Final

Preliminary Assessment Report

Bangor Training Site 

Bangor, Maine

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid 

(PFOA) Impacted Sites

ARNG Installations, Nationwide

January 2020

Prepared for:

Army National Guard Headquarter

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

Bangor Training Site, Bangor, ME

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Table of Contents

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

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

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

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

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

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

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

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

1.5.2 Hydrogeology.................................................................................................8

1.5.3 Hydrology.......................................................................................................9

1.5.4 Climate.........................................................................................................10

1.5.5 Current and Future Land Use.......................................................................10

2. Fire Training Areas...........................................................................................................15

3. Non-Fire Training Areas ...................................................................................................16

3.1 Bangor Training Site Eastern Properties .................................................................16

3.1.1 Building 254 (Cold Storage Hangar).............................................................16

3.1.2 Building 260 (Army Aviation Support Facility) ...............................................16

3.1.3 Building 250 (FMS #3)..................................................................................18

3.1.4 Building 262 (Covered Fuel Truck Building)..................................................18

3.2 Bangor Training Site Western Properties ................................................................18

3.2.1 Armed Forces Reserve Center (AFRC)........................................................18

3.2.2 Regional Training Institute (RTI)...................................................................19

3.2.3 Baffled Small Arms Range............................................................................19

4. Emergency Response Areas............................................................................................21

5. Adjacent Sources.............................................................................................................22

5.1 Bangor Air National Guard Base .............................................................................22

5.2 Fuel Strike Incident Location – Bangor International Airport....................................23

5.3 Former Dow Air Force Base FTA ............................................................................23

5.4 Waste Water Treatment Plant .................................................................................23

5.5 Landfills ..................................................................................................................23

6. Preliminary Conceptual Site Model ..................................................................................26

6.1 AOI 1 Building 260 (AASF) .....................................................................................26

6.2 AOI 2 Building 254 (Cold Storage Hangar) .............................................................27

7. Conclusions and Data Uncertainty ...................................................................................31

7.1 Conclusions ............................................................................................................31

7.2 Uncertainty .............................................................................................................32

7.3 Potential Future Actions ..........................................................................................33

8. References ......................................................................................................................36
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

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Tables

Table ES-1: Areas of Interest

Table 5-1: Bangor Air National Guard Base PFAS Release Locations

Table 7-1: Areas of Interest

Table 7-2: No Suspected Release Areas

Table 7-3: Sources of Uncertainties

Table 7-4: PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Area of Interest

Figure 6-2 Preliminary Conceptual Site Model for Building 260

Figure 6-3 Preliminary Conceptual Site Model for Building 254

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

iii

Acronyms and Abbreviations

oF

AASF

degrees Fahrenheit

Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFB Air Force Base

AFFF aqueous film forming foam

AFRC Armed Forces Reserve Center

amsl above mean sea level

AOI Area of Interest

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

Act

CSM conceptual site model

FAA Federal Aviation Administration

FMS Field Maintenance Shop

ft feet/foot

FTA fire training area

gpm gallons per minute

IED Installations and Environment Division

ME

MEANG

Maine

Maine Air National Guard

MEARNG Maine Army National Guard

MEDEP Maine Department of Environmental Protection

ng/L nanograms per liter

OWS Oil water separator

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

POL petroleum, oil, and lubricants

RTI Regional Training Institute

SI Site Inspection

US United States

USACE

USEPA

USGS

United States Army Corps of Engineers

United States Environmental Protection Agency

United States Geological Survey

USFWS United States Fish and Wildlife Service

USPFO United States Property and Fiscal Office

VSI visual site inspection

WWTP waste water treatment plant
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

1

Executive Summary

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

Army National Guard (ARNG)-Installations & Environment Division (IED), 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 (AFFF) released as part of firefighting 

activities, although other PFAS sources are possible.

AECOM completed a PA for PFAS at Bangor Training Site in Bangor, Maine (ME) 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 1-day site visit on 25 October 2018

• Interviewed personnel with knowledge of Bangor Training Site activities during the site visit,

including a Maine ARNG (MEARNG) Operations Officer, MEARNG Building Control 

Supervisor, MEARNG Stormwater Manager, and two Maine Air National Guard (MEANG) 

Fire Department Assistant Chiefs

• Completed visual survey inspections (VSIs) at known or suspected PFAS release locations

and document with photographs

Two Areas of Interest (AOIs) related to potential PFAS release were identified at the Bangor 

Training Site, based on PA data. The AOIs are shown on Figure ES-1 and described in the Table 

ES-1 below:

Table ES-1: Areas of Interest

Area of 

Interest Name Used by Potential Release Dates

AOI 1

Building 260 Army Aviation Support 

Facility (AASF)

MEARNG 2003, 2011, 2016

AOI 2 Building 254 (Cold Storage Hangar) MEARNG 2013-2018

Based on the known PFAS releases at AOI 1 and potential PFAS release at AOI 2, there is 

potential for exposure to PFAS in surface soil to site workers, construction workers, and 

trespassers/recreational users via ingestion; in subsurface soils to construction workers via 

inhalation and ingestion; in surface water and sediment to site workers and 

trespassers/recreational users via ingestion; and in groundwater to construction workers via 

ingestion. Additionally, a groundwater drinking well on the Bangor Training Site western property 

is sampled quarterly due to PFAS detections in drinking water during an ARNG 2017 sampling 

event. Releases at AOI 1 and AOI 2 are unlikely to have contributed to PFAS in groundwater on 

the western property; however, the pathway for PFAS exposure to site workers via ingestion of 

groundwater is complete via the active drinking water well. 

Although private domestic wells exist within a one-mile radius of the facility, they are located at 

greater distances from the specific locations of the AOIs, and are cross- or upgradient of the 

release areas. The pathway for PFAS exposure to off-facility residents is considered incomplete.
PFAS Preliminary Assessment Report

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Several adjacent sources of PFAS release to the environment were identified in the area 

surrounding MEARNG Bangor Training Site through interviews or review of previous 

environmental investigations. The preliminary conceptual site model (CSM) for the MEARNG 

Bangor Training Site is shown on Figure ES-2.
­ Figure ES-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Bangor Training Site, ME

11/6/2019

11/6/2019

11/6/2019

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)

11/6/2019

1:142,779

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\ME\Bangor_Training_Site_Figures\Bangor_PA_Figures\Fig_ES-1_Bangor_TS_Summary.mxd

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Former DOW

AFB FTA

Fuel Line

Strike Incident

Building 260

MEANG Former

Fire Department

MEANG Fire Department

(Building 512)

MEANG Fire Department Historic

Nozzle Testing Location

MEANG Dry

Detention Pond

MEANG Dry

Detention Basin

MEANG Building 542 (Fuel

Cell Repair Hangar)

MEANG Fire Department Current Nozzle

testing Location (East of Building 542)

MEANG Fire Department Current Nozzle

testing Location (East of Taxiway C)

MEANG Building

515 (Flight Line)

MEANG Building 496

(Former Main Hangar)

MEANG Building

493 (Base Supply)

MEANG Building 415 (Central

Accumulation Point)

Baffled Small Arms Range

RTI

AFRC Bangor International Airport

Building 254

Building 250 (FMS #3)

Building 262 

(Covered Fuel Truck Building)

Shaw

Brook

AOI 1

AOI 2

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Bangor ANG Facility Boundary

Water Body

Wetland

River/Stream

Souadabscook Stream

Sha w

Brook

Pine Tree

Landfill

!P

Penobscot River

City of

Bangor WWTP

1

2

3

Shaw

Brook

Pug Brook

W h eele r St ream

Penobscot River

Kendus keagStream

1

2

3

0 500 1,000 2,000

Feet

­
Media

SOURCE PATHWAY RECEPTOR

AOI 1 & 

AOI 2

Fire 

Suppression 

System 

Releases

PFAS on 

Paved 

Surfaces/

Sanitary 

Sewers

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

Bangor Training Site, ME

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Trespasser/ Recreational User

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
PFAS Preliminary Assessment Report

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1. Introduction

1.1 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 (IED), 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-D0014, Task Order W912DR17F0192, issued 11 August 2017. The ARNG is assessing potential 

effects on human health related to processes at their facilities that used per- and poly-fluoroalkyl 

substances (PFAS), primarily releases of aqueous film forming foam (AFFF) although other 

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

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

for a PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing 

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

framework at both federal and state levels continues to evolve. The US Environmental Protection 

Agency (USEPA) issued Drinking Water Health Advisories for PFOA and PFOS in May 2016, but 

there are currently no promulgated national standards regulating PFAS in drinking water. In the 

absence of federal maximum contaminant levels, some states have adopted their own drinking 

water standards for PFAS. The Maine Department of Environmental Protection (MEDEP)

established a Maximum Exposure Guideline concentration of 70 nanograms per liter (ng/L)

individually for PFOA and PFOS on 31 December 2016.

This report presents findings of a PA for PFAS at Bangor Training Site (also referred to as the 

“facility”) in Bangor, Maine 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 Part 300), and USACE 

requirements and guidance.

This PA documents the known army aviation support facilities as well as additional locations where 

PFAS may have been stored or released into the environment at Bangor Training Site. The term 

PFAS will be used throughout this report to encompass all PFAS chemicals being evaluated, 

including PFOS and PFOA, which are key components of AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks: 

• Reviewed data resources to obtain information relevant to suspected PFAS releases

• Conducted a 1-day site visit on 25 October 2018

• Interviewed personnel with knowledge of Bangor Training Site activities during the site visit,

including a Maine ARNG (MEARNG) Operations Officer, MEARNG Building Control 

Supervisor, MEARNG Stormwater Manager, and two Maine Air National Guard (MEANG) 

Fire Department Assistant Chiefs

• Completed visual site inspections (VSIs) at known or suspected PFAS release locations and 

documented with photographs 

• If Areas of Interest (AOIs) were identified, developed a preliminary conceptual site model 

(CSM) to outline the potential release and pathway of PFAS for each AOI
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1.3 Report Organization

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

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

of each are:

• 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 potential or suspected fire training areas 

(FTAs) at the facility identified during the site visit 

• Section 3 – Non-Fire Training Areas: describes other locations of potential or suspected 

PFAS releases at the facility identified during the site visit 

• Section 4 – Emergency Response Areas: describes areas of suspected or potential AFFF 

release at the facility, specifically in response to emergency situations 

• Section 5 – Adjacent Sources: describes sources of 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 at the facility 

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

PA 

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

• Appendix A – Data Resources

• Appendix B – Preliminary Assessment Documentation

• Appendix C – Photographic Log

1.4 Facility Location and Description

The MEARNG Bangor Training Site comprises 213.7 acres and 13 buildings between two 

properties located immediately east and west of the Bangor International Airport runway, in the 

city of Bangor, Penobscot County, Maine (MEARNG, 2015) (Figure 1-1). The MEARNG 

properties are owned by the Federal Government and licensed to MEARNG. 

The western property comprises approximately 161.85 acres and is used by both military and 

civilian groups. The western property includes a firing range in the northeastern area, a Regional 

Training Institute (RTI), and an Armed Forces Reserve Center (AFRC). The remainder of the area 

is forested with some open fields and wetlands. A small parcel of land within the western property,

near the southeastern boundary, is permitted to the Department of Transportation Federal Aviation 

Administration (FAA), in accordance with License DACA51-1-96-089A, and contains the Area 

Search Radar and FAA Tower, but it is not operated by MEARNG. The RTI (approximately 10 

acres) was constructed in 2012 and includes housing, training rooms, presentation rooms, and 

offices; the AFRC (approximately 4.5 acres) was constructed in 1992 and includes classrooms, 

administrative offices, and equipment parking and storage areas. The western property is located 

within the Airport Development District zone. The land is federally owned and licensed to the 

MEARNG by the USACE under the “Department of the Army License for National Guard 

Purposes” No. DACA33-3-08-123, dated 25 September 2008 (Summit Environmental 

Consultants, Inc., 2011) (Appendix A).

The eastern property is made up of seven parcels and comprises approximately 51.85 acres. 

According to the MEARNG title for the eastern property, the original 19.01-acre parcel was 
PFAS Preliminary Assessment Report

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7

licensed to the state of Maine Department of the Air Force in 1968 to be used for ARNG purposes. 

Since then, the MEARNG has leased an additional six parcels from the city of Bangor. The main 

operational buildings on the eastern property include Field Maintenance Shop (FMS) #3, an 

Aviation Readiness Center, and an Army Aviation Support Facility (AASF). Ground equipment 

maintenance occurs at FMS #3, and maintenance of helicopters occurs at the AASF. The AASF 

also serves as the flight operations center for the Aviation Companies. There are also several 

support buildings at the facility, including an aircraft hangar used for cold storage, a covered fuel 

tanker building that provides secondary containment for refueling vehicles, a Controlled Humidity

Storage Building used for cold storage, and a concrete block building used as for petroleum, oil,

and lubricants (POL) and hazardous materials storage (CES, Inc., 2017). The MEARNG title for 

the eastern property is included in Appendix A.

1.5 Facility Environmental Setting

Section 1.5 presents information taken from several sources, including the 2011 Environmental 

Baseline Study for the MEANRG Parcel 3 on the Bangor Training Site western property (Summit 

Environmental Consultants, Inc., 2011), the 2015 MEARNG Integrated Cultural Resources 

Management Plan Update (MEARNG, 2015), and the 2017 Integrated Contingency Plan for the 

facility (CES, Inc., 2017). The Bangor Training Site lies within the Coastal Province of Maine and 

is characterized by relatively flat terrain. Topographic relief in this region area is largely influenced 

by structural features greatly modified by Pleistocene glaciation (Hunt, 1974). The facility is 

approximately three miles west of the confluence of the Kenduskeag Stream and Penobscot 

River. Two small tributaries originate within the Bangor Training Site western property. 

According to the United States Geological Survey (USGS) 7.5 Minute Bangor quadrangle, the 

elevation of the western property ranges from 150 to 225 feet (ft) above mean sea level (amsl)

(USGS, 1981). The most conspicuous elevation change is associated with a hill in the southern 

part of the property, near the FAA tower. The remaining portions of the facility slope gently to the 

west, toward Hermon Bog (Summit Environmental Consultants, Inc., 2011). At the adjacent 

MEANG base, construction has modified the ground surface and reduced topographic relief to 

approximately 65 ft at elevations ranging from 170 to 240 ft amsl (Amec Foster Wheeler, 2018). 

A similar elevation is anticipated at the Bangor Training Site eastern property.

1.5.1 Geology

Section 1.5.1 presents information taken from the 2018 MEANG Final FY16 Phase 1 Regional 

SI for Perfluorinated Compounds at the adjacent Bangor Air National Guard Base (Amec Foster 

Wheeler, 2018). The Bangor Training Site is situated within the folded and faulted, 

metamorphosed, Paleozoic strata of the northeast trending Kearsarge-Central Maine 

Synclinorium. The oldest known rocks consist of interbedded pelite and sandstone overlain by 

mafic to felsic volcanic rock of Cambrian and Ordovician age. These rocks are unconformably 

overlain by late Ordovician-early Silurian age beds (Vassalboro Formation) of fine to medium 

grained feldspathic graywacke with layers or lenses of phyllite (Griffin, 1976). 

Regional overburden materials include the glacial moraine deposits of the Presumpscot 

Formation, glacial-stream deposits, and till. The Presumpscot Formation consists of silt, clay, and 

sand washed from glacial ice and deposited on the ocean floor during the Late Wisconsin 

(Pleistocene) glacial stage (Thompson, 1977). The formation can range up to 125 ft in thickness 

and is locally fossiliferous. Clayey-silts characterized by low permeability and poor drainage typify 

the Presumpscot Formation near the facility. Glacial-stream deposits consist of well-sorted sands 

and gravels deposited in layers by meltwater streams and currents during Late Wisconsin 

deglaciation. The deposits are commonly overlapped or entirely buried by the Presumpscot 

Formation and include kames and kame terraces, deltas, kettles, eskers, and outwash plains 

(Thompson, 1977). The glacial-stream deposits located nearest the facility are found along the
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Kenduskeag Stream. Glacial till is composed of a heterogeneous mixture of clay, silt, sand, gravel, 

cobbles, and boulders deposited directly by glacial ices. One of two varieties (basal or ablation) 

may be present in the area. Basal till is fine-grained, very compact, and exhibits low permeability 

and poor drainage. Ablation till consists of loose, sandy to stony material, characterized by 

moderate permeability and fair to good drainage. Glacial till generally overlies bedrock, but may 

overlie or include sand and gravel (Thompson, 1977).

Subsurface soils encountered near the Bangor Training Site eastern property during a 1997 

MEANG SI (ABB-ES, 1997) at the adjacent MEANG base generally consisted of clay to silty clay, 

silt, silty sand, or sand with trace to some gravel. Loose to medium dense soils overlying dense 

or very dense materials were encountered and were characterized as typical of the glacial till 

deposits as described by Thompson (1977) for the Bangor quadrangle. Bedrock was encountered 

at 4 to 16 ft below ground surface (bgs) in the borings that encountered bedrock. The bedrock 

appeared to be Vassalboro Formation, as shown in Figure 1-2, and consisted of dark gray Phyllite 

with quartz stringers. Wet fracture zones were encountered.

Bedrock outcrops exist throughout the Bangor Training Site western property. A preliminary 

geotechnical investigation was completed by Summit Geoengineering Services in August 2005 in 

support of the RTI construction; soil in the vicinity of the western property generally consists of 

topsoil/forest duff overlying a thin layer of sandy glacial alluvium overlying glacial marine and/or 

glacial till deposits overlying bedrock. Glacial till was encountered at shallow bedrock areas at

higher elevation while the glacial marine deposits were generally encountered at lower elevation 

areas. Bedrock was encountered at depths ranging from 1.5 inches to 15.5 ft. Soft glacial marine 

silty clay layers were also encountered at the northern and western edges of the investigation 

area adjacent to wetland systems (Summit Environmental Consultants, Inc., 2011). 

1.5.2 Hydrogeology

Information in this section was drawn from the 2018 MEANG Final FY16 Phase 1 Regional SI for 

Perfluorinated Compounds at the adjacent Bangor Air National Guard Base (Amec Foster 

Wheeler, 2018). The facility lies within the lower Penobscot River Basin, which covers an area of 

approximately 825 square miles. The largest supplies of groundwater in the basin occur in the 

unconsolidated deposits formed by glaciofluvial processes. Under favorable conditions, as much 

as 1,000 gallons of water per minute (gpm) may be obtained from wells constructed in ice-contact 

deposits (Prescott, 1964).

The nearest sand and gravel aquifers are located over three miles southwest of the facility, at the 

southern end of Hermon Bog (Foster & Smith, 1992). The bedrock formations in the lower 

Penobscot River Basin are sparsely fractured, and groundwater is generally only present in these 

secondary openings. Hydraulic continuity varies widely depending on the size of the fractures. A 

1964 survey of 613 bedrock wells in the lower Penobscot River Basin found that groundwater 

yields ranged from less than 0.5 to 100 gpm (Prescott, 1964). Drinking water at the Bangor 

Training Site is provided by the Bangor Water District. An active potable well also used for drinking 

water exists on the western parcel, which has tested positive for PFAS. This well is sampled 

quarterly for PFAS and is discussed further later in this section.

During a 1997 MEANG SI, groundwater at the adjacent Air National Guard (ANG) base existed 

at depths of 8 to 23 ft bgs (ABB-ES, 1997). The water table appeared to be present in the 

overburden at the southern portion of the MEANG base (closer to the Bangor Training Site), and

in the bedrock at the northern end of the base. Groundwater levels in MEANG monitoring wells 

ranged from approximately 1 to 15 ft bgs, with a fluctuation of 1 to 4 ft higher in the spring. 

Groundwater in overburden and bedrock appeared to constitute the same aquifer. Groundwater 

at the MEANG base flows southeast, towards the Penobscot River; however, local groundwater 

flow conditions in the overburden till may be locally influenced by large structures that extend 

below the surface and extend across large surface areas on the various properties across Bangor 
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International Airport. Average hydraulic conductivity values were 4.09 x 10-3ft per minute for 

bedrock wells, and 5.0074 x 10-3ft per minute for overburden wells (ABB-ES, 1997). 

A 2015 Environmental Data Resources, Inc. (EDR) Radius MapTM Report with Geocheck® for the 

MEANG base listed eight water wells within a one-mile radius of MEANG base (BB&E, 2015). Of 

these wells, three appear on the US Geological Survey (USGS) database, which usually lists 

monitoring or test wells, and five are listed in the State database. Two of the wells on the State 

database are listed as commercial use, and three are listed as domestic use (BB&E, 2015). Based 

on the interpreted southeasterly groundwater flow direction, these wells are upgradient and side 

gradient from the MEANG base and Bangor Training Site (Amec Foster Wheeler, 2018).

Data from the MEANG 2018 SI indicate that concentrations of PFOS and PFOA in groundwater 

beneath the MEANG base exceed the USEPA Drinking Water Health Advisory. Based on the 

presence of PFOA and PFAS in groundwater beneath the MEANG base and southeasterly 

groundwater flow, there is potential for PFOA and PFAS migration beneath the MEARNG Bangor 

training Site (Amec Foster Wheeler, 2018).

Groundwater flow direction on the western MEARNG property, based upon topography, is 

anticipated to generally flow west-northwest. The Maine Significant Sand and Gravel Aquifer Map, 

Bangor Quadrangle, indicates that the western property is not located on or near a mapped sand 

or gravel aquifer (Summit Environmental Consultants, Inc., 2011).

A 2018 EDR Radius MapTM Report with Geocheck® for the western MEARNG property listed 

three wells not previously identified in the 2015 EDR Radius MapTM Report within a one-mile 

radius of the facility; all three wells are listed in the State database (Appendix A). Two of the wells 

are listed for domestic use, and one well is listed for commercial use. The wells are located 

northwest and southeast of the western property, which is side gradient, based on an inferred 

westerly groundwater flow direction.

Additionally, the MEARNG sampled water from a drinking water well supplying a training facility 

at the RTI on 16 May 2017 for PFAS. Although several PFAS compounds were detected above 

reporting limits, neither PFOA (4.47 ng/L) nor PFAS (not-detected) exceeded the MEDEP 

Maximum Exposure Guideline concentration of 70 ng/L. Tabulated results from this sampling 

event are included in Appendix A. Due to the 2017 PFAS detections in drinking water, sampling 

for PFAS was mandated by the ARNG. Water from the RTI bathroom sink on the MEARNG 

western property is sampled quarterly for PFAS. PFOA was detected in the August 2018 sample 

at 24.7 ng/L; PFOS was not detected. Concentrations of remaining PFAS compounds ranged 

from not detected to 137 ng/L. The August 2018 sample concentration of PFOA increased from 

the 9.98 ng/L concentration observed in June 2018. Laboratory results from the August 2018 

sampling event are included in Appendix A, and Groundwater features are shown on Figure 1-

2.

1.5.3 Hydrology

No surface water features are present on the MEARNG Bangor Training Site eastern property. 

The “Domestic Channel”, which is a channelized portion of Birch Stream, abuts the property to 

the west-northwest and is the nearest surface waterbody. Storm water runoff from the facility flows 

into storm drains located on the property and in the vicinity, and drain to the Domestic Channel. 

The Domestic Channel/Birch Stream drains into the Kenduskeag Stream (CES, Inc., 2017), which

is located approximately one mile northeast of the facility. 

According to the 2013 Environmental Baseline Study performed at the western property, a natural 

pond is used as a storm water retention pond along the access road southeast of the AFRC. Two 

water containing “pot holes” are located within the forested portion of the property, south of the 

AFRC compound. According to MEARNG personnel, the “pot holes” are likely rip-rap lined energy 
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Bangor Training Site, Bangor, ME

10

dissipaters at culvert outlets. Storm water runoff associated with the AFRC complex drains 

primarily in two directions; storm water from paved areas to the northeast and southeast of the 

AFRC drains southeast toward the retention pond, storm water from the southwest parking lot 

and roadway drains southward into a natural wetland located to the south of the parking area. 

Surface water from the RTI is diverted to outfalls located to the west of the RTI that feed into Shaw 

Brook, a riverine wetland. Surface water from the northern portion of the property drains toward 

the west into Hermon Bog (Summit Environmental Consultants, Inc., 2011).

Based upon the topography of the facility (approximately 150 to 225 feet amsl) and the lack of 

nearby flooding sources, it is unlikely that the facility would experience a major flood event.

The US Fish and Wildlife Service (USFWS) National Wetlands Inventory Map identified several 

small wetland areas within the boundaries of the eastern property. These areas include freshwater 

forested wetlands, freshwater emergent wetlands, a freshwater pond, and a permanently flooded 

riverine habitat (USFWS, 2019). Surface water features are presented on Figure 1-3.

1.5.4 Climate

Bangor is located less than 50 miles from the Atlantic Ocean and within 30 miles of Penobscot 

Bay. The climate of Bangor is categorized as humid continental with cold, snowy winters and

warm summers. The weather in Bangor is influenced by air masses that originate from several

general regions. Continental air masses originating in the North America polar region consist of

dry, cool air. Warm maritime air masses can originate either from the subtropical Atlantic Ocean

or Gulf of Mexico, and cold maritime air masses can originate from the sub-polar regions of the

North Atlantic. Air masses that flow into Maine often originate in the prevailing westerlies (Amec 

Foster Wheeler, 2018).

The average temperature ranges from 10.8 degrees Fahrenheit (°F) in the winter to 77.3°F in the 

summer, with an annual average temperature of 44.3°F. Bangor receives an average annual 

precipitation in rainfall of 41.93 inches, and an average annual precipitation in snowfall of 66 

inches (National Oceanic and Atmospheric Administration, 2019). Rainfall is fairly evenly 

distributed throughout the year, with the wettest month being November, and the driest month 

being January. Snowfall generally occurs in November to April, with most snowfall occurring 

between December and March.

1.5.5 Current and Future Land Use

The MEARNG Bangor Training Site is used for the maintenance of rotary wing aircrafts and 

ground vehicles. Activities carried out at the facility include administrative and financial services, 

training of personnel, warehousing of supplies and equipment, building maintenance and repair, 

and vehicle maintenance and repair.

Land use around the Bangor Training Site is consistent with the city of Bangor Zoning for Airport 

Development District. The Bangor International Airport runway divides the eastern and western 

properties. The eastern property is located within the Bangor International Airport complex, which

is surrounded by mixed land use that includes commercial/industrial and business enterprise 

parks, a mobile home park and cemetery to the southwest, University College to the northeast, 

and Bangor Municipal Golf Course to the southeast. The MEANG Air Base and Bangor 

International Airport terminal and parking areas bound the eastern property to the northwest. The 

western property is bounded by the Bangor International Airport runway to the northeast, and by 

undeveloped and industrial areas in every other direction.

Prior to the opening of Bangor International Airport in 1931, the area surrounding the airport 

(including the Bangor Training Site western property) was primarily agricultural property. After the 

development of the airport, portions of the surrounding area were developed as industrial 
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property. In the early 1940s, the Dow Air Field Military Base was developed in the area as a 

military installation, which remained in operation until 1968. From 1968 to the present day, parcels 

of land associated with the former Dow Air Field Military Base have been developed as 

commercial properties (Summit Environmental Consultants, Inc., 2011).
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Figure 1-1

Facility Location

Legend

Facility Boundary

Bangor ANG Facility Boundary

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Miles

Bangor Training Site
&<

!P

!P

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Osgood Brook

Kenduskeag Stream

Shaw Brook

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Facility Boundary

Bangor ANG Facility

Boundary

Water Body

Wetland

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Inferred Groundwater

Flow Direction

Geology

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Figure 1-2

Groundwater Features

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Osgood Brook

Kenduskeag Stream

Shaw Brook

Lower Kenduskeag

Stream Watershed

Lower Souadabscook

Stream Watershed

Felts

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River Watershed

Domestic Channel

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Figure 1-3

Surface Water Features

0 1,400 2,800 5,600

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2. Fire Training Areas

No FTAs were identified at the Bangor Training Site eastern and western properties during the 

PA. MEARNG personnel confirmed that training with mobile AFFF fire extinguishers has never 

been performed by MEARNG on- or off-facility. Before mobile AFFF fire extinguishers were 

disposed of in 2012, they were tested by contractors off-facility. Because the MEANG fire 

department and City of Bangor Fire Department are responsible for providing emergency 

response in the vicinity of the MEARNG facility and the Bangor International Airport, the MEARNG 

has never trained with AFFF at the Bangor Training Site.

A former Dow Air Force Base (AFB) FTA exists off facility and west of the Bangor International 

Airport runway; this FTA is discussed further in Section 5.
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3. Non-Fire Training Areas

Non-FTAs on both the eastern and western properties of the Bangor Training Site were 

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

on Figure 3-1, with photographs appearing in Appendix C.

3.1 Bangor Training Site Eastern Properties

3.1.1 Building 254 (Cold Storage Hangar)

Building 254 is an aircraft hangar currently used for the cold storage of rotary wing aircraft located 

in the southeastern portion of the Bangor Training Site eastern property. The building was 

historically used for aviation maintenance but was transitioned to a cold storage hangar in the 

1980s. It contains a fire suppression system, including a 300-gallon tank containing Ansul Jet-X 

2% High Expansion Foam Concentrate, powered by diesel fire pumps and diesel fuel tanks. 

Additionally, five 55-gallon drums also containing Ansul Jet-X 2% High Expansion Foam 

Concentrate are stored within the building’s fire suppression system room. The Safety Data Sheet 

for the Ansul product stored in Building 254 (Appendix A) does not include PFAS in its 

composition, but only lists hazardous components. The Data Sheet for the product (Appendix A) 

states that it uses a hydrocarbon surfactant; however, no material information definitively states 

that Ansul Jet-X 2% High Expansion Foam Concentrate does not include PFAS. Additional dry 

chemical handheld fire extinguishers are stored within the building.

Building 254 is protected via a linear heat wire detection system. Triggering the heat wire detection 

system results in flooding the hangar bays with high expansion foam from the fire suppression 

system via overhead shafts. Annual, quarterly, and other regularly scheduled maintenance is

performed on the fire suppression system that does not result in suppression system contents 

releases.

According to the MEARNG Building Control Supervisor and Operations Officer, the building fire 

suppression system was tested once between 2013 and 2018. The test involved the full release 

of the 300-gallon high expansion foam tank and resulted in approximately 4 ft of standing foam 

inside the building. The test was completely enclosed, and sprayed foam was left to dry in place. 

After the foam dried, it was collected, containerized, and disposed of as municipal trash.

MEARNG personnel stated that the Jet-X 2% High Expansion Foam did not escape the building 

to site media during the release.

Floor drains in fire suppression room of the Building 254 discharge to the municipal sanitary 

system (CES, Inc., 2017). Stormwater runoff from areas west and south of Building 254 flows to 

catch basins south and west of the building. The catch basins direct stormwater via drainage 

pipes towards the southwest side of Building 260 and discharge to the Domestic Channel.

3.1.2 Building 260 (Army Aviation Support Facility)

Building 260 comprises the AASF on the Bangor Training Site eastern property, and it consists of 

hangars and landing pads for helicopters along with flight operations offices. Maintenance and 

repair on rotary wing aircraft are conducted in the three hangars at the AASF; helicopter refueling 

is conducted on the tarmac to the north and west of the AASF. Paved tarmac/apron areas along 

the south-southwest and north-northeast sides of the AASF serve as exterior staging/parking 

areas for rotary and fixed wing aircraft. The fire suppression system that serves the AASF hangars 

comprises two 1,200-gallon AFFF tanks: one tank contains National Foam Centurion 3% AFFF 

concentrate, the other contains Buckeye BFC-3.1 Platinum 3% AFFF concentrate. The deluge 

fire suppression system was installed in 2003 during the construction of new hangar space and 

is the only AFFF fire suppression system on the MEARNG property. Safety Data Sheets for 
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National Foam Centurion 3% AFFF concentrate and Buckeye BFC-3.1 Platinum 3% AFFF 

concentrate are included in Appendix A. Two 55-gallon storage drums that contain residual AFFF 

are also kept in the AASF fire suppression room. Water sprinklers service the AASF office and 

supply areas. The city of Bangor public water supply hydrant serves as the firefighting water 

source for the AASF. More than 100 dry chemical fire extinguishers are also staged throughout

the AASF. 

During the 2003 installation of the AFFF fire suppression system at the AASF, a small quantity of 

AFFF concentrate was inadvertently released from the AFFF tanks to pipes within the building. 

The exact volume of the release is unknown. MEARNG staff stated during interviews that AFFF 

did not migrate further than the building confines, and that the pipes AFFF was released to were 

replaced. 

In 2011, an incidental release of AFFF resulted from the malfunction of a gasket on one of the 

AFFF tank isolation valves. Approximately 1,200 gallons of Buckeye BFC-3.1 Platinum 3% AFFF 

concentrate were released, resulting in 7 ft of standing foam inside the fire suppression pump 

room. The AFFF drained into the fire suppression room floor drains and traveled via city sanitary 

system pipes to the city of Bangor treatment plant. No AFFF was observed to have escaped the 

fire suppression room. City sanitary system piping received all the released AFFF not captured in 

the fire suppression room.

In 2016, another incidental release from the AFFF tanks caused by triggering an incorrectly 

identified solenoid resulted in 30 gallons of Buckeye BFC-3.1 Platinum 3% AFFF solution spilling 

across the ramp outside the fire suppression room and into a sump designed to capture runoff. 

The AFFF solution escaped the suppression room through the 2-inch main drain line to the 

exterior ramp. According to MEARNG staff, the standing foam reached an approximate height of 

1 ft on the ramp outside the fire suppression room. The sump does not have an outlet or discharge 

drain. The AFFF solution in the sump did not reach a height capable of migrating to the main 

stormwater sewer. All AFFF was captured and contained within the ramp area and the sump, and 

the released AFFF was subsequently vacuumed out of the sump in a controlled manner.

Additionally, MEARNG staff confirmed that AFFF Tri-MaxTM fire extinguishers were previously 

stored on the parking areas at the AASF. Testing and maintenance of the mobile Tri-MaxTM fire 

extinguishers were performed off facility by private contractors. The Tri-MaxTM extinguishers were 

returned to the MEARNG Camp Keyes in 2012 under the purview of the US Property and Fiscal 

Office (USPFO). All AFFF procurement for the Bangor Training Site occurs through the USPFO.

A Flammable and Combustible Storage Building is present to the northeast of the AASF and is 

used for storage of POLs and small quantities of hazardous materials including alcohols, paints, 

and corrosives used at the AASF. As such, the AASF is considered a small quantity hazardous 

waste generator and has been assigned an individual hazardous waste generator.

The majority of AASF stormwater runoff is collected in catch basins and a storm drain southwest 

of the AASF, which discharges to a drainage channel. A small amount of storm water flows to the 

north of the AASF and is collected in a catch basin at the northwest corner of the AASF, which 

also flows to the drainage channel.

Oil water separators (OWSs) at the facility serve as secondary containment for spills associated 

with the AASF. Three 1,000-gallon OWSs are located outside of the AASF. The first OWS is 

located west of Hangar B and receives water from Hangar B’s floor drain system. The second 

OWS is located north of Hangar C and receives water from Hangar C’s floor drains and the indoor 

wash rack. The third OWS is located at the southeast corner of the AASF and receives water from 

the floor drains in Hangar A and the exterior helicopter engine wash rack. All three OWS’s 

discharge to the sanitary sewer.
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There are also two wash racks at the AASF. An exterior helicopter engine wash rack is located 

south of the AASF. Wash water generated at this wash rack flows through the OWS located near 

the southeast corner of the building prior to discharge to the sanitary sewer. An indoor wash rack 

located in the northwest corner of Hangar C drains to the OWS located north of Hangar C prior to 

discharge to the sanitary sewer system. 

3.1.3 Building 250 (FMS #3)

Building 250 comprises the FMS #3 at the Bangor Training Site and is located on the eastern 

property. Building 250 is used primarily for vehicle storage and maintenance. Unit-level 

maintenance is performed on engineering equipment, wheeled vehicles, material handling 

equipment, and power generators. Maintenance activities include filter and fluid changes, 

Preventative Maintenance Checks and Service, battery service, parts cleaning, and repairs. The 

FMS #3 is served by a water sprinkler fire suppression system. No AFFF is used or stored at 

Building 250. FMS #3 fire alarms alert the contracted local security company, which in turn 

evaluates the severity of the emergency and contacts the Bangor Fire Department as needed.

Dry chemical fire extinguishers are staged inside the building as well as outside in the fuel pump 

island area (CES, Inc., 2017).

Stormwater runoff at the FMS #3 is directed to a series of catch basins and storm drains east and 

south of Building 250. An under-drained soil filter northwest of FMS #3 receives stormwater runoff. 

This flow, along with aboveground flow and the storm drains, converge at a manhole-covered 

catch basin immediately west of FMS #3. Storm water flow is then discharged offsite into a 

drainage channel (CES, Inc., 2017).

Three OWSs are associated with FMS #3. One 350-gallon OWS is located inside FMS#3, near 

the interior, eastern wall. The two trench drains from the western section of the building flow into 

the OWS, which discharges to the sanitary sewer. A second 350-gallon OWS is located on the 

southwest exterior of the building. Trench drains in the eastern section of the building flow into 

this OWS before discharging to the sanitary sewer.

There is one wash rack at FMS #3 located outside and immediately south of the building. Wash 

water generated at this wash rack discharges directly to the sanitary sewer (CES, Inc., 2017).

3.1.4 Building 262 (Covered Fuel Truck Building)

The Covered Fuel Truck Building is located northeast of the Building 260 and includes a 

containment berm with an 8,000-gallon capacity and no drain outlet. The building accommodates 

up to six vehicles. Vehicles loaded with fuel are parked under cover and within a containment 

berm. The tankers are moved outside for fueling aircraft and then are moved back in the 

containment area. There is no fire suppression system at the Covered Fuel Truck Building; fire 

alarms notify the Bangor International Airport Crash Fire Department for emergency response. 

3.2 Bangor Training Site Western Properties

3.2.1 Armed Forces Reserve Center (AFRC)

The AFRC complex (approximately 4.5 acres) is located southwest of the Bangor International 

Airport runway, on the MEARNG Bangor Training Site western property. The AFRC includes the 

AFRC main building (classrooms and administrative offices), vehicle parking compounds, fueling 

pad, a covered wash rack, and a cold storage building. According to MEARNG staff, the covered 

wash rack has never been used for vehicle maintenance. The AFRC complex was constructed in 

1992, and according to MEARNG staff, has never been used for AFFF training or storage. No 

incidents have occurred at the AFRC complex that would require emergency response or fire 
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suppression. The City of Bangor Fire Department is responsible for responding to emergencies 

at the Bangor Training Site western property. The fire suppression system at the AFRC complex 

uses only water. No mobile AFFF fire extinguishers are stored at the complex, and the kitchen is 

supplied with Ansul K-Guard Fire Extinguishers. The Ansul K-Guard fire extinguisher is a Class A 

fire extinguisher that uses Ansulex Low pH Liquid Fire Suppressant. The data sheet for Ansulex 

Low pH Liquid Fire Suppressant is included in Appendix A.

3.2.2 Regional Training Institute (RTI)

The RTI complex (approximately 10 acres) is also located on the Bangor Training Site western 

property and includes the RTI building and associated paved parking areas. Construction of the 

RTI was completed in 2012, and similarly to the AFRC, MEARNG staff stated during interviews 

that the RTI has never been used for AFFF training or storage, nor have any incidents occurred 

requiring AFFF fire suppression. The fire suppression system at the RTI uses only water. No 

mobile AFFF fire extinguishers are stored at the complex, and the kitchen is supplied with 

compressed nitrogen fire extinguishers. The City of Bangor Fire Department is responsible for 

responding to emergencies at the RTI.

3.2.3 Baffled Small Arms Range

The MEARNG Bangor Training Site western property includes a baffled small arms range east of 

the AFRC complex, along the MEARNG property boundary with the Bangor International Airport 

runway. The area includes storage buildings, a storage container, a dry vault, and restroom, in 

addition to the range. The firing range was previously constructed as a wood-baffled range but 

has been reconstructed with steel baffles. MEARNG staff stated during interviews that no fire 

suppression system exists at the baffled small arms range, and that it has never been used for 

the AFFF training or storage. No information gathered during the VSI and interviews indicates that 

PFAS have been released to the environment at the baffled small arms range.
Building 260

Baffled Small Arms Range

RTI

AFRC

Building 254

Building 250 (FMS #3)

Building 262 (Covered Fuel Truck Building)

Kenduskeag Stream

ShawBrook

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No Suspected Release

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4. Emergency Response Areas

MEARNG and MEANG staff confirmed that no known crashes requiring AFFF fire suppression 

have occurred to their knowledge or during their collective tenure (spanning 1983-present) at the 

MEARNG Bangor Training Site properties. Emergency fire suppression systems have been 

incidentally triggered and released AFFF, but never in response to a true emergency. Numerous 

crashes have occurred at the Bangor International Airport; however, the use of AFFF in response 

to crashes is unknown.

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

release of PFAS to the environment in the form of AFFF. No locations involving the potential 

release of AFFF were identified within the MEARNG Bangor Training Site boundary during the 

VSI.
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5. Adjacent Sources

Several potential PFAS sources adjacent to the Bangor Training Site were identified during the 

PAand are discussed below. Figure 5-1 presents the location of potential adjacent PFAS sources.

5.1 Bangor Air National Guard Base

The Bangor ANG Base is located at the Bangor International Airport, approximately 0.5 miles 

northwest of the MEARNG Bangor Training Site eastern property. The Base encompasses 

approximately 314 acres of land leased from the city of Bangor and the Dow AFB. The MEANG 

has conducted a PA (BB&E, Inc., 2015) and an SI (Amec Foster Wheeler, 2018) for PFAS at the 

Bangor ANG Base (Appendix A). Based on the PA results, twelve areas at the MEANG facility 

were identified as potential PFAS release areas; they are identified in Table 5-1 below.

Table 5-1: Bangor Air National Guard Base PFAS Release Locations

Potential MEANG Release Area Nature of Release or Potential Release

Building 542 (Fuel Cell Repair 

Hangar)

Known release by AFFF fire suppression system during 

system testing.

Building 496 (Former Main 

Hangar)

Known releases of AFFF to interior trench drains and 

outside catch basins via fire suppression system.

Fire Department Current Nozzle 

Testing Location (East of Building 

542)

Known releases of PFAS to grass via nozzle testing with 

AFFF since 2000.

Fire Department Current Nozzle 

Testing Location (East End of 

Taxiway C)

Known releases of PFAS on paved area via nozzle 

testing with AFFF since 2000.

Fire Department Historic Nozzle 

Testing Location

Known releases of PFAS via historic nozzle testing.

Dry Detention Basin The basin receives drainage from known AFFF release 

areas (Fuel Cell Repair Hangar and Fire Department 

Current Nozzle Testing Locations).

Building 512 (Current Fire 

Department)

AFFF is stored and used within the building. Vehicle 

washing is also conducted within the building.

Former Fire Department AFFF was stored and used within the building. Vehicle 

washing was also conducted within the building.

Building 515 (Flight Line) Fire Department AFFF trailers are stored within the 

building.

Building 415 (Central 

Accumulation Point)

Used for waste AFFF storage.

Building 493 (Base Supply) Used for surplus AFFF storage.

Dry Detention Pond The dry detention pond receives drainage from known 

AFFF release areas (Historic Nozzle Testing Location)

Of the twelve areas listed above, the PA conducted by MEANG recommended moving forward to 

an SI at nine of the locations. The 2018 SI found no PFAS concentration exceedances of 

screening criteria in soil or sediment samples; however, PFAS concentrations in groundwater 
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exceeded the USEPA Drinking Water Health Advisory (70 ng/L) in samples collected at eight of 

the nine locations. Further groundwater and soil investigations were recommended by the SI at 

all nine locations, as well as a surface water investigation at one location (Amec Foster Wheeler, 

2018).

5.2 Fuel Strike Incident Location – Bangor International Airport

According to interviews with MEANG staff, a release of AFFF occurred in recent years within the 

Bangor International Airport property, on the tarmac area near the southwestern corner of the 

MEARNG Bangor Training Site eastern property. During construction activities, a fuel line was 

struck, causing a fuel release to the paved surface. The MEANG fire department responded to 

the incident by spraying AFFF across the fuel spill area to prevent a fire. The exact date of the 

incident as well as the volume and type of AFFF released are unknown. The area MEANG staff 

described where the incident occurred as a paved surface between the MEARNG property and 

the Bangor International Airport, south of the Domestic Channel. It is possible AFFF released to 

this area may have infiltrated the subsurface soil via cracks in the pavement, the grassy areas 

north and south of the incident, and the Domestic Channel.

5.3 Former Dow Air Force Base FTA

A former Dow AFB FTA exists off-facility, west of the Bangor International Airport runway, and east 

of the MEARNG eastern property. According to the 2011 Environmental Baseline Survey for the 

MEARNG Bangor Training Site western properties, the former Dow AFB FTA was used by the Air 

Force, the National Guard, and the city of Bangor for fire training from 1947 to 1984. During 

training, flammable liquids (including JP-4 fuel, cleaning solvents, hydraulic fluids, paint thinners 

and motor oil) and solid wastes (including fuel filters and tires) were burned or deposited at various 

pits within the FTA (Summit Environmental Consultants, Inc., 2011). MEANG fire department staff 

stated during interviews that the former FTA was used by the Air Force and city of Bangor for fire 

training. According to the MEANG 2015 PA, the FTA was located on property transferred from the 

Dow AFB to the MEANG, but it is unclear whether the MEANG ever used the FTA for training 

(BB&E, Inc., 2015). The property has since been relinquished by the MEANG. A Notice of 

Potential Liability from the MEDEP dated 17 October 2017 identifies the US Air Force, the 

MEANG, and city of Bangor as responsible parties under Maine’s Uncontrolled Hazardous 

Substance Sites law and CERCLA. The notice is included in Appendix A.

5.4 Waste Water Treatment Plant

There are no Waste Water Treatment Plants (WWTPs) at the MEARNG Bangor Training Site; 

however, the city of Bangor WWTP is located at 760 Main Street, Bangor, ME, approximately 2.3 

miles southeast of the MEARNG facility (Figure 1-3). The Bangor Training Site sanitary sewer 

system feeds into the city of Bangor sanitary sewer system which conveys waste water to the city 

of Bangor WWTP. The treated water is then released into the Penobscot River. Solids removed 

from the waste stream are dewatered and composted for reuse at a private composting facility.

Because onsite releases of AFFF at the MEARNG facility have resulted in AFFF entering the city 

sanitary sewer system, the city of Bangor WWTP is considered an adjacent source of potential 

PFAS release to the environment.

5.5 Landfills

There are no landfills on MEARNG Bangor Training Site properties. The nearest landfill that 

receives municipal waste from the city of Bangor is the Pine Tree Landfill, located at 358 Emerson 

Mill Rd, Hampden, ME, approximately 2.8 miles southwest of the Bangor Training Site western 

property.
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Landfills are not usually a primary potential release area of PFAS, but materials disposed of in 

landfills may create a secondary source of contamination. Such materials, to name a few, may 

include sludge from a WWTP that processes PFAS-laden water, used AFFF storage containers, 

or products associated with waterproofing uniforms or boots. At the Bangor Training Site, high 

expansion foam released as part of a Building 254 fire suppression system test was collected and 

disposed of as municipal waste; however, it is unknown whether Ansul Jet-X 2% High Expansion 

Foam Concentrate contains PFAS.
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Base Map: Sources: Esri, HERE, DeLorme, USGS, Intermap, increment P Corp.,

NRCAN, Esri Japan, METI, Esri China (Hong Kong), Esri (Thailand), MapmyIndia, ©

5/16/2019

1:142,779

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\ME\Bangor_Training_Site_Figures\Bangor_PA_Figures\Fig_5-1_Bangor_TS_Adjacent_Sources.mxd

Adjacent Sources

12420 Milestone Center Drive

Germantown, MD 20876

Former DOW

AFB FTA

Fuel Line

Strike Incident

MEANG Former

Fire Department MEANG Fire Department

(Building 512)

MEANG Fire Department Historic

Nozzle Testing Location

MEANG Dry

Detention Pond

MEANG Dry

Detention Basin

MEANG Building 542 (Fuel

Cell Repair Hangar)

MEANG Fire Department Current Nozzle

testing Location (East of Building 542)

MEANG Fire Department Current Nozzle

testing Location (East of Taxiway C) MEANG Building

515 (Flight Line)

MEANG Building 496

(Former Main Hangar)

MEANG Building

493 (Base Supply)

MEANG Building 415 (Central

Accumulation Point)

Bangor International Airport

Shaw

Brook

Domestic

Channel

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Bangor ANG Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

S haw B rook

Pine Tree

Landfill

Penobscot River

City of

Bangor WWTP

1

2

3

1

2

3

0 450 900 1,800

Feet
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

26

6. Preliminary Conceptual Site Model

Based on the PA findings, two potential PFAS release areas were identified within the MEARNG 

facility: AOI 1 - Building 260 (AASF) and AOI 2 - Building 254 (Cold Storage Hangar). The AOI 

locations are shown on Figure 6-1. The following sections describe the CSM components and 

the specific CSM developed for the AOIs. 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 is sparse and 

continues to be the subject of PFAS toxicological study (National Ground Water Association, 

2018). Receptors for the MEARNG Bangor Training Site include site workers, construction 

workers, and trespassers/recreational users. The preliminary CSM indicates which specific 

receptors could potentially be exposed to PFAS.

6.1 AOI 1 Building 260 (AASF)

AOI 1 is the Building 260 (AASF) complex. This complex includes the hangars and flight 

operations office space within the complex. AFFF releases at the AOI include a 2003 fire 

suppression system AFFF release contained to building pipes that have since been replaced, a 

2011 fire suppression system AFFF release to the fire suppression pump room and city sanitary 

sewer lines, and a 2016 fire suppression system AFFF release to the fire suppression pump room, 

ramp area outside the pump room, and runoff sump. 

Building 260 (AASF) is surrounded on all sides by pavement. According to MEARNG staff, AFFF 

releases at AOI 1 have been contained to the AASF interior, sanitary system pipes, and the ramp 

area and sump outside the fire suppression room. As such, surface soil at the AOI is considered 

an incomplete pathway for PFAS contamination to all receptors. No significant cracks in pavement 

were observed during the VSI, and the prevalence of pavement at the AOI inhibits subsurface 

migration. It is possible, however, that released AFFF may have infiltrated the subsurface via 

joints between areas that are paved with different materials. 

If AFFF released at the AOI infiltrated the subsurface, then ground-disturbing activities beneath 

the pavement may result in site and construction worker exposure to potential PFAS 

contamination in subsurface soil via ingestion and inhalation. Accidental ingestion of groundwater 

is also considered a complete pathway for exposure to PFAS during construction activities due to 

the shallow depth to groundwater beneath the adjacent MEANG facility and potential shallow 

groundwater beneath the MEARNG Bangor Training Site.

PFAS are water soluble and can migrate readily from soil to groundwater via leaching. Drinking 

water at the Bangor Training Site is predominantly provided by the Bangor Water District, but one

drinking water well that is known to contain groundwater with detectable PFAS concentrations

exists on the western property upgradient of AOI 1. Because PFAS releases at AOI 1 are unlikely 

to contribute to PFAS in the drinking water well, the source of PFAS in the drinking water is 

unknown. Although, the source of PFAS is unknown, PFAS exposure to site workers via 

groundwater is a complete pathway. 

Several domestic-use wells are listed in the Maine State database within a one-mile radius of the 

MEARNG properties; however, they are located at greater distances from the specific location of 

AOI 1, and are cross- or upgradient of the release area. If AFFF releases at the AOI infiltrated the 

subsurface, it is unlikely that PFAS migrated into groundwater within the vicinity of domestic wells. 

The pathway for off-facility resident exposure to PFAS in groundwater is considered incomplete. 
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

27

The majority of stormwater runoff at AOI 1 is collected in catch basins and a storm drain southwest 

of the AASF, which discharges to the Domestic Channel/Birch Stream. If any AFFF was not 

contained during the known releases, it is possible that PFAS migrated to into surface waters of 

the Domestic Channel/Birch Stream, and eventually the Kenduskeag Stream. As such, the

pathway for PFAS exposure to site workers and trespassers/recreational users via ingestion of 

surface water is considered potentially complete. The preliminary CSM for AOI 1 is shown on 

Figure 6-2.

6.2 AOI 2 Building 254 (Cold Storage Hangar)

AOI 2 is Building 254 (Cold Storage Hangar). The potential PFAS release at AOI 2 involves the

fire suppression system release of 300-gallons of Ansul Jet-X 2% High Expansion Foam 

Concentrate; it is unknown whether Ansul Jet-X 2% High Expansion Foam Concentrate contains 

PFAS. The test was confined by the hangar walls, and the dried foam was eventually

containerized and disposed of as municipal trash. If foam escaped during the release via floor 

drains, it entered into the municipal sanitary system.

Because the release was completely contained within the hangar walls, PFAS is not expected to 

have migrated to surface soil surrounding the hangar during the release; however, it is possible 

that residual PFAS was tracked out of the hangar during cleanup efforts. Potentially escaping 

PFAS may have infiltrated surface soil east of the hangar, or subsurface soil beneath the paved 

surface west of the hangar via the same mechanism as AOI 1. Surface soil at the AOI is 

considered a potentially complete pathway for PFAS exposure to site workers, construction 

workers, and trespassers/recreational users; subsurface soil is considered a potentially complete 

pathway to construction workers; and groundwater is considered a potentially complete pathway 

to construction workers via accidental ingestion during ground-disturbing activities. Although the 

release at AOI 2 is unlikely to be the source of PFAS in drinking water at the active upgradient 

well on the western property is unlikely, PFAS exposure to site workers via drinking water is a 

complete pathway.

If PFAS escaped the hangar during cleanup, it is possible that is migrated via surface water runoff 

to catch basins south and west of the building that discharge to the Domestic Channel/Birch 

Stream. Surface water is considered a potentially complete pathway for site workers and 

trespassers/recreational users.

If Ansul Jet-X 2% High Expansion Foam Concentrate escaped via floor drains, it may have 

migrated to sanitary sewer drains. The facility sanitary sewer system feeds into the city of Bangor 

sanitary sewer system which conveys waste water to the city of Bangor WWTP. The treated water 

is then released into the Penobscot River. As such, the pathway for PFAS exposure to off-facility 

recreational users via ingestion of surface water is considered potentially complete. The 

preliminary CSM for AOI 2 is shown on Figure 6-3.
Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\ME\Bangor_Training_Site_Figures\Bangor_PA_Figures\Fig_6-1_Bangor_TS_AOIs.mxd

­ Figure 6-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Bangor Training Site, ME

11/6/2019

11/6/2019

11/6/2019

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)

11/6/2019

1:142,779

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\ME\Bangor_Training_Site_Figures\Bangor_PA_Figures\Fig_6-1_Bangor_TS_AOIs.mxd

Area of Interest

12420 Milestone Center Drive

Germantown, MD 20876

!P

!P

!P

&<

Former DOW

AFB FTA

Fuel Line

Strike Incident

Building 260

MEANG Former

Fire Department

MEANG Fire Department

(Building 512)

MEANG Fire Department Historic

Nozzle Testing Location

MEANG Dry

Detention Pond

MEANG Dry

Detention Basin

MEANG Building 542 (Fuel

Cell Repair Hangar)

MEANG Fire Department Current Nozzle

testing Location (East of Building 542)

MEANG Fire Department Current Nozzle

testing Location (East of Taxiway C)

MEANG Building

515 (Flight Line)

MEANG Building 496

(Former Main Hangar)

MEANG Building

493 (Base Supply)

MEANG Building 415 (Central

Accumulation Point)

Baffled Small Arms Range

RTI

AFRC Bangor International Airport

Building 254

Building 250 (FMS #3)

Building 262

(Covered Fuel Truck Building)

Shaw

Brook

Lower Kenduskeag

Stream Watershed

Lower Souadabscook

Stream Watershed

Felts

Brook-Penobscot

River Watershed

AOI 1

AOI 2

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Bangor ANG Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow Direction

!P Commercial Well

!P Domestic Well

&<

Water Supply Well

Lower Souadabscook

Stream Watershed

Souadabscook Stream

Sha w

Brook

Pine Tree

Landfill

!P

Felts

Brook-Penobscot

River Watershed

Penobscot River

City of

Bangor WWTP

1

2

3 Shaw

B

or ok

Pug

Brook

W h eele r St ream

Penobscot River

KenduskeagSt ream

Lower Kenduskeag

Stream

Watershed

Lower Souadabscook

Stream Watershed

Felts

Brook-Penobscot

River Watershed

1

2

3

0 500 1,000 2,000

Feet

­
Media

SOURCE PATHWAY RECEPTOR

AOI 1 –

Building 

260 (AASF)

Accidental 

Fire 

Suppression 

System AFFF 

Releases

PFAS on 

Paved 

Surfaces/

Sanitary 

Sewers

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

Building 260 (AASF)

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
Media

SOURCE PATHWAY RECEPTOR

AOI 2 –

Building 

254 (Cold 

Storage 

Hangar)

Fire 

Suppression 

System Test 

Release

PFAS on 

Paved 

Surfaces/

Sanitary 

Sewers

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

Building 254 (Cold Storage Hangar)

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
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

31

7. Conclusions and Data Uncertainty

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

and storage of AFFF and other PFAS-related activities at the MEARNG Bangor Training Site. The 

PA findings are based on personnel interviews, environmental investigations and reports, 

historical documents, and the visual site inspection (Appendix A and Appendix B).

7.1 Conclusions

One AOI related to potential PFAS release was identified at the MEARNG Bangor Training Site

based on PA data (Figure 7-1) and is described in Table 7-1 below:

Table 7-1: Areas of Interest

Area of Interest Name Used by Potential Release Dates

AOI 1 Building 260 (AASF) MEARNG 203, 2011, 2016

AOI 1 Building 254 (Cold 

Storage Hangar) MEARNG 2013-2018

Based on known PFAS releases at AOI 1 and potential PFAS release at AOI 2, there is potential 

for exposure to PFAS contamination in surface soil to site workers, construction workers, and 

trespassers/recreational users via ingestion; subsurface soils to construction workers via 

inhalation and ingestion; surface water and sediment to site workers and trespassers/recreational 

users via ingestion; and in groundwater to construction workers via ingestion. Additionally, a 

groundwater drinking source on the Bangor Training Site western property is sampled quarterly 

for PFAS due to PFAS detections in drinking water during an ARNG 2017 sampling event. 

Although the known and potential PFAS releases at AOI 1 and AOI 2 are unlikely to have 

contributed to PFAS in groundwater on the western property, the pathway for PFAS exposure to 

site workers via ingestion of groundwater is complete. No known or documented AFFF releases 

have occurred on the western property. The source of PFAS in drinking water on the western 

property is unknown.

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

suspected release.

Table 7-2: No Suspected Release Areas

No Suspected 

Release Area Used By Rationale for No Suspected Release Determination

Building 250 (FMS #3) MEARNG Based on interviews and documentation, AFFF has 

never been stored or used at Building 250. The building 

relies on a water-only sprinkler system and dry chemical 

fire extinguishers.

Building 262 (Covered 

Fuel truck Building)

MEARNG Based on interviews and documentation, AFFF has 

never been stored or used at Building 262. No fire 

suppression system exists at the building.

Armed Forces 

Reserve Center

MEARNG Based on interviews and documentation, the AFRC has 

never been used for AFFF training or storage. No 

incidents have occurred at the AFRC complex that 

would require emergency response or fire suppression, 

and the fire suppression system at the AFRC complex 

uses only water.
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

32

Regional Training 

Institute

MEARNG Based on interviews and documentation, the RTI has 

never been used for AFFF training or storage. No 

incidents have occurred at the RTI that would require 

emergency response or fire suppression, and the fire 

suppression system at the AFRC complex uses only 

water.

Baffled Small Arms 

Range

MEARNG Based on interviews and documentation, the baffled 

small arms range has never been used for AFFF training 

or storage. No fire suppression system exists at the 

baffled small arms range.

Additionally, the adjacent Bangor Air National Guard Base has several documented releases of 

PFAS to the environment. According to the 2018 SI Report, AFFF releases at the adjacent 

MEANG facility have resulted in PFAS concentrations in groundwater exceeding the USEPA 

Drinking Water Health Advisory (70 ng/L). Further groundwater, soil, and surface water

investigations were recommended by the SI (Amec Foster Wheeler, 2018).

7.2 Uncertainty

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 MEARNG facility.

Historically, documentation of PFAS use was not required because PFAS were considered 

benign. Therefore, records were not typically kept by the MEARNG or available during the PA on 

the use of PFAS in training, firefighting, other non-traditional activities, or on its disposition.

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

with personnel who had direct knowledge of PFAS use at the facility. Sometimes the provided 

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

written documentation, the limited number of personnel with direct knowledge, the time passed 

since PFAS was first used (1969 to present), and a reliance on personal recollection. Inaccuracies 

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

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

how PFAS may enter the environment continually evolves.

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

of PFAS were reviewed, current personnel were interviewed from MEARNG and MEANG, 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

AOI 1 Building 260 

(AASF)

The volume of AFFF released to building pipes during the 2003 fire 

suppression system installation is unknown, as is the extent to which 

AFFF migrated during the release. No records exist for the 2011 and 

2016 AFFF release incidents. It is uncertain whether any AFFF 

solution released to the exterior ramp area migrated further than the 

ramp and sump. The migration of AFFF in sanitary sewer pipes is 

uncertain. It is unclear whether adjacent PFAS releases could have 

affected the MEARNG facility. 
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

33

Building 254 (Cold 

Storage Hangar)

Although Ansul Jet-X 2% High Expansion Foam Concentrate does not 

list PFAS compounds on its Safety Data Sheet, the sheet only lists 

hazardous components, and does not definitively state that it does 

not contain PFAS compounds. It is also unknown if Jet-X 2% High 

Expansion Foam could have escaped via runoff or on the feet of staff 

during the disposal effort following the system release. 

Bangor Training Site 

Facility-Wide

The only fixed AFFF fire suppression system at the MEARNG facility 

was installed in 2003; however, mobile Tri-Max AFFF fire 

extinguishers were previously stored at the facility. Use and storage 

practices pre-dating the tenure of MEARNG interviewees (2004-

present) are unknown. Tri-Maxes were relinquished in 2012.

Bangor Training Site 

Western Property

The source of PFAS in groundwater beneath the western property is 

unclear, and suspected to be an adjacent source. 

Fuel Strike Incident No emergency response record was available for the incident. The 

volume and type of AFFF used in response is unknown. It is unclear 

how AFFF was disposed of following the incident. 

Former Dow Air 

Force Base FTA

The use of AFFF during training events at the FTAis unknown. If used, 

the volume used over time and type frequently used are unknown. 

Bangor Air National 

Guard Base

The volume and type of AFFF released at each release location are

unknown. The migration pathways for PFAS at each release location 

is unknown. 

City of Bangor 

Wastewater 

Treatment Plant

The fate of PFAS reaching the WWTP is unclear; it may discharge to 

the Penobscot River. If PFAS is collected in biosolids removed from 

wastewater, it is unclear where biosolids are disposed of for 

composting.

Bangor International 

Airport

Numerous crashes have occurred at the Bangor International Airport, 

but the use of AFFF in response to crashes is unclear. Although no 

AFFF use in response to crashes at the MEARNG Bangor training 

Site has been confirmed, AFFF may have been used at various times 

in response to crashes elsewhere in the vicinity of the airport.

7.3 Potential Future Actions

Interviews with MEARNG facility staff whose first-hand knowledge at Bangor International Airport 

span 1997-present indicate that ARNG activities may have resulted in potential PFAS releases at 

AOI 1 and AOI 2 identified during the PA. Based on the preliminary CSM developed for the AOIs, 

there is potential for human receptors to be exposed to PFAS contamination in subsurface soil, 

surface water and sediment, and groundwater during construction activities. Table 7-4

summarizes the rationale used to determine if AOI 1 should be considered for further investigation 

under the CERCLA process and undergo a SI. 

Table 7-4: PA Findings Summary

Area of Interest AOI Location Rationale Potential Future Action

AOI 1 Building 

260 (AASF)

44°48'28.84"N;

68°48'39.94"W

Multiple AFFF releases from 

fire suppression system to 

floor drains and sumps

Proceed to an SI, focus on soil, 

surface water, sediment, and 

groundwater

AOI 2 Building 

254 (Cold Storage 

Hangar)

44°48'24.60"N;

68°48'31.46"W

Potential PFAS release 

during fire suppression 

system release

Proceed to an SI, focus on soil, 

surface water, sediment, and 

groundwater
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

34

ARNG will evaluate the need for an SI at AOI 1 and AOI 2 at the MEARNG Bangor Training Site 

based on the potential receptors, the potential migration of PFAS contamination off the facility, 

and the availability of resources.
Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\ME\Bangor_Training_Site_Figures\Bangor_PA_Figures\Fig_7-1_Bangor_TS_Summary.mxd

­ Figure 7-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Bangor Training Site, ME

11/6/2019

11/6/2019

11/6/2019

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)

11/6/2019

1:142,779

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Former DOW

AFB FTA

Fuel Line

Strike Incident

Building 260

MEANG Former

Fire Department

MEANG Fire Department

(Building 512)

MEANG Fire Department Historic

Nozzle Testing Location

MEANG Dry

Detention Pond

MEANG Dry

Detention Basin

MEANG Building 542 (Fuel

Cell Repair Hangar)

MEANG Fire Department Current Nozzle

testing Location (East of Building 542)

MEANG Fire Department Current Nozzle

testing Location (East of Taxiway C)

MEANG Building

515 (Flight Line)

MEANG Building 496

(Former Main Hangar)

MEANG Building

493 (Base Supply)

MEANG Building 415 (Central

Accumulation Point)

Baffled Small Arms Range

RTI

AFRC Bangor International Airport

Building 254

Building 250 (FMS #3)

Building 262 

(Covered Fuel Truck Building)

Shaw

Brook

AOI 1

AOI 2

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Bangor ANG Facility Boundary

Water Body

Wetland

River/Stream

Souadabscook Stream

Sha w

Brook

Pine Tree

Landfill

!P

Penobscot River

City of

Bangor WWTP

1

2

3

Shaw

Brook

Pug Brook

W h eele r St ream

Penobscot River

Kendus keagStream

1

2

3

0 500 1,000 2,000

Feet

­
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

36

8. References

ABB Environmental Services (ABB-ES), 1997. “Site Investigation Report, Volume 1 – Report,

101st Air Refueling Wing, Maine Air National Guard, Bangor International Airport, Bangor,

Maine. April 1997.

Amec Foster Wheeler, 2018. Final FY16 Phase 1 Regional Site Inspections for Perfluorinated

Compounds, Maine Air National Guard, 101st Air refueling Wing, Bangor Air National Guard Base, 

Bangor, Maine. March 9, 2018.

BB&E, 2015. Final Perfluorinated Compounds Preliminary Assessment Site Visit Report, Bangor 

Air National Guard Site, Bangor, Maine. December 2015.

CES, Inc., 2017. Integrated Contingency Plan, Maine Army National Guard Facility, Bangor 

International Airport, Bangor, Maine. June 2017.

Foster, L.E. and T.T. Smith, 1992. “Significant Sand and Gravel Aquifers in the Bangor

Quadrangle,” Maine Department of Environmental Protection and the USGS, Open File

Report No. 92-3.

Griffin, J.R. 1976. “Bedrock Geology of the Bangor Quadrangle, Maine,” Open File Report No.

76-23.

Hunt, C.B., 1974. National Regions of the United States and Canada, W.H. Freeman and

Company, San Francisco, CA, 725 pp.

Maine Army National Guard (MEARNG), 2015. Integrated Cultural resources Management Plan 

Update for Sites and Training Installations of the Maine Army National Guard, Fiscal Years 

2015-2019.

National Ground Water Association (NGWA). 2018. Groundwater and PFAS: State of 

Knowledge and Practice. January.

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

Maine, Bangor International Airport, ME, US. https://www.ncdc.noaa.gov/cdoweb/datatools/normals. Accessed June 2019. 

Prescott, G., 1964. Records of wells, springs, and test borings in the lower Penobscot River 

basin, Maine. July 1, 1964.

Summit Environmental Consultants, Inc., 2011. Environmental Baseline Study, Maine Army 

National Guard, Parcel 3, Bangor International Airport, Bangor, Maine. January 31, 2011.

Thompson, Woodrow B., 1977. “Surficial Geology of the Bangor Quadrangle, Bangor, Maine,”

Open File Report 77-24.

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

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

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

https://www.fws.gov/wetlands/data/mapper.html. Accessed February 2019.

United States Geospatial Survey, 1981. United States Geological Survey; Bangor Quadrangle 

7.5-minute series topographic quadrangle, revised 1981.
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

Appendix A

Data Resources
PFAS Preliminary Assessment Report

Bangor Training Site, ME

Data Resources will be provided separately on CD. Data Resources for Bangor Training Site

includes:

Facility Background Information Sources

• 2011 Environmental Baseline Study, Maine Army National Guard, Parcel 3, Bangor 

International Airport, Bangor, Maine

• 2015-2019 Integrated Cultural Resources Management Plan Update for Site and Training 

Installations of the Maine Army National Guard

• 2017 Integrated Contingency Plan, Maine Army National Guard Facility, Bangor 

International Airport, Bangor, Maine

Real Property Documents

• 2008 Department of the Army License for National Guard Purposes, Armed Forces Reserve 

Center, Bangor, Maine (No. DACA-33-3-08-123)

• MEARNG AFRC and Bangor Training Site Properties Map

• MEARNG Bangor Training Site East Parcel Title

• MEARNG Bangor Training Site East Parcel Map

Bangor Training Site EDR Report

• 2018 Bangor Training Site EDR Report 5484628

PFAS Analytical Data

• 2016-2018 PFOA and PFOS Sample Results at Bangor Training Site ETS Well

• May 16, 2017 MEARNG PFAS Analytical Data

• July 18, 2018 Per and Polyfluoroalkyl Substances (PFAS) Quarterly Sampling – 290 

Hildreth Street, Bangor, Maine

• October 15, 2018 Per and Polyfluoroalkyl Substances (PFAS) Quarterly Sampling – 290

Hildreth Street, Bangor, Maine

Firefighting Material Data Sheets

• 2015 Buckeye BFC-3.1 Platinum 3% AFFF Concentrate Data Sheet

• 2015 National Foam Centurion 3% AFFF Safety Data Sheet

• 2015 Ansul Jet-X 2% High Expansion Foam Concentrate Safety Data Sheet

• 2017 Ansul Jet-X 2% High-Expansion Foam Concentrate Data Sheet

Adjacent Source Investigations

• 2015 Bangor Air National Guard Base Perfluorinated Compounds Preliminary Assessment 

Site Visit Report

• 2018 Bangor Air National Guard Base FY16 Phase 1 Regional Site Inspections for 

Perfluorinated Compounds
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

Appendix B.1

Interview Records

PA Interview Questionnaire Facility:_Bangor Training Site

Interviewer:_Joe Witte_______

Date/Time:_10/25/2018; 09:00_

6. Are fire suppression systems currently charged with AFFF or have they been retrofitted for use of 

high expansion foam? If retrofitted, when was that done?

The fire suppression systems at Buildings 254 and 260 are charged with AFFF. AFFF is also stored in 

55 gallon drums at Building 254. 

7. How is AFFF procured? Do you have an inventory/procurement system that tracks use? 

AFFF is procured through the USFPO.

8. What type of AFFF has been/is being used (3%, 6%, Mil Spec Mil-F-24385, High Expansion)? 

Manufacturer (3M, Dupont, Ansul, National Foam, Angus, Chemguard, Buckeye, Fire Service Plus)?

Buckeye brand AFFF is stored at Building 254. Buckeye and National Foam AFFF is stored in 

the two AFFF storage tanks in Building 260.

9. Where is the AFFF stored? How is it stored (tanks, 55-gallon drums, 5-gallon buckets)? What 

size are the storage tanks? Is the AFFF stored as a mixed solution (3% or 6%) or concentrated 

material?

A 300 gallon tank of AFFF is stored in Building 254, along with several 55 gallon drums. Two 

1,200 gallon tanks of AFFF are stored in Building 260.

10. How many FTAs are/were on this facility and where are they? Locate on a map. How many FTAs 

are active and inactive? For inactive FTAs, when was the last time that fire training using AFFF 

was conducted at them? 

No FTAs exist at either the east or west Bangor properties. One FTA exists east of the western 

property (west of the runway) that has historically been used by other entities.
PA Interview Questionnaire Facility:_Bangor Training Site

Interviewer:_Joe Witte_______

Date/Time:_10/25/2018; 09:00_

11. When a release of AFFF occurs during a fire training exercise, now and in the past, how is the 

AFFF cleaned and disposed of? Were retention ponds built to store discharged AFFF? Was the 

AFFF trickled to the sanitary sewer or left in the pond to infiltrate?

Two events have resulted in MEARNG releases at the eastern Bangor property. During one incident, 

AFFF was released to drains that lead to City of Bangor water treatment; during the other incident, 

AFFF was captured in a sump that was vacuumed out in a controlled manner. A third release was 

planned as a test, and the AFFF was left to dry in the hangar (completely contained) and was then 

swept out and disposed of as solid waste (trash).

12. Can you recall specific times when city, county, and/or state personnel came on-post for training? If so, 

please state which state/county agency or military entity? Do you have any records, including 

photographs to share with us?

No known use of the MEARNG properties by other entities for training using AFFF.

13. Did military routinely or occasionally fire train off-post? List the units that you can recall used/trained 

at various areas.

MEARNG did not train with their mobile AFFF extinguishers. Testing occurred by contractors 

offsite. MEARNG did not train on or off-facility. Mobile AFFF extinguishers were disposed of 

through the USFPO in 2012. Because Air Guard FD was responsible for emergency response, 

MEARNG did not train with AFFF.

14. Did individual units come with their own safety personnel, did they also bring their own AFFF? Was 

training with AFFF part of these exercises? How were emergencies handled under these circumstances?

Not applicable.

15. Are there specific emergency response incident reports (i.e., aircraft or vehicle 

crash sites and fires)? If so, may we please copy these reports? Who (entity) was 

the responder?

See response to question 12. In 2011, 1,200 gallons of AFFF was released and 

reached the City of Bangor water treatment plant. In 2016, 30 gallons of 

AFFF was released to the ramp outside Building 260, but captured by the 

sump intake outside. 
PA Interview Questionnaire Facility:_Bangor Training Site

Interviewer:_Joe Witte_______

Date/Time:_10/25/2018; 09:00_

16. Do you have records of fuel spill logs? Was it common practice to wash away fuel spills with

AFFF? Is/was AFFF used as a precaution in response to fuel releases or emergency runway 

landings to prevent fires?

AFFF was not used to treat fuel spills. Fuel spill logs are unknown to exist.

17. Was AFFF used for forest fires or fire management on-post/off-post? If so, please describe what 

happened and who was involved?

No forest firefighting occurred at the facility. No known training occurred off-post.

18. Are there mutual aid/use agreements between county, city, and local fire department? Please list, even 

if informal. If formalized, may we have a copy of the agreement?

The Air Guard FD is responsible for emergency response at the MEARNG Bangor Training Site 

facilities.

19. Can you provide any other locations where AFFF has been stored, released, or used (i.e. hangars, 

buildings, fire stations, firefighting equipment testing and maintenance areas, emergency response

sites, storm water/surface water, waste treatment plants, and AFFF ponds)?

Storage of AFFF and its use at the Navy facility is captured in previously written reports.

20. Are you aware of any other creative uses of AFFF? If so, how was AFFF used? What entities were 

involved?

No known creative uses of AFFF.
PA Interview Questionnaire Facility:_Bangor Training Site

Interviewer:_Joe Witte_______

Date/Time:_10/25/2018; 09:00_

21. Are there past studies you are aware of with environmental information on plants/animals/ 

groundwater/soil types, etc., such as Integrated Cultural Resources Management Plans or Integrated 

Natural Resources Management Plans?

Environmental Baseline Study available through the Augusta office.

22. What other records might be helpful to us (environmental compliance, investigation records, admin 

record) and where can we find them?

Air Force PA reports already completed.

23. Do you have or did you have a chrome plating shop on base? What were/are the years of operation

of that chrome plating shop?

No.

24. Do you know whether the shop has/had a foam blanket mist suppression system or used a fume 

hood for emissions control? If foam blanket mist suppression was used, where was the foam 

stored, mixed, applied, etc.?

Not applicable,

25. How is off-spec AFFF disposed (used for training, turned in, or given to a local Fire Station)? If 

applicable, do you know the name of the vendor that removes off-spec AFFF? Do you have copies of 

the manifest or B/L?

USFPO is used for procurement of AFFF.
PA Interview Questionnaire Facility:_Bangor Training Site

Interviewer:_Joe Witte_______

Date/Time:_10/25/2018; 09:00_

26. Do you recommend anyone else we can interview? If so, do you have contact information for them?

Rob Coburn (MEARNG)

Air Force/Air Guard staff

Additional Notes:

• The 19.01 and 2.29 acre parcels on the Bangor East property are leased to the USACE.

• The 13.3 and 6.47 acre parcels are leased to the state of Maine or City of Bangor.

• The deluge system in Building 260 was installed in 2003 when the 2 hangars were 

renovated/constructed (Buildings 254 & 260).

• The Air Force Fire Department has been present at Bangor Airport for approximately 50 years.

• The maintenance area has an external wash rack. Water from the wash rack is directed to the city of 

Bangor treatment plant.

• The historic aviation maintenance transitioned to a cold storage hangar in the 1980s.

• The main portion of the historic aviation maintenance building was built in the 1970s. The rest of the 

building was built in 2004/2005.

• The administration building was once a ground vehicle maintenance building. Its previous use is 

unknown.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

Interviewee:_Rob Coburn_________________

Title:_Building Control/Maintenance Supervisor

Phone Number:__207-735-1186____________

Email:_______________________________

Can your name/role be used in the PA Report? Y or N 

Can you recommend anyone we can interview?

Y or N __Air Guard FD_____________________

1. Roles or activities with the Facility/years working at the Facility.

Building control supervisor with the MEARNG: 2007 to present

Air Force staff at Bangor: 21 years’ experience

2. Where can I find previous facility ownership information?

MEARNG Augusta office will have lease/ownership documents.

3. What can you tell us about the history of PFAS including aqueous film forming foam (AFFF) at the 

Facility? Was it used for any of the following activities, circle all that apply and indicate years of active 

use, if known? Identify these locations on a facility map. 

Maintenance – Yes, but no AFFF

Fire Training Areas – Across the runway there is an FTA. No MEARNG-used FTAs in the area

Firefighting (Active Fire) – Air Guard FD responds to emergencies. They carry AFFF.

Crash – No known MEARNG crashes resulting in fire suppression.

Fire Suppression Systems (Hangers/Dining Facilities) – Fire suppression in two hangars (Bldg 254 & 

260). Kitchens use Type K dry chemical fire suppression.

Fire Protection at Fueling Stations – No AFFF at fueling stations.

Non-Technical/Recreational/ Pest Management – No known creative uses of AFFF.

Metals Plating Facility – None known. Several other potential adjacent contributors.

Waterproofing Uniforms (Laundry Facilities) – None known.

Other

4. Fill out CSM Information worksheet with the Environmental Manager. 

5. Are any current buildings constructed with AFFF dispensing systems or fire suppression systems? 

What are the AFFF/suppression system test requirements? What is the frequency of testing the 

AFFF/suppression system? Do you have “As Built” drawings for the buildings?

Yes, Buildings 254 & 260 have fire suppression systems charged with AFFF. Building 254 also 

stores AFFF in 55 gallon drums. Parcel map of the Eastern property given to AECOM includes 

some technical drawings, but is not an as-built drawing.

No mobile AFFF extinguishers exist today at the property. They were relinquished in 2012.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

6. Are fire suppression systems currently charged with AFFF or have they been retrofitted for use of 

high expansion foam? If retrofitted, when was that done?

Yes, see answer to question 5. Annual, quarterly, and other regularly scheduled maintenance tests 

are performed on both systems. Building 254 underwent a full tank release as a test in the last 4-5 

years. The test resulted in approximately 4 feet of standing foam in Building 254. The foam was left 

in place, contained within the building to dry, and swept up and disposed as trash afterwards. No 

foam escaped the building during the test.

During the installation of the AFFF suppression system at Building 260, AFFF was inadvertently 

released to pipes within the building, but did not migrate further and the pipes were replaced.

7. How is AFFF procured? Do you have an inventory/procurement system that tracks use? 

AFFF is believed to be procured through the USFPO.

8. What type of AFFF has been/is being used (3%, 6%, Mil Spec Mil-F-24385, High Expansion)? 

Manufacturer (3M, Dupont, Ansul, National Foam, Angus, Chemguard, Buckeye, Fire Service Plus)?

National and Buckeye AFFF is stored at the Bangor MEARNG facility at Building 254 and 

Building 260.

9. Where is the AFFF stored? How is it stored (tanks, 55-gallon drums, 5-gallon buckets)? What 

size are the storage tanks? Is the AFFF stored as a mixed solution (3% or 6%) or concentrated 

material?

AFFF is stored in two large storage tanks in Building 260, and in one storage tank at Building 

254. AFFF is also stored in 55 gallon drums in Building 254.

10. How many FTAs are/were on this facility and where are they? Locate on a map. How many FTAs 

are active and inactive? For inactive FTAs, when was the last time that fire training using AFFF 

was conducted at them? 

No FTAs exist on MEARNG property. An FTA exists west of the runway, where it is believed 

the City of Bangor FD trained. Air Guard and Air Force use of the FTA is unknown. Before 

their disposal, mobile AFFF containers were tested off-facility by a contractor.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

11. When a release of AFFF occurs during a fire training exercise, now and in the past, how is the 

AFFF cleaned and disposed of? Were retention ponds built to store discharged AFFF? Was the 

AFFF trickled to the sanitary sewer or left in the pond to infiltrate?

AFFF is not used in fire training exercises by the MEARNG. During incidents at Building 260, AFFF 

concentrate has entered drains and traveled via city sewer drains to the City of Bangor treatment 

plant (2011) and across a ramp outside the hangar and into a sump that captured and contained the 

foam (2016).

12. Can you recall specific times when city, county, and/or state personnel came on-post for training? If so, 

please state which state/county agency or military entity? Do you have any records, including 

photographs to share with us?

No known training by non-MEARNG units on MEARNG property. The Bangor MEARNG property 

does not include training areas.

13. Did military routinely or occasionally fire train off-post? List the units that you can recall used/trained 

at various areas.

No MEARNG training occurred off-facility.

14. Did individual units come with their own safety personnel, did they also bring their own AFFF? Was 

training with AFFF part of these exercises? How were emergencies handled under these circumstances?

NA

15. Are there specific emergency response incident reports (i.e., aircraft or vehicle 

crash sites and fires)? If so, may we please copy these reports? Who (entity) was 

the responder?

No known MEARNG crashes resulting in AFFF release are known to have 

occurred. Incident reports for the releases already discussed may be available 

through the Augusta office.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

16. Do you have records of fuel spill logs? Was it common practice to wash away fuel spills with

AFFF? Is/was AFFF used as a precaution in response to fuel releases or emergency runway 

landings to prevent fires?

Washing fuel spills away with AFFF was not common practice, nor ever known to have been 

performed. Fuel spill logs may be included in the SPCC, available through the Augusta office.

17. Was AFFF used for forest fires or fire management on-post/off-post? If so, please describe what 

happened and who was involved?

No.

18. Are there mutual aid/use agreements between county, city, and local fire department? Please list, even 

if informal. If formalized, may we have a copy of the agreement?

A formal agreement between the Air Guard FD or City of Bangor FD may exist, but is not 

known of.

19. Can you provide any other locations where AFFF has been stored, released, or used (i.e. hangars, 

buildings, fire stations, firefighting equipment testing and maintenance areas, emergency response

sites, storm water/surface water, waste treatment plants, and AFFF ponds)?

All known releases already discussed. 

20. Are you aware of any other creative uses of AFFF? If so, how was AFFF used? What entities were 

involved?

No known creative uses of AFFF by MEARNG at the Bangor Training Site.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

21. Are there past studies you are aware of with environmental information on plants/animals/ 

groundwater/soil types, etc., such as Integrated Cultural Resources Management Plans or Integrated 

Natural Resources Management Plans?

An Air Force or Air Guard PA report has already been written for the use of AFFF at their adjacent 

properties. This may be available through contacts with those entities. 

22. What other records might be helpful to us (environmental compliance, investigation records, admin 

record) and where can we find them?

Augusta office would be best suited to provide documents from MEARNG.

23. Do you have or did you have a chrome plating shop on base? What were/are the years of operation

of that chrome plating shop?

No known chrome plating industry in the area.

24. Do you know whether the shop has/had a foam blanket mist suppression system or used a fume 

hood for emissions control? If foam blanket mist suppression was used, where was the foam 

stored, mixed, applied, etc.?

Air Guard properties believed to have roughly 4 times the amount of AFFF that MEARNG has at 

their facility.

25. How is off-spec AFFF disposed (used for training, turned in, or given to a local Fire Station)? If 

applicable, do you know the name of the vendor that removes off-spec AFFF? Do you have copies of 

the manifest or B/L?

AFFF is disposed of via the USFPO.
PA Interview Questionnaire Facility:_Bangor Training Site_

Interviewer:_Joe Witte________

Date/Time:__10/25/2018; 09:30_

26. Do you recommend anyone else we can interview? If so, do you have contact information for them?

Air Guard and Air Force staff would be a good resource for information on releases in the adjacent 

areas.
PA Interview Questionnaire – Fire Station Facility:_Bangor Training Site_

Interviewer:_Joe Witte_______

Date/Time:_8/25/2018_14:00_

Interviewee:_Scott Libby / Jeremiah Jordan __

Title:Asst. Chief Training & Safety / Asst. Chief

Phone Number:_________________________

Email:_______________________________

Can your name/role be used in the PA Report? Y or N 

Can you recommend anyone we can interview?

Y or N ___MEANG contact Winston_______

1. Roles or activities with the Facility/years working at the Facility.

Scott Libby: Air National Guard Fire Department Assistant Chief of Training and Safety – 1983 to 

present with MEANG. Also – Brunswick staff from 200-2003

Jeremeiah Jordan: Air National Guard Fire Department Assistant Chief

2. What can you tell us about the history of AFFF at the Facility? Was it used for any of the following 

activities, circle all that apply and indicate years of active use, if known? Identify these locations on a

facility map. 

Maintenance (e.g., ramp washing) – None at MEARNG facilities

Fire Training Areas – None at MEARNG facilities

Firefighting (Active Fire) – ANG FD responded to a fuel release by using AFFF to prevent fire

Crash – No known MEARNG crashes

Fire Suppression Systems (Hangers/Dining Facilities) – Yes, two hangars

Fire Protection at Fueling Stations – None known

Non-Technical/Recreational/ Pest Management – No

3. Are any current buildings constructed with AFFF dispensing systems or fire suppression systems? 

What are the AFFF/suppression system test requirements? What is the frequency of testing at the 

AFFF/suppression systems? 

Yes. Answer already known via interviews with MEARNG staff.

4. Are fire suppression systems currently charged with AFFF or have they been retrofitted for use of 

high expansion foam? 

Yes. Answer already known via interviews with MEARNG staff.

5. How is AFFF procured? Do you have an inventory/procurement system that tracks use? 

Answer already known via interviews with MEARNG staff.
PA Interview Questionnaire – Fire Station Facility:_Bangor Training Site_

Interviewer:_Joe Witte_______

Date/Time:_8/25/2018_14:00_

6. What type of AFFF has been/is being used (3%, 6%, Mil Spec Mil-F-24385, High Expansion)? 

Manufacturer (3M, Dupont, Ansul, National Foam, Angus, Chemguard, Buckeye, Fire Service Plus)?

Answer already known via interviews with MEARNG staff.

7. Is AFFF formulated on base? If so, where is the solution mixed, contained, transferred, etc.?

Unknown. Assumed to be mixed in the AFFF storage rooms.

8. Where is the AFFF stored? How is it stored (tanks, 55-gallon drums, 5-gallon buckets)? What 

size are the storage tanks? Is the AFFF stored as a mixed solution (3% or 6%) or concentrated 

material?

Answer already known via interviews with MEARNG staff.

9. How is the AFFF transferred to emergency response vehicles, suppression systems, flightline

extinguishers? Is/was there a specified area on the facility where vehicles are filled with AFFF and 

does this area have secondary containment in case of spills? How and where are vehicles storing 

AFFF cleaned/decontaminated?

MEARNG does not have any emergency response vehicles. AFFF is stored on ANG FD tucks in 

100 gallon tanks and in ANG buildings.

10. Provide a list of vehicles that carried AFFF, now and in the past, and where are/were they located? 

No MEARNG vehicles carry AFFF. MEANG CFR vehicle list not requested because MEANG is an 

adjacent source.

11. Any vehicles have a history of leaking AFFF? Do you/did you test the vehicles spray patterns to

make sure equipment is working properly? How often are/were these spray tests performed and can

you provide the locations of these tests, now and in the past?

The leak at Building 260 described by MEARNG staff was recounted. A leak in the suppression 

system at Building 260 resulted in the release of AFFF to city sewer lines, and traveled to the 

Bangor water treatment plant. Additionally, at the southwest corner of the MEARNG facility 

east property, a fuel line was struck in recent history. ANG FD used to prevent fire during the 

fuel spill incident and cleanup.
PA Interview Questionnaire – Fire Station Facility:_Bangor Training Site_

Interviewer:_Joe Witte_______

Date/Time:_8/25/2018_14:00_

12. How many FTAs are/were on this facility and where are they? Locate on a map. How many FTAs 

are active and inactive? For inactive FTAs, when was the last time that fire training using AFFF 

was conducted at them? 

No ANG FTAs exist at the facility. No ARNG FTAs exist at the facility. The Air Force uses the 

FTA across the runway to the west, along with the City of Bangor FD.

13. What types of fuels/flammables were used at the FTAs? 

NA

14. What was the frequency of AFFF use at each location? When a release of AFFF occurs during a fire 

training exercise, now and in the past, how is/was the AFFF cleaned and disposed of? Were 

retention ponds built to store discharged AFFF? Was the AFFF trickled to the sanitary sewer or 

left in the pond to infiltrate?

No AFFF use during any training. AFFF used by ANG to respond to fuel release at the southwest 

area of the MEARNG facility.

15. Are there mutual aid/use agreements between county, city, local fire department? Please list, even if 

informal. If formalized, may we have a copy of the agreement? Can you recall specific times when city, 

county, state personnel came on-post for training? If so, please state which state/county agency, 

military entity? Do you have any records, including photographs to share with us?

MEARNG Augusta may be able to provide agreement between MEARNG and ANG FD or City of 

Bangor FD.

16. Did individual units come on-post with their own safety personnel, did they also bring their own AFFF? 

Was training with AFFF part of these exercises? How were emergencies handled under these 

circumstances?

ANG FD staff provide their own AFFF and safety personnel when responding to emergencies. 
PA Interview Questionnaire – Fire Station Facility:_Bangor Training Site_

Interviewer:_Joe Witte_______

Date/Time:_8/25/2018_14:00_

17. Did military routinely or occasionally fire train off-post? List units that you can recall used/trained at 

various areas.

MEARNG does not train off-post with AFFF. MEANG does not use the FTA west of the runway.

18. Are there specific emergency response incident reports (i.e., aircraft or vehicle crash sites and fires)? If 

so, may we please copy these reports? Who (entity) was the responder?

Specific emergency response reports may be available through MEARNG.

19. Do you have records of fuel spill logs? Was it common practice to wash away fuel spills with

AFFF? Is/was AFFF used as a precaution in response to fuel releases or emergency runway 

landings to prevent fires?

Fuel spill response involving AFFF southwest off of the MEARNG facility will be requested.

20. Was AFFF used for forest fires or fire management on-post/off-post? If so, please describe what 

happened and who was involved?

No

21. Can you provide any other locations where AFFF has been stored, released, or used (i.e. hangars, 

buildings, fire stations, firefighting equipment testing and maintenance areas, emergency response

sites, storm water/surface water, waste water treatment plants, and AFFF ponds)?

No other known locations at the MEARNG facilities. ANG stores its own AFFF, along with the Air 

Force.
PA Interview Questionnaire – Fire Station Facility:_Bangor Training Site_

Interviewer:_Joe Witte_______

Date/Time:_8/25/2018_14:00_

22. Are you aware of any other creative uses of AFFF? If so, how was AFFF used? What entities were 

involved?

No

23. How is off-spec AFFF disposed (used for training, turned in, or given to a local Fire Station)? If 

applicable, do you know the name of the vendor that removes off-spec AFFF? Do you have copies of 

the manifest or B/L?

ANG AFFF disposal is unknown. 

24. Do you recommend anyone else we can interview? If so, do you have contact information for them?

Air Force staff
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

Appendix B.2

Visual Site Inspection Checklists








PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

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?

Bangor Training Site

The facility was identified as a training site with an AASF. Additionally, a confirmed AFFF

release has occurred at a former FTA less than 2,000 feet east of the facility.

Air National Guard presence, former Air Force presence, airport activities, private aviation industry, police training activities, city fire department fire training

No FTAs on MEARNG property, but adjacent

NA. Fire training by non-MEARNG did occur off-facility in several areas

NA

Eastern property: northeast via drainage channel; Western property: south

via Shaw Brook

41.93 inches

Flooding is uncommon

Pathway to drainage ditch on Eastern property is incomplete

Indirect pathway to Kenduskeag Stream/Penobscot River

Numerous water bodies/wetlands on Western property

No detention ponds, but a drainage channel and catch basin network

Most likely, but unknown

On eastern half of runway surface water drains to drainage channels. On western half several

wetlands and receive runoff
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?

Southeast

8-23 feet bgs at adjacent ANG property

Drinking water provided by Bangor Water District.

Unknown.

Supply well used for monitoring on western property

No

Yes, but the single well is unused due to PFAS presence

No

Cross-gradient

WWTP located approximately 2.5-3 miles southeast

Solids removed are composted for

reuse at a private composting facility final destination unknown

Potentially

Non-MEARNG Firefighting equipment is washed at adjacent locations

NA
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?

For releases that have occurred on MEARNG facility

No - releases were captured within facility pipes and/or facility sumps

Yes (potentially) - if construction work occurs in subsurface soil

No - recreational use of facility or immediately surrounding areas doesn't occur

Yes (potentially) - If releases result in subsurface/gw migration to off-facility residential wells

Yes (potentially) - If off-facility residential wells are used by children

Yes (potentially) - In wetlands near western property (due to adjacent releases)

Northern Light Pediatric Primary Care, All Saints Catholic School, Messiah Baptist Church

Unknown
PFAS Preliminary Assessment Report

Bangor Training Site, Bangor, ME

Appendix C

Photographic Log
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 1

Description:

Bangor Training Site Building 

254 used for aviation 

maintenance and cold storage. 

View facing south.

10/25/2018

Photograph No. 2

Description:

High expansion foam

suppression system storage 

room in Building 254.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 3

Description:

55 gallon drums containing 

high expansion foam

concentrate in the fire 

suppression system storage 

room of Building 254.

10/25/2018

Photograph No. 4

Description: 

AFFF Storage Tank 01 in the 

Building 260 Fire Suppression 

System Storage room.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 5

Description:

AFFF Storage Tank 02 in the 

Building 260 Fire Suppression 

System Storage room.

10/25/2018

Photograph No. 6

Description:

Floor drain in the AFFF Fire 

Suppression System Storage 

Room in Building 260.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 7

Description:

55 gallon drums for storage of 

residual AFFF concentrate in 

the AFFF Fire Suppression 

System Storage Room in 

Building 260.

10/25/2018

Photograph No. 8

Description:

Drainage pipe on the outside 

of the Building 260 AFFF Fire 

Suppression System Storage 

Room. AFFF escaped through 

pictured outlet during 

accidental release in 2016. 

Estimated 30 gallons of AFFF 

concentrate released.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 9

Description:

Ramp area outside Building 

260 AFFF Fire Suppression 

System Storage Room. 

Pictured area includes the 

extent to which AFFF 

concentrate was released 

during incident in 2016. 

Released AFFF was captured 

by the sum drain pictured at 

bottom right.

10/25/2018

Photograph No. 10

Description:

Floor drains in Building 260 

hangar area.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 11

Description:

Amerex Model 497 mobile 

fire extinguisher staged in the 

Building 260 hangar area.

10/25/2018

Photograph No. 12

Description:

MEARNG Bangor Regional 

Training Institute (RTI) on the 

western MEARNG property in 

Bangor. View facing 

northeast.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 13

Description:

Compressed nitrogen fire 

extinguisher in the MEARNG 

RTI kitchen area.

10/25/2018

Photograph No. 14

Description:

Fire Suppression System 

Storage Room at the 

MEARNG RTI. Pictured 

system uses only water.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 16

Description:

Fire training area (FTA) on 

west side of Bangor 

International Airport runway. 

Wooden pallets pictured at 

right; earthen berm pictured at 

left. No known use of FTA by 

MEARNG. View facing east.

10/25/2018

Photograph No. 16

Description:

Monitoring well adjacent to 

FTA west of Bangor 

International Airport runway.

View facing east.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 17

Description:

Vehicle maintenance area at 

the Navy/MEARNG the 

Armed Forces Reserve Center 

(AFRC) on the western 

MEARNG property in 

Bangor. Maintenance area 

never used for vehicle 

maintenance. View facing 

northwest.

10/25/2018

Photograph No. 18

Description:

“Type K” fire extinguisher in 

the MEARNG AFRC kitchen.

10/25/2018
Preliminary Assessment Report

Bangor Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Bangor Training Site Penobscot County, Maine

Photograph No. 19

Description:

Fire Suppression System 

Storage Room at the 

MEARNG AFRC. Pictured 

system uses only water.

10/25/2018

Photograph No. 20

Description:

Maintenance bay door at the 

Navy/MEARNG AFRC. 

Maintenance area outside door 

unused for vehicle 

maintenance. View facing 

south.

10/25/2018