Final

Preliminary Assessment Report

Tupelo Army Aviation Support 

Facility No. 2,

Tupelo, Mississippi

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

July 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

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

Tupelo AASF, Mississippi

i

Table of Contents

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

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

Authority and Purpose ..............................................................................................4

Preliminary Assessment Methods .............................................................................4

Report Organization ..................................................................................................5

Facility Location and Description...............................................................................5

Facility Environmental Setting ...................................................................................5

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

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

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

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

1.5.5 Current and Future Land Use .........................................................................7

2. Fire Training Areas ...........................................................................................................11

Release Area A – Wash Rack .................................................................................11

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

Release Areas B and C – Hangar Suppression System Test...................................13

Release Area D – Bladder Rupture Release ...........................................................13

No Suspected Release Area A – Hazardous Waste Storage Building .....................13

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

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

Tupelo Regional Airport Fire Department ................................................................17

Tupelo Regional Airport ...........................................................................................17

Old AASF Property and Hangar ..............................................................................17

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

AOI 1 Western Release Areas ................................................................................19

AOI 2 Bladder Rupture Release ..............................................................................20

7. Conclusions .....................................................................................................................24

Findings ..................................................................................................................24

Uncertainties ...........................................................................................................24

Potential Future Actions ..........................................................................................25

8. References ......................................................................................................................28
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

ii

Tables

Table ES-1 AOIs at Tupelo AASF

Table 7-1 AOIs at Tupelo AASF

Table 7-2 No Suspected Release Areas

Table 7-3 Uncertainties

Table 7-4 PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, Tupelo AASF

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 2-1 Fire Training Area

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model, AOI 1 Western Release Areas

Figure 6-3 Preliminary Conceptual Site Model, AOI 2 Bladder Rupture Release

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

Tupelo AASF, Mississippi

iii

Acronyms and Abbreviations

°F degrees Fahrenheit

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI Area of Interest

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

HA USEPA lifetime Drinking Water Health Advisory

MDEQ Mississippi Department of Environmental Quality

MSARNG Mississippi Army National Guard

NFPA National Fire Protection Association

OWS oil/water separator

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

VSI Visual Site Inpsection
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

1

Executive Summary

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

Army National Guard (ARNG) G9 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 polyfluoroalkyl 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 the current Army Aviation Support Facility (AASF) No. 2

(also referred to as the “facility”) in Tupelo, Mississippi, to assess potential PFAS release areas

and exposure pathways to receptors. The current AASF was constructed in 2011 on a two parcel,

38.9-acre area of land leased from the Tupelo Airport Authority by the State of Mississippi in 2007.

The performance of this PA included the following tasks:

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

· Conducted a site visit on 5 March 2019;

· Interviewed current Tupelo AASF Mississippi ARNG (MSARNG) and Tupelo Regional Airport

personnel during the site visit;

· Completed visual site inspections at known or suspected PFAS release locations and

documented with photographs;

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

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

Two AOIs related to a potential PFAS releases were identified at the Tupelo AASF during the PA.

The AOIs are shown on Figure ES-1 and described in Table ES-1 below:

Table ES- 1: AOIs at Tupelo AASF

Area of Interest Name Used by Potential Release Date

AOI 1 Western Release

Areas MSARNG Since October 2010

AOI 2 Bladder Rupture

Release MSARNG November 2011

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

contamination in surface soil to site workers, construction workers, residents, and trespassers via

ingestion and inhalation of dust; surface water and sediment to site workers, construction workers,

trespassers, and off-facility residents and recreational users via ingestion; subsurface soil to 

construction workers via ingestion; and groundwater to off-facility residents via ingestion. Potential

off-facility PFAS release areas exist adjacent to the current Tupelo AASF. Interviewees confirmed

that AFFF has been released to the environment in these adjacent areas. The preliminary CSM

for Tupelo AASF is shown on Figure ES-2.

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

PFAS were detected in a public water system above the USEPA lifetime Drinking Water Health

Advisory within 20 miles of the facility.
Old AASF

Hangar

Old AASF

Property

Tupelo Regional

Airport FD

Tupelo

Regional

Airport

Littl e Co onewah Creek

Russell Cre ek

AOI 1 AOI 2

0 700 1,400 2,800

Feet

W Jackson Street Ext

No Suspected

Release Area A

Release

Area A

AOI 1

AOI 2

Release

Area D

Release

Area C

Release

Area B

­ Figure ES-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Tupelo AASF, MS

7/1/2020

7/1/2020

7/1/2020

MS

JH

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)

7/1/2020

1:2,880

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_ES-1_Tupelo_AASF_Summary.mxd

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Area of Interest

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

0 120 240 480

Feet

2
Media

SOURCE PATHWAY RECEPTOR

AOI 1 &

AOI 2

Fire Training

Areas; Systems

Testing; Bladder

Rupture

PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOIs

Surface

Water/

Sediment

Shallow

Groundwater

Subsurface

Soil

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

LEGEND

Figure ES-2

Preliminary Conceptual Site Model

Tupelo AASF

Potential

Off-Facility

Source Not

under

Control of

ARNG

/ /

/ / /

Ingestion

/

/

/ / / /

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.

/ / /

/ / / /

/

/

3
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

4

1. Introduction

Authority and Purpose

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

Army National Guard (ARNG) G9 contracted AECOM Technical Services, Inc. (AECOM) to 

perform Preliminary Assessments (PAs) and Site Inspections (SIs) for Perfluorooctanesulfonic 

acid (PFOS) and Perfluorooctanoic acid (PFOA) Impacted Sites at ARNG Facilities Nationwide 

under Contract Number W912DR-12-D-0014, Task Order W912DR17F0192, issued 11 August 

2017. The ARNG is assessing potential effects on human health related to processes at facilities 

that used per- and polyfluoroalkyl substances (PFAS), primarily in the form of aqueous film 

forming foam (AFFF) released as part of firefighting activities, although other PFAS sources are 

possible. In addition, the ARNG is assessing businesses or operations adjacent to the ARNG 

facility (not under the control of ARNG) that could potentially be responsible for a PFAS release. 

PFAS are classified as emerging environmental contaminants that are garnering increasing 

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

formulations contain highly diverse mixtures of compounds. Thus, the fate of PFAS compounds 

in the environment varies. The regulatory framework at both federal and state levels continues to 

evolve. The US Environmental Protection Agency (USEPA) issued lifetime Drinking Water Health 

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

national standards regulating PFAS in drinking water. 

This report presents the findings of a PA for PFAS at the Army Aviation Support Facility (AASF) 

No. 2 (also referred to as the “facility”) in Tupelo, Mississippi, 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 a known fire training area (FTA) as well as other locations where PFAS may 

have been released into the environment at the current AASF. The term PFAS will be used 

throughout this report to encompass all PFAS chemicals being evaluated, including PFOS and 

PFOA, which are key components of AFFF.

Preliminary Assessment Methods

The performance of this PA included the following tasks: 

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

· Conducted a site visit on 5 March 2019;

· Interviewed current Mississippi ARNG (MSARNG) AASF and Tupelo Regional Airport 

personnel during the site visit; 

· Completed visual site inspections (VSI) at known or suspected PFAS release locations and 

documented with photographs; 

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

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

Tupelo AASF, Mississippi

5

Report Organization

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

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

of each are as follows:

· Section 1 – Introduction: identifies the project purpose and authority and describes the 

facility location, environmental setting, and methods used to complete the PA

· Section 2 – Fire Training Areas: describes the FTAs at the facility identified during the site 

visit 

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

at the facility identified during the site visit 

· Section 4 – Emergency Response Areas: describes areas of potential PFAS release at the 

facility, specifically in response to emergency situations 

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

facility that are not under the control of ARNG 

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

and receptors for the AOIs and the facility 

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

PA 

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

Facility Location and Description

The Tupelo AASF No. 2 is located on the eastern side of Tupelo Regional Airport in Lee County, 

Tupelo, Mississippi (Figure 1-1). The AASF is situated approximately 1.5 miles south of 

McCullough Boulevard and 1 mile west of Natchez Trace Parkway. Construction of the current 

AASF was finished in 2011, and the AASF encompasses 38.99 acres. According to leasing 

documents, the land has been leased to the State of Mississippi from the Tupelo Airport Authority 

since December 2007. The term of the lease is 40 years and is set to end on 10 December 2047. 

Prior to construction of the current facility, the old AASF was operated by the MSARNG from the 

1960s to 2008 and was located at the southern end of the airport, approximately 0.5 miles south 

of its current location; it is currently privately owned by an aviation salvage company.

The mission of the facility is to support the supervision and coordination of matters concerning 

the operations and use of ARNG aviation. The AASF houses multiple guard units and repairs and 

maintains aircraft. The building was designed to be a state emergency mobilization site for the 

state of Mississippi and operates in a dual role as an emergency center and AASF. 

Facility Environmental Setting

Tupelo is in the Black Belt Prairie physiographic region, which is a crescent-shaped region 

approximately 25 miles wide that stretches from Alabama, through northeastern Mississippi, into 

southern Tennessee. The Black Belt Prairie is characterized by its dark, fertile soil used primarily 

for farmland, and it is underlain by Cretaceous-aged geologic units (National Aeronautics and 
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

6

Space Administration, 2018). The facility sits at an elevation of about 330 to 350 feet above mean

sea level.

1.5.1 Geology

Tupelo is situated on top of the Cretaceous-aged Selma Group, with locally overlying yellowishorange alluvium deposits composed primarily of clay, silt, and sand. The Selma Group has three

members: the Demopolis Chalk, the Coffee Sand, and the Mooreville Chalk. In the eastern section

of the Tupelo 7.5-minute Quadrangle, Coffee Sand outcrops are present. In the western section,

closer to the AASF, Demopolis Chalk outcrops are present (Mississippi Department of

Environmental Quality [MDEQ], 2019a). The Selma Group overlies the Eutaw and Tuscaloosa

formations. Mineral resources in Lee County include limestone, water, and rocks with sufficient

calcium and aluminum silicates to manufacture mineral wool (Mississippi State Geological Survey,

1946).

1.5.2 Hydrogeology

The AASF sits atop the Coffee Sand, Eutaw-McShan, and Gordo (part of the Tuscaloosa

formation) aquifers and may also overly the Paleozoic aquifer, although its lateral extent is not

fully known (MDEQ, 2014; Strom and Mallory, 1995). The Paleozoic aquifer system consists of

chert beds, sandstone, shale, and limestone, whereas the Gordo, Eutaw-McShan, and Coffee

Sand aquifers consist mostly of clay, sand, and, in the case of the Coffee Sand aquifer, sandstone

(O’Hara, 1996).

The Eutaw-McShan aquifer is confined by the Mooreville Chalk, which ranges in thickness from

approximately 115 to 160 feet (MDEQ, 2019a). Various sources disagree with the latitude at which

the Mooreville Chalk becomes absent. Boswell (1976) states that the Mooreville Chalk is absent

at Tupelo and to the north of the city, meaning that the Coffee Sand and Eutaw-McShan aquifers

are hydraulically connected. However, Strom and Mallory (1995) state that the disappearance of

the Mooreville Chalk occurs at a latitude close to the Union-Pontotoc county boundary, meaning

the Eutaw-McShan aquifer is confined at Tupelo. Additionally, the Tupelo 7.5-minute quadrangle

map identified the Mooreville Chalk in Tupelo (MDEQ, 2019a), further suggesting the EutawMcShan is confined at the Site.

The 2014 MDEQ groundwater assessment surveyed a few wells within Lee County that were

tapping into the Coffee Sand, Eutaw-McShan, and Gordo aquifers. The surveyed wells collecting

water in the Coffee Sands aquifer were 147 and 200 feet below ground surface (bgs), 606 feet

bgs in the Eutaw-McShan aquifer, and 669 feet bgs in the Gordo aquifer. No recent local

groundwater studies/data were available. The inferred direction of groundwater flow is assumed

to flow south/southeast (Figure 1-2). It is possible that the groundwater may locally flow to the

southwest, towards Russell Creek, based on the proximity of the watershed divide.

No potable water wells are located within facility boundaries. Drinking water at the AASF and town

is supplied by the City of Tupelo, which purchases drinking water from the Northeast Mississippi

Regional Water District, who obtains the water from the Tombigbee River, approximately 18 miles

to the east. However, a domestic well exists approximately 400 feet east of the facility boundary

(Figure 1-2) and is completed within the Eutaw-McShan aquifer at 550 feet bgs. The US

Geological Survey (USGS) National Ground Water Information System (USGS, 2019) and the

MDEQ Borehole Collection (2019b) provide borehole data for wells around Tupelo. No wells

downgradient of the AASF that collect water at depths less than 400 feet bgs have been identified,

suggesting that none of the identified wells are collecting water in the Coffee Sand aquifer. Based

on the research presented above, these wells should be confined in the Eutaw-McShan aquifer.

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

PFAS were detected in a public water system above the HA within 20 miles of the facility.
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

7

1.5.3 Hydrology

The AASF is situated within the eastern portion of Kings Creek-Town Creek Watershed; the Little 

Coonewah Creek-Coonewah Creek watershed is present to the west of the facility and bisects

the Tupelo Regional Airport (Figure 1-3). Local surface water features include small, unnamed

ponds and tributaries that flow into Kings Creek. A drainage ditch associated with one of the

unnamed tributaries runs along the eastern facility boundary and flows north. Stormwater at the

AASF is directed towards one of two retention ponds located within the northeastern portion of

the facility. These retention ponds overflow into the drainage ditch system that flows north before

joining Kings Creek to the northeast and ultimately flows southeast through the city of Tupelo.

1.5.4 Climate

The humid subtropical climate at Tupelo AASF is characterized as having long, hot summers, and

a relatively short, mild winter (Mississippi State Geological Survey, 1946). The average

temperature is 73.4 degrees Fahrenheit (°F). Seasonally, temperatures vary from a summer

average monthly high of 92 °F to a winter average monthly low of 32 °F. Average precipitation is

55 inches (World Climate, 2019).

1.5.5 Current and Future Land Use

The AASF is a controlled access facility and is located adjacent to the Tupelo Regional Airport.

The Tupelo Regional Airport is owned and operated by the Tupelo Airport Authority. The AASF

operates in a dual role as a state emergency center and AASF. Reasonably anticipated future

land use is not expected to change from the current land use.
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JH

11/11/2019

11/11/2019

Preliminary Assessment for PFAS at Tupelo AASF, MS

11/11/2019

1:63,360 ­ Figure 1-1 PM RG 11/11/2019

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

^_

Tupelo AASF

PROJECT

0 0.5 1 2

Miles

Legend

Facility Boundary

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_1-1_Tupelo_AASF_Facility_Location.mxd

Tupelo Regional Airport

8
!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

!P

!P

!P

!P

!P

!P

!P

!P

!P

!P

A!

A!

A!

A!

A!

!P

!P

A!

A!

!5

!5

A!

!5

!P

!P

!P

!P

!P

!P

!P

!P

A!

A!

A!

A!

A!

A

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

Kings Creek

Little Coonewah Creek

Russell Creek

0 0.25 0.5 1

Miles

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Inferred Groundwater

Flow Direction

Geology

Demopolis Chalk

Coffee Sand

Wells

!P Domestic Well

A! Other/Unknown Well

Groundwater Features

Figure 1-2

CLIENT

REVISED

SCALE

6/30/2020 MS

JH

6/30/2020

6/30/2020

ARNG

GIS BY

CHK BY

TITLE

Preliminary Assessment for PFAS at Tupelo AASF, MS

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_1-2_Tupelo_AASF_Groundwater.mxd

PM RG 6/30/2020

1:31,680 ­ 12420 Milestone Center Drive

Germantown, MD 20876

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

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

9
Little Coonewah

Creek-Coonewah

Creek Watershed

Kings Creek-Town

Creek Watershed

Kings Creek

Little Coonewah Creek

Russell Creek

0 0.25 0.5 1

Miles

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow Direction

Surface Water Features

Figure 1-3

CLIENT

REVISED

SCALE

6/30/2020 MS

JH

6/30/2020

6/30/2020

ARNG

GIS BY

CHK BY

TITLE

Preliminary Assessment for PFAS at Tupelo AASF, MS

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_1-3_Tupelo_AASF_Surface_Water.mxd

PM RG 6/30/2020

1:31,680 ­ 12420 Milestone Center Drive

Germantown, MD 20876

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

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

10
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

11

2. Fire Training Areas

One FTA was identified within the current AASF facility during the PA through interviews. This FTA 

is described below and shown in Figure 2-1.

Release Area A – Tri-MaxTM Training

The current AASF houses eight to ten 30-gallon portable Tri-MaxTM units that are stored in the 

hangar unless needed on the flight line. Interviewees recalled that the AFFF originally stored 

within the Tri-MaxTM units was not freeze-resistant, and one canister froze, buckling the metal of 

the canister. Although the canister buckled, there was no breach or leak of the contents. The TriMaxTM units are recharged and refilled by a local fire service company in the city of Tupelo. An 

interviewee stated that training with an out of date Tri-MaxTM unit occurred once at the AASF. The 

training consisted of personnel discharging an unknown quantity of AFFF into the wash rack. The 

wash rack drains to an underground oil/water separator (OWS), which discharges to the sanitary 

sewer. Release Area A is shown on Figure 2-1 and includes the training area and the area 

immediately surrounding it.
W Jackson Street Ext

Release

Area A

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JH

6/30/2020

6/30/2020

Preliminary Assessment for PFAS at Tupelo AASF, MS

1:3,000

6/30/2020 ­ Figure 2-1

PM RG 6/30/2020

12420 Milestone Center Drive

Germantown, MD 20876

Fire Training Area

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

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

PROJECT

0 125 250 500

Feet

Legend

Potential PFAS Release

Facility Boundary

River/Stream

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_2-1_Tupelo_AASF_Fire_Training_Areas.mxd

12
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

13

3. Non-Fire Training Areas

Three non-FTAs where AFFF was stored and/or potentially released were identified during the 

PA. A description of each non-FTA is presented below and shown on Figure 3-1. 

Release Areas B and C – Hangar Suppression System Test

The AASF hangar is outfitted with a fire suppression system that consists of two 800-gallon AFFF 

tanks filled with Buckeye 3% Mil Spec; the system is supplied with water by two dedicated 93,000-

gallon water tanks. An initial system test was performed by a contractor in October 2010. 

Interviewees stated that the initial test was performed with foam, and an unknown quantity of 

AFFF was pumped out of the system by the contractor and directed towards a trench drain, which 

runs the length of the hangar bay doors. 

According to interviewees and the facility’s storm water pollution prevention plan, the trench drain 

flows to the OWS; however, in the event of activation of the fire suppression system, a trigger lock 

bypasses the OWS, and the trench drains are discharged to a retention pond in the northern area 

of the facility. In this event, a manual valve on the retention pond is supposed to be closed in order 

to prevent the AFFF and water from leaving the property until the release can be cleaned up. 

Interviewees did not know if either the trigger lock or manual valve were activated during testing. 

It is unknown if test water entered the OWS or was discharged directly to the retention pond. 

Additionally, pictures included in the system test report (Appendix A) show water/foam being 

pumped outside the hangar (Release Area B) onto the concrete apron. Release Area B includes 

portions of the hangar and apron where discharge from the system test was directed. Discharges 

in this area would likely flow to stormwater drains located along the apron that drain directly to the 

retention pond (Release Area C on Figure 3-1). Therefore, AFFF may have been released to the 

environment at Release Areas B and C shown on Figure 3-1.

Testing of the system last occurred in 2015, which involved a flow test with only water to test 

header pressure. No foam was discharged. Interviewees stated that no samples have ever been 

taken of the system’s AFFF. The fire marshal schedules system tests but no tests have been 

completed to date. 

Release Area D – Bladder Rupture Release

A tank bladder rupture in November 2011 led to a loss of approximately 800 gallons of AFFF. 

Interviewees noted that improper hardware used to install the system caused a coupling to break, 

which tripped the mixing valve. The leaks caused the bladder of one tank to rupture. Foam 

reportedly filled the office hallways and flowed out to the east side of the AASF, into the parking 

lot. AASF personnel recalled that the foam filled the retention pond and drainage ditches along 

the eastern facility boundary and flowed out into the road (W Jackson Street). Foam remaining in 

the office area was squeegeed out through the front door into the parking lot where the foam was 

allowed to naturally dissipate. Personnel recalled that several months after the release occurred, 

the concrete and grassy areas would foam whenever it rained. Release Area D includes portions 

of the building where the release occurred as well as the parking area and retention pond and 

where foam was directed (Figure 3-1).

No Suspected Release Area A – Hazardous Waste Storage 

Area

No Suspected Release Area A is a Hazardous Waste Storage area that stores 32 out-of-date 5-

gallon buckets of AFFF (Ansulite 3%, Mil Spec MIL-F-24385F) that were awaiting pick up for 

disposal at the time of the VSI. The storage area is temperature controlled and is completely 
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

14

enclosed. No evidence of spills or leaks were observed during the site visit. No Suspected

Release Area A is shown on Figure 3-1.
W Jackson Street Ext

No Suspected

Release Area A

Release

Area D

Release

Area C

Release

Area B

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JH

7/1/2020

7/1/2020

Preliminary Assessment for PFAS at Tupelo AASF, MS

1:3,000

7/1/2020 ­ Figure 3-1

PM RG 7/1/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

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

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

PROJECT

0 125 250 500

Feet

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

River/Stream

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_3-1_Tupelo_AASF_Non-Fire_Training_Areas.mxd

15
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

16

4. Emergency Response Areas

No instances of emergency response were identified at the Tupelo AASF during the PA based on

interviews, online research, and the Environmental Data Resources, Inc. (EDR)TM report

(Appendix A). The Tupelo Regional Airport provides aircraft rescue and firefighting to the airport

and the AASF. The Tupelo municipal Fire Department provides structure fire support. Joint training

occurs with AASF personnel but only includes simulation and aircraft walk through exercises. No

firefighting training with live fire has occurred. Tupelo Regional Airport personnel reported that

there has been no emergency response with foam in the last two years; however, emergency

response prior to that was unknown.
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

17

5. Adjacent Sources

Potential off-facility sources of PFAS adjacent to the Tupelo AASF were identified during the PA. 

No additional potential source areas were identified by the EDRTM report within a 1-mile radius 

surrounding the facility. A description of each adjacent source is presented below, and the 

adjacent sources are shown on Figure 5-1. 

Tupelo Regional Airport Fire Department

The airport fire department is located approximately 1,500 feet south of the AASF’s southern 

boundary. The department has several foam-capable firetrucks that are filled with AFFF. It is not 

known if any incidental spills of AFFF have occurred during routine maintenance or filling of the 

trucks. Emergency response with foam has not occurred within the last two years; however, 

previous emergency response is unknown. Airport personnel reported that fire training takes place 

at the Mississippi Fire Academy near Jackson, Mississippi, not at the airport. The geographic 

coordinates of the fire department are approximately 34°15'53.67" N; 88°45'59.25" W (Figure 5-

1).

Tupelo Regional Airport

Airport personnel reported that National Fire Protection Association (NFPA) testing is conducted 

annually at the airport. Testing involves the fire department being called to respond to a random 

location within the response area of the airport and discharging a small unspecified volume of 

AFFF on the ground in order to demonstrate capability. There is no specified testing area, such 

that AAFF may have been released to soil anywhere within airport property. The geographic 

coordinates of the center of the airport property are approximately 34°16'00.13" N; 88°46'11.11" 

W (Figure 5-1). 

Old AASF Property and Hangar

The Tupelo AASF was previously located at the southern end of the airport, approximately 0.5 

miles south of its current location. The old AASF was reportedly in operation from the 1960s to 

2008; it is currently privately owned by an aviation salvage company. During MSARNG 

occupancy, the Old AASF had eight to twelve Tri-MaxTM units on-site. Training with the units 

occurred at various locations within the property. Each unit was drained and refilled at the old 

facility annually. Interviewees recalled that AFFF was drained into the OWS, which discharged 

into the Tupelo sanitary sewer. Additionally, the Old AASF had a firetruck that was disposed of 

around 1990 or 1991. The truck was filled with AFFF but was never used for emergency response. 

Interviewees did not recall if training or testing with the truck occurred or if any leaks happened. 

The geographic coordinates of the Old AASF Property are approximately 34°15'42.52" N; 

88°45'49.35" W (Figure 5-1).

The Old AASF Hangar is still extant today and is used by the current owner (a private aviation 

salvage company). During MSARNG occupancy, an AFFF suppression system was installed in 

1992 or 1993. The system consisted of three 150- to 200-gallon AFFF vats that stood on legs 

within the hangar; each vat was equipped with a manned nozzle. Interviewees recalled that a fullscale test of the system was conducted when it was initially installed. Current AASF personnel 

stated that the AFFF suppression system in the old hangar is still active and used by the current 

owner. Personnel observed that a system test was conducted at the old hangar by the current 

owner around February 2019. The geographic coordinates of the Old AASF Hangar are 

approximately 34°15'42.89" N; 88°45'54.00" W (Figure 5-1).
Old AASF

Hangar

Old AASF

Property

Tupelo Regional

Airport FD

Tupelo

Regional

Airport

Lit tle Coonewah C reek

Russell Cr eek

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JH

6/30/2020

6/30/2020

Preliminary Assessment for PFAS at Tupelo AASF, MS

1:16,800

6/30/2020 ­ Figure 5-1

PM RG 6/30/2020

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

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

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

PROJECT

0 700 1,400 2,800

Feet

Legend

Potential PFAS

Facility Boundary

Water Body

Wetland

River/Stream

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_5-1_Tupelo_AASF_Adjacent_Sources.mxd

18
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

19

6. Preliminary Conceptual Site Model

Based on the PA findings, two AOIs were identified at the current AASF: AOI 1 Western Release 

Areas and AOI 2 Bladder Rupture Release. The AOI locations are shown on Figure 6-1. The 

following sections describe the CSM components and the specific preliminary CSMs developed 

for AOI 1 and 2. The CSMs identify 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 the current risk practice suggests it is an 

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

sparse and continue to be the subject of PFAS toxicological study. Receptors at the AASF include 

site workers, construction workers, residents, trespassers, and off-facility recreational users. The 

preliminary CSMs for AOI 1 (Figure 6-2) and AOI 2 (Figure 6-3) indicate which specific receptors 

could potentially be exposed to PFAS. 

Several adjacent sources of potential PFAS releases are located surrounding the facility, including 

the Tupelo Regional Airport, which conducts annual NFPA testing with AFFF, and the Old AASF 

Property and Hangar, which has both historical releases from MSARNG use and potential current 

day releases from private owners (Figure 6-1).

AOI 1 Western Release Areas 

AOI 1 Western Release Areas encompasses Release Areas A, B, and C (Figure 6-1). During a 

training event, an unknown quantity of AFFF was discharged into the wash rack (Release Area 

A), which discharges to the OWS and, subsequently, the sanitary sewer. Additionally, during an 

initial test of the hangar suppression system, an unknown quantity of AFFF was pumped out and 

directed towards the trench drain at the hangar bay doors. Foam may have also been discharged 

to stormwater drains on the apron during testing (collectively Release Area B). As a result, an 

unknown quantity of AFFF may have flowed directly into a retention pond to the north (Release 

Area C) from either of these drains during testing. 

Although no permanent surface water bodies are present within AOI 1, facility stormwater flows 

into this retention pond (Release Area C) via a system of stormwater drains. Additionally, the 

retention pond receives drainage from the hangar whenever the fire suppression system is 

activated. The retention pond drains into an unnamed tributary of Kings Creek. Therefore, both 

release events may have potentially released PFAS to surface water, sediment, and surface soil 

at Release Area C. PFAS may have migrated from surface soil to subsurface soil and groundwater 

via leaching.

Ground-disturbing activities to surface soil at AOI 1 could result in site worker, construction worker, 

and trespasser exposure to potential PFAS contamination via inhalation or ingestion of soil 

particles. Similarly, ground-disturbing activities to subsurface soil could result in construction 

worker exposure via inhalation of soil particles and ingestion of subsurface soil. Therefore, the 

inhalation and ingestion pathways for these receptors are considered potentially complete. 

The retention pond (Release Area C) within the facility boundary discharges into an unnamed 

tributary of Kings Creek. Consequently, the exposure pathway for surface water and sediment via 

ingestion is potentially complete for the off-facility residents and recreational users. The AASF 

and town’s drinking water is sourced from the Tombigbee River (located over 18 miles to the east 

of the facility). However, domestic and unknown use type wells are present immediately to the 

east and west of the facility. Because the specific hydrogeology beneath the facility is uncertain, 

it is not known if there is communication between the shallow and deeper aquifers. Given that the 
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

20

assumed groundwater flow is south/southeast, the pathway is considered potentially complete for 

groundwater to off-facility residents. Current depth to groundwater is unknown near the facility; 

however, historic USGS depth to groundwater measurements (USGS, 2019) suggest the 

groundwater may be too deep (>80 feet bgs) to affect construction workers working on trenching 

activities. Consequently, the exposure pathway for groundwater to construction workers is 

considered incomplete. The preliminary CSM for the AASF is shown on Figure 6-2.

AOI 2 Bladder Rupture Release

AOI 2 is located east of AOI 1. Due to a hardware malfunction from tank installation, approximately 

800-gallons of AFFF were discharged at the AASF. The AFFF subsequently flowed out of the

building, into the parking lot to the east, filled the eastern drainage ditches and retention pond, 

and eventually flowed out onto W Jackson Street (Figure 6-1). The foam was allowed to naturally 

dissipate.

The eastern drainage ditch and retention pond discharge into the same unnamed tributary as 

Release Area C and AOI 1. Consequently, PFAS may have been released to surface water, 

sediment, and surface soil. Additionally, foam that dissipated on the parking lot and W Jackson 

Street was likely transported by overland flow to surface soils and/or sediment, potentially 

releasing PFAS to these media. Depending on infiltration rates, PFAS may migrate from the 

surface soil to subsurface soil and groundwater via leaching. The pathways and receptors for AOI 

2 are the same as described in Section 6.1 with one exception. Due to the proximity of residential 

houses to the AOI, ground disturbing activities within AOI 2 could also expose residents (in 

addition to site workers, construction workers, and trespassers) to PFAS via inhalation of airborne 

soil particles. The preliminary CSM for AOI 2 is shown on Figure 6-3.
!C(

!C(

!C(

A!

A!

A!

!P

!P

!P

A!

A!

!P

A!

A!

A!

A!

A!

A!

A!

Old AASF

Hangar

Old AASF

Property

Tupelo Regional

Airport FD

Tupelo

Regional

Airport

Littl e Co onewah Creek

Russell Cre ek

Little Coonewah

Creek-Coonewah

Creek Watershed

Kings Creek-Town

Creek Watershed

0 700 1,400 2,800

Feet

!P

Release

Area D

Release

Area C

Release

Area B

Release

Area A

No Suspected 

Release Area A

Kings Creek-Town

Creek Watershed

AOI 1

AOI 2

­ Figure 6-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Tupelo AASF, MS

7/1/2020

7/1/2020

7/1/2020

MS

JH

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)

7/1/2020

1:2,880

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_6-1_Tupelo_AASF_AOIs.mxd

Areas of Interest

12420 Milestone Center Drive

Germantown, MD 20876

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow

Direction

Inferred Groundwater Flow

Direction

!P Domestic Well

A! Other/Unknown Well

!C( Public Water System

0 120 240 480

Feet

21
Media

SOURCE PATHWAY RECEPTOR

AOI 1

Fire Training

Areas and

Systems Testing

PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOIs

Surface

Water/

Sediment

Shallow

Groundwater

Subsurface

Soil

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

LEGEND

Figure 6-2

Preliminary Conceptual Site Model

AOI 1 Western Release Areas

Potential

Off-Facility

Source Not

under

Control of

ARNG

/ /

/ / /

/

Ingestion

/

/

/ / / /

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.

/ / /

/ / / /

/

22
Media

SOURCE PATHWAY RECEPTOR

AOI 2 Bladder Rupture PFAS in

Surface Soil

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOIs

Surface

Water/

Sediment

Shallow

Groundwater

Subsurface

Soil

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

LEGEND

Figure 6-3

Preliminary Conceptual Site Model

AOI 2 Bladder Rupture Release

Potential

Off-Facility

Source Not

under

Control of

ARNG

/ /

/ / /

Ingestion

/

/

/ / / /

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.

/ / /

/ / / /

/

/

23
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

24

7. Conclusions

This report presents a summary of available information gathered during the PA with respect to 

the use of AFFF and other PFAS-related activities at the AASF. The PA findings are based on the 

information presented in Appendix A and Appendix B.

Findings

Two AOIs related to potential PFAS releases were identified at the AASF during the PA. A 

summary of the AOIs is shown in Table 7-1 and their location on Figure 7-1.

Table 7-1: AOIs at Tupelo AASF

Area of Interest Name Used by

Potential Release 

Dates

AOI 1 Western Release 

Areas

MSARNG Since October 2010

AOI 2 Bladder Rupture 

Release

MSARNG November 2011

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

contamination in surface soil to site workers, construction workers, residents, and trespassers via 

ingestion and inhalation of dust; surface water and sediment to site workers, construction workers, 

trespassers, and off-facility residents and recreational users via ingestion; subsurface soil to 

construction workers via ingestion; and groundwater to off-facility residents via ingestion. Potential 

off-facility PFAS release areas exist adjacent to the current Tupelo AASF. Interviewees confirmed 

that AFFF has been released to the environment in these adjacent areas.

The following area discussed in Section 3 was determined to have no suspected PFAS releases 

(Table 7-2).

Table 7-2: No Suspected Release Areas

No Suspected Release Area Used by

Rationale for No Suspected 

Release Determination

No Suspected Release Area A – 

Hazardous Waste Storage Area MSARNG Building is properly isolated and there is no evidence of spills.

Uncertainties

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

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

documentation of PFAS use was not required because PFAS were considered benign. Therefore, 

records were not typically kept or historically maintained by the facility or available during the PA 

with respect to the use of PFAS in training, firefighting, other non-traditional activities, or 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 or conflicted with other sources. Gathered information has a degree of 

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

direct knowledge due to staffing changes, the time passed since PFAS were first used (1969 to 
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

25

present), and a reliance on personal recollection. Inaccuracies may arise in potential PFAS 

release locations, dates of release, volume of releases, and the concentration of AFFF used. 

There is also a possibility the PA has missed a source of PFAS, as the science of how PFAS may 

enter the environment continually evolves.

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

of PFAS were reviewed, current personnel were interviewed, multiple persons were interviewed 

for the same potential source area, and potential source areas were visually inspected. 

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

Table 7-3: Uncertainties

Area of Interest Source of Uncertainty

AOI 1 Western Release Areas – Release 

Area A

Dates of potential release at the wash rack were 

undocumented. However, construction of the 

current AASF was reportedly finished in 2011; 

therefore, the training had to have occurred in the 

past 8 years. The exact quantity and 

concentration of AFFF used during this release 

are unknown.

AOI 1 Western Release Areas – Release 

Area B

It is unknown if the trigger lock system for the 

OWS or manual valve of the retention pond were 

engaged during testing. It is therefore unknown if 

test water entered the OWS or was discharged 

directly to the retention pond.

General

Hydrogeology beneath the facility is uncertain. It 

is not known if there is communication between 

the shallow and deeper aquifers. Groundwater 

flow direction is also not definitively known due to 

the lack of reliant local data. Groundwater is 

assumed to flow to the south-southeast.

Adjacent Sources

Because groundwater flow direction is not certain, 

it is unknown if potential off-facility PFAS release 

areas are upgradient, side gradient, or 

downgradient of the current AASF. 

Potential Future Actions

Interviews and records indicate that ARNG activities may have resulted in potential PFAS releases 

at the AOIs identified during the PA. Based on the preliminary CSMs developed for the AOIs, there 

is potential for receptors to be exposed to PFAS contamination in soil, groundwater, surface water, 

and sediment at the two AOIs. Table 7-4 summarizes the rationale used to determine if the AOIs 

should be considered for further investigation under the CERCLA process and undergo a SI.

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

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

Tupelo AASF, Mississippi

26

Table 7-4: PA Findings Summary

Area of

Interest Rationale Potential Future Action

AOI 1 Western

Release Areas

During a training event and a

separate systems test, AFFF may

have been released in unknown

quantities.

Proceed to an SI, focus on

soil, groundwater, surface

water, sediment

AOI 2 Bladder

Rupture

Release

Tank bladder rupture resulted in an

800-gallon release of AFFF.

Proceed to an SI, focus on

soil, groundwater, surface

water, sediment
Old AASF

Hangar

Old AASF

Property

Tupelo Regional

Airport FD

Tupelo

Regional

Airport

Littl e Co onewah Creek

Russell Cre ek

AOI 1 AOI 2

0 700 1,400 2,800

Feet

W Jackson Street Ext

No Suspected

Release Area A

Release

Area A

AOI 1

AOI 2

Release

Area D

Release

Area C

Release

Area B

­ Figure 7-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at Tupelo AASF, MS

7/1/2020

7/1/2020

7/1/2020

MS

JH

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)

7/1/2020

1:2,880

C:\Users\grace.canham\AECOM Directory\Stankevich, Michael - ARNG_PFAS_GIS_60552172\MXDs\MS\Tupelo_AASF_Figures\Tupelo_PA_Figures\Fig_7-1_Tupelo_AASF_Summary.mxd

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Area of Interest

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

0 120 240 480

Feet

27
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

28

8. References

Boswell, E.H. 1976. The Eutaw-McShan Aquifer in Mississippi: U.S. Geological Survey WaterWater Resources Investigations Open-File Report 76-134.

O’Hara, C.G. 1996. Susceptibility of ground water to surface and shallow sources of

contamination in Mississippi: U.S. Geological Survey Hydrologic Investigations Atlas HA-739.

Mississippi Department of Environmental Quality (MDEQ). 2019a. Geologic Map of the Tupelo

Quadrangle, Office of Geology Open-File Report 307.

MDEQ. 2019b. Borehole Collection. Available at

https://geology.deq.ms.gov/environmental/boreholes/ (accessed 6 September 2019).

MDEQ. 2014. State of Mississippi Groundwater Quality Assessment. April.

Mississippi State Geological Survey. 1946. Lee County mineral resources: Bulletin 63, 135 p.

National Aeronautics and Space Administration. 2018. Black Belt Prairie. Available at

https://earthobservatory.nasa.gov/images/92321/black-belt-prairie (accessed 4 September

2019).

Strom, E.W., and Mallory, M.J. 1995. Hydrology and simulation of ground-water flow in the EutawMcShan Aquifer and the Tuscaloosa Aquifer System in northeastern Mississippi: U.S.

Geological Survey Water-Resources Investigations Report 94-4223, 83 p.

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

Preliminary Assessments under CERCLA. September.

United States Geological Survey. 2019. National Water Information System: Groundwater Levels

for Mississippi. Available at https://nwis.waterdata.usgs.gov/ms/nwis/gwlevels (accessed 4

September 2019).

World Climate. 2019. Average Weather Data for Tupelo, Mississippi. Available at

http://www.worldclimate.com/climate/us/mississippi/tupelo (accessed 3 September 2019).
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix A

Data Resources
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Data Resources will be provided separately on CD. Data Resources for Tupelo AASF, 

Mississippi. 

Tupelo AASF Leases, Licenses, and Permits

• 2007 Tupelo AASF Lease

Tupelo AASF Spill Prevention, Control, and Countermeasure Plan

• 2017 Army Aviation Support Facility No. 2 Tupelo, Mississippi Spill Prevention, Control, and

Countermeasure/Spill Contingency Plan

Tupelo AASF Storm Water Pollution Prevention Plan

• Final SWPPP, Volume 1

• 2017 Final SWPPP, Volume 2

Tupelo AASF Inspection Reports

• 2010 Foam System Inspection/Test/Maintenance Report

Tupelo AASF EDRTM Report

• 2019 EDR Aerial Photo Decade Package

• 2019 EDR Radius Map Report with GeoCheck

• 2019 Certified Sanborn Map Report 
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix B.1

Interview Records
PA Interview Questionnaire - Other Facility:_Tupelo AASF No. 2, MS_ 

Interviewer:_ _ 

Date/Time:_5 March 2019 @ 0800_ 

Interviewee:___See Below________

Title:__________________________________

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 __________________________

Roles or activities with the Facility/Years working at the Facility:

, GSE Technician, 7 years

, Facility Maintenance Coordinator, over 26 years (7 years in current position) 

, GSE Technician & Environmental Coordinator, 11 years

, Director of Operations at Tupelo Regional Airport, 2 years

PFAS Use: Identify accidental/intentional release locations, time frame of release, frequency of releases, 

storage container size (maintenance, fire training, firefighting, buildings with suppression systems (as 

builts), fueling stations, crash sites, pest management, recreational, dining facilities, metals plating, or 

waterproofing). How are materials ordered/purchased/disposed/shared with others?

• Facility history/description: Current AASF finished in approx. 2009. Purpose 

is duel role emergency center & AASF. Houses multiple guard units & 

maintains aircraft. Building designed to be a state emergency mobilization 

site for the state. 

• Old AASF: 

o Was located at southern end of airport from 1960’s to 2008, approx. 1⁄2 

mile south of current location and is now privately owned by an aviation 

salvage company.

o Old AASF Hangar had an AFFF suppression system installed in approx. 

1992/93 consisting of 3-vats on legs, each with a manned nozzle, within 

the hangar. Each vat has a ~150-200 gallon capacity. A full scale test of 

the system was conducted when it was installed.

o Old AASF had 8-12 Trimax units on-site. Training with the units occurred 

at various locations within the Old AASF. Each unit was drained and 

refilled at the facility annually. Old AFFF was drained into the OWS which 

discharges to the Tupelo sanitary sewer.

o Had an old fire truck at Old AASF that was gotten rid of in approx. 

1990/91. Was AFFF filled but never used for emergency responses. Not 

known in training occurred or leaks.

o AFFF suppression system still active at Old AASF hangar, now under 

private ownership. A system test was conducted approx. 1-month ago 

(Feb. 2019) by new owner.

• New/Current AASF: 

o Has 8-10 30-gallon Trimax units. Stored in the hangar unless needed on

the flight line. Originally the AFFF w/in was not freeze proof and one

Known Uses

Use 

Procurement

Disposition

Storage (Mixed)

Storage (Solution)

Inventory, Off-Spec

Containment

SOP on Filling

Leaking Vehicles

Nozzle & Suppression 

System Testing

Dining Facilities

Vehicle Washing

Ramp Washing

Fuel Spill Washing and 

Fueling Stations

Chrome Plating or 

Waterproofing 
PA Interview Questionnaire - Other Facility:_Tupelo AASF No. 2, MS_ 

Interviewer:_ _ 

Date/Time:_5 March 2019 @ 0800_ 

canister froze, buckling the metal of the canister but did not breech or leak. Trimax units are 

serviced (recharged/refilled) by a local fire service company in Tupelo. Training with out of 

date Trimax unit occurred once at AASF – an unknown quantity was discharged at/into the 

Wash Rack which discharges to the OWS.

o Hangar suppression system: two 800-gallon tank system with dedicated water supply tanks 

(two 93,000 gallon water tanks). System filled with Buckeye 3% MilSpec. Contractor 

conducted initial system test with foam. An unknown quantity of AFFF was pumped out by the 

contractor and directed towards the trench drain along the hangar bay doors. The trench drain 

flows to the OWS but has a trigger lock that bypasses and flows out to the stormwater pond to 

the north. It is not known if the system lock triggered or not. – pic of system test in manual 

shows pumping to outside of hangar, allowed to flow to storm drains on pad west of hangar. 

o November 2011: 800-gallons of AFFF lost during bladder rupture. Improper hardware used to 

install the system caused a coupling to blow which tripped the mixing valve. The leaks caused 

the tank bladder to rupture. Foam filled the office hallways and flowed out the east side of the 

AASF into the parking lot, filled the drainage ditches, and flowed out into the road. The office 

area was squeegeed out the front door and the foam outside allowed to naturally dissipate. 

For months after the release, the concrete and grassy areas would foam whenever it rained.

o Testing of the system was last done in 2015 – included a flow test with only water to test 

header pressure, no foam discharged. No samples have ever been taken of the system’s 

AFFF. The fire marshal schedules system tests but no tests to date.

o 32 out-of-date 5-gallon buckets of AFFF (Ansulite 3%, Mil Spec MIL-F-24385F) are currently 

stored in the Hazardous Waste storage building awaiting pick up for disposal. The building is 

temperature controlled and completely covered. No evidence of spills.

o Emergency response provided by City of Tupelo and Tupelo Regional Airport fire station. Joint 

training occurs with AASF personnel but only includes simulation and aircraft walk through

exercises – no fire and no foam.

o Drinking water at AASF and town is supplied by City of Tupelo which gets the water from the 

Tombigbee River

• Tupelo Regional Airport: 

o Airport provides Aircraft Rescue and Firefighting (ARFF) to airport and AASF, Tupelo 

municipal FD provides structure fire support.

o Airport FD located immediately east of tower.

o Airport fire department has several foam capable fire trucks with foam loaded. 

o No emergency response with foam within the last 2 years, unknown prior to that

o Training occurs at Mississippi Fire Academy near Jackson, MS – none on airport

o NFPA testing conducted annually at airport. Called to respond to random locations within the 

response area of the airport and discharge a small volume of foam to demonstrate capability.

o No other hangers on the airport have an AFFF suppression system except for the old AASF 

hangar (currently occupied by private aviation salvage company)
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix B.2

Visual Site Inspection Checklists
Visual Site Inspection Checklist

Names(s) of people performing VSI: (AECOM) & (ARNG)

Recorded by:

ARNG Contact:

Date and Time:

Method of visit (walking, driving, adjacent): walking

Source/Release Information

Site Name / Area Name / Unique ID: Tupelo AASF No. 2, Missis

approximately 37 acres

Historic Site Use (Brief Description): Tupelo Regional Airport, Current AASF finished in approx. 2009. Previous AASF

location now privately owned, located at southern end of the airport

Current Site Use (Brief Description): Duel role emergency center & AASF. Houses multiple guard units & maintains 

aircraft. Building designed to be a state emergency mobilization site for the state.

Physical barriers or access restrictions: fenced with controlled access gate 

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

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

2. Has usage been documented? Y / N

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

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

3a. Indicate what businesses are located near the site

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

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

Site / Area Acreage:

5-Mar-19

Current AASF: One time training with TriMax unit at wash rack. Hangar system testing by contractor directed 

to storm drains outside hanager. Hangar system bladder rupture in 2011 filled office building and eastern 

parking lot to the road with foam.

Record of current AASF initial system testing kept as hard copy onsite

Tupelo Regional Airport, church offices, research and development company.

Tupelo Regional Airport, a comercial aviation disassembly facility, various other private companies.

Page 1 of 4
Visual Survey Inspection Log

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

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

Buckeye 3% MilSpec

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

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

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

Yes, lead to OWS

Transport / Pathway Information

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

1a. If so, note observation and location:

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

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

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

3a. If so, please note the location: 

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

4a. If so, please note the location: 

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

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

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

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

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

Other Significant Site Features: 

Migration Potential:

Initial system testing by contractor, bladder rupture and release in 2011

Testing of the system was last done in 2015 – included a flow test with only water to test header pressure, no 

foam discharged. Frequency of testing unknown.

Drainage flows to one of two retention ponds (one north of facility and one east). Overflow of retention ponds 

flows offsiite to the north along riprapped drainage ditches.

Tupelo Regional Airport - annual NFPA testing

Commercial aviation disassembly facility - Former AASF location, recent system testing by current owners 

known

Page 2 of 4
Visual Survey Inspection Log

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

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

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

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

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

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

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

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

Receptor Information

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

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

2. Who can access the site? 

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

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

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

Approx. 500 feet to the east of the facility

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

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

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

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

Site Workers / Construction Workers / Trespassers / Residential / 

Recreational Users / Ecological

Fenced and controlled gate entry

Currently AASF built approx. 2009

all non-paved areas vegetated with grass

Significant Topographical Features: 

Page 3 of 4
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix B.3

Conceptual Site Model Information
Preliminary Assessment – Conceptual Site Model Information

Site Name: Tupelo AASF No. 2, Mississippi

Why has this location been identified as a site?

Aviation asset that has an AFFF suppression system.

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

Yes, Tupelo Regional Airport and commercial aircraft disassembly facility (former AASF location with 

known AFFF suppression system).

Training Events

Have any training events with AFFF occurred at this site? Yes, at both current and former AASF

locations

If so, how often? Once at current AASF, routine at former AASF

How much material was used? Is it documented? Unknown

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? Stormwater flows to the one of two retention ponds (respectively, north 

and east of the facility) that drain to an offsite riprap lined drainage channel that flows to the north.

Average rainfall?

Any flooding during rainy season?

Direct or indirect pathway to ditches? Both

Direct or indirect pathway to larger bodies of water? No

Does surface water pond any place on site? Only in stormwater retention ponds.

Any impoundment areas or retention ponds? Yes, two retention ponds – one north that receives 

stormwater from the western apron and overflow from the OWS and one east that receives stormwater 

from the eastern and southern POV parking areas.

Any NPDES location points near the site? Yes, Outfalls 001 and 002 associated with the retention 

ponds.

How does surface water drain on and around the flight line? Drainage from the apron flows east to 

French drains that flow to the northern retention pond. 
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction? Unknown – likely to the southeast towards Kings Creek and the larger 

Tombigbee River system

Depth to groundwater?

Uses (agricultural, drinking water, irrigation)?

Any groundwater treatment systems? Not at facility

Any groundwater monitoring well locations near the site? None known

Is groundwater used for drinking water? No, city municipal supply from Tombigbee River

Are there drinking water supply wells on installation? No

Do they serve off-post populations? N/A

Are there off-post drinking water wells downgradient 

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present? No – City of Tupelo WWTP located approx. 

4.5-miles to southeast of facility

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

Do we understand the fate of sludge waste? N/A

Is surface water from potential contaminated sites treated? Only via OWS.

Equipment Rinse Water

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

N/A

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?

N/A

3. Other?

One time training with a former TriMax unit at the wash rack which drains to the OWS
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker - yes

Construction Worker - potentially

Recreational User - no

Residential – offsite only

Child – offsite only

Ecological – no sensitive habitats

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

Commercial and industrial mostly, residential homes located on eastern side of facility approx 500-ft 

to east.

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur? Not since 

facility constructed in approx 2009
PFAS Preliminary Assessment Report

Tupelo AASF, Mississippi

Appendix C

Photographic Log
Preliminary Assessment Report

Tupelo AASF, Mississippi

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 Tupelo AASF Mississippi

Photograph No. 1

Description:

Out of date AFFF stored in 

No Suspected Release Area 

A.

Date Taken:

3 March 2019

Photograph No. 2

Description:

Release Area C. Standing on 

the eastern side of the AASF 

looking southeast across the 

parking lot and W Jackson 

Street where the release 

overflowed from the building.

Date Taken:

3 March 2019
Preliminary Assessment Report

Tupelo AASF, Mississippi

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 Tupelo AASF Mississippi

Photograph No. 3

Description:

Retention pond where AFFF 

from the Release Area C

flowed into. Standing on 

southwestern corner of the 

retention pond facing northnortheast.

Date Taken:

3 March 2019

Photograph No. 4

Description: 

Inside hangar facing north. 

Trench drains running length 

of the hangar bay doors 

visible on right had side of 

photo.

Date Taken:

3 March 2019
Preliminary Assessment Report

Tupelo AASF, Mississippi

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 Tupelo AASF Mississippi

Photograph No. 5

Description:

Fire suppression system. Two 

800-gallon capacity AFFF 

tanks and associated piping.

Date Taken:

3 March 2019

Photograph No. 6

Description:

Details and specifications 

listed on one of the 800-gallon 

AFFF tanks that supply the 

fire suppression system.

Date Taken:

3 March 2019
Preliminary Assessment Report

Tupelo AASF, Mississippi

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 Tupelo AASF Mississippi

Photograph No. 7

Description:

Release Area A. Standing on 

southwest corner facing 

northeast.

Date Taken:

3 March 2019

Photograph No. 8

Description: 

Release Area D. Standing on 

southeast corner facing 

northwest.

Date Taken:

3 March 2019
Preliminary Assessment Report

Tupelo AASF, Mississippi

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 Tupelo AASF Mississippi

Photograph No. 9

Description:

Former Tupelo AASF Hangar, 

now privately owned. 

Standing on the northwestern 

side of the hangar, facing 

southeast.

Date Taken:

3 March 2019