FINAL 

Site Inspection Report 

Army Aviation Support Facility 

Santa Fe, 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) at 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. SITE BACKGROUND ........................................................................................ 2-1

2.1 SITE 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 Critical 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 – FORMER FIRETRUCK BAY AND TRI-MAXTM HAND 

TRUCK STORAGE AREA ..................................................................... 3-1

3.1.1 Former Firetruck Bay ................................................................ 3-1

3.1.2 Former Tri-MaxTM Hand Truck Storage Area .......................... 3-1

3.2 ADJACENT AND HISTORICAL POTENTIAL SOURCES ................ 3-2

3.2.1 Santa Fe Regional Airport ........................................................ 3-2

3.2.2 Santa Fe WWTP, Associated Surface Disposal Site, and Solar 

Panel Farm ................................................................................ 3-2

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

4.1 PROBLEM STATEMENT ...................................................................... 4-1
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4.2 INFORMATION INPUTS ....................................................................... 4-1

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

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

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

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

5.1 PRE-INVESTIGATION ACTIVITIES ................................................... 5-2

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

5.3 MONITORING WELL INSTALLATION AND GROUNDWATER 

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

5.4 SYNOPTIC WATER LEVEL MEASUREMENTS ............................... 5-5

5.5 SURVEYING .......................................................................................... 5-5

5.6 INVESTIGATION-DERIVED WASTE ................................................. 5-6

5.7 LABORATORY ANALYTICAL METHODS ....................................... 5-6

5.8 DEVIATIONS FROM UFP-QAPP ADDENDUM ................................. 5-6

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

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

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

6.3 AOI 1 ....................................................................................................... 6-2

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

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

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

6.4 HISTORICAL WASTEWATER TREATMENT PLANT BIOSOLID 

SURFACE DISPOSAL SITE SAMPLE LOCATIONS ......................... 6-4

6.4.1 Historical Wastewater Treatment Plant Biosolid Surface 

Disposal Site – Soil Analytical Results .................................... 6-4

6.4.2 Historical Wastewater Treatment Plant Biosolid Surface 

Disposal Site – Groundwater Results ....................................... 6-4

6.4.3 Historical Wastewater Treatment Plant Biosolid Surface 

Disposal Site – Conclusions ..................................................... 6-5

6.5 BOUNDARY SAMPLE LOCATIONS .................................................. 6-5

6.5.1 Boundary Sample Locations – Soil Analytical Results ............ 6-5

6.5.2 Boundary Sample Locations – Groundwater Results ............... 6-5

6.5.3 Boundary Sample Locations – Conclusions ............................. 6-6

7. EXPOSURE PATHWAYS .................................................................................. 7-1
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7.1 SOIL EXPOSURE PATHWAY .............................................................. 7-2

7.1.1 AOI 1 ........................................................................................ 7-2

7.1.2 Historical Wastewater Treatment Plant Biosolid Surface 

Disposal Site ............................................................................. 7-2

7.2 GROUNDWATER EXPOSURE PATHWAY........................................ 7-3

7.2.1 AOI 1 ........................................................................................ 7-3

7.2.2 Historical Wastewater Treatment Plant Biosolid Surface 

Disposal Site ............................................................................. 7-3

7.3 SURFACE WATER/ SEDIMENT exposure pathway ............................ 7-3

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

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

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

9. REFERENCES .................................................................................................... 9-1

LIST OF APPENDICES

Appendix A. Data Usability Assessment and Data Validation Reports

Appendix B. Field Documentation

 B1. Logs of Daily Notice of Field Activities

 B2. Field Forms

 B3. Survey Data

 B4. Field Change Request Forms 

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. Surface Water Features

Figure 2-5 Groundwater Elevations, Perched (June 2022) 

Figure 2-6. Groundwater Elevations, Regional (June 2022) 

Figure 3-1. Areas of Interest

Figure 5-1. Site Inspection Sample Locations 

Figure 5-2. Site Inspection Sample Locations with Historical Imagery

Figure 6-1. AOI 1 PFOS Detections in Soil

Figure 6-2. AOI 1 PFOA Detections in Soil

Figure 6-3. AOI 1 PFBS Detections in Soil 

Figure 6-4. AOI 1 PFHxS Detections in Soil

Figure 6-5. AOI 1 PFNA Detections in Soil

Figure 6-6. AOI 1 PFOA, PFOS, and PFBS Detections in Groundwater 

Figure 6-7. AOI 1 PFHxS and PFNA Detections in Groundwater 

Figure 7-1. Conceptual Site Model, AOI 1 

Figure 7-2. Conceptual Site Model, Historical WWTP Biosolid Surface Disposal Site
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LIST OF TABLES

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

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

Table 5-1. Samples by Medium, Santa Fe AASF, New Mexico, Site Inspection Report 

Table 5-2. Soil Boring Depths and Well Screen Intervals, Santa Fe AASF, New Mexico, Site 

Inspection Report 

Table 5-3. Groundwater Elevation, Santa Fe AASF, New Mexico, Site Inspection Report 

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

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

Inspection Report, Santa Fe AASF 

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

Site Inspection Report, Santa Fe AASF

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

Inspection Report, Santa Fe AASF 

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

Inspection Report, Santa Fe AASF 

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

°C Degrees Celsius

°F Degrees Farhenheit

% Percent

μg/kg Microgram(s) per kilogram

AASF Army Aviation Support Facility 

AECOM AECOM Technical Services, Inc. 

AFFF Aqueous film-forming foam 

amsl Above mean sea level

AOI Area of Interest

ARNG Army National Guard

ASTM ASTM International 

bgs Below ground surface 

btoc Below top of casing 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

City City of Santa Fe 

CSM Conceptual site model

DoD Department of Defense

DPT Direct-push technology

DQO Data quality objective 

DUA Data Usability Assessment

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

ELAP Environmental Laboratory Accreditation Program

EM Engineer Manual 

EB Equipment blank 

FB Field blank 

FD Field duplicate 

FedEx Federal Express

ft Foot (feet)

GPS Global Positioning System 

HDPE High-density polyethylene 

HFPO-DA Hexafluoropropylene oxide dimer acid 

ID Identification

IDW Investigation-derived waste

ITRC Interstate Technology Regulatory Council 
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)

J Estimated concentration

J+ Estimated concentration, biased high 

LC/MS/MS Liquid chromatography with tandem mass spectrometry 

mg/kg Milligram(s) per kilogram

MS Matrix spike

MSD Matrix spike duplicate 

NA Not applicable 

ng/L Nanogram(s) per liter

NMARNG New Mexico Army National Guard

NMED New Mexico Environment Department 

NMOSE New Mexico Office of the Engineer

No. Number 

OSD Office of the Secretary of Defense

P&A Plugged and abandoned 

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 

QAPP Quality Assurance Project Plan

QSM Quality Systems Manual 

RI Remedial Investigation 

SAF Santa Fe Airport 

SI Site Inspection

SL Screening level

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 
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)

WWTP Wastewater Treatment Plan
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

ES-1 

EXECUTIVE SUMMARY

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

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

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

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

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

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

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. The applicable 

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

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

stored, disposed, or released historically (Table ES-2 for AOI locations). The objective of the SI 

is to determine 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 a comparison of SI results to 

SLs for the relevant compounds. This SI was completed at the Army Aviation Support Facility 

(AASF) in Santa Fe, New Mexico, and determined further evaluation under the Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA) is warranted for AOI 1.

The Santa Fe AASF will be referred to as the “Facility” throughout this document.

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

22 acres in Santa Fe, New Mexico, approximately 10 miles southwest of downtown. The original 

Facility was constructed in 1979 in the northwest corner of the Santa Fe Regional Airport. The 

Facility was renovated with a new, larger AASF building in 2012. The AASF and surrounding 

area consists of piedmont slopes underlain by late Cenozoic basin-filling deposits, or the Santa 

Fe marls. Basin-fill aquifers of the Santa Fe Group are the principal groundwater resource for the

cities of Santa Fe, Española, and six Pueblo nations (AECOM Technical Services, Inc. 2020). 

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

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

the results of this SI and following the CERCLA process, a remedial investigation (RI) is 

warranted for AOI 1. Note that based on historical aerial photographs, application of biosolids 

extended into the current Santa Fe AASF lease area; biosolid surface disposal extended to the 

north end of the current AASF building prior to the 2012 renovations of the facility. This area 

was therefore designated for further evaluation during the SI planning phases. 

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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ES-2 

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

Analyte 2

Residential

(Soil)

(μg/kg)1 

0 to 2 ft bgs

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg)1 

2 to 15 ft bgs

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 Regional SL Calculator. Hazard Quotient = 

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 aqueous 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.

bgs = Below ground surface

ft = Foot (feet)

μg/kg = Microgram(s) per kilogram

ng/L = Nanogram(s) per liter

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

Area

Potential Release

Area Soil

GroundwaterOn-site

Groundwater –

Facility 

Boundary 

Future 

Action

AOI 1 

Former Firetruck Bay and 

Tri-MaxTM Hand Truck 

Storage Area

Proceed to 

RI

Historical WWTP 

Biosolid Surface 

Disposal Site

Historical WWTP 

Biosolid Surface Disposal 

Site

 

Further 

Evaluation1 

Notes:

1. This area will be assessed during the RI to determine if the contamination present poses a detrimental 

impact on human health for personnel at the facility or the environment.

WWTP = Wastewater Treatment Plant 
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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 Site Inspections (SIs) at ARNG facilities nationwide based on the current 

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

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

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

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

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

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

hexafluoropropylene oxide-dimer acid (HFPO-DA)2 at ARNG facilities nationwide. The ARNG

performed this SI at the Army Aviation Support Facility (AASF) in Santa Fe, New Mexico. The 

Santa Fe AASF will be referred to as the “Facility” throughout this report. 

The SI project elements were performed in accordance with the Comprehensive

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

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

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

compliance with Army requirements and guidance for field investigations.

1.2 SITE INSPECTION PURPOSE

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

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

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

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

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

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

(SLs) for the relevant compounds. During the SI planning phase and review of the historical 

aerial photographs, it was noted that surface disposal of biosolids extended on to the current 

Santa Fe AASF lease area to the north end of the current AASF building prior to the 2012 

renovations of the Facility. This area was therefore designated for further evaluation under this 

SI. 

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 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. SITE BACKGROUND

2.1 SITE LOCATION AND DESCRIPTION

The Santa Fe AASF is located within the incorporated limits of and approximately 10 miles

southwest of downtown Santa Fe, New Mexico. The 22-acre Facility is located on the northwest

corner of the Santa Fe Regional Airport (SAF) and is leased to the New Mexico Army National 

Guard (NMARNG) by the City of Santa Fe (City). The land was acquired in 1976, and the 

original Facility was constructed in 1979. The original facility consisted of an AASF building 

and hangar and a small parking apron for helicopters. In 2012, the Facility was completely 

renovated with a new, larger AASF building constructed adjacent to the former AASF building, 

and the former AASF building converted to the Santa Fe Readiness Center (AECOM 2020).

The properties immediately surrounding the AASF are also owned by the City, with the Santa Fe 

Wastewater Treatment Plant (WWTP) to the north, and the Santa Fe Regional Airport 

immediately to the west, south, and east (Figure 2-1) (AECOM 2020). 

2.2 FACILITY ENVIRONMENTAL SETTING

The AASF is at an elevation of approximately 6,330 feet (ft) above mean sea level (amsl). The 

Facility is covered by the U.S. Geological Survey Turquoise Hill 7.5-minute quadrangle 

topographic map. The geographic coordinates for the center of the Facility are 106°18'31.454"W; 

35°37'27.146"N. The Facility is developed with two large buildings, three small structures, 

and a helicopter parking apron. One building, built in 1979 and renovated in 2012, is the former 

AASF and the current administration headquarters for the Santa Fe Readiness Center. The 

second building is the current AASF, which is comprised of a 75,000-square-foot (ft2

) hangar/ 

administration building. A 16,400- ft2 storage building; a guard house; fuel storage area; and 

455,000 ft2 of concrete airfield paving also exist on the property (AECOM 2020). Topography of 

the area is displayed in Figure 2-2. The regional geology and groundwater features are shown on 

Figure 2-3. The regional surface water features and drainage basins are shown on Figure 2-4. 

Groundwater elevations and contours, if applicable, are presented on Figures 2-5 and 2-6. 

2.2.1 Geology 

The City of Santa Fe, New Mexico, is located on the east border of the Rio Grande trough, in the 

Española Basin, within the Rio Grande Rift. The basin formed during 25 million years of plate 

tectonic stress pulling the land apart and causing a vast expanse of land to subside. When these 

basins formed, large amounts of sediment filled the basin from the ancient flow of the Rio 

Grande and from volcanic eruptions. These sediments, which fill the basin, make up an aquifer 

system that contains the primary source of water for most residents who live in the basin 

(AECOM 2020).

The Española basin in north-central New Mexico comprises the central portion of the Rio

Grande rift, which formed in response to rifting as early as Oligocene epoch. There are four main 

physiographic units associated with the Santa Fe area: a complex of metamorphic and igneous 

rocks from the Pre-Cambrian encompassing the Sangre de Cristo mountains in the eastern area;

sedimentary and volcanic rocks Neogene to Quaternary in age in the southwest; basalt flows of
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Quaternary in the western Mesa; and basin fill sediments of the Santa Fe group in the intervening

piedmont (AECOM 2020). 

Most of the area consists of piedmont slopes underlain by late Cenozoic basin-filling deposits

called the Santa Fe marls. These marls are composed of silty sandstones, sand, and gravel 

approximately 300 ft thick. This layer lies overtop of a bedrock floor that is made up of 

sedimentary and igneous rocks (AECOM 2020). 

Soils encountered during the SI were dominated by well-graded sand with interbedded gravel, 

silt, and clay. Samples for grain size analyses were collected at two locations, AOI101-01 and 

AOI01-02, and analyzed via ASTM International (ASTM) Method D-422. The results indicate 

that the soil samples are comprised primarily of sand (30.5 to 50.3 percent [%]) and silt (57.3 to 

41.3%). These results and field observations are consistent with the reported depositional 

environment of the region. pH in soil samples ranged from 8.7 to 8.9. Total organic carbon 

(TOC) concentrations ranged from 2,400 to 4,600 milligrams per kilogram (mg/kg). 

2.2.2 Hydrogeology 

Primary aquifers in the Española Basin are contained within the Tertiary-Quaternary Santa Fe

Group. Basin-fill aquifers of the Santa Fe Group are the principal groundwater resource for the 

cities of Santa Fe, Española, and six Pueblo nations. The Santa Fe Group thickens to the west 

and north, ranging from approximately 250 ft thick south of the City to greater than 10,000 ft 

beneath the Pajarito Plateau west of Española. The Ancha Formation is a locally important 

shallow aquifer that is present in the vicinity of the Facility (Johnson et al 2016). The Ancha 

Formation is comprised of alluvial deposits associated with the ancestral Santa Fe River and the 

alluvial slope deposits originating from the southwestern Sangre de Cristo Mountains. The 

Tesuque Formation lies beneath the Ancha Formation and is in hydraulic communication with 

aquifers within the overlying Ancha and Puye Formations. The highly heterogeneous and 

complex nature of the Tesuque aquifer reflects its depositional environment of coalescing 

alluvial fans, a heterogeneity that is compounded by discontinuities created by faulting. The 

Santa Fe Group aquifers are in hydraulic communication with Precambrian rocks along the 

eastern margin of the basin where most of the recharge occurs. Paleozoic limestones underlying 

the basin-fill aquifers, fractured Tertiary intrusive rocks, and Tertiary volcanics of the Jemez 

volcanic field also locally produce water. Recharge within the basin is assumed to occur 

primarily from the higher elevations with little or no recharge from the lower elevations because 

of high evapotranspiration and low precipitation (AECOM 2020). 

Regional groundwater studies indicate that the Facility is near a groundwater divide and 

that groundwater may travel southwest toward the Santa Fe River or south toward Arroyo 

Hondo/Cienega Creek (Johnson et al 2016). Based on the SI, regional groundwater flows 

south-southwest at the Facility. Numerous wells are located south and southwest of the Facility. 

The nearest domestic well is located approximately 1 mile southwest of the Facility. A municipal 

well located at the Santa Fe Airport is located a 0.5 mile southeast of the Facility (New Mexico 

Office of the Engineer [NMOSE] 2022). These and other wells identified during the PA are 

displayed on Figure 2-3. 
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Santa Fe’s drinking water comes from a nearly even split between groundwater from the 

Buckman and City Well Fields, and surface water from the Santa Fe and Rio Grande rivers. The 

City well fields are located within or northeast of Santa Fe (AECOM 2020), which are 

hydrologically upgradient of the Facility. Additionally, the community of La Cienega is located 

adjacent to, and presumed to be downgradient of the Facility. La Cienega residents rely 

exclusively on groundwater for drinking water, provided by individual residential wells and two 

public water systems, one of which derives its drinking water from a well approximately 1.8 

miles potentially downgradient from the Facility. 

During the SI, perched groundwater was observed on the west side of the Facility at depths of 

110–111 ft below ground surface (bgs). Groundwater flow direction of the perched groundwater 

could not be calculated since it was encountered in only two drilling locations (Figure 2-5). 

Depth to regional groundwater was observed at 176–185 ft bgs, which is consistent with 

observations made at Santa Fe WWTP monitoring wells located east of the Facility (New 

Mexico Environment Department [NMED] Ground Water Quality Bureau 2011). Measurements 

made during the SI indicate that regional groundwater flows south-southwest with a gradient of 

0.001 ft/ft (Figure 2-6). 

2.2.3 Hydrology 

The Facility’s topography is relatively flat. It straddles two watersheds with the northern portion 

within the Headwaters Santa Fe River Watershed and the southern portion within the Outlet 

Santa Fe River Watershed. The surface water flow direction is generally to the southwest on both 

sides of the watershed divide. The Santa Fe River cuts through undeveloped land approximately 

0.5 miles north of the Facility (AECOM 2020). Water features near the Facility are shown in 

Figure 2-4. 

Consistent with regional surface water flow directions, historical imagery indicates that 

stormwater flowed to the southwest from the historical helicopter parking apron and other paved 

areas. Stormwater also appears to have accumulated on either side of the taxiway historically. 

There are two stormwater retention basins that currently receive water from the tarmac. A 

stormwater detention pond north of the Readiness Center currently receives runoff and has an 

outflow that is directed north. Historical imagery suggests that those areas were constructed 

during the 2012 facility renovations and did not previously receive runoff. Current and historical 

areas that receive or appear to have received stormwater runoff are displayed in Figure 2-4. 

The City of Santa Fe’s surface water comes from the Santa Fe River and San Juan-Chama 

Project water via the Rio Grande, both of which are treated through conventional and advanced 

treatment processes to meet current permit regulations. The City of Santa Fe has a license to 

store up to 3,985-acre ft (combined) of Santa Fe River water in McClure and Nichols Reservoirs. 

Both municipal drinking water supply reservoirs are located east of Santa Fe (AECOM 2020). 

2.2.4 Climate 

Santa Fe is located in north central New Mexico at an elevation of approximately 7,000 ft amsl. 

January is the coldest month, with an average temperature of 30.5 degrees Fahrenheit (oF), while 

July is the hottest month, with an average temperature of 70.1oF. Santa Fe receives an average of 
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14.2 inches of precipitation annually, with 5.85 inches falling during summer months. The City 

receives an annual snowfall amount of 23 inches per year (AECOM 2020). 

2.2.5 Current and Future Land Use 

Presently, Santa Fe AASF resides on SAF property. The Facility is comprised of one hangar, 

multiple administrative buildings, a paved parking area, a fueling station, and a small, paved 

parking area. The current land use is listed as I-1 Light Industrial. Future land use is not 

anticipated to change (AECOM 2020). The Facility is fenced and has restricted access. Land 

directly to the north and east of the Facility is currently a WWTP surface disposal site owned by 

the City of Santa Fe. 

2.2.6 Critical 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 Santa Fe County, New Mexico (U.S. Fish and Wildlife Service 2022): 

 Birds: Mexican Spotted Owl, Strix occidentalis lucida (Threatened); Southwestern 

Willow Flycatcher, Empidonax traillii extimus (Endangered); and Yellow-billed Cuckoo, 

Coccyzus americanus (Threatened) 

 Fishes: Rio Grande Cutthroat Trout, Oncorhynchus clarkii virginalis (Candidate); and 

Rio Grande Silvery Minnow, Hybognathus amarus (Endangered) 

 Insects: Monarch Butterfly, Danaus plexippus (Candidate) 

 Amphibians: Jemez Mountains Salamander, Plethodon neomexicanus (Endangered) 

 Mammal: New Mexico Meadow Jumping Mouse, Zapas hudsonius luteus (Endangered). 

2.3 HISTORY OF PFAS USE 

Two potential PFAS release areas were identified at the Facility during the PA (AECOM 2020). 

The areas include the former AASF building and former Tri-MaxTM 70/30 hand-truck storage 

area, which consists of the flight line and paved parking apron. These two potential source areas 

are in close proximity to one another and have co-mingling stormwater runoff. As a result, these 

areas were combined and together comprise AOI 1. 

Personnel interviews confirmed that a firetruck parked within the former AASF building stored 

aqueous film-forming foam (AFFF). Personnel indicate that it was never used because no one at 

the Facility was qualified to use it; however, there is a possibility that the firetruck stored inside 

the former AASF Facility may have leaked AFFF or may have had its AFFF tank flushed out 
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during maintenance. There are no records or recollection of the AFFF stored on this firetruck 

being used or spilled. 

Prior to the 2012 facility renovation, Tri-MaxTM 70/30 hand trucks were stored in various places 

around the flight line and paved parking apron and constitute a potential PFAS source within 

AOI 1. The hand trucks were regularly serviced. Service for Tri-MaxTM 70/30 hand trucks may 

include nozzle checks that can result in an AFFF discharge. According to personnel, the TriMaxTM hand trucks were only used for 4 to 5 years in the mid-2000s and were turned in because 

they were too expensive to maintain. There is no recollection or record of any training conducted 

with these units or nozzle testing performed. A description of AOI 1 and its potential release 

areas are presented in Section 3. 
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Santa Fe AASF

Santa Fe

Municipal Airport

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Facility Data

Facility Boundary

3

0 2

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-1

Facility Location

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

Projection:........WGS 84 UTM 13N
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Santa Fe AASF

Santa Fe

Municipal Airport

^_

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Facility Data

Facility Boundary

3

0 2

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-2

Facility Topography

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Projection:........WGS 84 UTM 13N
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Santa Fe River

Arroyo de los Chamisos

Arroyo Hondo

^_

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Facility Data

Facility Boundary

Well Type

<! Domestic Well

<! Irrigation Well

<! Unknown/Other Well

Hydrology/Hydrogeology

Groundwater Flow Direction

(Deep Water-Bearing Zone)

Perennial Creek/Stream

Intermittent Creek/Stream

Wetlands

3

0 0.5

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-3

Groundwater Features

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Projection:........WGS 84 UTM 13N
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Santa Fe River

Arroyo de los Chamisos

Arroyo Hondo

Arroyo Hondo

Watershed

Headwaters

Santa Fe River

Watershed

Outlet Santa Fe

River Watershed

Arroyo de

los Chamisos

Watershed

Arroyo Hondo

Watershed

Arroyo

Calabasas

Watershed

^_

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Facility Data

Facility Boundary

Area of Interest

Hydrology

Surface Water Flow Direction

Perennial Creek/Stream

Intermittent Creek/Stream

Wetlands

Watershed Boundary

3

0 0.5

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 2-4

Surface Water Features

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Former AASF

Former Fire

Truck Bay

Stormwater

Detention Pond

Stormwater

Retention Basins

Date:...............................July 2023

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

Projection:........WGS 84 UTM 13N
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AOI 1

Former Fire

Truck Bay

Former Trimax

Hand Truck

Storage Area

Santa Fe WWTP

Land Application Area

Former AASF

Santa Fe

Regional

Airport

AOI01-02

6,214.00 ft

AOI01-04

6,213.16 ft

^_

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Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Sample Locations

Sonic Soil Boring/Monitoring Well

3

0 500

Feet

Data Sources:

ESRI 2022

AECOM 2020

Figure 2-5

Groundwater Elevations,

Perched (June 2022)

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Note:

Groundwater elevation is provided

in feet above mean sea level.

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
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AOI 1

Former Fire

Truck Bay

Former Trimax

Hand Truck

Storage Area

Santa Fe WWTP

Land Application Area

Former AASF

Santa Fe

Regional

Airport

AOI01-01

6,152.38 ft

SFAASF-03

6,152.88 ft

SFAASF-04

6,152.26 ft

6,152.50

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Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Sample Locations

Sonic Soil Boring/Monitoring Well

Hydrology/Hydrogeology

Groundwater Flow Direction

Groundwater Elevation

Deep Water Contour Interval

Dashed where Inferred

3

0 500

Feet

Data Sources:

ESRI 2022

AECOM 2020

Figure 2-6

Groundwater Elevations,

Regional (June 2022)

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Note:

Groundwater elevation is provided

in feet above mean sea level.

Date:...............................July 2023

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

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

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

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

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

Santa Fe AASF: AOI 1 Former Firetruck Bay and Tri-MaxTM Hand Truck Storage Area. 

Additionally, there are off-facility potential source areas as detailed in Section 3.2. The potential 

source areas are shown on Figure 3-1 and described in subsequent sections. 

3.1 AOI 1 – FORMER FIRETRUCK BAY AND TRI-MAXTM HAND TRUCK 

STORAGE AREA

AOI 1 consists of the Santa Fe AASF Former Firetruck Bay and Tri-MaxTM Hand Truck Storage 

Area. Each of these areas is described below and shown on Figure 3-1. 

3.1.1 Former Firetruck Bay

The former AASF building, which is now the current Santa Fe Readiness Center, is located on

the western portion of the Facility and historically housed a single firetruck within a bay. The 

firetruck was stored in this bay for an unknown length of time, but it was sold in 2005 to the 

Santa Fe Fire Department. Personnel interviews confirmed that the firetruck stored AFFF foam, 

but it was never used because no personnel at the Facility were qualified to use it. There are no 

records or recollection of the use or release of the AFFF stored on the firetruck; however, there is 

a possibility that the firetruck stored may have leaked AFFF or had its AFFF tank flushed out 

during maintenance. 

The building was renovated in 2012 and received a new roof, exterior wall openings and 

finishes, interior walls, floor finishes, ceilings, and lighting. Mechanical, electrical, plumbing, 

fire protection, telecommunication, and security systems were replaced as well. There is no floor 

drain in the remodeled bay and no evidence one was previously present. The current Santa Fe 

Readiness Center building does not currently house any materials containing AFFF (AECOM 

2020). 

3.1.2 Former Tri-MaxTM Hand Truck Storage Area

The flight line and paved parking apron currently stretch across the majority of the Facility and 

are directly adjacent to both the current and former AASF buildings. The area was expanded 

and repaved in 2012 during the construction and renovation of the Facility. Prior to the 2012 

renovation, Tri-MaxTM 70/30 hand trucks were stored in various places around the flight line and 

parking apron and were regularly serviced. Service for Tri-MaxTM 70/30 hand trucks may include 

nozzle checks that can result in an AFFF discharge. According to personnel, the Tri-MaxTM hand 

trucks were only used for 4 to 5 years in the mid-2000s and their use was discontinued because

they were too expensive to maintain. There is no recollection or record of any training conducted 

with these units or nozzle testing performed. Interviewees were unsure about when or where, 

specifically, the Tri-MaxTM units were turned in, but they no longer exist at the Facility and have 

since been replaced with fire extinguishers that do not contain PFAS (AECOM 2020). 
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3.2 ADJACENT AND HISTORICAL POTENTIAL SOURCES

Two potential off-facility sources of PFAS are located adjacent to the Facility and are not under 

the control of the NMARNG. A description of each potential off-facility source is presented 

below and shown on Figure 3-1. 

3.2.1 Santa Fe Regional Airport 

The SAF is a public airport that opened in 1941 and covers 2,128 acres. The SAF has three 

active asphalt runways. Interviews with NMARNG facility staff and a historical records search 

provided little information regarding use of AFFF at SAF; however, the records search detailed 

two emergency incidents that happened on or near the runway on 27 November 2018, and on 

8 April 2019. According to a local news source, the first crash occurred when a single-engine 

Mooney M20 crashed just short of the runway and burst into flames. The second crash happened 

several months later, when a two-seater aircraft crashed and burst into flames at the airport on a 

secondary runway just south of the AASF Facility (AECOM 2020). Fire Station 10 supports the 

Santa Fe Airport with a crash rescue fire truck (City of Santa Fe 2022), which is presumably 

AFFF-enabled. 

Historically, certain training and foam testing were required by the Federal Aviation

Administration (FAA), and are assumed to have occurred at the Santa Fe Regional Airport. 

Since 2018, FAA has worked on reducing releases of AFFF on airports under their jurisdiction, 

and has adopted the use of testing procedures that do not require dispensing foam. 

As a result, the entirety of the airport is considered a potential AFFF release area. The Santa Fe 

Regional Airport is located upstream of surface water flow and cross-gradient to groundwater 

flow at the time of gauging. 

3.2.2 Santa Fe WWTP, Associated Surface Disposal Site, and Solar Panel Farm 

The Santa Fe WWTP is located north of the Santa Fe AASF. Areas to the north and east of the

Santa Fe AASF are currently used as surface disposal sites for the surface disposal of biosolids. 

Based on historical aerial photographs, the biosolids surface disposal site extended into the 

current Santa Fe AASF lease area. This biosolids surface disposal site also extended to the north 

end of the current AASF building prior to the 2012 renovations of the Facility (Figure 3-1). 

Although WWTPs are not usually primary potential release areas of PFAS, sludges and liquids 

from areas of potential release that are treated at WWTPs can create a secondary source of 

contamination. 

A solar panel farm exists within the Santa Fe WWTP surface disposal site. Although research is 

conflicted about the potential of PFAS in the construction of solar panels, the solar farm is 

considered a potential PFAS source due to incomplete data regarding solar panel construction 

and the possible use of PFAS-containing insulated electrical wires and cables within the solar 

farm.
Former Fire

Truck Bay Former Trimax

Hand Truck

Storage Area

Santa Fe

Regional Airport

Santa Fe WWTP

AOI 1

Santa Fe WWTP

Land Application Area/

Solar Panel Farm

Arroyo de los Chamisos

Santa Fe River

Solar Panel Farm

^_

NM

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential Source Areas

Potential PFAS Release

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

Intermittent Creek/Stream

Wetlands

3

0 0.5

Miles

Data Sources:

ESRI 2020

AECOM 2020

Figure 3-1

Areas of Interest

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

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

Federal Policy- (UFP) Quality Assurance Project Plan (QAPP) Addendum (EA Engineering, 

Science, and Technology, Inc., PBC [EA] 2021a), 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 presence or absence of relevant compounds at the sampled AOI.

4.1 PROBLEM STATEMENT

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

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

levels. The SLs are presented in Section 6.1. 

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for the Santa Fe AASF (AECOM 2020) 

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

facility

• Groundwater and soil sample data collected as part of this SI in accordance with the 

site-specific UFP-QAPP Addendum (EA 2021a) 

• Field data collected 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 2-2). 

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). The scope of the SI was vertically bounded as follows: 

groundwater (110−185 ft bgs), soil from hand-auger borings (0−2 ft bgs), soil from direct-push 

technology (DPT) borings (15 ft bgs), and soil from sonic drilling borings (197 ft bgs). Temporal 

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

the study. 

4.4 ANALYTICAL APPROACH

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

Manual (QSM) Version 5.3 by Eurofins Lancaster Laboratories Environmental, LLC, accredited 

under the DoD Environmental Laboratory Accreditation Program (ELAP) (DoD ELAP; 
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Accreditation No. 1.01). PFAS data underwent 100 % Stage 2B validation in accordance with 

the DoD General Data Validation Guidelines (2019) and DoD Data Validation Guidelines 

Module 3: Data Validation Procedure of PFAS Analysis by QSM Table B-15 (2020). 

Data were compared to applicable SLs and decision rules as defined in the UFP-QAPP 

Addendum (EA 2021b). 

4.5 DATA USABILITY ASSESSMENT

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

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

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

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

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

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

decision-making (DoD 2019a, 2019b; USEPA 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. These data are of sufficient quality to meet the objectives and 

requirements of the UFP-QAPP Addendum (EA 2021b). 
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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, Santa Fe Army Aviation Support Facility, dated 

August 2020 (AECOM 2020)

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

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

Nationwide, dated December 2020 (EA 2020a)

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

Addendum, Santa Fe Army Aviation Support Facility, Santa Fe, New Mexico dated 

December 2021 (EA 2021b)

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

2020b)

• Final Accident Prevention Plan/Site Safety and Health Plan Addendum, Santa Fe Army 

Aviation Support Facility, New Mexico, dated August 2021 (EA 2021a). 

The SI field activities were conducted during two mobilizations. Field activities for the first 

mobilization were conducted from 7 to 8 February 2022 and consisted of hand augering and 

surface soil sample collection. The second mobilization was conducted 25 April through 3 June 

2022. Field activities included sonic and DPT drilling, collection of soil samples, installation of 

permanent monitoring wells, groundwater gauging and sampling, and collection of spatial data. 

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

except as noted in Section 5.8. 

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

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

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

• Eighteen (18) surface soil samples collected by hand auger from 16 locations 

• Fifteen (15) shallow subsurface samples collected by direct push/sonic drilling from 10 

locations 

• Eight (8) deep subsurface samples collected from 6 locations by sonic drilling 

• Six (6) groundwater samples from 5 groundwater monitoring wells

• Nineteen (19) field blanks
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• Twenty-one (21) equipment rinsate samples.

Figure 5-1 provides the sample locations for all media across the Facility. Figure 5-2 displays 

the sample locations with historical imagery to show features and Facility layout before the 

facility renovation. 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. Field notes are 

provided in Appendix B2. Survey data is presented in Appendix B3. Field change request forms 

are provided in Appendix B4. Additionally, a photographic log of field activities is provided in 

Appendix C. 

5.1 PRE-INVESTIGATION ACTIVITIES

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

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

water. Details of these activities are presented below. 

5.1.1 Technical Project Planning

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

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

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

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

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

address the AOIs identified in the PA. 

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

included a site walk with stakeholders. 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, and the NMED, 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 2021b). 

A TPP Meeting 3 was held on 4 April 2023 to discuss the results of the SI. Meeting minutes for 

TPP 3 are included in Appendix D of this report. Future TPP meetings will provide an 

opportunity to discuss the results and findings, and future actions, where warranted.

5.1.2 Utility Clearance

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

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

boring locations on 7 February 2022 with input from the EA field team. It was discovered that 

incorrect locations received utility clearance for AOI01-02 and AOI01-06. As a result, the 

corrected locations were surveyed on 27 April 2022. General locating services were used to 

complete the clearance. Additionally, the first 5 ft of each boring were pre-cleared by EA’s 
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drilling subcontractors using a hand auger to verify utility clearance in shallow subsurface where 

utilities would typically be encountered. 

5.1.3 Source Water and PFAS Sampling Equipment Acceptability

The potable water source used for decontamination of drilling equipment was sampled prior to 

the start of field activities and confirmed to be acceptable for this use during the SI. A potable 

water source sample was collected at the wash rack on 14 October 2021, prior to mobilization, 

and analyzed for PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15. The results 

of the decontamination water sample associated with the wash rack spigot source used during the 

SI are provided in Appendices F and G. A discussion of the results is presented in the DUA 

(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 provided as Appendix B to the 

Programmatic UFP-QAPP (EA 2020a).

5.2 SOIL BORINGS AND SOIL SAMPLING

A hand auger was used to collect surface soil samples from 0 to 2 ft bgs. It was also used to 

collect soil from the top 5 ft of the boring in compliance with utility clearance procedures. For 

boring locations advanced to a depth greater than 5 ft, soil samples were collected via sonic or 

DPT drilling methods in accordance with 025 Standard Operating Procedure for Soil Sampling 

(EA 2021b). Soil borings associated with monitoring wells were installed with a truck-mounted 

Boart LS600 full-sized sonic rig. Continuous soil cores were collected to the target depth. For 

15-ft borings, a Geoprobe® 7822DT dual-tube sampling system was used. 

At hand auger borings, a soil sample was collected from 0 to 2 ft bgs with a total depth of 2 ft 

bgs. Three discrete soil samples were collected for chemical analysis from all other soil borings: 

one sample at the surface (0 to 2 ft bgs) and two subsurface soil samples. In 15-ft DPT borings, 

subsurface soil samples were collected at 6–8 ft bgs and 13–15 ft bgs. In deeper soil borings 

associated with monitoring wells and drilled with sonic, one subsurface soil sample was 

collected at the 13–15 ft bgs interval, and one sample was collected approximately 1 ft above the 

groundwater table. Total depth for soil borings associated with monitoring wells ranged from 

110 to 184 ft bgs. Note that subsurface soil samples were not collected at SFAASF-03; 

concentrations in sub-surface soil are considered to be represented by the samples collected at 

SFAASF-03-PA due to the close proximity of the two borings. 

All soil sample locations are shown on Figures 5-1 and 5-2 and boring sample depths are 

provided in Table 5-1. The soil boring locations were selected based on the AOI information 

provided in the PA (AECOM 2020) and as agreed upon by stakeholders during the TPP and 

review of the UFP-QAPP Addendum (EA 2021b), with several exceptions. Soil boring locations 

AOI01-06B, AOI01-09, and SFAASF-03-PA are not included in the UFP-QAPP Addendum but 

are discussed in Section 5.8. 
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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 boring log forms 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. Soil borings 

SFAASF-03 and AOI01-09 were not logged due to their close proximity (17 ft or less) to 

soil borings SFAASF-03-PA and AOI01-01, respectively. The boring logs are provided in 

Appendix E. 

Boreholes advanced to a maximum depth of 2 ft bgs were filled with bentonite. Boreholes 

advanced to a maximum depth of 15 ft bgs were backfilled with material removed from the 

borehole and then bentonite pellets filled the remainder to land surface except for boring AOI01-

06B which was filled with bentonite and the cuttings were drummed. 

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 procedures to 

the laboratory and analyzed for PFAS (LC/MS/MS compliant with QSM Version 5.3 Table 

B-15), TOC (USEPA Method 9060A) and pH (USEPA Method 9045D) in accordance with the 

UFP-QAPP Addendum (EA 2021b). 

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

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

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

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

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

the same parameters as the soil samples. One field blank (FB) was collected per day. A 

temperature blank was placed in each cooler to ensure that samples were preserved at or below 

6 degrees Celsius (°C) during shipment. After removal of the drilling equipment, boreholes were 

abandoned using bentonite chips. In borings installed on paved surfaces, the borings were 

abandoned by backfilling with bentonite chips. Borings were installed in unpaved areas to avoid 

disturbing concrete or asphalt surfaces.

5.3 MONITORING WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Monitoring wells were installed using a truck-mounted Boart LS600 full-sized sonic rig. Once 

the borehole was advanced to the desired depth, a monitoring well was constructed of a 20-ft 

section of 2-inch Schedule 80 polyvinyl chloride (PVC) screen with sufficient casing to reach the 

ground surface. The screen intervals for the monitoring wells are provided in Table 5-2. 

Two wells were installed and subsequently plugged and abandoned due to the lack of water 

production (AOI01-09) or the presence of grout in the well (SFAASF-03-PA). Upon the 

completion of SFAASF-03-PA, the well was gauged and found to contain grout. The well was 

abandoned by filling the PVC pipe with bentonite chips from a depth of 197 to 138.8 ft and 

adding water to hydrate overnight. The next day the top 5 ft of PVC was removed and a tremie 
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5-5

pipe was inserted to fill the rest of the well/borehole with mixed grout 136 ft to ground surface. 

After AOI01-09 was completed to the target depth, the well was left overnight to allow any 

groundwater to accumulate. No groundwater accumulated so the well was abandoned by 

removing the entire PVC pipe and pumping mixed grout to fill the open borehole to ground 

surface. 

Groundwater samples were collected using a PFAS-free Geosub pump and PFAS-free HDPE 

tubing. Samples were collected at least 1 week after well development. Each sample was 

collected in laboratory-supplied PFAS-free HDPE bottles and labeled using a PFAS-free marker 

or pen. The monitoring wells were purged at a rate determined in the field to reduce turbidity and 

draw down prior to sampling. 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. Samples were packaged on ice and transported via FedEx under 

standard chain-of-custody procedures to the laboratory 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 

2021b). Additionally, a separate groundwater sample was collected for the purpose of conducting 

a field-administered shake test to observe the presence or absence of foam.

Field duplicate samples 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. One FB per day was collected in accordance with the 

UFP-QAPP Addendum (EA 2021b). A minimum of one EB was collected per day and analyzed 

for the same parameters as the groundwater samples due to the use of a non-dedicated pump. A 

temperature blank was placed in each cooler to ensure that samples were preserved at or below 

6°C during shipment. 

5.4 SYNOPTIC WATER LEVEL MEASUREMENTS

Groundwater levels were measured and used to calculate facility-wide groundwater elevations 

and assess groundwater flow direction. Synoptic water-level elevation measurements were 

collected on 3 June 2022 from the groundwater monitoring wells, taken from the survey mark 

on the northern side of the well casing. Groundwater elevation maps for perched and regional 

groundwater are provided in Figures 2-5 and 2-6, respectively. Groundwater elevation data are

provided in Table 5-3. 

5.5 SURVEYING

The northern side of each new temporary well casing was surveyed using a Trimble R10 

real-time kinematic differential Global Positioning System (GPS). Positions are provided in the 

applicable Universal Transverse Mercator zone projection with North American Datum 1983 

(horizontal) and North American Vertical Datum 1988 using Geoid 18 (vertical). Surveying data 

were collected on 3 June 2022 and are provided in Appendix B3. 

GPS locations for soil borings and land application of soil cuttings were collected using a 

Trimble Geo 7x by EA on 19–20 May 2022 and 17 June 2022. Coordinates were differentially 
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5-6

corrected, and point locations meet accuracy objectives outlined in the UFP-QAPP Addendum 

Worksheet #22 (EA 2021b). Coordinates are presented in Appendix B3. 

5.6 INVESTIGATION-DERIVED WASTE

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

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

waste was managed according to a set of decision rules approved by ARNG, NMARNG, and 

NMED and documented in Field Change Request 1. PFAS concentrations from Mobilization 1 

were compared to the industrial screening levels published in the Risk Assessment Guidance for 

Investigations and Remediation, Volume 1 (NMED 2021) for the purpose of directing IDW 

management for Mobilizations 1 and 2.

Surface soil collected during Mobilization 1 had concentrations below NMED industrial SLs. In 

accordance with the IDW decision rules outlined in Section 5.8, these cuttings were land applied. 

All land application areas were recorded with a GPS. Appendix B3 contains maps displaying 

land application areas and a table of coordinates. 

For Mobilization 2, in accordance with the IDW decision rules outlined in Section 5.8, in cases 

where PFAS concentrations in surface soil were less than the NMED industrial SLs, cuttings 

generated during Mobilization 2 from surface to the capillary fringe were land applied. Soil 

cuttings from Mobilization 2 were drummed in borehole-specific drums if they were sourced 

from the capillary fringe or below. Soil cuttings from above the capillary fringe were land 

applied, with the exception of DPT boring location AOI01-06B. Cuttings from AOI01-06B were 

drummed due to the lack of surface soil analytical results that could be used to characterize the 

cuttings. All land application areas were recorded with a GPS. Appendix B3 contains maps 

displaying land application areas and a table of coordinates. 

Liquid IDW (i.e., purge water, development water, and decontamination fluids) generated during 

the SI activities were drummed. All liquid and solid IDW drums are currently stored at the 

Facility. 

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

monitoring well construction materials utilized during the field activities were disposed of as 

municipal waste.

5.7 LABORATORY ANALYTICAL METHODS

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

Lancaster Laboratories Environmental, LLC, in Lancaster, Pennsylvania, a DoD ELAP-certified 

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

USEPA Method 9045D. 

5.8 DEVIATIONS FROM UFP-QAPP ADDENDUM

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

encountered during the field investigation activities. These deviations were discussed between 
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5-7

EA, ARNG, USACE, NMARNG, and the NMED and are documented in a Field Change 

Request Form (Appendix B4). Deviations from the UFP-QAPP Addendum are noted below: 

• The UFP-QAPP Addendum indicates that non-hazardous waste generated during SI

activities would be containerized in 55-gallon drums. Based on discussions with ARNG 

and with the NMED, surface soil samples from each of the drilling locations were 

collected during a first mobilization. PFAS concentrations were reviewed and compared 

to state industrial standards for purposes of IDW management. NMED approved the land 

application of soil cuttings down to the capillary fringe in borings where surface soil 

concentrations did not exceed state standards. NMED granted approval via email on 

January 18, 2022 (J. Rhoderick, email). Areas of land application were recorded with a 

GPS. Locations are provided in a table and a map in Appendix B3. Solid IDW from the 

capillary fringe down were containerized in drums. 

• The UFP-QAPP Addendum states that borings will be advanced with air rotary or sonic 

drilling; however, DPT was used to install 15-ft borings. The alternate technology was 

used to reduce the length of the field event, as the DPT rig could install 15-ft boreholes 

while the sonic rig was installing deeper boreholes. 

• The UFP-QAPP Addendum identifies AOI01-01 as a 15-ft soil boring and AOI01-03 as a 

soil boring/monitoring well location. Due to the results of the surface soil sampling 

during the first mobilization, the project team decided to convert AOI01-01 a soil 

boring/monitoring well and AOI01-03 to a 15-ft soil boring. 

• Soil boring AOI01-06B was installed as a replacement for soil boring AOI01-06. The 

location of the 0–2 ft surface soil sample from AOI01-06 was collected from the lowest 

point in the area rather than from the edge of the pavement, as depicted in the UFP-QAPP 

Addendum (Figure 17-1). Soil boring AOI01-06B was installed at a location in closer 

proximity to the former parking apron, which was identified as a possible PFAS source.

• An additional soil boring (AOI01-09) was installed 11 ft northeast of monitoring well 

AOI01-01, which was screened in regional groundwater. The purpose of the installing 

AOI01-09 was to characterize the groundwater and capillary fringe of perched 

groundwater if present. Perched groundwater was not observed during drilling and a 

monitoring well was not installed at the location.

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

(Appendix B4) are described below: 

• Monitoring wells installed in perched groundwater were constructed with 10 ft of screen 

rather than 20 ft of screen due to the limited thickness of the water-bearing zone. 

• The deep soil sample from AOI01-01 was collected at 181–182 ft bgs, which was the 

1-ft interval above observed moisture in soil. Groundwater was later observed at 176 ft 

bgs. As a result, the deep sample collected from AOI01-01 may represent PFAS

concentrations in saturated soil rather than the capillary fringe.
Site Inspection Report

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5-8

Table 5-1. Samples by Medium

AASF, Santa Fe, New Mexico

Site Inspection Report

Sample Identification

Sample 

Collection 

Date

Sample

Depth

(ft bgs)

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

Comments

Soil Samples

AOI01-01-SB-0-2 2/8/2022 0-2 X

AOI01-01-SB-13-15 4/25/2022 13-15 X

AOI01-01-SB-135-136 4/25/2022 135-136 X

AOI01-01-SB-181-182 4/26/2022 181-182 X

AOI01-02-SB-0-2 2/8/2022 0-2

AOI01-02-SB-0-2-D 2/8/2022 0-2 X FD

AOI01-02-SB-13-15 4/27/2022 13-15 X

AOI01-02-SB-113-115 4/28/2022 113-115 X

AOI01-02-SB-113-115-DUP 4/28/2022 113-115 X FD

AOI01-02-SB-119-120 4/28/2022 119-120 X

AOI01-03-SB-0-2 2/7/2022 0-2 X X X

AOI01-03-SB-6-8 5/4/2022 6-8 X

AOI01-03-SB-13-15 5/4/2022 13-15 X

AOI01-04-SB-0-2 2/7/2022 0-2 X

AOI01-04-SB-13-15 5/3/2022 13-15 X

AOI01-04-SB-109-110 5/4/2022 109-110 X

AOI01-04-SB-109-110- DUP 5/4/2022 109-110 X FD

AOI01-05-SB-0-2 2/7/2022 0-2 X

AOI01-05-SB-6-8 5/4/2022 6-8 X

AOI01-05-SB-13-15 5/4/2022 13-15 X

AOI01-06-SB-0-2 2/7/2022 0-2 X

AOI01-06B-SB-0-2 5/4/2022 0-2 X

AOI01-06B-SB-6-8 5/4/2022 6-8 X

AOI01-06B-SB-13-15 5/4/2022 13-15 X

AOI01-07-SB-0-2 2/8/2022 0-2 X

AOI01-08-SB-0-2 2/8/2022 0-2 X

AOI01-09-SB-0-2 5/9/2022 0-2 X

AOI01-09-SB-13-15 5/5/2022 13-15 X

AOI01-09-SB-111-112 5/6/2022 111-112 X

SFAASF-01-SB-0-2 2/8/2022 0-2 X

SFAASF-02-SB-0-2 2/8/2022 0-2 X X X

SFAASF-02-SB-0-2-D 2/8/2022 0-2 X FD

SFAASF-03-SB-0-2 5/7/2022 0-2 X

SFAASF-03-PA-SB-0-2 2/7/2022 0-2 X

SFAASF-03-PA-SB-13-15 5/1/2022 13-15 X

SFAASF-03-PA-SB-183-184 5/2/2022 183-184 X

SFAASF-04-SB-0-2 2/7/2022 0-2 X

SFAASF-04-SB-13-15 4/28/2022 13-15 X

SFAASF-04-SB-180-181 4/30/2022 180-181 X
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Table 5-1. Samples by Medium

AASF, Santa Fe, New Mexico

Site Inspection Report

Sample Identification

Sample 

Collection 

Date

Sample

Depth

(ft bgs)

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

Comments

SFAASF-05-SB-0-2 2/7/2022 0-2 X

SFAASF-05-SB-6-8 5/4/2022 6-8 X

SFAASF-05-SB-13-15 5/4/2022 13-15 X

SFAASF-05-SB-13-15-DUP 5/4/2022 13-15 X FD

Groundwater Samples

AOI01-01-GW 5/20/2022 NA X

AOI01-02-GW 5/20/2022 NA X

AOI01-02-GW-DUP 5/20/2022 NA X FD

AOI01-04-GW 5/20/2022 NA X

SFAASF-03-GW 5/19/2022 NA X

SFAASF-04-GW 5/19/2022 NA X

Blank Samples

SFAASF-EB-01 2/7/2022 NA X EB

SFAASF-EB-02 2/8/2022 NA X EB

SFAASF-EB-03 4/25/2022 NA X EB

SFAASF-EB-04 4/26/2022 NA X EB

SFAASF-EB-05 4/26/2022 NA X EB

SFAASF-EB-06 4/27/2022 NA X EB

SFAASF-EB-07 4/28/2022 NA X EB

SFAASF-EB-08 4/28/2022 NA X EB

SFAASF-EB-09 4/29/2022 NA X EB

SFAASF-EB-10 4/30/2022 NA X EB

SFAASF-EB-11 5/1/2022 NA X EB

SFAASF-EB-12 5/2/2022 NA X EB

SFAASF-EB-13 5/3/2022 NA X EB

SFAASF-EB-14 5/4/2022 NA X EB

SFAASF-EB-15 5/4/2022 NA X EB

SFAASF-EB-16 5/5/2022 NA X EB

SFAASF-EB-17 5/6/2022 NA X EB

SFAASF-EB-18 5/7/2022 NA X EB

SFAASF-EB-19 5/9/2022 NA X EB

SFAASF-EB-20 5/19/2022 NA X EB

SFAASF-EB-21 5/20/2022 NA X EB

SFAASF-FB-01 2/7/2022 NA X FB

SFAASF-FB-02 2/8/2022 NA X FB

SFAASF-FB-03 4/25/2022 NA X FB

SFAASF-FB-04 4/26/2022 NA X FB

SFAASF-FB-05 4/27/2022 NA X FB

SFAASF-FB-06 4/28/2022 NA X FB

SFAASF-FB-07 4/29/2022 NA X FB
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

5-10

Table 5-1. Samples by Medium

AASF, Santa Fe, New Mexico

Site Inspection Report

Sample Identification

Sample 

Collection 

Date

Sample

Depth

(ft bgs)

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

Comments

SFAASF-FB-08 4/30/2022 NA X FB

SFAASF-FB-09 5/1/2022 NA X FB

SFAASF-FB-10 5/2/2022 NA X FB

SFAASF-FB-11 5/3/2022 NA X FB

SFAASF-FB-12 5/4/2022 NA X FB

SFAASF-FB-13 5/5/2022 NA X FB

SFAASF-FB-14 5/6/2022 NA X FB

SFAASF-FB-15 5/7/2022 NA X FB

SFAASF-FB-16 5/8/2022 NA X FB

SFAASF-FB-17 5/9/2022 NA X FB

SFAASF-FB-18 5/19/2022 NA X FB

SFAASF-FB-19 5/20/2022 NA X FB

Notes:

EB = Equipment blank

FB = Field blank

FD = Field duplicate

NA = Not applicable
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

5-11

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

AASF, Santa Fe, New Mexico

Site Inspection Report

Areas of Interest

Boring

Location

Soil Boring

Depth

(ft bgs)

Well Screen 

Interval

(ft bgs)

Current Well

Status

1 

AOI01-01 192 170-190 Existing

AOI01-02 119 107-117 Existing

AOI01-03 15 - -

AOI01-04 115 105-115 Existing

AOI01-05 15 - -

AOI01-06 2 - -

AOI01-06b 15 - -

AOI01-07 2 - -

AOI01-08 2 - -

AOI01-09 115 110-115 P&A

Historical WWTP Surface Disposal 

Site

SFAASF-01 2 - -

SFAASF-02 2 - -

Santa Fe AASF Boundary

SFAASF-03 197 175-195 Existing

SFAASF-03-PA 197 175-195 P&A

SFAASF-04 193 171-191 Existing

SFAASF-05 15 - -

Notes:

P&A = Plugged and abandoned

Table 5-3. Groundwater Elevation 

AASF, Santa Fe, New Mexico

Site Inspection Report

Monitoring Well 

ID

Top of Casing Elevation

(ft amsl)

Depth to Water1

(ft btoc)

Groundwater Elevation

(ft amsl)

AOI01-01 6,328.84 176.46 6,152.38

AOI01-02 6,324.96 110.96 6,214.00

AOI01-04 6,323.20 110.04 6,213.16

SFAASF-03 6,337.69 184.81 6,152.88

SFAASF-04 6,332.85 180.59 6,152.26

Notes: 

1. Measured on 3 June 2022.

btoc = Below top of casing

ID = Identification
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AOI 1 Former Fire

Truck Bay

Former Trimax

Hand Truck

Storage Area

Santa Fe WWTP

Land Application Area

Former AASF

Santa Fe

Regional

Airport

AOI01-05

AOI01-06B

SFAASF-02

SFAASF-01

AOI01-07

AOI01-08

AOI01-02

AOI01-03

AOI01-09

SFAASF-03-PA

SFAASF-05

AOI01-06

AOI01-01

AOI01-04

SFAASF-03

SFAASF-04

^_

NM

3

0 500

Feet

Data Sources:

ESRI 2022

AECOM 2020

Figure 5-1

Site Inspection Sample Locations

Army National Guard Site Inspections

Site Inspection Report

Santa Fe AASF, New Mexico

Path: \\lovetongis\GISdata\Federal\Nationwide\PFAS\MAES_634250383\PROJECTS\SIReport\SantaFe\SantaFeSIReport.aprx

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Sample Locations

DPT Soil Boring

Hand Auger Soil Boring

Sonic Soil Boring

Sonic Soil Boring/Monitoring Well

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

Note:

Gray labels represent Perched Groundwater

Monitoring Wells and yellow labels represent

Regional Groundwater Monitoring Wells

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

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5-14

This page intentionally left blank
AOI 1 Former Fire

Truck Bay

Former Trimax

Hand Truck

Storage Area

Santa Fe WWTP

Land Application Area

Former AASF

Santa Fe

Regional

Airport

AOI01-05

AOI01-06B

SFAASF-02

SFAASF-01

AOI01-07

AOI01-08

AOI01-02

AOI01-03

AOI01-09

SFAASF-03-PA

SFAASF-05

AOI01-06

AOI01-01

AOI01-04

SFAASF-03

SFAASF-04

^_

NM

3

0 500

Feet

Data Sources:

AECOM 2020

RGIS UNM 2005

Figure 5-2

Site Inspection Sample Locations

with Historical Imagery

Army National Guard Site Inspections

Site Inspection Report

Santa Fe AASF, New Mexico

Path: \\lovetongis\GISdata\Federal\Nationwide\PFAS\MAES_634250383\PROJECTS\SIReport\SantaFe\SantaFeSIReport.aprx

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Sample Locations

DPT Soil Boring

Hand Auger Soil Boring

Sonic Soil Boring

Sonic Soil Boring/Monitoring Well

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

Note:

Gray labels represent Perched Groundwater

Monitoring Wells and yellow labels represent

Regional Groundwater Monitoring Wells

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
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Santa Fe AASF, New Mexico Version: FINAL

6-1

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 is provided in Sections 6.3 and 6.4. Table 

6-1 provides applicable screening levels. Tables 6-2 through 6-5 present PFAS results for the 

relevant compounds in soil and groundwater. 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 concentration for sampled media exceed the SLs 

established in the OSD memorandum, the AOI may proceed to the next phase under CERCLA. 

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

Table 6-1. 

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

Analyte 2

Residential

(Soil)

(μg/kg)1 

0 to 2 ft bgs

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg) 1 

2 to 15 ft bgs

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 

USEPA’s Regional Screening Level Calculator. Hazard Quotient = 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 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.

μg/kg = Microgram(s) per kilogram.

 ng/L = Nanogram(s) per liter.

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

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

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

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

bgs) and the industrial/commercial worker scenario is applied to all shallow subsurface soil
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6-2

results (2–15 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 and pH, which 

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

of the TOC and pH sampling. 

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

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

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

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

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

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

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

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

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

factors (e.g., pH and presence of polyvalent cations) may also affect PFAS sorption to solid 

phases (ITRC 2018). 

6.3 AOI 1 

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

AOI 1, which includes Former Firetruck Bay and Tri-MaxTM Hand Truck Storage Area. The soil 

and groundwater results are summarized on Tables 6-2 through 6-5. Soil and groundwater 

results are presented on Figures 6-1 through 6-7. 

In the sections below, estimated analyte concentrations are followed by a ‘J’ qualifier. 

Concentrations that are estimated and biased higher are followed by a ‘J+’ qualifier.

6.3.1 AOI 1 - Soil Analytical Results

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

present the ranges of detections in soil. 

Soil was sampled at 10 boring locations associated with potential release areas at AOI 1. Soil 

was sampled from three intervals at locations AOI01-01, AOI01-02, AOI01-03, AOI01-04, 

AOI01-05, AOI01-06B, and AOI01-09; and one interval at locations AOI01-06, AOI01-07, and 

AOI01-08. 

PFOS was detected in seven of 10 surface soil sample locations with concentrations exceeding 

the applicable SL in three surface soil sample locations (AOI01-02, AOI01-07, and AOI01-08). 

The highest PFOS concentration of 920 μg/kg was detected at AOI01-07. PFOA, PFNA, and 

PFHxS were detected in surface soil at AOI 1 at concentrations that did not exceed the applicable 

residential SLs. PFOA was detected in 8 of 10 surface soil sample locations at concentrations 

below the SL of 19 μg/kg. PFOA had a maximum reported concentration of 1.2 μg/kg (AOI01-
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-3

07). PFHxS was detected in 5 the 10 surface soil sample locations at concentrations below the 

SL of 130 μg/kg. PFHxS had a maximum reported concentration of 8.3 μg/kg (AOI01-07). 

PFNA was detected in 3 of the 10 surface soil sample locations at concentrations below the SL 

of 19 μg/kg. PFNA had a maximum reported concentration of 3.8 μg/kg (AOI01-07). PFBS 

was not detected in any of the 10 surface soil sample locations at AOI 1. 

Shallow subsurface soil3 samples collected from 2 to 15 ft bgs did not exceed the SLs for the 

relevant compounds in any of the sample locations. PFOS was detected in AOI01-02, AOI01-03, 

and AOI01-04 at concentrations ranging up to 5.9 μg/kg. PFOA was detected in two locations, 

AOI01-02 and AOI01-04, with a maximum concentration of 0.59 J μg/kg (AOI01-02). PFHxS

was detected in three soils samples, AOI01-02, AOI01-03, and AOI01-04, with a maximum 

concentration of 3 μg/kg (AOI01-02). PFNA was detected in one location (AOI01-04) at a 

concentration of 0.37 J μg/kg. 

PFBS was not detected in any of the deep subsurface soil samples. In AOI01-02, PFHxS was 

detected at a concentration of 0.32 J μg/kg. In AOI01-04, PFOS, PFOA, PFHxS, 

and PFNA were detected at concentrations of 2.2 J+ μg/kg, 0.48 J μg/kg, 1.1 J μg/kg, and 

0.32 J μg/kg, respectively. 

6.3.2 AOI 1 - Groundwater Results 

Figures 6-6 and 6-7 present the ranges of detections in groundwater. Table 6-5 summarizes the 

groundwater results. 

Groundwater samples were collected from three permanent monitoring wells associated with the 

potential release area AOI 1. Two wells, AOI01-02 and AOI01-04, are screened in perched 

groundwater between 105 to 117 ft bgs; one well, AOI01-01, is screened regional groundwater 

between 170 to 190 ft bgs. PFOA and PFHxS were detected in perched groundwater at 

concentrations exceeding the applicable SLs. The maximum concentrations of PFOA and PFHxS 

of 38 ng/L and 230 ng/L, respectively, were detected at AOI01-04. PFBS was detected below the 

applicable SL in both perched groundwater wells. PFOS and PFNA were not detected in perched 

groundwater. 

PFOS, PFOA, PFBS, PFHxS, and PFNA were not detected in AOI01-01, which is screened in 

regional groundwater. 

A shake test was administered to samples collected from each of the three monitoring wells in 

AOI 1. Foam was not observed in any of the samples. 

6.3.3 AOI 1 - Conclusions

Based on the results of the SI, four relevant compounds (PFOA, PFOS, PFHxS, and PFNA) were

detected in AOI 1. PFOS exceeded the SL in surface soil. Three of the five relevant compounds 

(PFOA, PFHxS, and PFBS) were detected in groundwater at AOI 1. PFOA and PFHxS exceeded 

3 Shallow subsurface soil also referred to as intermediate depth.
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6-4

SLs in groundwater. Based on the exceedance of the SLs, further evaluation at AOI 1 is 

warranted.

6.4 HISTORICAL WASTEWATER TREATMENT PLANT BIOSOLID SURFACE 

DISPOSAL SITE SAMPLE LOCATIONS

Based on historical aerial photographs, biosolid surface disposal extended into the current Santa 

Fe AASF lease area; biosolid surface disposal extended to the north end of the current AASF 

building prior to the 2012 renovations of the facility. This section presents the analytical results 

for soil in comparison to SLs for sample locations within the historical WWTP biosolid surface 

disposal site that extends onto the current Santa Fe AASF lease area. Tables 6-2 through 6-5

summarize detected compounds in soil. Figures 6-1 through 6-5 present the ranges of detections 

in soil. 

6.4.1 Historical Wastewater Treatment Plant Biosolid Surface Disposal Site – Soil 

Analytical Results

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

present the ranges of detections in soil.

Soil was sampled at two boring locations (SFAASF-01 and SFAASF-02) within the historical 

WWTP biosolid surface disposal site, as identified using historical aerial photography. Only 

surface soil was sampled at these locations. 

PFOS and PFOA concentrations in surface soils exceeded SLs both sample locations within the 

historical WWTP biosolid surface disposal site. PFBS, PFNA, and PFHxS in soil, when detected, 

did not exceed the SLs. PFOS exceeded the applicable SL in both surface soil sample locations. 

The highest PFOS concentration of 60 μg/kg was detected at SFAASF-02. PFOA was detected 

in both surface soil sample locations with the concentration exceeding the applicable SL in one 

surface soil sample locations (SFAASF-02), which had a reported concentration of 33 μg/kg. 

PFHxS and PFNA were detected below their respective applicable SLs in both sample locations. 

PFBS was detected below the applicable SL in surface soil at one location (SFAASF-02). 

6.4.2 Historical Wastewater Treatment Plant Biosolid Surface Disposal Site – 

Groundwater Results

Groundwater was not sampled within the historical WWTP biosolid surface disposal site; 

however, groundwater samples at AOI01-01 are considered downgradient from the historical 

WWTP biosolid surface disposal site and upgradient of AOI 1, and samples from SFAASF-03 

and SFAASF-04 are also considered downgradient from the offsite biosolid surface disposal site. 

There were no detections of the relevant compounds in these samples. Subsurface soil was not 

sampled at these locations and perched water was not encountered, thus the fate and transport of 

the relevant compounds in the surface soil is unknown. 
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6-5

6.4.3 Historical Wastewater Treatment Plant Biosolid Surface Disposal Site – 

Conclusions

During the SI, PFBS, PFNA, and PFHxS were detected below SLs in surface soil samples. PFOS 

and PFOA were detected above SLs. Elevated PFAS concentrations within the historical WWTP 

biosolid surface disposal site may be a result of the historical application of WWTP biosolids to 

the land currently leased by NMARNG or the current surface disposal of WWTP biosolids on 

the adjacent property. Sub-surface soils and groundwater were not sampled at these locations. 

Based on the exceedance of SLs in surface soil within the historical WWTP biosolid surface 

disposal site, further evaluation is warranted. 

6.5 BOUNDARY SAMPLE LOCATIONS

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

boundary sample locations. Tables 6-2 through 6-5 summarize the detected compounds in soil 

and groundwater. Figures 6-1 through 6-7 present the ranges of detections in soil and 

groundwater. 

6.5.1 Boundary Sample Locations – Soil Analytical Results

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

present the ranges of detections in soil.

Soil was sampled at four boring locations associated with the facility boundary. Soil was 

sampled from three intervals at locations SFAASF-03-PA, SFAASF-04, and SFAASF-05. Only 

surface soil was sampled at SFAASF-03. 

PFOS and PFOA were detected below SLs in surface soils at the facility boundary. PFBS, 

PFNA, and PFHxS were not detected. PFOS was detected below the SL in three of four 

boundary surface soil samples. The highest PFOS concentration of 0.94 μg/kg was detected at 

SFAASF-04. PFOA was detected below the SL in three of four surface soil sample locations

with a maximum concentration of 0.96 μg/kg at SFAASF-05. PFHxS, PFNA, and PFBS were

not detected. Relevant compounds were not detected in subsurface soil collected from these 

locations. 

6.5.2 Boundary Sample Locations – Groundwater Results 

Table 6-5 summarizes the groundwater results. Figures 6-6 and 6-7 present the ranges of 

detections in groundwater. 

Groundwater samples were collected from two well locations along the facility boundary 

(SFAASF-03 and SFAASF-04). The boundary wells were completed in regional groundwater 

due to the lack of observed perched groundwater. None of the relevant compounds were detected 

in groundwater samples collected from boundary wells.

A shake test was administered to samples collected from both monitoring wells along the facility 

boundary. Foam was not observed in either sample. 
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6-6

6.5.3 Boundary Sample Locations – Conclusions

Based on the results of the SI, PFBS, PFNA, and PFHxS were not detected in samples at the

facility boundary. PFOS and PFOA were detected below SLs in surface soil. Relevant 

compounds were not detected in sub-surface soil. 

Relevant compounds were not detected in groundwater monitoring wells installed for the 

purpose of characterizing off-facility contamination. Samples representing off-facility 

groundwater quality to the west (SFAASF-03 and SFAASF-04) and to the northwest (AOI01-01) 

suggest that PFAS compounds are not present in the regional groundwater upgradient of AOI 1. 

Perched groundwater was not observed at boundary monitoring well locations during the SI. 

Based on the lack of SL exceedances in groundwater and soil at the boundary, further evaluation 

is not warranted. 
Site Inspection Report

Santa Fe Army Aviation Support Facility, New Mexico 

Analyte1,2 Screening Level1,2 Result Qual Result Qual Result Qual Result Qual Result Qual Re

Perfluorobutanesulfonic acid (PFBS) 1900 ND U ND U ND U ND U ND U NPerfluorohexanesulfonic acid (PFHxS) 130 0.41 J 0.5 J 0.96 1.4 0.64 NPerfluorononanoic acid (PFNA) 19 ND U 0.32 J 0.51 J ND U ND U NPerfluorooctanesulfonic acid (PFOS) 13 3.1 61 86 6.5 3.6 NPerfluorooctanoic acid (PFOA) 19 0.64 0.26 J 0.53 J 0.39 J 0.36 J NNotes:J = Estimated concentration.J+ = Estimated concentration, biased high.μg/kg = Microgram(s) per kilogram.Values exceeding the Screening Level are shaded gray.bgs = Below ground surface.ft = Foot (feet).Qual = Qualifier.ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).2. The Screening Levels for soil are based on a residential scenario for direct ingestion of contaminated soil.PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 (μg/kg)U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD).UJ = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD). However, the associated numerical value is approximate.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. 

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

Sample Date 2/8/2022 2/8/2022 2/8/2022 2/7/2022 2/7/2022 

AOI01-02 

Parent Sample ID AOI01-02-SB-0-2

Location ID AOI01-01

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

AOI01-02 AOI01-03 AOI01-04

Sample Name AOI01-01-SB-0-2 AOI01-02-SB-0-2 AOI01-02-SB-0-2-D AOI01-03-SB-0-2 AOI01-04-SB-0-2 A

EA Engineering, Science, and Technology, Inc., PBC
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Analyte1,2 Screening Level1,2

Perfluorobutanesulfonic acid (PFBS) 1900

Perfluorohexanesulfonic acid (PFHxS) 130Perfluorononanoic acid (PFNA) 19Perfluorooctanesulfonic acid (PFOS) 13Perfluorooctanoic acid (PFOA) 19Notes:J = Estimated concentration.J+ = Estimated concentration, biased high.μg/kg = Microgram(s) per kilogram.Values exceeding the Screening Level are shaded gray.bgs = Below ground surface.ft = Foot (feet).Qual = Qualifier.ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).2. The Screening Levels for soil are based on a residential scenario for direct ingestion of contaminated soil.PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 (μg/kg)U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD).UJ = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD). However, the associated numerical value is approximate.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. 

Depth (bgs ft)

Sample Date

Parent Sample ID

Location ID

Sample Name

Result Qual Result Qual Result Qual Result Qual Result Qual Re

ND U ND U ND U 0.58 J 0.59 J NND J ND U 2.7 4.5 4.7 NND U 0.4 J 1.8 2.9 2.9 N

21 7.5 42 60 49 0

0.47 J 0.68 19 30 33 0

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

2/8/2022 5/9/2022 2/8/2022 2/8/2022 2/8/2022

SFAASF-02-SB-0-2

AOI01-08 AOI01-09

AOI01-08-SB-0-2 AOI-01-09-SB-0-2 SFA

SFAASF-01-SB-0-2 SFAASF-02-SB-0-2 SFAASF-02-SB-0-2-D

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

SFAASF-01 SFAASF-02 SFAASF-02 S

EA Engineering, Science, and Technology, Inc., PBC
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Analyte1,2 Screening Level1,2 Result Qual Result Qual Result Qual Result Qual 

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 (μg/kg)Perfluorobutanesulfonic acid (PFBS) 25000 ND U ND U ND U ND U Perfluorohexanesulfonic acid (PFHxS) 1600 ND U 3 0.27 J 0.23 J 

Perfluorononanoic acid (PFNA) 250 ND U ND U ND U ND U 

Perfluorooctanesulfonic acid (PFOS) 160 ND U 1.2 5.9 0.66 

Perfluorooctanoic acid (PFOA) 250 ND U 0.59 J ND U ND U 

Notes:J = Estimated concentration.Values exceeding the Screening Level are shaded gray.ft bgs = Foot (feet) below ground surface.μg/kg = Microgram(s) per kilogram.Qual = Qualifier.ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).

UJ = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD). However, the associated numerical value is approximate.

Depth (bgs ft) 13-15 13-15 13-15 6-8 

U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD).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. 2. The Screening Levels for soil are based on incidental ingestion of soil in a industrial/commercial worker scenario.

Sample Date 4/25/2022 4/27/2022 5/4/2022 5/4/2022 

Parent Sample ID

A

Sample Name AOI01-01-SB-13-15 AOI01-02-SB-13-15 AOI01-03-SB-13-15 AOI01-03-SB-6-8

Table 6-3. PFOA, PFOS, PFBS, PFNA, and PFHxS Detections in Shallow Subsurface Soil, Site Inspection Report, Sa

Location ID AOI01-01 AOI01-02 AOI01-03 AOI01-03 

EA Engineering, Science, and Technology, Inc., PBC
Site Inspection Report

Santa Fe Army Aviation Support Facility, New Mexico 

Analyte1,2 Screening Level1,2

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 (μg/kg)Perfluorobutanesulfonic acid (PFBS) 25000Perfluorohexanesulfonic acid (PFHxS) 1600Perfluorononanoic acid (PFNA) 250Perfluorooctanesulfonic acid (PFOS) 160Perfluorooctanoic acid (PFOA) 250Notes:J = Estimated concentration.Values exceeding the Screening Level are shaded gray.ft bgs = Foot (feet) below ground surface.μg/kg = Microgram(s) per kilogram.Qual = Qualifier.ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).UJ = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD). However, the associated numerical value is approximate.

Depth (bgs ft)

U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD).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. 2. The Screening Levels for soil are based on incidental ingestion of soil in a industrial/commercial worker scenario.

Sample Date

Parent Sample ID

Sample Name

Location ID

Result Qual Result Qual Result Qual Result 

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

5/4/2022 5/5/2022 5/1/2022 

6-8 13-15 13-15 

4/28/202

13-15

AOI01-06B-SB-6-8 AOI01-09-SB-13-15 SFAASF-03-PA-SB-13-15 SFAASF-04-S

AOI01-06B

Table 6-3. PFOA, PFOS, PFBS, PFNA, and PFHxS Detections in Shallow Subsurface Soil, Site Inspection Report, San

AOI01-09 SFAASF-03-PA SFAASF-

EA Engineering, Science, and Technology, Inc., PBC
Site Inspection Report

Santa Fe Army Aviation Support Facility, New Mexico 

Location ID

Sample Name

Parent Sample ID

Sample Date

Depth (bgs ft)

Analyte1 Result Qual Result Qual Result Qual Result Qual Result Qual 

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

Perfluorohexanesulfonic acid (PFHxS) ND U 0.32 J ND U 1.1 J ND UJ Perfluorononanoic acid (PFNA) ND U ND U ND U 0.32 J ND U 

Perfluorooctanesulfonic acid (PFOS) ND U ND U ND U 2.2 J+ ND UJ 

Perfluorooctanoic acid (PFOA) ND U ND U ND U 0.48 J ND U Notes:J = Estimated concentration.U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD).J+ = Estimated concentration, biased high.UJ = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection (LOD). However, the associated numerical value is approximate.μg/kg = Microgram(s) per kilogram.ft bgs = Foot (feet) below ground surface.ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).Qual = Qualifier.

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

181-182 113-115 113-115 109-110 109-110 

4/26/2022 4/28/2022 4/28/2022 5/4/2022 5/4/2022 

AOI01-02-SB-113-115 AOI01-04-SB-109-

AOI01-01-SB-181-182 AOI01-02-SB-113-115 AOI01-02-SB-113-115-DUP AOI01-04-SB-109-110 AOI01-04-SB-109-11

AOI01-01 AOI01-02 AOI01-02 AOI01-04 AOI01-04 

EA Engineering, Science, and Technology, Inc., PBC
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Site Inspection Report

Santa Fe Army Aviation Support Facility, New Mexico 

Analyte1 Screening Level1 Result Qual Result Qual Result Q

PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 (ng/L)Perfluorobutanesulfonic acid (PFBS) 601 ND U 120 130 

Perfluorohexanesulfonic acid (PFHxS) 39 ND U 72 74 

Perfluorononanoic acid (PFNA) 6 ND U ND U ND U 

Perfluorooctanesulfonic acid (PFOS) 4 ND U ND U ND U 

Perfluorooctanoic acid (PFOA) 6 ND U 2.5 2.3 J

Notes:J = Estimated concentration.J+ = Estimated concentration, biased high.Values exceeding the Screening Level are shaded gray.ng/L = Nanogram(s) per liter.Qual = Qualifier.

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

Sample Date 5/20/2022 5/20/2022 5/20/2022 

Parent Sample ID

Sample Name AOI01-01-GW AOI01-02-GW AOI01-02-GW-D

Location ID AOI01-01 AOI01-02 AOI01-02 

1. Assistant Secretary of Defense. July 2022. Risk-Based Screening Levels in Groundwater and Soilusing EPA’s Regional Screening Level Calculator. Hazard Quotient (HQ)=0.1. May 2022.

AOI01-02-GW

U = The analyte was not detected at a level greater than or equal to the adjusted Limit of Detection(LOD).ND = Analyte not detected above the LOD (LOD values are presented in Appendix F).

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Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Figure 6-1

AOI 1

PFOS Detections in Soil

AOI 1

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-09

AOI01-03

AOI01-02

AOI01-05

SFAASF-04

SFAASF-05

AOI01-06B

SFAASF-03-PA

AOI 1

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-09

AOI01-02

SFAASF-04

SFAASF-05

SFAASF-03-PA

AOI 1

3

0 500

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

0 500

Feet

0 500

Feet

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFOS Results (μg/Kg)

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

Notes:

PFOS = Perfluorooctanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

> 1,600

> 160 - 1,600

> 13 - 160

> ND - 13

ND (Non-Detect)

PFOS Results (μg/Kg)

> 1,600

> 160 - 1,600

> 13 - 160

> ND - 13

ND (Non-Detect)

PFOS Results (μg/Kg)

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
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Figure 6-2

AOI 1

PFOA Detections in Soil

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-03

AOI01-02

AOI01-05

SFAASF-04

SFAASF-05

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-02

SFAASF-04

SFAASF-05

SFAASF-03-PA

3

0 500

Feet

^_

NM

0 500

Feet

0 500

Feet

Shallow Intermediate Deep

Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Data Sources:

ESRI 2022

AECOM 2019

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

> 2,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)

> 2,500

> 250- 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)

> 2,500

> 250- 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFOA Results (μg/Kg)

Notes:

PFOA = Perfluorooctanoic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location.

Note:

Labels with dull gray background are

Perched Groundwater Monitoring Wells

and labels with dull yellow background

are Regional Groundwater Monitoring Wells.

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-18

This page intentionally left blank
Figure 6-3

AOI 1

PFBS Detections in Soil

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

AOI 1

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-03

AOI01-02

AOI01-05

SFAASF-04

SFAASF-05

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-02

SFAASF-04

SFAASF-05

SFAASF-03-PA

3

0 500

Feet

^_

NM

0 500

Feet

0 500

Feet

Shallow Intermediate Deep

Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Data Sources:

ESRI 2022

AECOM 2019

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)

> 25,000

> 1,900 - 25,000

> 10 - 1,900

> ND - 10

ND (Non-Detect)

PFBS Results (μg/Kg)

Notes:

PFBS = Perfluorobutanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location. Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-20

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Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Figure 6-4

AOI 1

PFHxS Detections in Soil

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-03

AOI01-02

AOI01-05

SFAASF-04

SFAASF-05

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-02

SFAASF-04

SFAASF-05

SFAASF-03-PA

3

0 500

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

0 500

Feet

0 500

Feet

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)

> 1,600

> 130 - 1,600

> 10 - 130

> ND - 10

ND (Non-Detect)

PFHxS Result (μg/Kg)

Notes:

PFHxS = Perfluorohexanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location. Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-22

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Figure 6-5

AOI 1

PFNA Detections in Soil

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-06

AOI01-09

AOI01-03

AOI01-02

AOI01-08

AOI01-07

AOI01-05

SFAASF-04

SFAASF-03

SFAASF-05

SFAASF-01

SFAASF-02

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-03

AOI01-02

AOI01-05

SFAASF-04

SFAASF-05

AOI01-06B

SFAASF-03-PA

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI 1

AOI01-04

AOI01-01

AOI01-09

AOI01-02

SFAASF-04

SFAASF-05

SFAASF-03-PA

3

0 500

Feet

^_

NM

Data Sources:

ESRI 2022

AECOM 2019

0 500

Feet

0 500

Feet

Shallow Intermediate Deep

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

> 2,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)

> 2 ,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)

> 2 ,500

> 250 - 2,500

> 19 - 250

> ND - 19

ND (Non-Detect)

PFNA Results (μg/Kg)

Notes:

PFNA = Perfluorononanoic acid

Exceedances of the OSD SL are depicted

with a yellow halo. Depth intervals shown

represent respective sampling position

within a given soil boring location. Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-24

This page intentionally left blank 
Figure 6-6

AOI 1

PFOA, PFOS and PFBS Detections in Groundwater

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-02

SFAASF-04

SFAASF-03

AOI 1

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-02

SFAASF-04

SFAASF-03

AOI 1

3

0 500

Feet

^_

NM

0 500

Feet

PFOA PFOS

Sante Fe

Regional

Airport

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

Santa Fe WWTP

Land Application Area

AOI01-04

AOI01-01

AOI01-02

SFAASF-04

SFAASF-03

AOI 1

0 500

Feet

PFBS

Notes:

PFOA = Perfluorooctanesulfonic acid

PFOS = Perfluorooctanoic acid

PFBS = Perfluorobutanesulfonic acid

Exceedances of the OSD SL are depicted

with a yellow halo.

Gray labels represent Perched Groundwater

Monitoring Wells and yellow labels represent

Regional Groundwater Monitoring Wells

Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Data Sources:

ESRI 2022

AECOM 2019

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

> 70

> 40 - 70

> 6 - 40

> ND - 6

ND (Non-Detect)

PFOA Results (ng/L)

> 70

> 40 - 70

> 4 - 40

> ND - 4

ND (Non-Detect)

PFOS Results (ng/L)

> 1,000

> 600 - 1,000

> 100 - 600

> ND - 100

ND (Non-Detect)

PFBS Results (ng/L)

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-26

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

Santa Fe, New Mexico

Figure 6-7

AOI 1

PFHxS and PFNA Detections in Groundwater

Santa Fe

Regional

Airport

Santa Fe WWTP

Land Application Area

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

AOI 1

AOI01-04

AOI01-01

AOI01-02

SFAASF-04

SFAASF-03

Santa Fe

Regional

Airport

Santa Fe WWTP

Land Application Area

Former Trimax

Hand Truck

Storage Area

Former Fire

Truck Bay

Former AASF

AOI 1

AOI01-04

AOI01-01

AOI01-02

SFAASF-04

SFAASF-03

3

0 300

Feet

Facility Data

Facility Boundary

Area of Interest

Adjacent Potential

Source Areas

Historical WWTP Biosolid

Surface Disposal Site

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

(Regional)

^_

NM

Data Sources:

ESRI 2020

AECOM 2020

Path: \\lovetongis\GISdata\Federal\Nationwide\PFAS\MAES_634250383\PROJECTS\SIReport\SantaFe\SantaFeSIReport.aprx

0 300

Feet

PFHxS PFNA

Notes:

PFHxS = Perfluorohexanesulfonic acid

PFNA = Perfluorononanoic acid

Exceedances of the OSD SL are depicted

with a yellow halo.

Gray labels represent Perched Groundwater

Monitoring Wells and yellow labels represent

Regional Groundwater Monitoring Wells

> 1,000

> 100 - 1,000

> 39 - 100

> ND - 39

ND (Non-Detect)

PFHxS Result (ng/L)

> 1,000

> 100 - 1,000

> 6 - 100

> ND - 6

ND (Non-Detect)

PFNA Results (ng/L)

Note:

Labels with dull gray background are

Perched Groundwater Monitoring Wells

and labels with dull yellow background

are Regional Groundwater Monitoring Wells.

Date:...............................July 2023

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

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

Projection:........WGS 84 UTM 13N
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

6-28

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Site Inspection Report

Santa Fe AASF, 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 was also created for the Historical WWTP Biosolid Surface 

Disposal Site. Because the potential source of contamination in this area is not likely a result of 

DoD activities, a complete pathway will not initiate the decision to move from SI to RI or to 

trigger a removal action but can result in additional investigation.

A CSM presents the current understanding of the site conditions with respect to known and 

suspected sources, potential transport mechanisms and migration pathways, and potentially 

exposed human receptors. A human exposure pathway is considered potentially complete when 

the following conditions are present: 

1 Contaminant source 

2 Environmental fate and transport

3 Exposure point 

4 Exposure route 

5 Potentially exposed populations. 

If any of these elements are missing, the pathway is incomplete. The CSM 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 relevant compounds above the SLs. Areas with an identified potentially complete 

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

investigation. Although the 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 PFAS exposure pathways are ingestion and inhalation. Human exposure 

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

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

continue to be the subject of PFAS toxicological study. The receptors evaluated are consistent 

with those listed in USEPA guidance for risk screening (USEPA 2001). Receptors at the Facility

include facility workers (e.g., staff and visiting soldiers), and construction workers. Construction 

workers are only considered as potential future receptors due to the lack of current construction 

activity at the Facility. Receptors also include off-facility residential for drinking water receptors. 

Trespassers are not considered as receptors due to the presence of secured entry and exit points 

at the Facility. The CSM for AOI 1, revised based on the SI findings, is presented on Figure 7-1. 

The CSM created for the Historical WWTP Biosolid Surface Disposal Site is presented on 

Figure 7-2. 
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-2

7.1 SOIL EXPOSURE PATHWAY 

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

between the source and potential receptors at AOI 1 or the historical WWTP biosolid surface 

disposal site based on the aforementioned criteria. 

7.1.1 AOI 1 

AOI 1 encompasses potential PFAS release areas associated with an AFFF-equipped firetruck 

parked within the former AASF building and Tri-MaxTM 70/30 hand trucks stored at various 

places around the flight line and paved parking apron. AFFF releases could have occurred 

directly onto surface soil but may also have infiltrated soil via cracks in pavement or joints 

between areas that are paved with different materials. 

PFOS was detected at 7 of 10 surface soil sample locations with concentrations exceeding the 

applicable SL in three surface soil sample locations completed at AOI 1. PFOA, PFHxS, and 

PFNA were detected at concentrations less than SLs at multiple locations within AOI 1. Facility

workers and construction workers could contact constituents in surface soil via incidental 

ingestion and inhalation of dust. Therefore, the surface soil exposure pathways for facility

workers and construction workers are potentially complete. 

PFOS, PFOA, PFHxS, and PFNA were detected in sub-surface soil at concentrations less than 

SLs. Ground disturbing activities to subsurface soil could also result in exposure to those 

compounds by construction workers via ingestion. Therefore, the exposure pathways for 

inhalation and ingestion are potentially complete for future construction workers. The CSM is 

presented in Figure 7-1. 

PFAS were detected in AOI 1 groundwater samples, indicating a complete soil to perched

groundwater pathway. It is not known if the perched groundwater is in hydrologic 

communication with the deeper regional aquifer.

7.1.2 Historical Wastewater Treatment Plant Biosolid Surface Disposal Site

The historical WWTP Biosolid Surface Disposal Site encompasses the potential PFAS release 

area located within the facility boundary. Historical biosolid surface disposal may have 

contained PFAS. 

PFOS was detected at both surface soil sample locations with concentrations exceeding the 

applicable SL. PFOA was detected at both locations, with the concentration exceeding the SL at 

SFAASF-02. PFBS, PFHxS, and PFNA were detected at concentrations less than SLs at one or 

more locations. Facility workers and construction workers could contact constituents in surface 

soil via incidental ingestion and inhalation of dust. Therefore, the surface soil exposure pathway 

for facility workers and construction workers are potentially complete.

Subsurface soil samples were not collected during the SI. As a result, the pathways of subsurface 

soil to construction workers via inhalation and ingestion are considered potentially complete 

pending further assessment. 
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-3

Due to the presence of PFAS in soil, a potentially complete soil to groundwater pathway exists. 

The CSM is presented in Figure 7-2. 

7.2 GROUNDWATER EXPOSURE PATHWAY

The SI results for relevant compounds in groundwater were used to determine whether a 

potentially complete pathway exists between the source and potential receptors based on the 

aforementioned criteria. 

7.2.1 AOI 1 

PFHxS and PFOA were detected above applicable SLs in AOI 1 perched groundwater. PFBS 

was detected below the SL. Domestic wells are present in a direction that is potentially 

downgradient of AOI 1. Although it is unclear if the contaminated perched groundwater is in 

communication with the regional aquifer, the potential for a complete pathway is present. As a 

result, the groundwater exposure pathway is considered potentially complete for off-facility 

residents via ingestion. The CSM is presented in Figure 7-1. 

7.2.2 Historical Wastewater Treatment Plant Biosolid Surface Disposal Site

Relevant compounds were not detected in groundwater downgradient from the historical 

wastewater treatment plant surface disposal site. However, subsurface soil was not sampled and 

perched water was not encountered, and the fate and transport of PFAS at this location is 

unknown. As a result, the groundwater exposure pathway to off-facility residents 

via ingestion is potentially complete pending further assessment. The CSM is presented in 

Figure 7-2. 

7.3 SURFACE WATER/ SEDIMENT EXPOSURE PATHWAY

Surface water flow at the Facility is generally to the southwest. Two stormwater retention basins 

are present adjacent to the tarmac and a stormwater detention pond is present north of the former 

AASF. PFAS was not detected in surface soil collected from the stormwater retention basins 

adjacent to the tarmac; however, samples were not collected from the stormwater retention pond. 

The stormwater retention pond may receive runoff from PFAS-contaminated areas. As a result, 

the surface water/sediment exposure pathway is considered potentially complete. 
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-4

This page intentionally left blank
Notes:

1. No current active construction at the facility.

2. The resident refers to off-Facility drinking 

water receptors.

3. Inhalation of dust for off-Facility receptors is 

likely insignificant.

4. Trespassers are not considered likely due to 

the high level of security at the facility.

Figure 7-1

Conceptual Site Model

AOI 1 Santa Fe AASF

RECEPTOR

Human Receptors:

Current/Future

Facility

Worker

Construction 

Worker1 Resident2,3

Facility 

Worker

Construction 

Worker1 Resident2,3

AOI 1

PFAS in 

Surface 

Soil and 

Paved 

Tarmac

Human 

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne 

Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Ingestion

Ingestion

Ingestion

AFFF tank in 

Firetruck or TriMaxTM Hand 

Truck

SOURCE

Source Release 

Mechanism Media

PATHWAY

Transport

and Migration Media Exposure 

Routes

Inhalation 

of Dust

Potentially Complete Pathway 

with Exceedance of Screening 

Level

Trespasser4

Groundwater Ingestion

Trespasser4
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

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

This page intentionally left blank
Figure 7-2

Conceptual Site Model

Historical WWTP Biosolid Surface 

Disposal Site

Santa Fe AASF

RECEPTOR

Human Receptors:

Current/Future

Site 

Worker

Construction 

Worker2 Resident3,4

Site 

Worker

Construction 

Worker2

Resident3,4

Human 

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne 

Soil 

Particulate

Surface Soil 

Surface 

Water/ 

Sediment

Subsurface 

Soil

Ingestion

Ingestion

Ingestion

Historical 

WWTP 

Biosolid 

Surface 

Disposal 

Site

SOURCE

Source Release 

Mechanism Media

PATHWAY

Transport

and Migration Media Exposure 

Routes

Inhalation 

of Dust

Potentially Complete Pathway 

with Exceedance of Screening 

Level

Trespasser5

Trespasser5

Groundwater Ingestion

WWTP Biosolid 

Surface 

Disposal1

PFAS in 

Surface 

Soil

Notes:

1. Likely release mechanism for contaminated 

media is not the result of DoD activities.

2. No current active construction at the facility.

3. The resident refers to off-Facility drinking 

water receptors.

4. Inhalation of dust for off-Facility receptors is 

likely insignificant.

5. Trespassers are not considered likely due to 

the high level of security at the facility.
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-8

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Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

8-1 

8. SUMMARY AND OUTCOME

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

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

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

the SLs. 

8.1 SITE INSPECTION ACTIVITIES SUMMARY 

The SI field activities were conducted during two mobilizations. Field activities for the first 

mobilization were conducted from 7 to 8 February 2022 and consisted of hand augering and 

surface soil sample collection. The second mobilization was conducted 25 April through 3 June 

2022. Field activities included sonic and DPT drilling, collection of soil samples, installation of 

permanent monitoring wells, groundwater gauging and sampling, and collection of spatial data. 

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

except as noted in Section 5.8. 

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 24 compounds by LC/MS/MS compliant 

with QSM 5.3 Table B-15. The 24 PFAS analyzed as part of the ARNG SI program are specified 

in Section 5.6 of this SI Report. Samples collected and analyzed are as follows:

• Thirty-eight (38) soil grab samples from 16 boring locations 

• Five (5) grab groundwater samples from five permanent monitoring wells

• Forty-six (46) quality assurance/quality control 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 is

described in Section 7. 

8.2 OUTCOME

Based on the results of this SI, further evaluation under CERCLA is warranted in an RI for AOI

1 (Table 8-1). The Historical WWTP Biosolid Surface Disposal Site will also be assessed to 

determine if the contamination present poses a detrimental impact on human health for personnel 

at the Facility or the environment. Based on the CSMs developed and revised based on the SI 

findings, the exposure pathways are potentially complete for facility workers and construction 

workers during surface soil-disturbing activities and to construction workers during subsurface 

soil-disturbing activities from historical DoD activities. These pathways are also potentially 

complete from historical non-ARNG activities at the historical WWTP biosolid surface disposal 

site. Additionally, there are potentially complete exposure pathways for residential drinking
Site Inspection Report

Santa Fe AASF, New Mexico Version: FINAL

8-2 

water receptors from releases during historical DoD activities and from historical non-ARNG 

sources at the Facility. Sample analytical concentrations collected during this SI were compared 

against the project SLs in soil and groundwater, as described in Table 6-1. 

A summary of the results of the SI data relative to the SLs is as follows: 

• At AOI 1:

 PFOS was detected in surface soil above the SL in three of the 10 sampling locations 

with a maximum concentration of 920 μg/kg. PFOA, PFNA, and PFHxS were 

detected in soil samples at concentrations which did not exceed the SLs. PFBS was 

not detected in any soil samples collected from AOI 1. 

 PFOA and PFHxS were detected in groundwater at concentrations above the SL with 

a maximum concentration of 38 ng/L and 230 ng/L, respectively. PFHxS exceeded 

the SL in two of the three groundwater wells. Both wells with exceedances are 

screened in perched groundwater, downgradient of the suspected source area. PFBS 

was detected in both downgradient wells, but concentrations did not exceed the SL. 

PFOA and PFNA were not detected in groundwater at AOI 1.

• At the Historical WWTP Biosolid Surface Disposal Site: 

 PFOA was detected in both surface soil sample locations and exceeded the SL in 

one location with a maximum concentration of 33 μg/kg. 

 PFOS was detected in both surface soil sample locations above the SL with a 

maximum concentration of 60 μg/kg. 

 PFBS, PFHxS, and PFNA were detected below SLs in one or more surface soil 

samples.

 Neither subsurface soil nor groundwater were sampled in this area.

• At the facility boundary: 

 PFOA and PFOS were detected in three of four surface soil samples at 

concentrations below SLs. PFNA, PFBS, and PFHxS were not detected in surface 

soil samples.

 PFOA, PFOS, PFBS, PFNA, and PFHxS were not detected in shallow or deep 

subsurface soil samples. 

 PFOA, PFOS, PFBS, PFNA, and PFHxS were not detected in groundwater

samples. 
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Santa Fe AASF, New Mexico Version: FINAL

8-3 

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.

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

be considered for further investigation under CERCLA and undergo an RI. It also summarizes SI 

results to determine if the historical WWTP biosolid surface disposal site should be considered 

for non-CERCLA evaluation.

Table 8-1. Summary of Site Inspection Findings 

Area

Potential Release

Area Soil

GroundwaterOn-Site

Groundwater –

Facility 

Boundary 

Future 

Action

AOI 1 

Former Firetruck Bay and 

Tri-MaxTM Hand Truck 

Storage Area

Proceed to RI

Historical WWTP 

Biosolid Surface 

Disposal Site

Historical WWTP Biosolid 

Surface Disposal Site

 

Further 

Evaluation1

Notes:

1. This area will be assessed during the RI to determine if the contamination present poses a detrimental impact 

on human health for personnel at the facility or the environment

WWTP = Wastewater Treatment Plant
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Santa Fe AASF, New Mexico Version: FINAL

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