FINAL

Preliminary Assessment Report 

Nome Army Air Operating Facility

Nome, Alaska

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

August 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

i

Table of Contents

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

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

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

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

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

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

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

1.5.1 Geology ......................................................................................................... 5

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

1.5.3 Hydrology ....................................................................................................... 6

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

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

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

3. Non-Fire Training Areas ................................................................................................... 12

3.1 AAOF Hangar ......................................................................................................... 12

4. Emergency Response Areas ............................................................................................ 14

5. Adjacent Sources ............................................................................................................. 15

5.1 Nome Airport Fire Department ................................................................................ 15

5.2 Nome Airport Fire Department AFFF Spray Area .................................................... 15

5.3 Nome WWTP .......................................................................................................... 15

6. Preliminary Conceptual Site Model .................................................................................. 17

6.1 AOI 1: AAOF Hangar ............................................................................................. 17

7. Conclusions ..................................................................................................................... 21

7.1 Findings .................................................................................................................. 21

7.2 Uncertainties ........................................................................................................... 21

7.3 Potential Future Actions .......................................................................................... 22

8. References ...................................................................................................................... 24
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

ii

Tables

Table ES-1 AOIs at Nome AAOF

Table 7-1 AOIs at Nome AAOF

Table 7-2 Summary of Uncertainties

Table 7-3 PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, Nome AAOF, AK

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Area

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model, AOI 1

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

iii

Acronyms and Abbreviations

°F degrees Fahrenheit

AAOF Army Aviation Operating Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AKARNG Alaska Army National Guard

AOI area of interest

ARNG Army National Guard

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

HA Health Advisory

PA Preliminary Assessment

NAFD Nome Airport Fire Department

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

UCMR3 Unregulated Contaminant Monitoring Rule 3

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

WWTP Wastewater Treatment Plant
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

1

Executive Summary

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

Inspections (SIs) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA)

Impacted Sites at ARNG Facilities Nationwide. A PA for per- and polyfluoroalkyl substances

(PFAS)-containing materials was completed for Nome Army Aviation Operating Facility (AAOF) in

Nome, Alaska to assess potential PFAS release areas and exposure pathways to receptors.

Nome AAOF provides training and maintenance for the various aviation units that support the

Alaska ARNG (AKARNG). The facility includes a single hangar and concrete pad on just over an

acre. The land has been leased by the AKARNG from the Alaska Department of Transportation

since 1988, and the hangar was constructed approximately in 1992.

The performance of this PA included the following tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

Inc. (EDR)TM report packages to obtain information relevant to potential PFAS releases, such

as: drinking water well locations, historical aerial photographs, Sanborn maps, and

environmental compliance actions in the area surrounding the facility; 

· Conducted a site visit on 31 August 2018 and completed visual site inspections at locations

where PFAS-containing materials were suspected of being stored, used, or disposed;

· Interviewed current Nome AAOF personnel during the site visit including the Facility

Commander; and,

· Identified Area(s) of Interest (AOIs) and developed a preliminary conceptual site model (CSM)

to summarize potential source-pathway-receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI.

One AOI related to a potential PFAS release was identified at the facility during the PA. The AOI

is shown on Figure ES-1 and described in Table ES-1 below:

Table ES-1: AOIs at Nome AAOF

Area of Interest Name Used by Potential Release Date

AOI 1 AAOF Hangar AKARNG 1992 to present

Based on potential PFAS releases at AOI 1, there is potential for exposure to PFAS contamination

in media at or near the facility. The preliminary CSM for AOI 1, which presents the potential

receptors and media impacted, is shown on Figure ES-2. Based on the US Environmental

Protection Agency (USEPA) Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, it was

indicated that no PFAS were detected in a public water system above the USEPA’s lifetime Health

Advisories (HAs) within 20 miles of the facility. The HA is 70 parts per trillion for PFOS and PFOA,

individually or combined. PFAS analyses performed in 2016 had method detection limits that were

higher than currently achievable. Thus, it is possible that low concentrations of PFAS were not

detected during the UCMR3 but might be detected if analyzed today.
Nome AAOF

Nome Airport Fire Department

Nome Airport Fire Department AFFF Spray Area

AOI 1

0 200 400 800

Feet

Legend

Area of Interest

Potential PFAS Release

Facility Location

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

7/20/2020

7/20/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:4,800

7/20/2020 ­ Figure ES-1 PM RG 7/20/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, Maxar, GeoEye, Earthstar

Geographics, CNES/Airbus DS, USDA, USGS,

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_ES-1_Nome_Summary.mxd

2
Media

SOURCE PATHWAY RECEPTOR

AOI 1

PFOS/ 

PFOA in 

Surface Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site 

Worker

Construction 

Worker Resident1 Recreational User1

LEGEND

/ /

/

Figure ES-2

Preliminary Conceptual Site Model

Nome AAOF, AK

Potential Leaks 

from Storage of 

AFFF 

/ /

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ / / /

/ /

/

/

/ /

/ /

/ /

NOTES

1. The resident and recreational users refer to 

off-site receptors.

Site 

Worker

Construction 

Worker Resident1 Recreational 

User1

3
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

4

1. Introduction

1.1 Authority and Purpose

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

(PAs) and Site Inspections (SIs) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic

acid (PFOA) at Impacted Sites at ARNG Facilities Nationwide. This work is supported by the

United States (US) Army Corps of Engineers (USACE) Baltimore District and their contractor

AECOM Technical Services, Inc. (AECOM) under Contract Number W912DR-12-D-0014, Task

Order W912DR17F0192, issued 11 August 2017.

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

that used per- and poly-fluoroalkyl substances (PFAS) (a suite of related chemicals), primarily

releases of aqueous film forming foam (AFFF) although other sources of PFAS are possible. In

addition, the ARNG is assessing businesses or operations adjacent to the ARNG facility (not

under the control of ARNG) that could potentially be responsible for a PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing

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

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

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

continues to evolve. The US Environmental Protection Agency (USEPA) issued Drinking Water

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

national standards regulating PFAS in drinking water. The HA is 70 parts per trillion for PFOS and

PFOA, individually or combined.

This report presents findings of a PA for PFAS-containing materials at Nome Army Aviation

Operating Facility (AAOF) in Nome, Alaska in accordance with the Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA), as amended, the National Oil and

Hazardous Substances Pollution Contingency Plan (40 Code of Federal Regulations Part 300),

and Army requirements and guidance.

This PA documents potential locations where PFAS containing materials are stored and have the

potential to be released into the environment at or adjacent to the Nome AAOF. The term PFAS

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

PFOS and PFOA, which are key components of AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

Inc. (EDR)TM report packages to obtain information relevant to potential PFAS releases, such

as: drinking water well locations, historical aerial photographs, Sanborn maps, and

environmental compliance actions in the area surrounding the facility; 

· Conducted a site visit on 31 August 2018 and completed visual site inspections at locations

where PFAS-containing materials were suspected of being stored, used, or disposed;

· Interviewed current Nome AAOF personnel during the site visit including the Facility

Commander; and 

· Identified Area(s) of Interest (AOIs) and developed a preliminary conceptual site model (CSM)

to summarize potential source-pathway-receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI.
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

5

1.3 Report Organization

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

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

of each are:

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

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

· Section 2 – Fire Training Areas: describes the fire training areas (FTAs) at the facility

identified during the site visit.

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

at the facility identified during the site visit.

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

facility, specifically in response to emergency situations.

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

facility that are not under the control of ARNG.

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

transport and receptors at the facility.

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

uncertainties of the PA.

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

The Nome AAOF is in Nome, Alaska on the southern coast of the Seward Peninsula, the middle

of Alaska’s three western lobes, approximately 130 miles from the Bering Strait (Figure 1-1). The

AAOF is comprised of a single hangar where Prospect Street meets New Center Creek Road,

across from Runway 12 near the northeastern end of the airfield. The 1.07-acre lot consists of the

AAOF hangar, a section of asphalt pavement, a concrete pad, water and fuel/oil storage tanks,

underground piping, and a wash water recycling system.

1.5 Facility Environmental Setting

The facility lies on a gently sloping coastal plain approximately a quarter mile inland from Norton

Sound, an embayment of the Bering Sea. The coastal plain consists mainly of unconsolidated

glacial deposits grading into colluvium at the foothills of the mountains to the northeast and worked

into beach deposits along the coast. Loess deposits, along with silty gravel, silt, and peat are

present over much of the plain, ranging in thickness from one to thirty six feet (Sainsbury, 1975).

1.5.1 Geology

Nome and its surroundings have undergone many geological studies in the 20th and 21st centuries

due to Nome’s importance as a gold mining town. Nome’s coastal plain is made of placer deposits

found in alluvial sands along the Snake River, which are mined using the technique commonly

known as “panning for gold.”
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

6

Regionally, the Seward Peninsula comprises rocks from a large section of geologic history

including Precambrian metamorphics and limestone, Paleozoic carbonates, Jurassic volcanics,

and sedimentary clastics from the Cretaceous and Tertiary. Felsic and intermediate composition

granitic intrusions occur throughout the peninsula and basaltic lava flows are found centrally

located overlying large areas of older rock (Sainsbury, 1975). Glaciation played a prominent factor

in the shaping of Alaska’s current landscape in the Quaternary Period, depositing the till of the

coastal plain.

Locally, the sediments of the coastal plain vary greatly in composition and clast size,

predominating in angular schist with minor limestone, but also including finer stream sediments

(silt and sand), well-rounded gravel, and angular slabs of up to two feet (Moffit, 1913). Permafrost

is prevalent in the area, freezing soils and unconsolidated sediments top to bottom, with ice at the

surface in many places preventing or inhibiting infiltration.

1.5.2 Hydrogeology

Due to the local permafrost, groundwater in the Nome area is generally restricted along coastal

areas as permafrost will confine groundwater flow to units above or below the frozen sections

(Figure 1-2). Coastal sections of unfrozen ground may be hydraulically connected to marine water

and therefore wells typically yield poor quality or insufficient quantities of potable water (Dorava,

1995).

Drinking water for Nome is provided by the municipal Moonlight Springs, located less than 3 miles

to the north at the base of Anvil Mountain. A fractured marble aquifer is accessed by drinking

water wells. Its secondary porosity provides variable hydraulic conductivity ranging from 10-2 to

10-8 centimeters per second. Static water levels in three of the spring wells measured 25 – 30 feet

below ground surface (Bristol, 2005), and the wells are completed from approximately 80 to 120

feet. This difference in well depth versus groundwater levels indicates that the aquifer is confined.

An EDRTM report conducted a well search for a 1-mile radius surrounding the facility (Appendix

A). Using additional online resources, such as state and local Geographic Information System

databases, wells were researched to a 4-mile radius of the facility. Based on the USEPA

Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, it was indicated that no PFAS was

detected in a public water system above the USEPA HAs within 20 miles of the facility. The HA is

70 parts per trillion for PFOS and PFOA, individually or combined. PFAS analyses performed in

2016 had method detection limits that were higher than currently achievable. Thus, it is possible

that low concentrations of PFAS were not detected during the UCMR3 but might be detected if

analyzed today.

1.5.3 Hydrology

Nome is approximately a quarter mile from open, navigable marine waters (Figure 1-3). These

waters of the Norton Sound provide wave action which works the sediments of the shore into

beach deposits. Despite its proximity to the shore, the AAOF is not within the 100-year flood plain

(City of Nome, 2010).

The coastal plane on which Nome is built is classified as a freshwater palustrine wetland,

seasonally saturated, and containing woody vegetation, both shrubby and arboreal. This

landscape is dotted with freshwater lakes and ponds, tidal marine estuaries, and crosscut by a

number of rivers. The lakes and ponds are prone to freezing through if shallower than 6 feet

(Dorava, 1995).

The unconsolidated sediments of the plain are believed to be hydrologically connected to marine

water in the water table where permafrost has not precluded access. This marine water renders

local shallow wells unfit for producing potable water.
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

7

The Snake River flows from the west along the southern border of Nome Airport. Typical discharge

for the river from the 1960s to 1991 was 5.3 cubic meters per second.

1.5.4 Climate

The climate in Nome is cool during the summer with temperatures in the 50's and extremely cold

during the winter with sub-zero temperatures. The warmest month of the year is July with an

average maximum temperature of 58.60 degrees Fahrenheit (°F), while the coldest month of the

year is February with an average minimum temperature of -2.30 °F. The annual average

precipitation at Nome is 16.56 Inches. Rainfall is evenly distributed throughout the year. The

wettest month of the year is August with an average rainfall of 3.23 Inches (IDcide, 2018).

1.5.5 Current and Future Land Use

The property is currently under lease by the Alaska ARNG (AKARNG) and is operated as an

AAOF which services aircraft for the AKARNG. The AKARNG has leased the property from the

Alaska Department of Transportation until 2022. Reasonably anticipated future land use is not

expected to change from the current land use described above.
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

5/7/2020

5/7/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:31,680

5/7/2020 ­ Figure 1-1 PM RG 5/7/2020

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_1-1_Nome_Location_Map.mxd

0 0.25 0.5 1

Miles

^_

Legend

Facility Location

Nome AAOF

8
A!

A!

A!

A!

A!

A!

A!

Snake River

Dry Creek

Bourbon Creek

Little Creek

0 1,000 2,000 4,000

Feet

Legend

Facility Location

Water Body

River/Stream

Inferred Groundwater

Flow Direction

Geology

Glacial Till

Wells

A! Unknown Well

Groundwater Features

Figure 1-2

CLIENT

REVISED

SCALE

7/20/2020 MS

LC

7/20/2020

7/20/2020

ARNG

GIS BY

CHK BY

TITLE

PROJECT Preliminary Assessment for PFAS at Nome AAOF, AK

PM RG 7/20/2020

1:24,000 ­ 12420 Milestone Center Drive

Germantown, MD 20876

Base Map: Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS,

USDA, USGS, AeroGRID, IGN, and the GIS User Community

9
Quartz Creek-Frontal

Norton Sound Watershed

Outlet Snake

River Watershed

Snake River

Dry Creek

Bourbon Creek

Little Creek

0 1,000 2,000 4,000

Feet

Legend

Facility Location

Water Body

River/Stream

Surface Water Flow

Direction

Surface Water Features

Figure 1-3

CLIENT

REVISED

SCALE

7/20/2020 MS

LC

7/20/2020

7/20/2020

ARNG

GIS BY

CHK BY

TITLE

PROJECT Preliminary Assessment for PFAS at Nome AAOF, AK

PM RG 7/20/2020

1:24,000 ­ 12420 Milestone Center Drive

Germantown, MD 20876

Base Map: Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS,

USDA, USGS, AeroGRID, IGN, and the GIS User Community

10
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

11

2. Fire Training Areas

No FTAs were identified at Nome AAOF during personnel interviews or the site visit. FTAs are

considered a primary potential release area for PFAS because of the common use of AFFF in

training events. The Nome Airport Fire Department (NAFD) serves as the first responder to

emergencies at Nome AAOF. FTAs associated with the NAFD are discussed in Section 5. The

City of Nome Fire Department also responds to fires at the facility.
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

12

3. Non-Fire Training Areas

In addition to FTAs, the PA evaluated areas where PFAS-containing materials may have been

broadly used, stored, or disposed. This may include buildings with fire suppression systems, paint

booths, AFFF storage areas, and areas of compliance demonstrations. Information on these

features obtained during the PA are included in Appendices A and B. One non-FTA was identified

during the PA. A description is presented below and shown on Figure 3-1. Photographs of the

non-FTA are included in the Photographic Log (Appendix C).

3.1 AAOF Hangar

The AAOF was constructed in 1992, and comprises a hangar, concrete pad, asphalt apron, boiler

room, closed-loop wash water recycling system, and several 100-gallon above-ground storage

tanks. The geographic coordinates are 64°30'58.25"N and 165°25'33.46"W. There are floor drains

within the hangar that drain to a 500-gallon below ground storage tank. The concrete pad outside

has several above and below ground storage tanks ranging from 2,000- to 30,000-gallons which

store sewage, water, and jet fuel. The hangar is not equipped with an AFFF fire suppression

system. Five 5-gallon buckets of Chemguard 3% AFFF concentrate are stored in the hangar. No

AFFF solution has been mixed or sprayed within the hangar. A single Tri-MaxTM 30 emergency

response cart is onsite at the AAOF. The AKARNG interviewees do not recall the Tri-MaxTM cart

being used or discharged at the facility. The cart is sent to Anchorage for hydrostatic testing and

replaced with an upgraded model every few years. Based on the storage of AFFF in 5-gallon

buckets and the Tri-MaxTM cart, the AAOF Hangar is considered a potential PFAS release area.
Nome AAOF

0 200 400 800

Feet

Legend

Potential PFAS Release

Facility Location

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

7/20/2020

7/20/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:4,800

7/20/2020 ­ Figure 3-1 PM RG 7/20/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Area

Base Map: Source: Esri, Maxar, GeoEye, Earthstar

Geographics, CNES/Airbus DS, USDA, USGS,

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_3-1_Nome_Non-Fire_Training_Area.mxd

13
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

14

4. Emergency Response Areas

No instances of emergency response were identified at Nome AAOF during the PA based on

interviews, online research, and the EDRTM report (Appendix A). The primary emergency

response unit for the AAOF is the NAFD, with supplementary support provided by the City of

Nome Fire Department. There has been no need for emergency responses at the AAOF based

on the PA interviews. Interviewees highlighted their history of zero incidents at the facility

(Appendix B).
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

15

5. Adjacent Sources

Three potential off-site PFAS sources were identified adjacent to the Nome AAOF during the PA

interviews (Appendix B) and the EDRTM report (Appendix A). Figure 5-1 shows the location of

the NAFD, NAFD AFFF Spray Area, and the nearby Nome Wastewater Treatment Plant (WWTP).

5.1 Nome Airport Fire Department

The NAFD (64°30'42.11"N, 165°26'7.20"W) is the primary first responder to the AAOF with

supplemental assistance provided by the City of Nome Fire Department. Historically, the NAFD

trained with AFFF twice a year on the sand patch in front of the station. The NAFD personnel also

train at the city of Kenai periodically. The NAFD emergency trucks contain AFFF and the type,

amount, and concentration of AFFF is unknown.

5.2 Nome Airport Fire Department AFFF Spray Area

According to interviews with the Assistant Fire Chief, the NAFD trains twice a year with AFFF in

the adjacent gravel patch to the north (64°30'46.16"N, 165°26'7.54"W). The type, amount, and

concentration of AFFF used by the NAFD during its training sessions are unknown.

5.3 Nome WWTP

The Nome WWTP is located 1 mile south of the AAOF (64°30'12.12"N, 165°26'34.24"W) on

Submarine Beach Road, outside the airport boundary. The WWTP is currently active, but is

downgradient of the site and therefore poses no risk of cross contamination. Although no use of

AFFF has been identified here, WWTPs can often be sources of PFAS.
Nome Waste Water Treatment Plant

Dry Creek

Snake River

Nome Airport Fire Department

Nome Airport Fire Department AFFF Spray Area

0 350 700 1,400

Feet

Legend

Potential PFAS Release

Facility Location

Water Body

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

7/20/2020

7/20/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:8,400

7/20/2020 ­ Figure 5-1 PM RG 7/20/2020

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, Maxar, GeoEye, Earthstar

Geographics, CNES/Airbus DS, USDA, USGS,

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_5-1_Nome_Adjacent_Sources.mxd

16
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

17

6. Preliminary Conceptual Site Model

Based on the PA findings, one non-FTA was identified where PFAS may have been incidentally

spilled or discharged to the ground surface: AOI 1 AAOF Hangar. As such, this area is determined

to be an AOI and may be a potential PFAS source area. The AOI location is shown in Figure 6-

1.

The following section describes the CSM components and the specific preliminary CSM

developed for AOI 1. The CSM identifies the three components necessary for a potentially

complete exposure pathway: (1) source, (2) pathway, (3) receptor. If any of these elements are

missing, the pathway is considered incomplete. The preliminary CSM for AOI 1 is shown in Figure

6-2.

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 (National Ground Water

Association, 2018). Receptors for the facility include site workers, construction workers, and

recreational users. The preliminary CSM for the facility indicates which specific receptors could

potentially be exposed to PFAS.

6.1 AOI 1: AAOF Hangar

AOI 1 is the AAOF Hangar, which contains the storage of five 5-gallon buckets of Chemguard 3%

AFFF concentrate and a single Tri-MaxTM 30 emergency response cart. Although AFFF solution

is not mixed or sprayed within the hangar, it is possible that leakages may have occurred from

the storage of AFFF.

Potential AFFF releases within the hangar are most likely directed to the floor drains within the

hangar. The floor drains lead to a 500-gallon below ground storage tank, and the hangar has a

closed-loop wash water recycling system. Thus, receptors are unlikely exposed to PFAS through

this exposure pathway. However, potential AFFF releases outside the hangar may have occurred

on paved and unpaved surfaces. PFAS are water soluble and can migrate readily from soil to

groundwater via leaching. Drinking water for Nome AAOF is provided by the municipal Moonlight

Springs, located less than 3 miles to the north at the base of Anvil Mountain. Static water levels

in three of the spring wells measured 25 to 30 feet below ground surface (Bristol, 2005). Based

on the inferred southern groundwater flow direction, the spring wells are located upgradient of the

facility and are unlikely to be impacted by PFAS attributable to the facility. The shallow

groundwater ingestion pathway is incomplete for site workers and residents that receive drinking

water from the spring wells. Based on the static water levels of the three spring wells, construction

workers at the facility are unlikely to encounter shallow groundwater even under trenching

scenarios (typically up to 15 feet below ground surface); therefore, the shallow groundwater 

ingestion pathway is incomplete for construction workers.

If AFFF releases occurred outside the hangar on either paved or unpaved surfaces, grounddisturbing activities in these areas may result in potential exposure to surface soils via ingestion

and inhalation of dust particles for site workers and construction workers. Potential AFFF releases

to unpaved surface soils could have migrated to the subsurface soil via leaching. Potential AFFF

releases to the paved surfaces could have also infiltrated the subsurface via cracks in the

pavement or joints between areas that are paved with different materials. Ground-disturbing

activities in the subsurface soil may result in potential exposure via ingestion for construction

workers working under trenching or other subsurface conditions.

Nome AAOF is approximately a quarter mile from open, navigable marine waters and a tributary

of Snake River flows adjacent to the western border of the facility. It is possible that PFAS migrated
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

18

to the nearby surface waters. Recreational users of these surface waters may be potentially

exposed to PFAS via the ingestion of PFAS-impacted surface water and/or sediment. Additionally,

the unconsolidated sediments of the plain are believed to be hydrologically connected to marine

water in the water table where permafrost has not precluded access. Therefore, the shallow

groundwater ingestion pathway for recreational users is considered potentially complete. The

preliminary CSM for AOI 1 is shown on Figure 6-2.
A!

A!

A!

A!

A!

A!

A!

A!

A!

Ingraham Creek

B

Dry Creek

ourbon Creek

An vil Cre ek

Little Creek

Snake River

Quartz Creek-Frontal

Norton Sound Watershed

Outlet Snake

River Watershed

Nome AAOF

Nome Airport Fire Department

Nome Airport Fire Department AFFF Spray Area

AOI 1

0 0.25 0.5 1

Miles

Legend

Area of Interest

Potential PFAS Release

Facility Location

Water Body

River/Stream

Surface Water Flow Direction

Inferred Groundwater Flow Direction

A! Unknown Well

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

7/20/2020

7/20/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:31,680

7/20/2020 ­ Figure 6-1 PM RG 7/20/2020

12420 Milestone Center Drive

Germantown, MD 20876

Area of Interest

Base Map: Source: Esri, Maxar, GeoEye, Earthstar

Geographics, CNES/Airbus DS, USDA, USGS,

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_6-1_Nome_AOI.mxd

19
Media

SOURCE PATHWAY RECEPTOR

AOI 1

PFOS/ 

PFOA in 

Surface Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ 

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release 

Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site 

Worker

Construction 

Worker Resident1 Recreational User1

LEGEND

/ /

/

Figure 6-2

Preliminary Conceptual Site Model

AOI 1 AAOF Hangar

Potential Leaks 

from Storage of 

AFFF 

/ /

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ / / /

/ /

/

/

/ /

/ /

/ /

NOTES

1. The resident and recreational users refer to 

off-site receptors.

Site 

Worker

Construction 

Worker Resident1 Recreational 

User1

20
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

21

7. Conclusions

This report presents a summary of available information gathered during the PA on PFAS-related

activities at Nome AAOF. The PA findings are based on the information presented in Appendix A

and Appendix B.

7.1 Findings

One AOI related to a potential PFAS release was identified at Nome AAOF during the PA. The

AOI is shown on Figure 7-1 and described in Table 7-1 below:

Table 7-1: AOIs at Nome AAOF

Area of Interest Name Used by Potential Release Date

AOI 1 AAOF Hangar AKARNG 1992 to present

Based on potential PFAS releases at AOI 1, there is potential for exposure to PFAS contamination

in media at or near the facility. The preliminary CSM for AOI 1 is shown on Figure 6-2, which

presents the potential receptors and media impacted.

7.2 Uncertainties

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

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

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

records were not typically kept by the facility or available during the PA on the use of PFAS in

training, firefighting, other non-traditional activities, or on its disposition.

The conclusions of this PA are based on all available information, including: previous

environmental reports, EDRsTM, observations made during the VSI, and interviews. Interviews of

personnel with direct knowledge of a facility generally provided the most useful insights regarding

a facility's historical and current PFAS-containing materials. Sometimes the provided information

is vague or conflicts with other sources. Gathered information has a degree of uncertainty due to

the absence of written documentation, the limited number of personnel with direct knowledge due

to staffing changes, the time passed since PFAS was first used (early 1970s), and a reliance on

personal recollection. Inaccuracies may arise in potential PFAS release locations, dates of

release, volume of releases, and the concentration of AFFF used. There is also a possibility the

PA has missed a potential source of PFAS, as the science of how PFAS may enter the

environment continually evolves.

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

storage of PFAS were reviewed, retired and current personnel were interviewed, multiple persons

were interviewed for the same potential source area, and the facility was visually inspected. Table

7-2 summarizes the uncertainties associated with the PA.
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

22

Table 7-2: Summary of Uncertainties

Location Source of Uncertainty

AOI 1: AAOF Hangar

There is uncertainty and a lack of documentation

regarding the use, leakage, and/ or nozzle testing

of the Tri-MaxTM carts. It is also unknown if the

stored AFFF concentrate may have leaked.

NAFD

The amount of AFFF stored in firetruck tanks and

as concentrate in 5-gallon buckets is unknown.

No or limited information was available on the

type, amount, and concentration of AFFF used

during the semiannual fire training at the NAFD.

7.3 Potential Future Actions

Interviews and records (covering 1980s to present) indicate that ARNG activities may have

resulted in a potential PFAS release at the one AOI identified during the PA. Based on the

preliminary CSM developed for the AOI, there is potential for receptors to be exposed to PFAS

contamination in media at or near the facility. Table 7-3 summarizes the rationale used to

determine if the AOI should be considered for further investigation under the CERCLA process

and undergo an SI.

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

potential migration of PFAS contamination off the facility, and the availability of resources.

Table 7-3: PA Findings Summary

Area of Interest AOI Location Rationale Potential Future Action

AOI 1: AAOF

Hangar

64°30'58.25"N

165°25'33.46"W

Storage of AFFF in five 5-

gallon buckets and a

single Tri-MaxTM 30 cart

Proceed to an SI, focus

on soil, groundwater,

surface water, sediment
Nome AAOF

Nome Airport Fire Department

Nome Airport Fire Department AFFF Spray Area

AOI 1

0 200 400 800

Feet

Legend

Area of Interest

Potential PFAS Release

Facility Location

River/Stream

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

LC

7/20/2020

7/20/2020

NOTES Preliminary Assessment for PFAS at Nome AAOF, AK

1:4,800

7/20/2020 ­ Figure 7-1 PM RG 7/20/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, Maxar, GeoEye, Earthstar

Geographics, CNES/Airbus DS, USDA, USGS,

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\AK\Nome_Figures\Nome_PFAS_PA_Figures\Fig_7-1_Nome_Summary.mxd

23
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

24

8. References

Bristol Environmental & Engineering Services Corp. (Bristol). 2005. Technical Memorandum:

Moonlight Wells Protection Area, Nome, Alaska. BEESC Project No. 25071.

City of Nome. 2010. 100 Year Floodplain, City of Nome, Alaska. Published May 3rd, 2010.

Dorava, J. M. 1995. Overview of Environmental and Hydrogeologic Conditions at Nome, Alaska.

USGS Open File Report 95-178.

Dorava, J.M. 1995. Hydraulic characteristics near streamside structures along the Kenai River,

Alaska. U.S. Geological Survey Water-Resources Investigations Report 95-4226, 41 p.

Environmental Data Report (EDR). 2018. The EDR Radius Maptm Report with Geocheck®, target

address 227 Airport Road, Nome, Alaska 99762. Inquiry Number: 5509593.2s December 12,

2018.

Gerdine, T. G.; Oliver, R. B.; Hill, W. R. 1913. Topographic Map of Nome Quadrangle, Alaska.

House Document No. 1428, 62nd Congress, 3rd session.

Google Earth. 2018. Google Earth Imagery. Approximate Coordinates 64°30'58.25"N,

165°25'33.46"W.

IDcide. 2019. Nome Climate Data. https://www.idcide.com/weather/ak/nome.htm. Accessed

January 2019.

Moffit, F. H. 1913. Geology of the Nome and Grand Central Quadrangles. USGS Bulletin 533,

Dept. of the Interior.

National Ground Water Association, 2018. Groundwater and PFAS: State of Knowledge and

Practice. January.

Sainsbury, C. L. 1975. Geology, Ore Deposits, and Mineral Potential of the Seward Peninsula,

Alaska. Open File Report, Bureau of Mines, US Dept. of the Interior.

U.S. Fish and Wildlife Service. 2018. National Wetlands Inventory. https://www.fws.gov/wetlands/

Accessed December 2018.

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

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

Wilson, F. H.; Hults, C. P.; Mull, C. G.; Karl, S. M. 2015a. Geologic Map of Alaska. USGS Scientific

Investigations Map 3340, Sheets 1 & 2.

Wilson, F. H.; Hults, C. P.; Mull, C. G.; Karl, S. M. 2015b. Geologic Map of Alaska. USGS Scientific

Investigations Map 3340, Pamphlet to Accompany.
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix A

Data Resources
PFAS Preliminary Assessment Report 

Nome Army Air Operating Facility, Alaska 

Data Resources will be provided separately on CD. Data Resources for Nome AAOF include: 

2018 EDRTM Report 

• 2018 The EDR Radius MapTM Report with GeoCheck®

; Aerial Photo Decade Package; &

Certified Sanborn Map Report; Target Property Nome AAOF, 227 Airport Road, Nome,

Alaska 99762. Inquiry Number: 5509593.2s 

Final Site SPCC

• 2008 Nome AAOF Final Site Spill Prevention, Control, and Countermeasure Plan

Lease 

• 1988 Nome AAOF Lease Agreement ADA-70299. Alaska Department of Transportation
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix B.1

Interview Records



PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix B.2

Visual Site Inspection Checklists



PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix B.3

Conceptual Site Model Information
Preliminary Assessment – Conceptual Site Model Information

Site Name: Nome AAOF

Why has this location been identified as a site?

Historically held TRI-MAX 30 AFFF crash carts

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

There is a fire department that trains with AFFF half a mile to the south.

Training Events

Have any training events with AFFF occurred at this site? No.

If so, how often?

How much material was used? Is it documented?

Identify Potential Pathways: Do we have enough information to fully understand over land 

surface water flow, groundwater flow, and geological formations on and around the facility? Any direct 

pathways to larger water bodies?

Surface Water:

Surface water flow direction? South into Norton Sound, an embayment of the Bering Sea.

Average rainfall? 16.56 inches

Any flooding during rainy season? Coastal floodplain sometimes floods

Direct or indirect pathway to ditches? Yes

Direct or indirect pathway to larger bodies of water? Indirect pathway to Norton Sound.

Does surface water pond any place on site? No

Any impoundment areas or retention ponds? There are natural lakes nearby.

Any NPDES location points near the site? N/A

How does surface water drain on and around the flight line? South 
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction? South

Depth to groundwater? Approx. 30 Feet. (Coastal tides and permafrost affect the depth)

Uses (agricultural, drinking water, irrigation)?

Any groundwater treatment systems? No

Any groundwater monitoring well locations near the site? Maybe

Is groundwater used for drinking water? No

Are there drinking water supply wells on installation? No

Do they serve off-post populations? No

Are there off-post drinking water wells downgradient . No

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present? No, but there is one south of the site. 

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

Do we understand the fate of sludge waste?

Is surface water from potential contaminated sites treated?

Equipment Rinse Water

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

Only the airport has fire fighting equipment that is tested. 

2. Are nozzles tested? How often are nozzles tested? Where are nozzles tested? Are nozzles cleaned after 

use? Where does the rinse water flow after cleaning nozzles?

TRI-MAX carts are not tested here.

3. Other?

Identify Potential Receptors:

Site Worker 

Construction Worker 

Recreational User

Residential 

Child 
Preliminary Assessment – Conceptual Site Model Information

Ecological

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

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur?
PFAS Preliminary Assessment Report

Nome Army Air Operating Facility, Alaska

Appendix C

Photographic Log
Preliminary Assessment Report

Nome AAOF

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Nome AAOF Nome, Alaska

Photograph No. 1

Description:

TRI-MAX stored at the Nome 

AAOF, located in the west 

corner of the hangar.

Date Taken:

31 August 2018

Photograph No. 2

Description:

Five 5-gallon buckets of AFFF 

stored next to the flame 

cabinet in the Nome AAOF, 

near the south corner of the 

hangar.

Date Taken:

31 August 2018
Preliminary Assessment Report

Nome AAOF

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Nome AAOF Nome, Alaska

Photograph No. 3

Description:

Outside front of the Nome 

AAOF, looking east.

Date Taken:

31 August 2018

Photograph No. 4

Description: 

Outside front of the Nome 

AAOF, looking southeast. 

Date Taken:

31 August 2018
Preliminary Assessment Report

Nome AAOF

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Nome AAOF Nome, Alaska

Photograph No. 5

Description:

Fire hydrant and well near the 

Nome Airport Fire 

Department, about 200 yards 

south of the Fire Department’s

AFFF training area, looking 

west northwest.

Date Taken:

31 August 2018

Photograph No. 6

Description: 

Noma Airport Fire 

Department (about 200 -300 

yards from the Fire 

Department’s AFFF training

area), looking south. 

Date Taken:

31 August 2018
Preliminary Assessment Report

Nome AAOF

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Nome AAOF Nome, Alaska

Photograph No. 7

Description: 

Complete view of the Nome 

Airport Fire Department, 

looking south southwest. 

AFFF training area is out of 

frame 90 degrees to the right.

Date Taken:

31 August 2018

Photograph No. 8

Description:

Nome Airport Fire 

Departmnet AFFF training 

area (piles of sand/gravel on 

the other side of the fence), 

looking north from the fire 

station.

Date Taken:

31 August 2018
Preliminary Assessment Report

Nome AAOF

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Nome AAOF Nome, Alaska

Photograph No. 9

Description:

Nome Airport Fire 

Department’s AFFF training

area (piles of sand/gravel on 

the other side of the fence), 

looking west from a hilltop 

north of the fire station.

Date Taken:

31 August 2018