) are noted below: 

• Soil boring AOI1-06 was moved approximately 70 ft to the northeast so that it would be 

in closer proximity to the evaporation lagoon and the drain line discharge for the wash

racks/oil water separator.

• Soil boring AOI1-02 was moved approximately 30 ft to the southeast so that it would be 

in closer proximity to the evaporation lagoon.

Additional deviations from the UFP-QAPP not included in the Field Change Request Form 

(Appendix B.3) are described below:

• The UFP-QAPP Addendum (EA 2021a) outlined that one pH/TOC sample, and one 

duplicate would be collected for the SI; however, the laboratory did not analyze the 

duplicate sample that was submitted. This inconsistency was noted after the sample 

holding time had passed. Because of likely biodegradation and the availability of data 

from the parent sample, the duplicate sample was not analyzed. This deviation does not 

affect the conclusions of the SI. 

• The UFP-QAPP Addendum (EA 2021a) contained an inconsistency regarding the 

collection of field blanks (FBs). Worksheet #17 specifies that one FB will be collected 

per day, but Worksheet #20 indicates that no FBs will be collected. The discrepancy was 

discovered during sampling. One FB was collected instead of two due to a shortage of 
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available sample bottles. An EB can perform the same function as an FB, though with 

less specificity regarding the source of contamination. Because analytes were not 

detected in the EB, this deviation does not affect the conclusions of the SI.

• Percent recovery was not recorded for soil borings. PID measurements were not recorded 

for 0 to 2 ft soil borings. Though the PID was brought to the Facility the area was not a 

former fire training area and there was no evidence of staining or olfactory indication of a 

release. This deviation does not affect the conclusions of the SI. 
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Table 5-1. Samples by Medium

Rio Rancho Training Site, New Mexico

Site Inspection Report

Sample 

Identification

Sample 

Collection 

Date

Sample

Depth

(ft bgs)

PFAS(USEPA Method 537 Modified)TOC(USEPA Method 9060A)pH (USEPA Method 9045D)Grain Size(ASTM D422)

Comments

Soil Samples

AOI01-01-SB-0-2 12/21/2021 0-2 X

AOI01-01-SB-0-2-Dup 12/21/2021 0-2 X FD

AOI01-01-SB-6-8 12/21/2021 6-8 X

AOI01-01-SB-13-15 12/21/2021 13-15 X

AOI01-02-SB-0-2 12/20/2021 0-2 X

AOI01-02-SB-6-8 12/20/2021 6-8 X X X X

AOI01-02-SB-6-8-Dup* 12/20/2021 6-8 X FD

AOI01-02-SB-13-15 12/20/2021 13-15 X

AOI01-03-SB-0-2 12/20/2021 0-2 X

AOI01-03-SB-6-8 12/20/2021 6-8 X

AOI01-03-SB-13-15 12/20/2021 13-15 X

AOI01-04-SB-0-2 12/20/2021 0-2 X

AOI01-04-SB-6-8 12/20/2021 6-8 X

AOI01-04-SB-13-15 12/20/2021 13-15 X

AOI01-05-SB-0-2 12/20/2021 0-2 X

AOI01-05-SB-6-8 12/20/2021 6-8 X

AOI01-05-SB-6-8-Dup 12/20/2021 6-8 X FD

AOI01-05-SB-13-15 12/20/2021 13-15 X

AOI01-06-SB-0-2 12/20/2021 0-2 X

AOI01-06-SB-6-8 12/20/2021 6-8 X

AOI01-06-SB-13-15 12/20/2021 13-15 X

AOI01-07-SB-0-2 12/21/2021 0-2 X

AOI01-08-SB-0-2 12/21/2021 0-2 X

AOI01-09-SB-0-2 12/21/2021 0-2 X

AOI01-09-SB-0-2-Dup 12/21/2021 0-2 X FD

AOI01-10-SB-0-2 12/21/2021 0-2 X

AOI01-11-SB-0-2 12/21/2021 0-2 X

Blank Samples

RANCHO-EB-01 12/20/2021 - X EB

RANCHO-EB-02 12/21/2021 - X EB

RANCHO-FB-01 12/20/2021 - X FB

Notes:

* Sample was collected but not analyzed by laboratory. See deviations from UFP-QAPP addendum listed in 

Section 5.9.
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Table 5-2. Soil Boring Depths and Temporary Well Screen Intervals

Rio Rancho Training Site, New Mexico

Site Inspection Report

Area of Interest Boring ID

Soil Boring Depth

(ft bgs)

Temporary Well 

Screen Interval

(ft bgs)

1 

AOI01-01 15.0 -

AOI01-02 15.0 -

AOI01-03 15.0 -

AOI01-04 15.0 -

AOI01-05 15.0 -

AOI01-06 15.0 -

AOI01-07 2.0 -

AOI01-08 2.0 -

AOI01-09 2.0 -

AOI01-10 2.0 -

AOI01-11 2.0 -
AOI 1

Haz Mat

Storage Lockers

Evaporation

Lagoon

Rio Rancho

FMS-3

Cellphone

Tower Oil and Water

Separator

AOI1-01

AOI1-02

AOI1-03

AOI1-04

AOI1-05

AOI1-06

AOI1-07

AOI1-08

AOI1-09

AOI1-10

AOI1-11

AOI 1

^_

NM

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Sample Locations

Soil Boring 0 to 15 Feet

Soil Boring 0 to 2 Feet

Hydrology

Surface Water Flow Direction

OWS Drainage Flow Direction

3

0 200

Feet

Data Sources:

ESRI 2020

AECOM 2020

Figure 5-1

Site Inspection Sample Locations

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Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N
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6. SITE INSPECTION RESULTS

This section presents the analytical results of the SI for each AOI. The analytical results are 

reported and evaluated in the subsequent sections. The SLs used in this evaluation are presented 

in Section 6.1. A discussion of the results for the AOI is provided in Section 6.3. Table 6-1

provides applicable SLs. Tables 6-2 through 6-5 present relevant compound results for samples 

with detections in soil; only constituents detected in one or more samples are included. Tables 

that contain all results are provided in Appendix F. Laboratory reports for source water and SI 

samples are provided in Appendix G. 

6.1 SCREENING LEVELS

The DoD has adopted a policy to retain facilities in the CERCLA process based on risk-based

SLs for soil and groundwater, as described in a memorandum from the OSD dated 6 July 2022 

(Assistant Secretary of Defense 2022). The ARNG program under which this SI was performed 

follows this DoD policy. Should the maximum concentration for sampled media exceed 

the SLs established in the OSD memorandum, the AOI will proceed to the next phase under 

CERCLA. The SLs established in the OSD memorandum apply to the five compounds presented 

on Table 6-1. 

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

Analyte1,2 

Residential 0 to 2 ft bgs

(Soil)

(μg/kg)1,2

Industrial/Commercial

Composite Worker 2 to 15 ft bgs

(Soil)

(μg/kg) 1,2

Tap Water

(Groundwater)

(ng/L) 1,2

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

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

USEPA’s Regional Screening Level Calculator. Hazard Quotient=0.1. May 2022.

2. The Assistant Secretary of Defense established screening criteria for HFPO-DA also known as GenX.

However, HFPO-DA was not included in the analysis as it was not used or stored at the Facility (AECOM

2020).

μg/kg = Microgram(s) per kilogram

ng/L = Nanogram(s) per liter

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

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

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

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

ft bgs). The industrial/commercial worker scenario is applied to shallow and deep subsurface soil 

results (2 to 15 ft bgs), which is the reasonable extent of construction that may occur at the 

Facility. No soil samples were collected from depths exceeding 15 ft bgs. 
Site Inspection Report

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6-2

6.2 SOIL PHYSICOCHEMICAL ANALYSES

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

are important for evaluating transport through the soil medium. Appendix F contains the results 

of the TOC and pH sampling. 

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

appropriate, to assess fate and transport of PFAS contaminants. According to the Interstate 

Technology Regulatory Council (ITRC), several important PFAS partitioning mechanisms 

include hydrophobic and lipophobic effects, electrostatic interactions, and interfacial behaviors. 

At relevant environmental pH values, certain PFAS are present as organic anions, and are 

therefore relatively mobile in groundwater (Xiao et al. 2015) but tend to associate with the 

organic carbon fraction that may be present in soil or sediment (Higgins and Luthy 2006; Guelfo 

and Higgins 2013). When sufficient organic carbon is present, organic carbon normalized 

distribution coefficients can help in evaluating transport potential, though other geochemical 

factors (for example, pH and presence of polyvalent cations) may also affect PFAS sorption to 

solid phases (ITRC 2018). 

6.3 AOI 1 – HAZARDOUS WASTE STORAGE SHEDS 2 AND 3/WASH 

RACKS/CONCRETE LAGOON

This section presents the analytical results for soil in comparison to SLs for AOI 1, which 

includes Hazardous Waste Storage Sheds 2 and 3, the adjacent wash racks, and the concrete 

evaporation lagoon. The detected compounds are summarized in Tables 6-2, through 6-4. 

Figures 6-1 through 6-5 present detections for PFOS, PFOA, PFBS, PFHxS, and PFNA in soil.

6.3.1 AOI 1 – Soil Analytical Results

Tables 6-2 through 6-4 summarize the detected compounds in soil. Figures 6-1 through 6-5

present the ranges of detections in soil. 

Soil was sampled in 11 boring locations associated with potential release areas at AOI 1. Soil 

was sampled from 0 to 2 ft bgs at locations in the vicinity of the wash rack drains (five

locations); and in three intervals (0–2 ft bgs, 6–8 ft bgs, and 13–15 ft bgs) at the remaining six

soil boring locations.

PFOA was detected in surface soil samples from six soil borings at concentrations up to an 

estimated 0.40 μg/kg, which was detected at AOI01-08. PFOA was also detected in shallow 

subsurface soil2 at one location, AOI01-01, at an estimated concentration of 0.26 μg/kg at a 

depth of 6–8 ft bgs. Although PFOA was detected in the vicinity of the wash racks, in the 

drainage north of the wash racks, and on the unpaved area south of the wash racks, all detected 

concentrations of PFOA were below the SLs. 

PFOS was detected in surface soil samples from five soil borings with a maximum estimated 

concentration of 8.3 μg/kg at AOI01-09. PFOS was also detected in shallow subsurface soils at 

2 Shallow subsurface soil is referred to as intermediate depth in figures.
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6-3

6-8 ft bgs and deep subsurface soils at 13-15 ft bgs at AOI01-01 with a maximum concentration 

of 1.2 μg/kg in the deep subsurface. Although PFOS was detected in the vicinity of the wash 

racks, in the drainage north of the wash racks, and north of the evaporation lagoon, all detected 

concentrations of PFOS were below the SLs.

PFHxS was detected below the SL in surface soil samples from two locations near the wash 

racks. It was detected at an estimated concentration of 0.31 μg/kg and a concentration of 0.9 

μg/kg at AOI01-07 and AOI01-08, respectively.

PFBS and PFNA were not detected in soil samples at the Facility.

6.3.2 AOI 1 – Groundwater Analytical Results 

Groundwater was not sampled during this SI.

6.3.3 AOI 1 – Conclusions

Based on the results of the SI, PFOA, PFOS, and PFHxS were detected in soil below their 

respective SLs. Based on the lack of exceedances of the SLs in soil, further evaluation at AOI 1 

is not warranted.
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Analyte1,2 Screening Level1,2 Unit Result Qual Result Qual Result Qual R

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15Perfluorobutanesulfonic acid (PFBS) 1900 μg/kg ND U ND U ND U Perfluorohexanesulfonic acid (PFHxS) 130 μg/kg ND U ND U ND U Perfluorononanoic acid (PFNA) 19 μg/kg ND U ND U ND U Perfluorooctanesulfonic acid (PFOS) 13 μg/kg 1.1 1.4 0.43 J Perfluorooctanoic acid (PFOA) 19 μg/kg 0.21 J 0.24 J ND U 

Notes:J = Estimated concentration.U = Analyte was not detected at or above the quantitation limit.μg/kg = Microgram(s) per kilogram.ft bgs = Feet below ground surface.ND = Analyte not detected above the limit of detection.Qual = Qualifier.

Depth (ft bgs) 0-2 0-2 0-2 

1. Assistant Secretary of Defense. July2022. Risk-Based Screening Levels in

Groundwater and Soil U.S. Environmental Protection Agency’s RegionalScreening Level Calculator. Hazard Quotient =0.1. May 2022.

2. The Screening Levels for soil are based on incidental ingestion of soil in a

residential scenario for direct ingestion of contaminated soil.

Sample Date 12/21/2021 12/21/2021 12/20/2021 

Parent Sample ID AOI01-01-SB-0-2

Sample Name AOI01-01-SB-0-2 AOI01-SB-01-SB-0-2-Dup AOI01-02-SB-0-2 

Location ID AOI01-01 AOI01-01 AOI01-02 

Table 6-2. PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soi

Site Inspection Report, Rio Rancho Training Site
Site Inspection Report

Rio Rancho Training Site, New Mexico 

Analyte1,2 Screening Level1,2 Unit

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15Perfluorobutanesulfonic acid (PFBS) 1900 μg/kgPerfluorohexanesulfonic acid (PFHxS) 130 μg/kgPerfluorononanoic acid (PFNA) 19 μg/kgPerfluorooctanesulfonic acid (PFOS) 13 μg/kgPerfluorooctanoic acid (PFOA) 19 μg/kgNotes:J = Estimated concentration.U = Analyte was not detected at or above the quantitation limit.μg/kg = Microgram(s) per kilogram.ft bgs = Feet below ground surface.ND = Analyte not detected above the limit of detection.Qual = Qualifier.

Depth (ft bgs)

1. Assistant Secretary of Defense. July 2022. Risk-Based Screening Levels

in Groundwater and Soil U.S. Environmental Protection Agency’s RegionalScreening Level Calculator. Hazard Quotient =0.1. May 2022.

2. The Screening Levels for soil are based on incidental ingestion of soil in a

residential scenario for direct ingestion of contaminated soil.

Sample Date

Parent Sample ID

Sample Name

Location ID

Result Qual Result Qual Result Qual Result Q

ND U ND U ND U ND ND U 0.31 J 0.9 ND ND U ND U ND U ND ND U 3.7 0.28 J 3.3 ND U 0.31 J 0.4 J 0.22 

12/21/2021 12/21/2021 12/21/2021

0-2 0-2 0-2 0-2 

12/20/2021 

AOI01-07-SB-0-2 AOI01-08-SB-0-2 AOI01-09-SB

AOI01-06-SB-0-2

AOI01-06 AOI01-07 AOI01-08 AOI01-09 

Table 6-2. PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soi

Site Inspection Report, Rio Rancho Training Site
Site Inspection Report

Rio Rancho Training Site, New Mexico 

Analyte1,2 Screening Level1,2 Unit Result Qual Result Qual Result Qual Result Q

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15Perfluorobutanesulfonic acid (PFBS) 25000 μg/kg ND U ND U ND U ND 

Perfluorohexanesulfonic acid (PFHxS) 1600 μg/kg ND U ND U ND U ND 

Perfluorononanoic acid (PFNA) 250 μg/kg ND U ND U ND U ND 

Perfluorooctanesulfonic acid (PFOS) 160 μg/kg 0.66 J ND U ND U ND 

Perfluorooctanoic acid (PFOA) 250 μg/kg 0.26 J ND U ND U ND 

Notes:J = Estimated concentration.U = Analyte was not detected at or above the quantitation limit.μg/kg = Microgram(s) per kilogram.ft bgs = Feet below ground surface.ND = Analyte not detected above the limit of detection.Qual = Qualifier.

1. Assistant Secretary of Defense. July 2022. Risk-Based Screening Levelsin Groundwater and Soil U.S. Environmental Protection Agency’s RegionalScreening Level Calculator. Hazard Quotient =0.1. May 2022.2. The Screening Levels for soil are based on incidental ingestion of soil in aindustrial/commercial worker scenario.

Depth (ft bgs) 6-8 6-8 6-8 6-8 

12/21/2021 12/20/2021 12/20/2021 12/20/202

Sample Date

Parent Sample ID

Table 6-3. PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurf

Site Inspection Report, Rio Rancho Training Site

Sample Name

Location ID AOI01-01 AOI01-02 AOI01-03 

AOI01-01-SB-6-8 AOI01-02-SB-6-8 AOI01-03-SB-6-8 AOI01-04-SB

AOI01-04 
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Analyte1,2 Screening Level1,2 Unit Result Qual Result Qual Result Qual R

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15Perfluorobutanesulfonic acid (PFBS) 25000 μg/kg ND U ND U ND U N

Perfluorohexanesulfonic acid (PFHxS) 1600 μg/kg ND U ND U ND U N

Perfluorononanoic acid (PFNA) 250 μg/kg ND U ND U ND U N

Perfluorooctanesulfonic acid (PFOS) 160 μg/kg 1.2 ND U ND U N

Perfluorooctanoic acid (PFOA) 250 μg/kg ND U ND U ND U N

Notes:

Depth (ft bgs) 13-15 ft 13-15 ft 13-15 ft 

1. Assistant Secretary of Defense. July 2022. Risk-Based Screening Levelsin Groundwater and Soil U.S. Environmental Protection Agency’s RegionalScreening Level Calculator. Hazard Quotient =0.1. May 2022.2. The Screening Levels for soil are based on incidental ingestion of soil in aindustrial/commercial worker scenario.J = Estimated concentration.U = Analyte was not detected at or above the quantitation limit.μg/kg = Microgram(s) per kilogram.ft bgs = Feet below ground surface.ND = Analyte not detected above the limit of detection.Qual = Qualifier.

Sample Date 12/21/2021 12/20/2021 12/20/2021 

Parent Sample ID

Table 6-4. PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Deep Subsurfac

Site Inspection Report, Rio Rancho Training Site

Sample Name AOI01-01-SB-13-15 AOI01-02-SB-13-15 AOI01-03-SB-13-15 A

Location ID AOI01-01 AOI01-02 AOI01-03 
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Figure 6-1

AOI 1

PFOS Detections in Soil

AOI 1

AOI 1

AOI01-02

AOI01-11

AOI01-10

AOI01-09

AOI01-08

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-07

AOI01-01

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3 AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

AOI 1

AOI 1

Evaporation

Lagoon

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Rio Rancho

FMS-3

AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

3

0 250

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

0 250

Feet

0 250

Feet

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Hydrogeology

Surface Water

Flow Direction

OWS Drainage Flow Direction

Notes:

PFOS = Perfluorooctanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 1,600

> 160 - 1,600

> 13 - 160

> ND - 13

ND (Non-Detect)

PFOS Results (μg/Kg)

> 1,600

> 160 - 1,600

> 13 - 160

> ND - 13

ND (Non-Detect)

PFOS Results (μg/Kg)

> 1,600

> 160 - 1,600

> 13 - 160

> ND - 13

ND (Non-Detect)

PFOS Results (μg/Kg)
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Figure 6-2

AOI 1

PFOA Detections in Soil

AOI 1

AOI 1

AOI01-02

AOI01-11

AOI01-10

AOI01-09

AOI01-08

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-07

AOI01-01

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3 AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

3

0 250

Feet

^_

NM

0 250

Feet

0 250

Feet

Shallow Intermediate Deep

Army National Guard Site Inspections

Site Inspection Report

Rio Rancho, New Mexico

Data Sources:

ESRI 2022

AECOM 2019

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Hydrogeology

Surface Water

Flow Direction

OWS Drainage Flow Direction

Notes:

PFOA = Perfluorooctanoic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 2,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)

> 2,500

> 250- 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)

> 2,500

> 250- 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)
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Figure 6-3

AOI 1

PFBS Detections in Soil

AOI 1

AOI 1

AOI01-02

AOI01-11

AOI01-10

AOI01-09

AOI01-08

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-07

AOI01-01

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3 AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

3

0 250

Feet

^_

NM

0 250

Feet

0 250

Feet

Shallow Intermediate Deep

Army National Guard Site Inspections

Site Inspection Report

Rio Rancho, New Mexico

Data Sources:

ESRI 2022

AECOM 2019

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Hydrogeology

Surface Water

Flow Direction

OWS Drainage Flow Direction

Notes:

PFBS = Perfluorobutanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)
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Figure 6-4

AOI 1

PFHxS Detections in Soil

AOI 1

AOI 1

AOI01-02

AOI01-11

AOI01-10

AOI01-09

AOI01-08

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-07

AOI01-01

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3 AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

AOI 1

AOI 1

Evaporation

Lagoon

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Rio Rancho

FMS-3

AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

3

0 250

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

0 250

Feet

0 250

Feet

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Hydrogeology

Surface Water

Flow Direction

OWS Drainage Flow Direction

Notes:

PFHxS = Perfluorohexanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)
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Figure 6-5

AOI 1

PFNA Detections in Soil

AOI 1

AOI 1

AOI01-02

AOI01-11

AOI01-10

AOI01-09

AOI01-08

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-07

AOI01-01

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3

AOI 1

AOI 1

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Evaporation

Lagoon

Rio Rancho

FMS-3 AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

AOI 1

AOI 1

Evaporation

Lagoon

Haz Mat

Storage Lockers

Oil and Water

Separator

Cellphone

Tower

Rio Rancho

FMS-3

AOI01-02

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-01

3

0 250

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

Date:..........................August 2022

Prepared By:.............................EA

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

Projection:........WGS 84 UTM 13N

0 250

Feet

0 250

Feet

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Potential PFAS Release Area

Hydrogeology

Surface Water

Flow Direction

OWS Drainage Flow Direction

Notes:

PFNA = Perfluorononanoic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 2,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)

> 2 ,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)

> 2 ,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)
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7-1

7. EXPOSURE PATHWAYS

The conceptual site model (CSM) for the AOI, revised based on the SI findings, is presented on 

Figure 7-1. Please note that while the CSM discussion assists in determining if a receptor may 

be impacted, the decision to move from SI to RI or interim action is determined based upon 

exceedances of the SLs for the relevant compounds and whether the release is more than likely 

attributable to the DoD. A CSM presents the current understanding of the Facility conditions 

with respect to known and suspected sources, potential transport mechanisms and migration 

pathways, and potentially exposed human receptors. A human exposure pathway is considered 

potentially complete when the following conditions are present:

1. Contaminant source

2. Environmental fate and transport

3. Exposure point

4. Exposure route

5. Potentially exposed populations. 

If any of these elements are missing, the pathway is incomplete. The CSM figures use an empty 

circle symbol to represent an incomplete exposure pathway. Areas with no identified complete 

pathway generally warrant no further action. However, the pathway is considered potentially 

complete if the relevant compounds are detected, in which case the CSM figure uses a half-filled 

circle symbol to represent a potentially complete exposure pathway. Additionally, a completely 

filled circle symbol is used to indicate when a potentially complete exposure pathway has 

detections of relevant compounds above the SLs. Areas with an identified potentially complete 

pathway that have detections of the relevant compounds above the SLs may warrant further 

investigation. Although the CSMs indicate whether potentially complete exposure pathways may 

exist, the recommendation for future study in a RI or no action at this time is based on the 

comparison of the SI analytical results for the relevant compounds to the SLs.

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. The receptors evaluated are consistent 

with those listed in USEPA guidance for risk screening (USEPA 2001). Receptors at Rio Rancho 

TS include Facility workers, construction workers, and trespassers. 

7.1 SOIL EXPOSURE PATHWAY 

The SI results for soil were used to determine whether a potentially complete pathway exists 

between the source and potential receptors at each AOI based on the aforementioned criteria. 

7.1.1 AOI 1 – Hazardous Waste Storage Sheds 1 and 2/Wash Racks/Evaporation Lagoon

Potential PFAS release areas associated with AOI 1 include the hazardous waste storage lockers 

where AFFF was stored, adjacent wash racks, and the concrete evaporation lagoon. PFOA and/or

PFOS were detected at seven boring locations, providing evidence of a potential AFFF release at 

the wash racks or nearby paved area. Based on previous sampling of wastewater from the 
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7-2

evaporation lagoon, PFAS appear to have been discharged to the lagoon via plumbing from the 

wash racks. Additionally, runoff from the wash rack area may have resulted in PFAS detections 

(PFOS and PFOA at concentrations below SLs) reported in soil to the north and south of the 

wash racks. A PFAS detection (PFOS at a concentration below the SL) was also reported in the 

soil boring located adjacent to and north of the evaporation lagoon.

Based on the results of the SI for AOI 1, ground-disturbing activities to surface soil could result 

in Facility worker and construction worker exposure to PFOA and PFOS via inhalation of dust. 

Ground-disturbing activities to surface and subsurface soil could result in construction worker 

exposure to PFOA and PFOS via ingestion. Therefore, the exposure pathways for inhalation and 

ingestion are potentially complete for these receptors. The CSM is presented in Figure 7-1.

7.2 GROUNDWATER EXPOSURE PATHWAY

Due to the depth to groundwater at 1,000 ft bgs, groundwater is not considered a potentially 

complete pathway for migration of PFAS compounds to groundwater.

7.3 SURFACE WATER/ SEDIMENT EXPOSURE PATHWAY

Due to the presence of PFAS compounds detected in historical evaporation lagoon samples, the 

surface water/sediment exposure pathway is considered potentially complete. 
Notes:

1. The resident and recreational users refer to 

off-facility receptors.

Figure 7-1

Conceptual Site Model

AOI 1 Rio Rancho Training Site

RECEPTOR

Human Receptors:

Current/Future

Facility 

Worker

Construction 

Worker Resident

1

Facility

Worker

Construction 

Worker

Resident

1

AOI 1 PFAS in 

Surface Soil 

or on 

Pavement

Human 

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Potential Use, 

Spill, Leak, or 

Overflow

SOURCE

Source Release 

Mechanism Media

PATHWAY

Transport

and Migration Media Exposure 

Routes

Inhalation of 

Dust

Potentially Complete Pathway with Exceedance of 

Screening Level

Trespasser

Trespasser
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8. SUMMARY AND OUTCOME

This section summarizes SI activities and findings. The most significant findings are summarized 

in this section and are reproduced directly or abstracted from information contained in this 

report. The outcome provides general and comparative interpretations of the findings relative to 

the SLs. 

8.1 SITE INSPECTION ACTIVITIES SUMMARY 

The SI field activities at the facility were conducted from 20 to 21 December 2021. The SI field 

activities included soil sampling only, due to a groundwater depth of approximately 1,000 ft bgs. 

Field activities were conducted in accordance with the UFP-QAPP Addendum (EA 2021a), 

except as previously noted in Section 5.9. 

To fulfill the project DQOs set forth in the approved SI UFP-QAPP Addendum (EA 2021a), 

samples were collected and analyzed for a subset of 24 compounds by LC/MS/MS compliant 

with QSM Version 5.3 Table B-15 as follows:

• Six (6) surface soil samples from five locations including a duplicate sample (hand auger 

boring locations)

• Twenty-one (21) soil samples from six locations including three duplicate samples (DPT 

boring locations).

• One (1) field blank sample (FB).

• Two (2) equipment rinsate samples. 

An SI is conducted when the PA determines an AOI exists based on probable use, storage, and/or

disposal of PFAS-containing materials. The SI includes multi-media sampling at AOIs to 

determine whether or not a release has occurred. The SI may conclude further investigation is 

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

required. Additionally, the CSM was refined to assess whether a potentially complete pathway 

exists between the source and potential receptors for potential exposure at the AOI, which is 

described in Section 7. 

8.2 OUTCOME

Based the results of this SI, further evaluation is not warranted for AOI 1 (see Table 8.1). Based 

on the CSMs developed and revised in light of the SI findings, there is potential for exposure to 

soil receptors from AOI 1 from sources on the facility resulting from historical DoD activities. 

Sample analytical concentrations collected during the SI were compared against the project SLs 

in soil, as described in Table 6-1. 
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A summary of the results of the SI data relative to the SLs is as follows: 

• AOI 1:

 PFOA, PFOS, and PFHxS were detected in soil below SLs at AOI 1. 

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

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

screening values were established after SI planning and execution. However, ARNG will add 

HFPO-DA to the list of constituents sampled during the next phase of CERCLA if warranted.

Table 8-1 summarizes the SI results for soil and groundwater used to determine if an AOI should 

be considered for further investigation under CERCLA and undergo an RI. 

Table 8-1. Summary of Site Inspection Findings and Recommendations

AOI Potential Release Area

Soil

Source Area

Groundwater

Source Area

Groundwater

Facility Boundary

Future 

Action

1 

Hazardous Materials Storage 

Lockers/Wash 

Racks/Evaporation Lagoon

Not Applicable Not Applicable No Further 

Action

Legend:

 = Detected; exceedance of SLs

 = Detected; no exceedance of SLs

 = Not detected
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9. REFERENCES

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Rancho, Rio Rancho, New Mexico. August. 

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the Department of Defense Cleanup Program. United States Department of Defense. 6 

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Department of the Army. 2016. EM-200-1-2, Environmental Quality, Technical Project 

Planning Process. 29 February. 

Department of Defense (DoD). 2019a. Department of Defense (DoD), Department of Energy 

(DOE) Consolidated Quality Systems Manual (QSM) for Environmental Laboratories, 

Version 5.3. May. 

. 2019b. General Data Validation Guidelines. November. 

. 2020. Data Validation Guidelines Module 3: Data Validation Procedure for Per- and 

Polyfluoroalkyl Substances Analysis by QSM Table B-15. May. 

EA Engineering, Science, and Technology, PBC (EA). 2020a. Final Programmatic Uniform 

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Substances Impacted Sites, ARNG Installations, Nationwide. December.

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aqueous film-forming foam (AFFF)-impacted sites. Environ. Sci. Technol. 47(9):4164-71. 

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. 2017b. National Functional Guidelines for Organic Superfund Data Review. OLEM 

9355.0-136, EPA-540-R-2017-002. Office of Superfund Remediation and Technology 

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