FINAL

Site Inspection Report

Roswell Field Maintenance Shop

Roswell, New Mexico

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

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

Oxide Dimer Acid (HFPO-DA), and Perfluorobutanesulfonic Acid (PFBS)

ARNG Installations, Nationwide

October 2023

Prepared for:

Army National Guard Headquarters

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
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TABLE OF CONTENTS

Page

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

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

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

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

EXECUTIVE SUMMARY .........................................................................................................1

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

1.1 Project Authorization............................................................................ 1-1

1.2 Site Inspection Purpose......................................................................... 1-1

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

2.1 Facility Location And Description........................................................ 2-1

2.2 Facility Environmental Setting ............................................................. 2-1

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

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

2.2.3 Hydrology.............................................................................. 2-3

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

2.2.5 Current and Future Land Use ................................................. 2-4

2.2.6 Sensitive Habitat and Threatened/Endangered Species........... 2-4

2.3 History of PFAS Use ............................................................................ 2-4

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

3.1 AOI 1 –Field Maintenance Shop – Vehicle Maintenance Bay............... 3-1

3.2 Adjacent Sources.................................................................................. 3-1

3.2.1 Roswell International Air Center............................................ 3-1

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

4.1 Problem Statement ............................................................................... 4-1

4.2 Information Inputs................................................................................ 4-1

4.3 Study Boundaries ................................................................................. 4-1

4.4 Analytical Approach............................................................................. 4-1

4.5 Data Usability Assessment ................................................................... 4-2

5. SITE INSPECTION ACTIVITIES................................................................... 5-1
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5.1 Pre-Investigation Activities .................................................................. 5-2

5.1.1 Technical Project Planning ..................................................... 5-2

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

5.1.3 Source Water and PFAS Sampling Equipment Acceptability . 5-3 

5.2 Hand Auger Soil Sampling ................................................................... 5-3

5.3 Soil Borings and Soil Sampling ............................................................ 5-3

5.4 Temporary Well Installation and Groundwater Grab Sampling ............. 5-5 

5.5 Synoptic Water Level Measurements .................................................... 5-6

5.6 Surveying ............................................................................................. 5-6

5.7 Investigation-Derived Waste................................................................. 5-6

5.8 Laboratory Analytical Methods ............................................................ 5-7

5.9 Deviations from SI UFP-QAPP Addendum .......................................... 5-7

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

6.1 Screening Levels .................................................................................. 6-1

6.2 Soil Physicochemical Analyses............................................................. 6-2

6.3 AOI 1 – Field Maintenance Shop – Vehicle Maintenance Bay .............. 6-2 

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

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

6.3.3 Conclusions ........................................................................... 6-3

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

7.1 Soil Exposure Pathway ......................................................................... 7-1

7.1.1 AOI 1 – FIELD MAINTENANCE SHOP – VEHICLE 

MAINTENANCE BAY ........................................................ 7-2

7.2 Groundwater Exposure Pathway ........................................................... 7-2

7.2.1 AOI 1 – AOI FIELD MAINTENANCE SHOP – VEHICLE 

MAINTENANCE BAY ........................................................ 7-2

7.3 Surface Water and Sediment Exposure Pathway ................................... 7-2

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

8.1 SI Activities.......................................................................................... 8-1

8.2 Outcome ............................................................................................... 8-1

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

Appendix A. Data Usability Assessment and Validation Reports

Appendix B. Field Documentation

B1. Log of Daily Notice of Field Activities

B2. Sampling Forms

B3. Survey Data

B4. Corrective Action Report

B5. Investigative Derived Waste Placement Location

Appendix C. Photographic Log

Appendix D. Technical Project Planning Meeting Minutes

Appendix E. Boring Logs and Well Construction Diagrams

Appendix F. Analytical Results

Appendix G. Laboratory Reports
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LIST OF FIGURES

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Groundwater Elevations, June, 2022

Figure 2-5 Surface Water Features

Figure 3-1 Areas of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOS Detections in Soil

Figure 6-2 PFOA Detections in Soil

Figure 6-3 PFBS Detections in Soil

Figure 6-4 PFHxS Detections in Soil

Figure 6-5 PFNA Detections in Soil

Figure 6-6 PFOS, PFOA, and PFBS Detections in Groundwater

Figure 6-7 PFHxS and PFNA Detections in Groundwater

Figure 7-1 Conceptual Site Model, AOI 1
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LIST OF TABLES

Table ES-1 Screening Levels (Soil and Groundwater)

Table ES-2 Summary of Site Inspection Findings and Recommendations

Table 5-1 Samples by Medium, Roswell FMS, Roswell, Site Inspection Report

Table 5-2 Soil Boring Depths and Temporary Well Screen Intervals, Roswell FMS, 

Roswell, Site Inspection Report

Table 5-3 Groundwater Elevation, Roswell FMS, Roswell, Site Inspection Report

Table 6-1 Screening Levels (Soil and Groundwater)

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

Report, Roswell FMS

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

Inspection Report, Roswell FMS

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

Inspection Report, Roswell FMS

Table 6-5 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater, Site Inspection 

Report, Roswell FMS

Table 8-1 Summary of Site Inspection Findings and Recommendations
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LIST OF ACRONYMS AND ABBREVIATIONS

°C Degrees Celsius

% Percent

μg/kg Microgram(s) per kilogram

g/L Microgram(s) per liter

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF Aqueous Film-Forming Foam

amsl Above mean sea level

ANG Air National Guard

AOI Area of Interest

ARNG Army National Guard

ASTM American Society for Testing and Materials

bgs Below ground surface

blvd Boulevard

bmsl Below mean sea level

btoc Below top of casing

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

COC Chain-of-custody

CSM Conceptual site model

DA Department of the Army

DoD Department of Defense

DOE Department of Energy

DOT Department of Transportation

DPT Direct-push technology

DQI Data quality indicator

DQO Data quality objective

DUA Data Usability Assessment

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EB Equipment Blank

EIS Extraction internal standards

ELAP Environmental Laboratory Accreditation Program

EM Engineer Manual

EPA Environmental Protection Agency

FB Field blank

FedEx Federal Express

ft Foot (feet)

ft/ft foot per foot

FMS Field Maintenance Shop
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GPR Ground-penetrating radar

GPS Global positioning system

HAZMAT Hazardous Material

HDPE High-density polyethylene

HFPO-DA Hexafluoropropylene oxide dimer acid

HQ Hazard Quotient

HSA Hollow Stem Auger

IDW Investigation-derived waste

ITRC Interstate Technology Regulatory Council

LC/MS/MS Liquid chromatography tandem mass spectrometry

LCS Laboratory control sample

LCSD Laboratory control sample duplicate

LOQ Limit of quantification

MIL-SPEC military specification

MS Matrix spike

MSD Matrix spike duplicate

NELAP National Environmental Laboratory Accreditation Program

ng/L Nanogram(s) per liter

NM New Mexico

NMARNG New Mexico Army National Guard

NMED New Mexico Environmental Department

No. Number

OSD Office of the Secretary of Defense

PA preliminary assessment

PFAS per- and polyfluoroalkyl substances

PFBS perfluorobutanesulfonic acid

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PID photoionization detector

PVC polyvinyl chloride

QA Quality assurance

QAPP Quality Assurance Project Plan

QC Quality control

QSM Quality Systems Manual

RC Readiness Center

Rd Road
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RI Remedial investigation

RIAC Roswell International Air Center

RPD Relative percent difference

SI Site Inspection

SL Screening level

TCRA Time Critical Removal Action

TOC Total organic carbon

TPP Technical Project Planning

UFP Uniform Federal Policy

USACE U.S. Army Corps of Engineers

USEPA U.S. Environmental Protection Agency

W West

Wood Wood Environment & Infrastructure Solutions, Inc.

WSP WSP USA Environment & Infrastructure, Inc.
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EXECUTIVE SUMMARY

The Army National Guard (ARNG) G-9 is performing Preliminary Assessments (PAs) and Site 

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

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

memorandum regarding Investigating Per- and Polyfluoroalkyl Substances within the 

Department of Defense Cleanup Program (Assistant Secretary of Defense, 2022) from the Office 

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

memorandum include perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), 

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

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1. These compounds are 

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

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

The PA identified one Area of Interest (AOI) within the Roswell Field Maintenance Shop (FMS)

(the Installation) where PFAS-containing materials may have been stored, disposed, or released 

historically (see Table ES-2 for the AOI location). The objective of the SI is to identify whether 

there has been a release to the environment from the AOI identified in the PA and determine

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

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

compounds. This SI was completed at the Roswell FMS in Roswell, New Mexico (NM) and 

determined no further investigation is warranted for AOI 01: Field Maintenance Shop – Vehicle 

Maintenance Bay. The Roswell FMS will be referred to as the “Facility” throughout this 

document.

The Facility, operated by the NM ARNG (NMARNG), encompasses approximately 13.01 acres 

in Roswell, New Mexico. The Facility is located on the northwest corner of the Roswell 

International Air Center (RIAC) and is leased to the NMARNG by the City of Roswell. The land 

for the Facility was acquired in 1987, and the buildings were constructed in 1989. The Facility 

features two buildings (a readiness center and an FMS building), hazardous materials (Hazmat) 

storage, and several parking areas (AECOM, 2020).

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

AOI was compared to OSD SLs. Table ES-2 summarizes the SI results for the AOI.

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

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS. 
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Table ES-1. Screening Levels (Soil and Groundwater)

Analyte1,2

Residential

(Soil)

(μg/kg)1

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg) 1

Tap Water

(Groundwater)

(ng/L) 1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

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

and Soil using United States Environmental Protection Agency’s (USEPA’s) Regional 

Screening Level Calculator. Hazard Quotient (HQ)=0.1. May 2022.

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

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

on the CSM developed during the PA and revised based on SI findings, the presence of 

HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a component 

of MIL-SPEC AFFF and based on its history including distribution limitations that restricted 

use of GenX, it is generally not a component of other products the military used. In addition, 

it is unlikely that GenX would be an individual chemical of concern in the absence of other 

PFAS.

g/kg = microgram(s) per kilogram

ng/L = nanogram(s) per liter

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

AOI

Potential Release 

Area

Soil –

Source Area

Groundwater –

Source Area

Groundwater –

Facility Boundary Future Action

1

Field Maintenance 

Shop – Vehicle 

Maintenance Bay 

No further action

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
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1. INTRODUCTION

1.1 PROJECT AUTHORIZATION

The Army National Guard (ARNG) G-9 is the lead agency in performing Preliminary 

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

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

compounds presented in the memorandum regarding Investigating Per- and Polyfluoroalkyl 

Substances within the Department of Defense Cleanup Program (Assistant Secretary of Defense, 

2022) from the Office of the Secretary of Defense (OSD) dated 6 July 2022 (Assistant Secretary 

of Defense, 2022). The six compounds listed in the OSD memorandum are referred to as 

“relevant compounds” throughout this document and include perfluorooctanesulfonic acid

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

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

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

performed this SI at the Roswell Field Maintenance Shop (FMS) in Roswell, New Mexico. The 

Roswell FMS is also referred to as the “Facility” throughout this report.

The SI project elements were performed in accordance with the Comprehensive Environmental 

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

[EPA] 1980), as amended, the National Oil and Hazardous Substances Pollution Contingency 

Plan (40 Code of Federal Regulations Part 300; EPA 1994), and in compliance with Army

requirements and guidance for field investigations.

1.2 SITE INSPECTION PURPOSE

A PA was performed at the Roswell FMS (AECOM Technical Services, Inc. [AECOM] 2020) 

that identified one Area of Interest (AOI) where PFAS-containing materials may have been used, 

stored, disposed, or released historically. The objective of the SI is to identify whether there has 

been a release to the environment from the AOI identified in the PA and determine whether 

further investigation is warranted, a removal action is required to address immediate threats, or 

no further action is required based on screening levels (SLs) for the relevant compounds.

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

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS. 
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2. FACILITY BACKGROUND

2.1 FACILITY LOCATION AND DESCRIPTION

Roswell FMS sits on 13.01 acres in Chaves County, southeastern New Mexico, along W Earl

Cummings Boulevard and approximately 5 miles south of the City of Roswell (Figure 2-1). The 

Facility is located on the northwest corner of the Roswell International Air Center (RIAC) and is 

leased to the NMARNG by the City of Roswell. The land for the Facility was acquired in 1987, 

and the buildings were constructed in 1989. The Installation is comprised of a readiness center

(RC), FMS building, hazardous materials (HAZMAT) storage, motor pool, and parking

(AECOM, 2020). The concrete surface surrounding the FMS building has been extended since 

the Facility’s original construction.

2.2 FACILITY ENVIRONMENTAL SETTING

Roswell FMS is located on the Mescalero Pediment, within the Lower Pecos Valley subsection 

of the Great Plains physiographic province. The elevation of the Facility is approximately 3,600 

feet (ft) above mean sea level (msl) and is generally flat with a gentle slope towards the east 

(AECOM, 2020).

2.2.1 Geology

Roswell FMS is located within the Roswell Basin, which comprises a 12,000-square-mile area in 

southeastern New Mexico. The Facility is underlain by Permian-age bedrock from the Artesia 

Group that dips eastward. The Yates Formation and the underlying Seven Rivers Formation both 

outcrop at the Facility and are associated with the Artesia Group. The Yates Formation is 

composed of sandstone, siltstone, limestone, dolomite, and anhydrite. The underlying Seven 

Rivers Formation is composed primarily of white gypsum and orange to red mudstone, 

sandstone, siltstone, and shale. The Artesia Group also locally includes the Queen and Grayburg 

Formations, which underlie the Seven Rivers Formation. The Queen Formation consists of finegrained sandstone and siltstone with interbedded gypsum, and the Grayburg Formation consists 

of dolomite and gypsum with interbedded sandstone and shale (AECOM, 2020).

The San Andres Formation underlies the Artesia Group and consists of gray, massive- to thinbedded, cavernous limestone and dolomite. While limestone and dolomite are the principal rock 

types, the San Andres Formation also contains the Glorieta Sandstone near the base of the 

formation. The depth of the San Andres Formation ranges from 300 to 1,300 ft along the eastern 

margin of the Roswell Basin (AECOM, 2020).

Quaternary-aged alluvium associated with the Pecos River floodplain is located to the west of the 

Facility. This alluvium consists of unconsolidated gravel, sand, silt, and clay deposits, which 

overlie the Permian-age bedrock. During the SI, unconsolidated sediments at the Facility were 

dominated by medium plastic fines (silt/clay) with interbedded layers of sands and gravels. The 

borings were completed at depths between 15 and 144 ft below ground surface (bgs). The 

shallow boring lithology (0 to 15 ft bgs) was predominately silty sands and well graded gravels. 

The deep boring (greater than [>] 15 ft bgs) lithology was predominately medium plastic fines 

(clay) with layers of well graded gravels, sand, and less plastic fines (silt). Layers of well graded 
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gravels with fines (silt/clay) and/or sand was observed consistently in the borings with 

thicknesses ranging from a few inches to 34 ft. The lithology at AOI01-09 (original location and 

offset) consisted of significant layers of the well graded gravel with calcium carbonate present 

which severely limited penetration capability of the available drilling equipment as noted in the 

boring logs included in Appendix E. A sample for grain size analyses was collected at one

location, AOI01-01 and analyzed via American Society for Testing and Materials (ASTM) 

Method D-422. The results indicate that the soil samples are comprised primarily of sand (43%) 

and silt (38%). These results and Facility observations are consistent with the reported 

depositional environment of the region. Boring logs are presented in Appendix E and grain size 

results are presented in Appendix F. The thickness of the alluvium is generally 150 to 300 ft.

2.2.2 Hydrogeology

The Roswell FMS is located in the Roswell Basin aquifer system, which underlies a portion of 

the Pecos River and encompasses an area of approximately 2,200 square miles from north of 

Roswell to northwest of Carlsbad, New Mexico. This aquifer system consists of a shallow 

alluvial aquifer and the Roswell Artesian aquifer. The Roswell Artesian aquifer is a leakyconfined carbonate aquifer with a saturated thickness of approximately 500 ft; it consists of 

water bearing zones associated with the lower Grayburg Formation and upper to middle sections 

of the San Andres Formation. The generally low permeability of the Queen Formation and upper 

Grayburg Formation serves as an upper confining unit for the aquifer. The lower confining unit 

of the Roswell Artesian aquifer is formed by the lower, unaltered portion of the San Andres 

Formation, Glorieta Sandstone, and the Yeso Formation. The direction of groundwater flow 

across the basin is to the east, then upward through the leaky upper confining unit, and into the 

Pecos River (AECOM, 2020) (Figure 2-3).

Recharge to the Roswell Artesian aquifer is primarily through infiltration of precipitation, a 

majority of which occurs west of the City of Roswell, where the San Andres Formation outcrops. 

Additional recharge occurs through sinkholes via solution-enlarged pathways. Principal 

discharge from the Roswell Artesian aquifer is by groundwater withdrawal, primarily for the 

purpose of irrigation. Although there is agricultural land use near the City of Roswell, 

agricultural activity and demand for water to irrigate crops are more intensive south of Roswell. 

Natural discharge also occurs and is evidenced by the presence of karst springs, lakes, and 

wetlands in the Roswell Basin (AECOM, 2020). Groundwater features are shown on Figure 2-3.

The PA Report (AECOM, 2020) included a search of wells within a 4-mile radius of the Facility. 

Although the PA Report indicated a potential depth to groundwater of 500 ft bgs at the Facility, a 

review of drillers’ logs for wells installed in the vicinity between 2015 and 2020 indicates a 

regional depth to water in the shallow alluvial aquifer of between approximately 100 and 200 ft 

bgs, with an average of approximately 130 ft bgs (AECOM, 2020). The depth to groundwater in 

June 2022 observed during the SI ranged from approximately 117 to 132 ft bgs. Groundwater 

elevations from the SI are presented on Figure 2-4. The regional groundwater flow identified in 

the PA is likely pertaining to the deeper Roswell Artesian aquifer and flows generally eastward. 

Based on groundwater elevations calculated using depth to groundwater measurements and 

survey data collected during the SI, groundwater flow at the Facility during the SI generally 

flows to the west toward AOI01-06 with an approximate gradient of 0.017 foot per foot (ft/ft). 

The shallow alluvial aquifer encountered during the SI is likely influenced by local structures, 
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localized subsurface anomalies, and nearby groundwater usage. The SI was performed during a 

rain event, and while AOI01-06 is located within a paved parking lot, AOI01-07 and AOI01-08 

are located in areas that do not have impervious surfacing (Figure 2-4). The extension of the 

concrete surface surrounding the FMS building is shown on Figure 2-4. Nearby water supply 

wells are completed in the Roswell artesian aquifer, with the closest well located approximately 

0.45 miles to the east, between West (W) Earl Cummings Boulevard (Blvd) and W Byrne Street 

(St) and to the south of W Hobson Road (Rd). Private wells located to the northwest and 

northeast within the vicinity of the Facility tend to be completed within the alluvial aquifer (New 

Mexico Environment Department [NMED] Drinking Water Bureau, 2019). The closest wells are 

located approximately 0.22 miles to the northwest and 0.28 miles to the northeast.

The Facility receives potable water from the City of Roswell. The City of Roswell currently 

sources its drinking water from groundwater drawn from the San Andres water basin through a 

network of 20 wells completed in the artesian aquifer and having depths of over 300 feet (NMED 

Drinking Water Bureau, 2019). PFAS analysis was not included in the City of Roswell 2019 

Water Quality Report. The United States Environmental Protection Agency (USEPA) 

Unregulated Contaminant Monitoring Rule 3 (UCMR3) data indicate that PFAS were not 

detected in a public water system above 70 parts per trillion for PFOA or PFOS individually or 

combined within a 20-mile radius of the facility. It is possible that low concentrations of PFAS 

were not detected during the UCMR3 due to the limitations of the current method detection 

limits but might be detected if analyzed today (AECOM, 2020).

2.2.3 Hydrology

The Pecos River Basin drains an area of approximately 19,500 square miles within New Mexico. 

The Pecos River flows north to south through Chaves County. A portion of the Pecos River 

flows approximately 10 miles west of Roswell. The Pecos River has an average flow rate of 185 

cubic ft per second (ft3/sec). Wetlands east of the City of Roswell are associated with segments 

of the Pecos River and the Bottomless Lakes State Park. These wetlands are specifically 

classified as freshwater emergent wetlands, freshwater forested/shrub wetlands, and riverine 

zones (Figure 2-5).

Stormwater at the Facility, along with the stormwater at the RIAC, generally flows to the northnortheast. The first receiving water for stormwater discharge is the Hangerman Canal, located 

approximately 6.7 miles from the Facility (Barron’s Environmental Solutions – In Time!, Inc. 

[Barron’s], 2021). The Hangerman Canal discharges to the Pecos River. Stormwater at the 

Facility flows away from the Facility and toward the outflows located on the northern edge of the 

property. The washrack is surrounded by a concrete berm and all water collected at the washrack 

flows into the drain.

2.2.4 Climate

The climate of the Roswell area is temperate and semiarid. The average annual daily temperature 

ranges from 41 to 77 degrees Fahrenheit (°F). Temperatures during the SI ranged from 66 to 

108°F with several scattered rain and thunderstorms. Excessive heat and lighting during field 

activities caused intermittent delays of the SI field work. The average annual precipitation is 

approximately 15 inches, most of which occurs during the months of July and August, and the 

average annual snowfall is approximately 7.3 inches. Precipitation is exceeded by an annual 
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evaporation rate of 89 inches, according to a measurement taken at the Bitter Lake National 

Wildlife Refuge (AECOM, 2020).

2.2.5 Current and Future Land Use

Presently, the Roswell RC and FMS reside on land owned by the City of Roswell and are part of 

the RIAC, and are used to support personnel readiness and organizational maintenance of 

military equipment, respectively. The current land use is listed as L-2 Heavy Industrial. Future 

land use is not anticipated to change (AECOM, 2020). The facility is within a fenced boundary 

with limited access. Each area within the Facility boundary requires an escort and approved 

Facility access including site-specific badging.

2.2.6 Sensitive Habitat and Threatened/Endangered Species

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

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

in the surrounding area.

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

species in Chaves County, New Mexico (U.S. Fish and Wildlife Services, 2021):

Birds:

Northern Aplomado Falcon, Falco Femoralis Septentrionalis (experimental population)

Piping Plover, Charadrius Melodus (threatened)

Fishes:

Pecos Bluntnose Shiner, Notropis Simus Pecosensis (threatened)

Pecos Gambusia, Gambusia Nobilis (endangered)

Flowering Plants:

Pecos Sunflower, Helianthus Paradoxus (threatened)

Insects:

Monarch Butterfly, Danaus Plexippus (candidate)

2.3 HISTORY OF PFAS USE

One AOI where aqueous film-forming foam (AFFF) may have been stored, disposed, or released 

historically at the Roswell RC and FMS was identified in the PA (AECOM, 2020). The one AOI 

is located within the property boundary of the Facility. The FMS building vehicle maintenance 

bay of the Roswell FMS is located on the southeastern portion of the Facility. According to 

personnel interviews, one Tri-MaxTM hand truck (a mobile AFFF fire extinguisher) was stored 

within this bay until 2016, when it was turned in to the Defense Reutilization Marketing Office. 

It was reported that the Tri-MaxTM unit was never used or leaked and was regularly serviced by a 

contractor. There are no records or recollection of any leaks or incidents.
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Figure 2-1

Facility Location

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

)

NM

Facility Data

Facility Boundary

Field Maintenance Shop
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Figure 2-2

Facility Topography

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

)

NM

Facility Data

Facility Boundary

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Figure 2-3

Groundwater Features

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Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

0 1

Miles
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Figure 2-4

Groundwater Elevations

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Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

)

Facility Data

Area of Interest (AOI)

Facility Boundary

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Notes:

FMS = Field Maintenance Shop

AOI 1

NM
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Figure 2-5

Surface Water Features

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3

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Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

)

NM

Facility Data

Facility Boundary

Hydrology/Hydrogeology

Inferred Local Surface Water Flow Direction

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Stream/River

Watershed
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3. SUMMARY OF AREAS OF INTEREST

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

or released historically. Based on the PA findings, one potential release area was identified at the 

Roswell FMS and identified as: AOI 1 - FMS Truck Bay/Vehicle Maintenance Bay. The AOI is

shown on Figure 3-1.

3.1 AOI 1 –FIELD MAINTENANCE SHOP – VEHICLE MAINTENANCE BAY

AOI 01 consists of the FMS building vehicle maintenance bay, which is located on the 

southeastern portion of the Facility. This maintenance bay is used to service organizational 

military vehicles and is adjacent to the Facility’s motor pool. Interviews and records obtained 

during the PA indicate that maintenance bay is used to service various vehicles on and around 

the Facility. According to personnel interviews, one Tri-MaxTM hand truck (a mobile AFFF fire 

extinguisher) was stored within this bay until 2016, when it was turned in to the Defense 

Reutilization Marketing Office. It was reported that the Tri-MaxTM unit was never used or leaked 

and was regularly serviced by a contractor. There are no records or recollection of any leaks or 

incidents. If the Tri-MaxTM hand truck was used or leaked during the time it was stored in the 

vehicle maintenance bay, it was likely left to dry before being cleaned up or drained to the 

center-line floor drain within the vehicle maintenance bay (AECOM, 2020). The vehicle 

maintenance bay had a center-line floor drain that, prior to June 2021, discharged to a sand/grit 

trap and then to the Roswell sanitary sewer. The center-line floor drain was filled with concrete, 

the lines leading to and from the sand trap were grouted, and the sand trap structure was filled 

with sand and capped with concrete. The abandonment work was completed 09 June 2021. There 

are vehicle wash racks outside of the FMS to the southeast and east. The vehicle wash racks 

drain through a 550-gallon oil water separator to the Roswell sanitary sewer.

3.2 ADJACENT SOURCES

One potential off-facility source of PFAS was identified adjacent to the Facility in the PA 

(AECOM, 2020) and is not under the control of the New Mexico ARNG (NMARNG). A 

description of the off-facility source is presented below and shown on Figure 3-1.

3.2.1 Roswell International Air Center

RIAC occupies the former Roswell Army International Airfield and Walker Air Force Base 

(1941-1967). Historic Military AFFF usage at the RIAC property is unknown but may have 

occurred with potential wide distribution from fire training, nozzle checks, and other uses or 

releases. The PA Report identified two emergency incidents at the Air Center on 02 April 2011 

and 05 June 2019.

• 02 April 2011: a Gulfstream G650 jet impacted a concrete structure and an airport 

weather station at the end of the runway during takeoff, resulting in extensive structural 

damage and a post-crash fire. It is unknown if AFFF containing PFAS was used to 

extinguish the fire.

• 05 June 2019: an ignition event occurred in a storage building onsite leading to the 

explosion/consumption of Class C fireworks (3- 6 inch shells) and the explosion of the 
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structure. The storage building is located approximately 1.5 miles to the east of the 

FMS. It is unknown if AFFF containing PFAS was used to extinguish the fire.

No other off-facility source areas were identified in the PA Report. Although the RIAC, formerly 

Walker Air Force Base, is an area of concern for PFAS, the Roswell FMS is likely cross 

gradient/upgradient of any releases at the Air Center (AECOM, 2020).
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Figure 3-1

Areas of Interest

FMS

Facility

FMS Vehicle Maintenance Bay 

AOI 1

3

0 200

Feet

Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:........................WSP

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

)

NM

Facility Data

Area of Interest (AOI)

Facility Boundary

No Suspected PFAS Release

Potential PFAS Release

Note: FMS = Field Maintenance Shop
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4. PROJECT DATA QUALITY OBJECTIVES

As identified during the Data Quality Objective (DQO) process and outlined in the SI Uniform 

Federal Policy (UFP) - QAPP Addendum (EA/Wood, 2022a), the objective of the SI is to 

identify whether there has been a release to the environment at the AOI identified in the PA. For 

each AOI, ARNG determines if further investigation is warranted, a removal action is required to 

address immediate threats, or whether no further action is warranted. This SI evaluated 

groundwater and soil for the presence or absence of relevant compounds at the sampled AOI.

4.1 PROBLEM STATEMENT

ARNG will recommend an AOI for remedial investigation (RI) if site-related soil and 

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

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

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for Roswell RC and FMS (AECOM, 2020)

• Analytical data from groundwater and soil samples collected as part of this SI in 

accordance with the site-specific UFP –QAPP Addendum (EA/Wood 2022a)

• Field data collected during the SI, including groundwater elevation and water quality 

parameters measured at the time of sampling.

4.3 STUDY BOUNDARIES

The scope of the SI was bounded horizontally by the property limits of the Facility (Figure 2-1 

and 3-1). The scope of the SI was bounded vertically by the depth of temporary monitoring wells 

installed within groundwater, where encountered (maximum depth of 144 ft bgs). Off-facility 

sampling was not included in the scope of this SI. If future off-facility sampling is required, the 

proper stakeholders will be notified, and necessary rights of entry will be obtained by ARNG 

with property owner(s). Temporal boundaries were limited to the earliest available time field 

resources were available to complete the study.

4.4 ANALYTICAL APPROACH

Samples were analyzed by Eurofins, accredited under the Department of Defense (DoD)

Environmental Laboratory Accreditation Program (DoD ELAP; Accreditation Number 1.01) and 

the National Environmental Laboratory Accreditation Program (NELAP; Certificate Number 

021). PFAS data underwent 100 percent (%) Stage 2B validation in accordance with the DoD 

General Data Validation Guidelines (2019a) and DoD Data Validation Guidelines Module 3: 

Data Validation Procedure of Per- and Polyfluoroalkyl Substances Analysis by Quality Systems 

Manual (QSM) Table B-15 (2020). PFAS data were compared to applicable SLs within this 

document and decision rules as defined in the UFP-QAPP Addendum (EA/Wood 2022a).
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4.5 DATA USABILITY ASSESSMENT

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

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

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

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

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

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

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

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

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

associated data validation reports. Groundwater quality downgradient of AOI 1 is a data gap. The

SI data are of sufficient quality to meet the objectives and requirements of the UFP-QAPP 

(EA/Wood, 2022a).
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5. SITE INSPECTION ACTIVITIES

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

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

implemented in accordance with the following approved documents.

• Final Preliminary Assessment Report, Roswell Readiness Center and Field 

Maintenance Shop, Roswell, New Mexico, dated August 2020 (AECOM 2020)

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

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

Installations, Nationwide, dated December 2020 (EA 2020)

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

Addendum, Roswell Readiness Center and Field Maintenance Shop, New Mexico, 

dated May 2022 (EA/Wood, 2022a)

• Final Programmatic Accident Prevention Plan, Revision 1, dated June 2022 (EA 

2022b)

• Final Site Safety and Health Plan, Roswell Readiness Center and Field 

Maintenance Shop, STATE, dated June 2022 (EA/Wood 2022b).

The SI field activities were conducted in two sampling events: the first event was on 28 

and 29 April 2022, and the second event was from 06 to 23 June 2022. The SI field 

activities consisted of utility clearance, hand augering to clear utilities and collect surface 

soil samples, hollow stem auger (HSA) boring advancement and soil sample collection, 

temporary monitoring well installation, grab groundwater sample collection, and land 

surveying. Field activities were conducted in accordance with the UFP-QAPP Addendum 

(EA/Wood, 2022a), except as noted in Section 5.9.

The following samples were collected during the SI and analyzed for 24 PFAS via liquid 

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

5.3 Table B-15 to fulfill the project DQOs:

• Eighteen (18) soil samples from 6 locations (soil borings locations)

• Three (3) grab groundwater samples from temporary well locations AOI01-06, 

AOI01-07, and AOI01-08

• 18 quality assurance (QA)/QC samples.

Figure 5-1 provides the sample locations for all media (soil and groundwater) across the 

Facility. Table 5-1 presents the list of samples collected for each medium. Field 

documentation is provided in Appendix B. A log of Daily Notice of Field Activity was 

completed throughout the SI field activities, which is provided in Appendix B1. 

Sampling forms are provided in Appendix B2, land survey data is provided in Appendix 

B3, a corrective action report is provided in Appendix B4, and the investigation-derived 
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waste (IDW) placement location is provided in Appendix B5. Additionally, a 

photographic log of field activities is provided in Appendix C.

5.1 PRE-INVESTIGATION ACTIVITIES

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

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

water. Details of these activities are presented below.

5.1.1 Technical Project Planning

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

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

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

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

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

address the AOIs identified in the PA.

A combined TPP Meeting 1 and 2 was held on 16 February 2022 followed by a Facility walk, 

prior to SI field activities. The combined TPP Meeting 1 and 2 was conducted in general 

accordance with EM 200-1-2. The stakeholders for this SI include, ARNG, NMARNG, USACE, 

New Mexico Environmental Department (NMED), and representatives familiar with the Facility, 

the regulations, and the community. Stakeholders were provided the opportunity to make 

comments on the technical sampling approach and methods at the combined TPP Meeting 1 and 

2. The outcome of the combined TPP Meeting 1 and 2 was memorialized in the UFP-QAPP 

Addendum (EA/Wood, 2022a).

A TPP Meeting 3 was held after the field event to discuss the results of the SI on 17 August 

2023. Meeting minutes for TPP 3 are included in Appendix D of this report. The TPP3 

meeting provided an opportunity to discuss results and findings, and future actions, where 

warranted.

5.1.2 Utility Clearance

WSP USA Environment & Infrastructure, Inc. (WSP), previously doing business as Wood

Environment & Infrastructure Solutions, Inc., contacted the Utility Notification Center to notify 

them of intrusive work at the Facility. WSP contracted MYC Environmental & Construction,

LLC (MYC), a private utility location service and construction company, to perform utility 

clearance and concrete cutting at the Facility. Utility clearance was performed at each of the 

proposed boring locations on 28 April 2022 with input from the WSP field team. General

locating services and ground-penetrating radar (GPR) were used to complete the clearance. 

Additionally, the first 5 ft of each boring were pre-cleared by WSP or WSP’s drilling 

subcontractor, Cascade Drilling and Technical Services (Cascade), using a hand auger to verify 

utility clearance in shallow subsurface where utilities would typically be encountered.

During the first sampling event, surface soil samples were collected at the soil boring locations 

using a hand auger. A buried irrigation line was encountered during the hand auger advancement. 

The line had minimal damage and was repaired by MYC with a poly-vinyl chloride (PVC)
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coupler on 29 April 2022. A corrective action report was prepared following the incident 

(Appendix B4). Photos of the ground disturbance and associated repair are included in 

Appendix C.

5.1.3 Source Water and PFAS Sampling Equipment Acceptability

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

acceptability criteria, as defined in the UFP-QAPP Addendum, prior to the start of field 

activities. A sample from a potable water source at the Facility wash rack, was collected on 16 

February 2022, prior to mobilization and during the initial Facility walk and analyzed for PFAS 

by LC/MS/MS compliant with QSM 5.3 Table B-15. The results of the sample of the potable 

water source used for decontamination of drilling equipment during the SI are provided in 

Appendix F. A discussion of the results is presented in the Data Usability Assessment 

(Appendix A).

Materials that were used within the sampling zone were confirmed as acceptable for use in the

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

environment was provided in the Standard Operating Procedures appendix to the Programmatic 

UFP-QAPP (PQAPP) (EA, 2020).

5.2 HAND AUGER SOIL SAMPLING

Hand auger soil sampling was conducted during the first sampling event from 28 to 29 April 

2022 to collect surface soil samples (0 to 2 feet bgs) at 6 locations (AOI01-01, AOI01-02, 

AOI01-03, AOI01-04, AOI01-05, and AOI01-06). All soil sample locations are shown on 

Figure 5-1. The hand auger locations were selected based on the AOI information provided in 

the PA (AECOM 2020) and as agreed upon by stakeholders during the TPP and site walk, and 

review of the UFP-QAPP Addendum (EA/Wood, 2022a). Several boring locations were adjusted 

within a 50-ft offset for reasons including drill rig access, utility avoidance and bias toward 

sampling within observed drainage features. Non-dedicated sampling equipment (i.e., hand 

auger) was decontaminated between sampling locations. Additionally, an equipment blank 

sample was collected from all non-dedicated sampling equipment (EA/Wood, 2022a).

Each sample was collected into a laboratory-supplied PFAS-free high-density polyethylene 

(HDPE) bottle and labeled using a PFAS-free marker or pen. Samples were packaged on ice and 

transported via Federal Express (FedEx) under standard chain-of-custody (COC) procedures to 

the laboratory and analyzed for PFAS (LC/MS/MS compliant with QSM Version 5.3 Table B15), total organic carbon (TOC) (USEPA Method 9060A), grain size (ASTM Method D-422),

and pH (USEPA Method 9045D) in accordance with the UFP-QAPP Addendum (EA/Wood,

2022a). QC samples and analysis were performed as described in the UFP-QAPP Addendum 

(EA/Wood, 2022a).

5.3 SOIL BORINGS AND SOIL SAMPLING

Subsurface soil samples were collected in June 2022 via HSA drilling methods in accordance 

with Standard Operating Procedure 025 and 047 HSA Drilling and Sampling (EA/Wood, 2022a).

A split spoon sampler was used to collect continuous soil cores to the target depth. A hand auger 

was used to clear the top 5 ft of the boring in compliance with utility clearance procedures. The 
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soil boring locations are shown on Figure 5-1, and boring sample depths are provided in Table 

5-1. Several boring locations were adjusted within a 50-ft offset for reasons including drill rig 

access, utility avoidance and bias toward sampling within observed drainage features.

Three (3) discrete soil samples were collected from each of the six (6) specified soil borings

(AOI01-01, AOI01-02, AOI01-03, AOI01-04, AOI01-05, and AOI01-06): one sample at the 

surface (0 to 2 ft bgs) and two subsurface soil samples. The surface soil samples were collected 

during the first sampling event as described in Section 5.2. Subsurface samples were collected 

during the second sampling event in June 2022 and were defined as intermediate and deep 

samples (EA/Wood, 2022a). Intermediate samples were collected at 6 to 7 ft bgs at AOI01-01, 

AOI01-02, AOI01-03, AOI01-04, and AOI01-05 (shallow borings) and at 14 to 15 ft bgs at 

AOI01-06 (deep boring and temporary well location). Deep samples were collected 

approximately 1 ft above the groundwater table at AOI01-06, and for the remaining borings, 

were collected at 14 to 15 ft bgs. Groundwater during drilling was encountered at depths ranging 

from approximately 128 to 130 ft bgs. Total boring completion depths, to accommodate 

temporary well installation, ranged from approximately 135 to 144 ft bgs, and the shallow total 

boring completion depths ranged from approximately 15 to 18 ft bgs.

During drilling, soil cores were continuously logged for lithological descriptions by a field 

geologist using the Unified Soil Classification System. A photoionization detector (PID) was 

used to screen the breathing zone during boring activities as a part of personal safety 

requirements. Observations and measurements were recorded on sampling forms (Appendix B2) 

and in a non-treated field logbook. Depth interval, recovery thickness, PID concentrations, 

moisture, relative density, Munsell color, and Unified Soil Classification System texture were 

recorded. The boring logs are provided in Appendix E.

Soil borings completed during the SI found predominately medium plastic fines (silt/clay) with

interbedded layers of sands and gravels below the Facility. The borings were completed at depths 

between 15 and 144 feet bgs. The Facility lithology was predominately silty sands and well 

graded gravels in the shallow subsurface and predominately medium plastic fines (clay) with 

layers of well graded gravels, sand, and less plastic fines (silt) in the deeper subsurface. Layers 

of well graded gravels with fines (silt/clay) and/or sand was observed consistently in the borings 

with thicknesses ranging from a few inches to 34 ft. These observations are consistent with the 

understood depositional environment of the region.

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

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

standard COC procedures to the laboratory (Eurofins) and analyzed for PFAS (LC/MS/MS 

compliant with QSM Version 5.3 Table B-15), TOC (USEPA Method 9060A), pH (USEPA 

Method 9045D), and grain size (ASTM Method D-422) in accordance with the UFP-QAPP 

Addendum (EA/Wood, 2022a).

Field duplicate samples (Table 5-1) were collected at a rate of 10% and analyzed for the same 

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

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

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

for the shallow soil samples, one equipment blank (EB) was collected per day and analyzed for 
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the same parameters as the soil samples. The specific equipment is noted in Table 5-1. A 

temperature blank was placed in each cooler for use in confirming that samples were preserved 

at or below 6 degrees Celsius (°C) during shipment.

5.4 TEMPORARY WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Temporary wells were installed at locations AOI01-06, AOI01-07, and AOI01-08 using an HSA

CME 75 system. Once the borehole was advanced to the desired depth, a temporary well was 

constructed of a 10-ft section of 2-inch Schedule 40 poly-vinyl chloride (PVC) screen with 

sufficient casing to reach the ground surface. New PVC pipe and screen were used at each 

location to avoid cross contamination between locations. The screen intervals for the temporary 

wells are provided in Table 5-2.

Groundwater samples were collected, after a period of time following well installation to allow 

groundwater to infiltrate and recharge the temporary well intervals, using a monsoon pump at 

AOI01-06 with PFAS-free HDPE tubing and a PFAS-free bailer at AOI01-07 and AOI01-08. 

Different sampling methods were required due to the accumulated fines within the screened 

interval and the limited infiltration and groundwater recharge within the temporary wells. The 

temporary well, AOI01-06 was purged at a low flow rate but purged nearly dry following 

removal of 3.2 gallons of water. The AOI01-06 sample was collected once the well had 

recharged sufficient for sampling. At AOI01-07, approximately one gallon of water was purged 

by pumping before the water column in the well dropped to the point that there was insufficient 

head pressure to continue pumping, at which time a PFAS-free bailer was deployed to collect the 

water sample at AOI01-07. AOI01-08 was purged with a PFAS-free bailer to remove 

accumulated fines and then sampled. Water quality parameters (e.g., temperature, specific 

conductance, pH, dissolved oxygen, and oxidation-reduction potential) were measured using a 

water quality meter and recorded on the field sampling form (Appendix B2) before each grab 

sample was collected in a separate container.

Each sample was collected in laboratory-supplied PFAS-free HDPE bottles and labeled using a 

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

(FedEx) under standard COC procedures to the laboratory (Eurofins) and analyzed for PFAS by 

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

Addendum (EA/Wood, 2022a).

Field duplicate samples (Table 5-1) were collected at a rate of 10% and analyzed for the same 

parameters as the accompanying samples. MS/MSDs were collected at a rate of 5% and analyzed 

for the same parameters as the accompanying samples. Three (3) field blanks (FBs) were

collected in accordance with the UFP-QAPP Addendum (EA/Wood, 2022a). In instances when 

non-dedicated sampling equipment was used, such as a bladder or monsoon pump, one EB was 

collected per day and analyzed for the same parameters as the groundwater samples. A 

temperature blank was placed in each cooler for use in confirming that samples were preserved 

at or below 6°C during shipment.
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Following well surveying (described below in Section 5.6), temporary wells were abandoned in 

accordance with the SI UFP-QAPP Addendum (EA/Wood, 2022a) by removing the PVC and 

backfilling the hole with bentonite chips.

For deep HSA borings (AOI01-06, AOI01-07, and AOI01-08), Portland cement was used for 

abandonment pursuant to NM requirements. Borings were installed in grass/dirt, asphalt, and 

concrete areas and all boring locations were restored to originally condition at the best of the 

ability of Cascade.

5.5 SYNOPTIC WATER LEVEL MEASUREMENTS

Groundwater levels were used to monitor Facility-wide groundwater elevations and assess 

groundwater flow. A synoptic groundwater gauging event was performed on 19 June 2022. 

Groundwater elevation measurements were collected from the 3 newly installed temporary 

monitoring wells, taken from the survey mark on the northern side of the well casing.

Groundwater elevation data is provided in Table 5-3. A groundwater flow contour map is 

provided as Figure 2-4.

5.6 SURVEYING

The northern side of each new temporary well casing was surveyed using a Trimble R10 realtime kinematic differential global positioning system. Positions were collected in the applicable 

Universal Transverse Mercator zone projection with World Geodetic System 1984 datum 

(horizontal) and North American Vertical Datum 1988 (vertical). Surveying data were collected 

by Atkins Engineering Associates, Inc. (Atkins) on 21 June 2021 and are provided in Appendix 

B3.

5.7 INVESTIGATION-DERIVED WASTE

As of the date of this report, the disposal of PFAS IDW is not regulated federally. IDW 

generated during the SI is considered non-hazardous waste and was managed in accordance with 

the UFP-QAPP Addendum (EA/Wood, 2022a) and subsequent discussions with NMED and 

Facility personnel.

Surface soil IDW from the first sampling event was containerized pending analysis. Following 

review of the surface soil sample results with all stakeholders and with verbal approval by 

NMED, the surface soil IDW was returned to the ground surface at each sampling location and

non-saturated soil IDW from subsurface sampling and temporary well installation was 

consolidated and placed on the ground in a location within the motor pool at the Facility. Water 

saturated soil IDW (i.e., saturated soil cuttings) were placed into Department of Transportation 

(DOT)-approved steel drums, labeled, and stored on-Facility on plastic sheeting on an asphaltpaved surface pending analytical results. The subsurface IDW was not sampled and assumes the 

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

Liquid IDW generated during SI activities (i.e., purge water, development water, and 

decontamination fluids) were contained in labeled, 55-gallon Department of Transportation 

(DOT)-approved steel drums and left on plastic sheeting on an asphalt-paved surface. The liquid 

IDW was not sampled and assumes the characteristics of the associated groundwater samples 
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collected from that source location. The liquid IDW will be disposed of via a Resource 

Conservation and Recovery Act Subtitle C landfill. The disposal contract is being managed 

under a separate contract (EA Engineering, Science, and Technology, Inc., 2021). Specifics on 

the disposal of liquid IDW will be addressed in an IDW Treatment Memorandum.

Geographic coordinates were collected using a Global positioning system (GPS) around each 

location where IDW was placed (i.e., an IDW polygon). The IDW polygons are displayed on the 

figure in Appendix B5.

The IDW disposal is being managed separately under a contract with EA Engineering, Science, 

and Technology, Inc. Specifics on the disposal of solid and liquid IDW will be addressed in an 

IDW Technical Memorandum.

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

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

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

5.8 LABORATORY ANALYTICAL METHODS

Samples were analyzed by LC/MS/MS, compliant with QSM Version 5.3 Table B-15, at 

Eurofins in Lancaster, Pennsylvania, a DoD ELAP and NELAP-certified laboratory.

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

Method 9045D, and grain size using ASTM Method D-422.

5.9 DEVIATIONS FROM SI UFP-QAPP ADDENDUM

Deviations from the UFP-QAPP Addendum (EA/Wood, 2022a) occurred based on field 

conditions. These deviations were discussed between EA, WSP, ARNG, USACE, and

NMARNG. Deviations from the UFP-QAPP Addendum are noted below:

• AOI01-05: This location was moved slightly southeast to allow for a sufficient distance 

from the wash rack drain and the associated underground utilities. The location was 

placed as close as was deemed safe by Cascade and WSP.

• AOI01-09: No temporary well was installed at this location and subsequently no 

groundwater sample or groundwater elevation were collected. Gravels with calcium 

carbonate were encountered in significant volumes during borehole advancement at this 

location. The lithology at this location placed excessive amounts of stress onto the 

drilling equipment and refusal was encountered during the first and second attempt at 97 

and 70 ft bgs, respectively. Following refusal during the first attempt, a step out was 

agreed upon which was placed 10 ft to the east. Cascade noted concerns of the equipment 

not being able to reach the proposed total depth at this location and a verbal agreement on 

20 June 2022 between WSP and ARNG was reached to not proceed with this location 

based on the location’s lithology and the limited capability of the available equipment. 

This was documented on the Daily Field Record included in Appendix B-1.

• During drilling of the deep boreholes for temporary wells, approximately three to five 

gallons of potable water was intermittently sprayed on the augers to cool frictional heat 
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that was generated by the drill bit while cutting through the subsurface lithology. The 

intermittent intervals at which water was introduced are denoted on the boring logs in 

Appendix E. With the minimal volume added, potable water that was not converted to 

vapor by the heat and frictional forces is expected to have been adsorbed by the borehole 

soil. No potable water was added to the saturated interval.

• Due to limited recharge conditions, the temporary wells were not able to be purged until 

water quality indicator parameters stabilized. Groundwater purging with a submersible

pump at AOI01-06 removed approximately 3.2 gallons of groundwater before the well 

was purged nearly dry. The groundwater sample was collected from AOI01-06 once the 

well had recharged to a sufficient level. Approximately 1 gallon of groundwater was 

purged at AOI01-07 before the water column dropped to where there was insufficient 

head pressure for pumping. The groundwater was then sampled at AOI01-07 with a 

PFAS-free bailer as stated in Section 5.4. Approximately 2 gallons of groundwater was 

purged and sampled with a PFAS-free bailer from AOI01-08 and no submersible pump 

purging was performed due to sediment, minimal water volume present, and conditions 

observed at AOI01-06 and AOI01-07.

• No shaker tests were performed on the groundwater samples due to limited water 

recovered at AOI01-06 and a field omission at AOI01-07 and AOI08.

• Temporary monitoring wells were abandoned with a mixture of water, Quikrete Portland 

Cement (Type I/II), and a Quick Gel. This grout mixture is in compliance with the NM 

abandonment requirements.
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Table 5-1. Site Inspection Samples by Medium

Roswell FMS, Roswell, NM

Site Inspection Report

Sample Identification

Sample Collection 

Date

Sample Depth

(ft bgs)

PFAS(LC/MS/MS compliant with QSM 5.3 Table B-15)TOC(USEPA Method 9060A) pH (USEPA Method 9045D)Grain Size (ASTM Method D-422)

Comments

Soil Samples

AOI01-01-SB-0-2 4/28/2022 8:50 0-2 X X X X Parent Sample – AOI01-

01-SB-01-02-DUP

AOI01-01-SB-01-02-DUP 4/28/2022 8:50 0-2 X FD

AOI01-01-SB-06-07 6/7/2022 16:40 6-7 X MS/MSD

AOI01-01-SB-14-15 6/7/2022 16:50 14-15 X

ROS-FD-01 6/7/2022 16:50 14-15 X FD

AOI01-02-SB-0-2 4/28/2022 9:55 0-2 X

AOI01-02-SB-06-07 6/13/2022 13:42 6-7 X

AOI01-02-SB-14-15 6/13/2022 13:46 14-15 X

AOI01-03-SB-0-2 4/28/2022 15:20 0-2 X

AOI01-03-SB-06-07 6/13/2022 10:57 6-7 X

AOI01-03-SB-14-15 6/13/2022 11:09 14-15 X

AOI01-04-SB-0-2 4/28/2022 10:50 0-2 X

AOI01-04-SB-06-07 6/13/2022 15:10 6-7 X

AOI01-04-SB-14-15 6/13/2022 15:15 14-15 X

AOI01-05-SB-0-2 4/28/2022 16:00 0-2 X

AOI01-05-SB-06-07 6/13/2022 9:05 6-7 X

AOI01-05-SB-14-15 6/13/2022 9:35 14-15 X

AOI01-06-SB-0-2 4/28/2022 16:25 0-2 X

AOI01-06-SB-14-15 6/10/2022 9:35 14-15 X

AOI01-06-SB-139-140 6/12/2022 12:02 139-140 X

ROS-FD-02 6/12/2022 12:00 139-140 X FD

Groundwater Samples

AOI01-06-GW 6/21/2022 14:55 NA X

AOI01-07-GW 6/22/2022 12:15 NA X

ROS-FD-03 6/22/2022 12:15 NA X FD

AOI01-08-GW 6/22/2022 13:45 NA X MS/MSD

Blank Samples

ROS-ERB-01 4/28/2022 4:50 NA X Hand Auger

ROS-ERB-01 6/7/2022 15:50 NA X Split Spoon Sampler

ROS-ERB-02 6/10/2022 8:16 NA X Split Spoon Sampler

ROS-ERB-03 6/13/2022 15:28 NA X Split Spoon Sampler

ROS-ERB-04 6/13/2022 8:46 NA X Split Spoon Sampler

ROS-ERB-05 6/16/2022 11:00 NA X Auger Bolts with 

Lubricant

ROS-ERB-06 6/21/2022 7:15 NA X GeoTech Pump

ROS-ERB-07 6/21/2022 12:00 NA X PVC Pump – Monsoon
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Sample Identification

Sample Collection 

Date

Sample Depth

(ft bgs)

PFAS(LC/MS/MS compliant with QSM 5.3 Table B-15)TOC(USEPA Method 9060A) pH (USEPA Method 9045D)Grain Size (ASTM Method D-422)

Comments

ROS-ERB-08 6/22/2022 11:15 NA X Stainless Steel Bailer

ROS-FB-01 4/28/2022 11:15 NA X

ROS-FB-01 6/21/2022 7:30 NA X

Notes:

ASTM = American Society for Testing and Materials

bgs = below ground surface

ERB = equipment rinsate blank

FB = field blank

FD = field duplicate

FMS = Field Maintenance Shop

FRB = field reagent blank

LC/MS/MS = Liquid Chromatography Mass Spectrometry

MS/MSD = matrix spike/ matrix spike duplicate

QSM = Quality Systems Manual

TOC = total organic carbon

USEPA = United States Environmental Protection Agency
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Table 5-2. Soil Boring Depths and Temporary Well Screen Intervals

Roswell FMS, Roswell, NM

Site Inspection Report

Area of Interest Boring Location

Soil Boring Depth

(ft bgs)

Temporary Well 

Screen Interval 1

(ft bgs)

1

AOI01-01 15 NA

AOI01-02 15 NA

AOI01-03 15 NA

AOI01-04 15 NA

AOI01-05 15 NA

AOI01-06 144 131.8-141.8

AOI01-07 135 126.3-136.3

AOI01-08 135 125.3-135.3

AOI01-09 

(original)

97 NA2

AOI01-09 

(step out)

70 NA2

Notes:

1 Temporary well screen set above total depth to capture groundwater interface

2 Refusal was encountered and could not be advanced to groundwater table

AASF = Army Aviation Support Facility

amsl = Above mean sea level

bgs = below ground surface

btoc = below top of casing

ft = feet

FMS = Field Maintenance Shop

NA = not applicable

NAVD88 = North American Vertical Datum 1988
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Table 5-3. Groundwater Elevation

Roswell FMS, Roswell, NM

Site Inspection Report

Monitoring Well 

ID

Top of Casing Elevation1

(ft NAVD88)

Depth to Water

(ft btoc)

Groundwater Elevation

(ft NAVD 88)

AOI01-06 3652.81 132.25 3520.62

AOI01-07 3650.95 118.43 3532.67

AOI01-08 3650.58 117.37 3533.22

Notes:

1 Temporary well screen set above total depth to capture groundwater interface

amsl = Above mean sea level

bgs = below ground surface

btoc = below top of casing

FMS = Field Maintenance Shop

Ft = feet

NA = not applicable

NAVD88 = North American Vertical Datum 1988
Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 5-1

Site Inspection Sample Locations

!(

!(

!(

!(

!(

!(

!(

!(

!(!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-09-West AOI01-08

AOI01-09-East

3

0 100

Feet

Data Sources: 

ESRI 2020

AECOM 2019

Date:.......................October 2022

Prepared By:........................WSP

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

)

Facility Data

Area of Interest (AOI)

Facility Boundary

No Suspected PFAS Release

Potential PFAS Release

Original Paved Area

Hydrology/Hydrogeology

Inferred Local Surface Water

Flow Direction

Shallow Aquifer Approximate

Groundwater Flow Direction

FMS Vehicle Maintenance Bay 

Wash Rack

Sample Type

!( Soil Boring

!( Monitoring Well

FMS = Field Maintenance Shop

AOI 1

NM
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6. SITE INSPECTION RESULTS

This section presents the analytical results of the SI. The SLs used in this evaluation are 

presented in Section 6.1. A discussion of the results for the AOI is provided in Sections 6.3. SLs

for relevant compounds, for both soil and groundwater, are presented in Table 6-1. Tables 6-2

through 6-6 present results in soil or groundwater for the relevant compounds. Tables that 

contain all results are provided in Appendix F, and the laboratory reports are provided in 

Appendix G.

6.1 SCREENING LEVELS

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

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

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

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

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

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

on Table 6-1.

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

Analyte

Residential 0-2 ft bgs

(Soil)

(μg/kg)1

Industrial / Commercial

Composite Worker 2-15 ft bgs

(Soil)

(μg /kg) 1

Tap Water

(Groundwater)

(ng/L) 1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

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

Environmental Protection Agency’s (EPA’s) Regional Screening Level Calculator. Hazard Quotient 

(HQ)=0.1. May 2022.

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

referred to as GenX) was not included as an analyte at the time of this SI. Based on the CSM developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility 

because HFPO-DA is generally not a component of MIL-SPEC AFFF and based on its history including 

distribution limitations that restricted use of GenX, it is generally not a component of other products the 

military used. In addition, it is unlikely that GenX would be an individual chemical of concern in the 

absence of other PFAS.

Abbreviations:

g/kg = microgram(s) per kilogram

bgs = below ground surface

ft = feet

ng/L = nanogram(s) per liter
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The data in the subsequent sections are compared against the SLs presented in Table 6-1. The 

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

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

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

ft bgs) and the industrial/commercial worker scenario is applied to shallow subsurface soil 

results (2 to 15 ft bgs). The SLs are not applied to deep subsurface soil results (greater than 15 ft 

bgs) because 15 ft is the anticipated limit of construction activities.

6.2 SOIL PHYSICOCHEMICAL ANALYSES

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

size, which are important for evaluating transport through the soil medium. Appendix F contains 

the results of the TOC, pH, and grain size sampling.

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

appropriate, to assess fate and transport. According to the Interstate Technology Regulatory 

Council (ITRC), several important PFAS partitioning mechanisms include hydrophobic and 

lipophobic effects, electrostatic interactions, and interfacial behaviors. At relevant environmental 

pH values, certain PFAS are present as organic anions, and are therefore relatively mobile in 

groundwater (Xiao et al., 2015), but tend to associate with the organic carbon fraction that may 

be present in soil or sediment (Higgins and Luthy 2006; Guelfo and Higgins 2013). When 

sufficient organic carbon is present, organic carbon normalized distribution coefficients (Koc 

values) can help in evaluating transport potential, though other geochemical factors (for example, 

pH and presence of polyvalent cations) may also affect PFAS sorption to solid phases (ITRC, 

2018).

6.3 AOI 1 – Field Maintenance Shop – Vehicle Maintenance Bay

This section presents the analytical results for soil and groundwater in comparison to SLs for 

AOI 1: FMS – Vehicle Maintenance Bay. The soil and groundwater results are summarized in 

Table 6-2 through 6-4. Soil and groundwater results are presented on Figures 6-1 through 6-7.

6.3.1 AOI 1 Soil Analytical Results

Soil samples were collected from 6 boring locations associated with AOI 1 during the SI. Figure 

6-1 through Figure 6-5 present the ranges of detections in soil. Tables 6-2 and Table 6-3

summarize the soil results.

Surface soil (0 to 2 ft bgs) was sampled from boring locations AOI01-01 through AOI01-06. Soil 

was sampled from the shallow subsurface soils (6 to 7 ft bgs) and deep subsurface soil intervals 

(14 to 15 ft bgs) from boring locations AOI01-01 through AOI01-05. Soil was also sampled from 

the shallow subsurface soil interval of 14 to 15 ft bgs and a very deep subsurface soil interval of 

139 to 140 ft bgs at boring location, AOI01-06.

PFOS and PFOA were detected in surface soil at concentrations below their respective SLs. 

PFOA was detected at AOI01-01 at a concentration of 0.2 J μg/kg. PFOS was detected at 

AOI01-04 at a concentration of 1.6 J+ μg/kg. PFBS, PFHxS, and PFNA were not detected in the 

surface soil samples.
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No relevant compounds (PFBS, PFHxS, PFNA, PFOS, and PFOA) were detected in shallow and 

deep subsurface soils.

6.3.2 AOI 1 Groundwater Analytical Results

Groundwater samples were collected from 3 temporary wells associated with AOI 1 during the 

SI as discussed in Section 5.0. Figure 6-6 and 6-7 presents the ranges of detections in 

groundwater. Table 6-4 summarizes the groundwater results.

Groundwater was sampled from temporary monitoring well locations AOI01-06 through AOI01-

08. PFBS and PFOA were detected at concentrations below their respective SLs. Two of the 

three locations (AOI01-06 and AOI01-07) had detections of PFBS, at concentrations of 1.0 J and

1.2 J ng/L, respectively. Two of the three locations (AOI01-06 and AOI01-07) had detections of 

PFOA, at concentration of 1.2 J and 0.75 J ng/L (0.78 J ng/L in the duplicate), respectively. 

PFHxS, PFNA, and PFOS were not detected in the groundwater samples.

6.3.3 Conclusions

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

PFBS and PFOA were detected in groundwater at concentrations below their respective SLs. 

There were no exceedances of the SLs in soil or groundwater, and no further evaluation at AOI 1 

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

Site Inspection Report

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Area of Interest AOI 1

Location ID AOI01-01 AOI01-01 AOI01-02 AOI01-03 AOI01-04 AOI01-05 AOI01-06

Sample Name AOI01-01-SB0-2

AOI01-01-SB-0-

2-DUP

AOI01-02-SB0-2AOI01-03-SB0-2AOI01-04-SB0-2

AOI01-05-SB-0-2 AOI01-06-SB-0-2

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

Depth 0-2 ft 0-2 ft 0-2 ft 0-2 ft 0-2 ft 0-2 ft 0-2 ft

Sample Date 4/28/2022 4/28/2022 4/28/2022 4/28/2022 4/28/2022 4/28/2022 4/28/2022

Analyte

OSD Screening 

Level

0-2 ft bgs1

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

Soil, PFAS (PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15) (μg/kg)

PFBS 1,900 ND U ND U ND U ND U ND U ND U ND U

PFHxS 130 ND U ND U ND U ND U ND U ND U ND U

PFNA 19 ND U ND U ND U ND U ND U ND U ND U

PFOS 13 ND U ND U ND U ND U 1.6 J+ ND U ND U

PFOA 19 0.2 J ND U ND U ND U ND U ND U ND U

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations:

References PFBS Perfluorobutanesulfonic acid 

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

Groundwater and Soil using EPA’s Regional Screening Level Calculator. Hazard Quotient 

(HQ)=0.1. May 2022. Soil screening levels based on residential scenario for incidental 

ingestions of contaminated soil.

PFHxS Perfluorohexanesulfonic acid

PFNA Perfluorononanoic acid

PFOS Perfluorooctanesulfonic acid

PFOA Perfluorooctanoic acid

Interpreted Qualifiers

J = Estimated concentration

J+ = Estimated quantity but may be biased high

U = The analyte was not detected at a level greater than or equal to the adjusted detection level.

Acronyms and Abbreviations

μg/kg = micrograms per kilogram 

AOI = Area of Interest

ft = Feet

LOD = Limit of Detection

LOQ = Limit of Quantitation

ND = Analyte not detected above the LOD.

Qual = Qualifier
Table 6-3 

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil

Site Inspection Report

Roswell Field Maintenance Shop, New Mexico

Analyte OSD Screening Level

>2 ft bgs1,2 Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

Soil, PFAS (PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15) (μg/kg)

PFBS 25,000 ND U ND U ND U ND U ND U ND U ND U

PFHxS 1,600 ND U ND U ND U ND U ND U ND U ND U

PFNA 250 ND U ND U ND U ND U ND U ND U ND U

PFOS 160 ND U ND U ND U ND U ND U ND U ND U

PFOA 250 ND U ND U ND U ND U ND U ND U ND U

Chemical Abbreviations:

PFBS Perfluorobutanesulfonic acid 

References PFHxS Perfluorohexanesulfonic acid 

PFNA Perfluorononanoic acid 

PFOS Perfluorooctanesulfonic acid 

PFOA Perfluorooctanoic acid 

Interpreted Qualifiers

J = Estimated concentration

J+ = Estimated quantity but may be biased high

Acronyms and Abbreviations

μg/kg = micrograms per kilogram 

AOI = Area of Interest

ft = Feet

LOD = Limit of Detection

LOQ = Limit of Quantitation

ND = Analyte not detected above the LOD.

Qual = Qualifier

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels Calculated for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s 

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil based on are based on Industrial/Commercial Composite Worker scenario for 

incidental ingestion of contaminated soil. 

AOI01-02 AOI01-02 AOI01-03 AOI01-03

Sample Name AOI-01-SB-06-07 AOI-01-SB-14-15 ROS-FD-01 AOI01-02-SB-06-07

Area of Interest 

Location ID AOI01-01 AOI01-01 AOI01-01

AOI01-02-SB-14-15 AOI01-03-SB-06-07 AOI01-03-SB-14-15

Depth 6-7 ft 14-15 ft 14-15 ft 6-7 ft

Parent Sample ID AOI-01-SB-14-15

Detected concentration exceeded 

OSD Screening Levels Grey Fill

U = The analyte was not detected at a level greater than or 

equal to the adjusted detection level.

AOI 1

Sample Date 6/7/2022 6/7/2022 6/7/2022 6/13/2022 6/13/2022 6/13/2022 6/13/2022

6-7 ft 14-15 ft 14-15 ft
Table 6-3 

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil

Site Inspection Report

Roswell Field Maintenance Shop, New Mexico

Analyte OSD Screening Level

>2 ft bgs1,2

Soil, PFAS (PFAS by LC/MS/MS compliant with QSM 

PFBS 25,000

PFHxS 1,600

PFNA 250

PFOS 160

PFOA 250

References

Interpreted Qualifiers

J = Estimated concentration

J+ = Estimated quantity but may be biased high

Acronyms and Abbreviations

μg/kg = micrograms per kilogram 

AOI = Area of Interest

ft = Feet

LOD = Limit of Detection

LOQ = Limit of Quantitation

ND = Analyte not detected above the LOD.

Qual = Qualifier

1. Assistant Secretary of Defense. July 2022. Risk Based Sc 

Regional Screening Level Calculator. HQ=0.1. May 2022. 

incidental ingestion of contaminated soil. 

Sample Name

Area of Interest 

Location ID

Depth

Parent Sample ID

Detected concentration exceeded 

OSD Screening Levels Grey Fill

U = The analyte was not detected at a level greater than or 

equal to the adjusted detection level.

Sample Date

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

ND U ND U ND U ND U ND U ND U

ND U ND U ND U ND U ND U ND U

ND U ND U ND U ND U ND U ND U

ND U ND U ND U ND U ND U ND U

ND U ND U ND U ND U ND U ND U

Chemical Abbreviations:

PFBS Perfluorobutanesulfonic acid 

PFHxS Perfluorohexanesulfonic acid 

PFNA Perfluorononanoic acid 

PFOS Perfluorooctanesulfonic acid 

PFOA Perfluorooctanoic acid 

14-15 ft

6/10/2022

6-7 ft 14-15 ft 6-7 ft 14-15 ft 6-7 ft

6/13/2022 6/13/2022 6/13/2022 6/13/2022 6/10/2022

AOI01-04-SB-06-07 AOI01-04-SB-14-15 AOI01-05-SB-06-07 AOI01-05-SB-14-15 AOI01-06-SB-06-07 AOI01-06-SB-14-15

AOI01-04 AOI01-04 AOI01-05 AOI01-05 AOI01-06 AOI01-06

AOI 1
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-7

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

Site Inspection Report

Roswell Field Maintenance Shop, New Mexico

Area of Interest AOI 1

Location ID AOI01-06 AOI01-06

Sample Name AOI01-06-SB-139-140 ROS-FD-02

Parent Sample ID AOI01-06-SB-139-140

Depth 139-140 ft 139-140 ft

Sample Date 6/12/2022 6/12/2022

Analyte Result Qual Result Qual

Soil, PFAS (PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15) (μg/kg)

PFBS ND U ND U

PFHxS ND U ND U

PFNA ND U ND U

PFOS ND U ND U

PFOA ND U ND U

Interpreted Qualifiers Chemical Abbreviations:

U = The analyte was not detected at a level greater than or 

equal to the adjusted detection level.

PFBS Perfluorobutanesulfonic acid 

PFHxS Perfluorohexanesulfonic acid 

PFNA Perfluorononanoic acid 

Acronyms and Abbreviations PFOS Perfluorooctanesulfonic acid 

μg/kg = micrograms per kilogram PFOA Perfluorooctanoic acid 

AOI = Area of Interest

ft = Feet

LOD = Limit of Detection

LOQ = Limit of Quantitation

ND = Analyte not detected above the 

LOD.

Qual = Qualifier
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-8

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Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-9

Table 6-5. PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

Roswell Field Maintenance Shop, New Mexico

Location ID AOI01-06 AOI01-07 AOI01-07 AOI01-08

Sample Name AOI01-06-GW AOI01-07-GW ROS-FD-03 AOI01-08-GW

Parent Sample ID AOI01-07-GW

Sample Date 6/21/2022 6/22/2022 6/22/2022 6/22/2022

Analyte

OSD 

Screening 

Level 1

Result Qual Result Qual Result Qual Result Qual

PFAS (ng/L)

PFBS 601 1.0 J 1.2 J 1.2 J ND U

PFHxS 39 ND U ND U ND U ND U

PFNA 6 ND U ND U ND U ND U

PFOS 4 ND U ND U ND U ND U

PFOA 6 1.2 J 0.75 J 0.78 J ND U

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations:

References PFBS Perfluorobutanesulfonic acid 

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

Screening Levels in Groundwater and Soil using EPA’s 

Regional Screening Level Calculator. Hazard Quotient 

(HQ)=0.1. May 2022. Groundwater screening levels based on 

residential scenario for direct ingestion of groundwater.

PFHxS Perfluorohexanesulfonic acid 

PFNA Perfluorononanoic acid 

PFOS Perfluorooctanesulfonic acid 

PFOA Perfluorooctanoic acid 

Interpreted 

Qualifiers

J = Estimated concentration

J+ = Estimated quantity but may be biased high

U = The analyte was not detected at a level greater than or equal to the 

adjusted detection level.

Acronyms and Abbreviations

AOI = Area of 

Interest

ft = Feet

LOD = Limit of Detection

LOQ = Limit of Quantitation

ND = Analyte not detected above the 

LOD.

ng/L = nanograms per liter

Qual = Qualifier
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-10

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:........................Wood

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

Facility Data

Facility Boundary

Area of Interest (AOI)

Potential PFAS Release

Original Paved Area

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-1

PFOS Detections in Soil (AOI 1)

)

NM

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

0 50

Feet

0 50

Feet

0 50

Feet

Shallow Intermediate Deep

PFOS Results (μg/kg)

!( Non-Detect (ND)

!( >ND-13

PFOS Results (μg/kg)

!( Non-Detect (ND)

PFOS Results (μg/kg)

!( Non-Detect (ND)

3
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-12

This page intentionally left blank
Facility Data

Area of Interest (AOI)

Fac ility Bound ary

No Suspected P FAS Release

P otential P FAS Release

Orig inal P aved Area

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-2

PFOA Detections in Soil (AOI 1)

)

NM

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

0 50

Feet

0 50

Feet

0 50

Feet

Sh allow Interm ed iate Deep 3

Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

P repared By:........................WSP

P repared For:....................USACE

AOI01-06 w as ad vanc ed to g round w ater. Interm ed iate

soil sam ple at AOI01-06 tak en at 14-15 ft bg s. Deep soil

sam ple at AOI01-06 tak en at 139-140 ft bg s.

PFOA Results (μg/kg)

!( ND (Non-Detec t)

!( >ND - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500

NOTES:

P FAS = P er- and P olyfluoroalk yl Substanc es

P FOA = perfluorooc tanoic ac id

ND = Non-Detec t

(μg /Kg ) = Mic rog ram (s) per Kilog ram

Exc eed ances of Th e Offic e of th e Sec retary of Defense

(OSD) Sc reening Level (SL) are d epic ted w ith a yellow h alo.
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-14

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

P repared By:........................WSP

P repared For:....................USACE

Facility Data

Area of Interest (AOI)

Fac ility Bound ary

No Suspected P FAS Release

P otential P FAS Release

Orig inal P aved Area

PFBS Detectio n s in So il (AOI 1)

)

NM

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

0 50

Feet

0 50

Feet

0 50

Feet

Sh allow Interm ed iate Deep

PFBS Res ults (μg/kg)

!( Non-Detect (ND)

3

PFBS Res ults (μg/kg) NOTES:

P FAS = P er- and P olyfluoroalk yl Substanc es

P FBS = perfluorobutanesulfonic ac id

ND = Non-Detec t

(μg /Kg ) = Mic rog ram (s) per Kilog ram

Exc eed ances of Th e Office of th e Sec retary of Defense (OSD)

Sc reening Level (SL) are d epic ted w ith a yellow h alo.

!( ND (Non-Detec t)

!( >ND - 10

!( >10 - 1,900

!!( >1,900 - 25,000

!!( >25,000

AOI01-06 w as ad vanc ed to g round w ater.

Interm ed iate soil sam ple at AOI01-06 tak en at 14-

15 ft bg s. Deep soil sam ple at AOI01-06 tak en at

139-140 ft bg s.

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-3
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-16

This page intentionally left blank
Data Sources: 

ESRI 2020

AECO M 2020

Date:........................O ctob er 2022

Prepared By:........................WSP

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

Facility Data

Area of Interest (AO I)

Fac ility Boundary

No Suspected PFAS Release

Potential PFAS Release

O rig inal Pav ed Area

PFHxS Detectio n s in So il (AOI 1)

)

NM

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

0 50

Feet

0 50

Feet

0 50

Feet

Sh allow Interm ediate Deep 3

NOTES:

PFAS - Per- and Polyfluoroalkyl Sub stances

PFHxS = perfluoroh exanesulfonic ac id

ND = Non-Detect

(μg /Kg ) = Mic rog ram (s) per Kilog ram

Exc eedances of Th e O ffice of th e Sec retary of Defense (O SD)

Sc reening Lev el (SL) are depicted with a yellow h alo.

PFHxS Res ults (μg/kg)

!( ND (Non-Detec t)

!( >ND - 13 !!( >1,600 !( >13 -130

!!( >130 - 1,600

AO I01-06 was adv anc ed to g roundwater.

Interm ediate soil sam ple at AO I01-06 taken at 14-

15 ft b g s. Deep soil sam ple at AO I01-06 taken at

139-140 ft b g s.

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-4
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-18

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

P repared By:........................WSP

P repared For:....................USACE

Facility Data

Area of Interest (AOI)

Fac ility Bound ary

No Suspected P FAS Release

P otential P FAS Release

Orig inal P aved Area

)

NM

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

0 50

Feet

0 50

Feet

0 50

Feet

Sh allow Interm ed iate Deep

PFNA Re su lts (μg/kg)

!( Non-Detec t (ND)

PFNA Re su lts (μg/kg)

!( Non-Detec t (ND)

PFNA Re su lts (μg/kg)

!( Non-Detect (ND)

3

NOTES:

P FAS = P er- and P olyfluoroalk yl Substanc es

P FNA = perfluorononanoic ac id

ND = Non-Detec t

(μg /Kg ) = Mic rog ram (s) per Kilog ram

Exc eed anc es of Th e Offic e of th e Sec retary of Defense (OSD)

Sc reening Level (SL) are d epic ted w ith a yellow h alo.

PFNA Re su lts (μg/kg)

!( ND (Non-Detec t)

!( >ND - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500

AOI01-06 w as ad vanc ed to g round w ater.

Interm ed iate soil sam ple at AOI01-06 tak en at 14-

15 ft bg s. Deep soil sam ple at AOI01-06 tak en at

139-140 ft bg s.

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-5

PFNA Detections in Soil (AOI 1)
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-20

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:........................WSP

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

Facility Data

Area of Interest (AOI)

Facility Boundary

No Suspected PFAS Release

Potential PFAS Release

Original Paved Area

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-6

PFOA,PFOS, and PFBS Detections in Groundwater (AOI 1)

)

NM

3

!(

!(

!(

AOI01-06

AOI01-07

AOI01-08

!(

!(

!(

AOI01-06

AOI01-07

AOI01-08

!(

!(

!(

AOI01-06

AOI01-07

AOI01-08

0 50

Feet

0 50

Feet

0 50

Feet

PFOA PFOS PFBS 3

PFOA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

PFOS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 4

!!( >4 - 40

!!( >40 - 70

!!( >70

PFBS (ng/L)

!( >100 - 601

!( ND (Non-Detect)

!( >ND - 100

!!( >601 - 1,000

!!( >1,000

AOI01-06 was advanced to groundwater.

Intermediate soil sample at AOI01-06 taken at 14-15

ft bgs. Deep soil sample at AOI01-06 taken at 139-

140 ft bgs.

NOTES:

PFAS = Per- and Polyfluoroalkyl Substances

PFOS = perfluorooctanesulfonic acid

PFOA = perfluorooctanoic acid

PFBS = perfluorobutanesulfonic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD) Screening

Level (SL) are depicted with a yellow halo.

Hydrology/Hydrogeology

Inferred Local Surface Water Flow

Direction

Shallow Aquifer Approximate

Groundwater Flow Direction
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-22

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:........................WSP

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

Facility Data

Area of Interest (AOI)

Facility Boundary

No Suspected PFAS Release

Potential PFAS Release

Original Paved Area

Army National Guard Site Inspections

Site Inspection Report

Field Maintenance Shop

Roswell, New Mexico

Figure 6-7

PFHxS and PFNA Detections in Groundwater (AOI 1)

)

NM

3

!(

!(

!(

AOI01-06

AOI01-07

AOI01-08

!(

!(

!(

AOI01-06

AOI01-07

AOI01-08

0 50

Feet

0 50

Feet

PFHxS PFNA

Hydrology/Hydrogeology

Inferred Local Surface Water Flow

Direction

Shallow Aquifer Approximate

Groundwater Flow Direction

3

PFHxS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 39

!!( >39 - 100

!!( >100 - 1000

!!( >1,000

PFNA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 100

!!( >100 - 1000

!!( >1000

NOTES:

PFAS - Per-and Polyfluoroalkyl Substances

PFHxS = Perfluorohexanesulfonic acid

PFNA = Perfluorononanoic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD)

Screening Level (SL) are depicted with a yellow halo.

AOI01-06 was advanced to groundwater.

Intermediate soil sample at AOI01-06 taken at 14-15

ft bgs. Deep soil sample at AOI01-06 taken at 139-

140 ft bgs.
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-24

This page intentionally left blank
Site Inspection Report

Roswell Field Maintenance Shop, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-1

7. EXPOSURE PATHWAYS

The Conceptual Site Model (CSM) for the AOI, revised based on the SI findings, is presented on 

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

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

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

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

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

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

potentially complete when the following conditions are present. SLs are presented in Section 6.1 

of this report.

1. Contaminant source

2. Environmental fate and transport

3. Exposure point

4. Exposure route

5. Potentially exposed populations.

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

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

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

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

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

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

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

complete pathway and a complete pathway may warrant further investigation. Although the 

CSM indicates whether potentially complete exposure pathways may exist, the recommendation 

for future study in a RI or no action at this time is based on the comparison of the SI analytical 

results for the relevant compounds to the SLs.

In general, the potential routes of exposure to the relevant compounds are ingestion and 

inhalation. Human exposure via the dermal contact pathway may occur, and current risk practice 

suggests it is an insignificant pathway compared to ingestion; however, exposure data for dermal 

pathways are sparse and continue to be the subject of toxicological study. The receptors 

evaluated are consistent with those listed in EPA guidance for risk screening (EPA 2001). 

Receptors at the Facility include Facility workers (e.g., facility staff and visiting soldiers), 

construction workers, trespassers, residents outside the facility boundary, and recreational users 

outside of the facility boundary.

7.1 SOIL EXPOSURE PATHWAY

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

between the source and potential receptors at the AOI based on the aforementioned criteria.
Site Inspection Report

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EA Engineering, Science, and Technology, Inc., PBC 7-2

7.1.1 AOI 1 – FIELD MAINTENANCE SHOP – VEHICLE MAINTENANCE BAY

AOI 1 is the FMS – Vehicle Maintenance Bay, where a Tri-MaxTM mobile fire extinguisher 

containing AFFF was historically stored. No potential releases or AFFF usage was noted during 

the PA at AOI01 (AECOM, 2020).

PFOA and PFOS were detected in the surface soil at AOI 1 at concentrations below their

respective SLs. Facility workers, construction workers, and trespassers could contact constituents 

in surface soil via incidental ingestion and inhalation of dust. Therefore, the surface soil exposure 

pathway for Facility workers, construction workers, and trespassers are potentially complete. No 

relevant compounds were detected in the subsurface soil at AOI01 therefore, the subsurface soil 

exposure pathway for Facility workers and construction workers is incomplete. The CSM for 

AOI 1 is presented on Figure 7-1.

7.2 GROUNDWATER EXPOSURE PATHWAY

The SI results in groundwater were used to determine whether a potentially complete pathway 

exists between the source and potential receptors at the AOI based on the aforementioned 

criteria.

7.2.1 AOI 1 – AOI FIELD MAINTENANCE SHOP – VEHICLE MAINTENANCE BAY

PFBS and PFOA were detected below their respective SLs in groundwater samples collected 

from the groundwater at AOI 1 (shallow aquifer). No potable wells are located within the 

Facility boundary, and the Facility receives water from a municipal source that extracts water 

from the deep aquifer. Depths to water measured at AOI 1 in June 2022 during the SI ranged 

from approximately 117 to 132 ft bgs. Therefore, the ingestion exposure pathway for Facility 

workers, construction workers, and trespassers is considered incomplete. Domestic wells 

surround the Facility and are located primarily to the northeast and east within a 4-mile radius of 

the Facility (Figure 2-3). The closest domestic wells are located approximately 0.22 miles to the 

northwest and 0.28 miles to the northeast. One drinking well was identified during the PA

(AECOM, 2020), located to the south of the Facility. Six production wells completed in the 

Roswell Artesian aquifer are located within the RIAC boundary and four to the south of the 

RIAC boundary (NMED Drinking Water Bureau, 2019). Three commercial water and 18 

irrigation wells are located within a 4-mile radius of the Facility. The wells identified may be 

completed in either the shallow aquifer or the deep Roswell Artesian aquifer. Thus, the pathway 

for exposure to off-facility residents via ingestion of groundwater is considered potentially 

complete. The CSM for AOI 1 is presented on Figure 7-1.

7.3 SURFACE WATER AND SEDIMENT EXPOSURE PATHWAY

Surface water and sediment were not sampled as part of the SI. The facility has natural drainage 

flow paths and stormwater swales that flow outside the Facility boundary to the north-northeast. 

All stormwater for the RIAC flows northeast toward the Hangerman Canal (Barron’s, 2021). 

There are two outfalls within the RIAC property located to the east of the Facility. SI results in 

soil and groundwater from AOI 1, in combination with knowledge of the fate and transport 

properties of PFAS, were used to determine whether a potentially complete pathway exists 

between the source and potential receptors.
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PFAS are water soluble and can migrate readily from soil to surface water via leaching and runoff. Because PFOA and PFOS were detected in soil and PFOA and PFBS were detected in 

groundwater at AOI 1, it is possible that these compounds may have migrated from soil and/or 

groundwater to the north of the Facility via groundwater discharge or overland flow. Therefore,

the surface water and sediment ingestion exposure pathway for site workers, construction

workers, trespassers, and off-site residents is considered potentially complete.
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Notes:

1. The resident users refer to off-site receptors.

2. Dermal contact exposure pathway is 

incomplete for PFAS.

Figure 7-1

Conceptual Site Model

AOI 1 Roswell FMS

RECEPTOR

Human Receptors:

Current/Future

Site 

Worker

Construction 

Worker

Resident1

Site 

Worker

Construction 

Worker

Resident1 Trespasser

AOI 1

PFAS in 

Surface Soil 

and Paved 

Tarmac or 

Near Wash 

Rack

Human 

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil 

Particulate

Surface Soil at 

AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

Tri-MaxTM Hand 

Truck – Mobile 

AFFF Fire 

Extinguisher

SOURCE

Source Release 

Mechanism Media

PATHWAY

Transport

and Migration Media Exposure 

Routes

Inhalation of 

Dust

Trespasser
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8. SUMMARY AND OUTCOME

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

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

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

the SLs.

8.1 SI ACTIVITIES

The SI field activities were conducted during two sampling events, between 28 to 28 April 2022 

and 06 to 23 June 2022. The SI field activities included soil and groundwater sampling. Field 

activities were conducted in accordance with the UFP-QAPP Addendum (EA/Wood, 2022a), 

except as previously noted in Section 5.9.

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

samples were collected and analyzed for a subset of PFAS by LC/MS/MS compliant with QSM 

5.3 Table B-15 as follows.

• 18 soil grab samples from 6 boring locations

• 3 grab groundwater samples from 3 temporary well locations

• 18 QA/QC samples.

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

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

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

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

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

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

described in Section 7.

8.2 OUTCOME

Based on the results of this SI, further evaluation is not warranted for AOI 1. Based on the CSM 

developed and revised based on the SI findings, there are potentially complete pathways for 

exposure to receptors from AOI 1 from sources on the Facility resulting from historical DoD 

activities.

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

in soil and groundwater, as described in Table 6-1. The following bullets summarize the SI 

results relative to the SLs:

At AOI 1:

• In the surface soils, PFOS was detected at AOI01-04 and PFOA was detected at AOI01-01, 

both below their respective SLs. PFOS and PFOA were detected in soil at concentrations less 

than the respective SLs. The maximum PFOS concentration in soil was 1.6 J+ μg/kg. The 

maximum PFOA concentration in soil was 0.2 J μg/kg. There were no detections of relevant 

compounds in the subsurface soils.
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• PFOA and PFBS were detected in groundwater at AOI 1 at concentrations that did not 

exceed SLs. The maximum concentration of PFOA and PFBS were 1.2 J ng/L for both 

constituents.

• Based on the results of the SI, further evaluation of AOI 1 is not warranted in the RI.

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

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

the conceptual site model (CSM) developed during the PA and revised based on SI findings, the 

presence of HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a 

component of military specification (MIL-SPEC) aqueous film-forming foam (AFFF) and based 

on its history including distribution limitations that restricted use of GenX, it is generally not a 

component of other products the military used. In addition, it is unlikely that GenX would be an 

individual chemical of concern in the absence of other PFAS. Table 8.1 summarizes the SI 

results for soil and groundwater used to determine if an AOI should be considered for further 

investigation under CERCLA and undergo an RI. 
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Table 8-1. Summary of Site Inspection Findings and Recommendations

AOI

Potential Release 

Area

Soil –

Source Area

Groundwater –

Source Area

Groundwater –

Facility Boundary Future Action

1

Field Maintenance 

Shop – Vehicle

Maintenance Bay

No further action

Legend:

 = Detected; exceedance of screening levels

= Detected; no exceedance of screening levels

 = Not detected
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Higgins, C.P., and R.G. Luthy. 2006. Sorption of perfluorinated surfactants on sediments. 

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

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Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk 

Assessments). December.

⎯⎯⎯. 2005. Federal Facilities Remedial Site Inspection Summary Guide. 21 July.

⎯⎯⎯. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process

USEPA/240/B-06/001. February.

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

Water, EPA 822-R-16-005. May.

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

of Water, EPA 822-R-16-004. May.

⎯⎯⎯. 2018. Regional Screening Levels – Generic Tables (November 2018). Residential = 

Direct Contact Soil. https://www.epa.gov/ris/regional-screening -levels-rsls-generictables. November.

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and perfluorooctanoate (PFOA) in soils and groundwater of a U.S. metropolitan area: 

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