FINAL

Site Inspection Report

State Military Reservation

Concord, New Hampshire

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

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

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

ARNG Installations, Nationwide

August 2023

Prepared for:

Army National Guard Headquarters 

111 S. George Mason Drive 

Arlington, VA 22204

UNCLASSIFIED
This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

TABLE OF CONTENTS

Page

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

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

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

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

EXECUTIVE SUMMARY ...................................................................................................... ES-1

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

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

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

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

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

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

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

2.2.2 Hydrogeology ........................................................................... 2-3

2.2.3 Hydrology ................................................................................. 2-4

2.2.4 Climate ...................................................................................... 2-5

2.2.5 Current and Future Land Use .................................................... 2-5

2.2.6 Sensitive Habitat and Threatened/Endangered Species ............ 2-5

2.3 History of PFAS use ................................................................................ 2-6

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

3.1 AOI 1 – Former Army Aviation Support Facility ................................... 3-1

3.2 AOI 2 – Former Camp Labonte ............................................................... 3-5

3.3 Adjacent Sources ..................................................................................... 3-6

3.3.1 Electropac Worldwide Inc. Site (former Vishay Sprague Facility)

 .................................................................................................. 3-6

3.3.2 The Richard M. Flynn Fire Academy ....................................... 3-6

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

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

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

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

4.4 Analytical Approach ................................................................................ 4-1
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

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.. 5-2

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

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

5.4 Temporary Well Installation and Groundwater Grab Sampling.............. 5-4

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

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

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

5.8 Laboratory Analytical Methods............................................................... 5-6

5.9 Deviations from SI 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 Analytical Results.................................... 6-3

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

6.4 AOI 2 ....................................................................................................... 6-3

6.4.1 AOI 2 Soil Analytical Results................................................... 6-4

6.4.2 AOI 2 Groundwater Analytical Results.................................... 6-4

6.4.3 Conclusions............................................................................... 6-4

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

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

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

7.1.2 AOI 2 ........................................................................................ 7-2

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

7.2.1 AOI 1 – Former AASF ............................................................. 7-2

7.2.2 AOI 2 – Former Camp LaBonte ............................................... 7-3

7.3 Surface Water and Sediment Exposure Pathway..................................... 7-3

7.3.1 AOI 1 – Former AASF ............................................................. 7-3
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

7.3.1 AOI 2 – Former Camp LaBonte ............................................... 7-3

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

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

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

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

LIST OF APPENDICES

Appendix A. Data Usability Assessment and Validation Reports

Appendix B. Field Documentation

B1. Log of Daily Notice of Field Activities

B2. Sampling Forms 

B3. Survey Data

B4. Investigation-Derived Waste Placement Locations

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
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

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, June 2022

Figure 3-1 Areas of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOS Detections in Soil

Figure 6-2 PFOA Detections in Soil

Figure 6-3 PFBS Detections in Soil

Figure 6-4 PFHxS Detections in Soil

Figure 6-5 PFNA Detections in Soil

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

Figure 6-7 PFHxS and PFNA Detections in Groundwater

Figure 7-1 Conceptual Site Model, AOI 1 

Figure 7-2 Conceptual Site Model, AOI 2
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

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, State Military Reservation, Concord, New Hampshire, Site 

Inspection Report

Table 5-2 Soil Boring Depths and Temporary Well Screen Intervals, State Military 

Reservation, Concord, New Hampshire, Site Inspection Report

Table 5-3 Groundwater Elevation, State Military Reservation, Concord, New Hampshire, 

Site Inspection Report

Table 6-1 Screening Levels (Soil and Groundwater)

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

Report, State Military Reservation

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

Site Inspection Report, State Military Reservation

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

Inspection Report, State Military Reservation

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

Report, State Military Reservation

Table 8-1 Summary of Site Inspection Findings and Recommendations
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

LIST OF ACRONYMS AND ABBREVIATIONS

°C Degrees Celsius

°F Degrees Fahrenheit

% 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

bgs Below ground surface

btoc Below top of casing

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

COC Chain-of-custody

CSM Conceptual site model

CSMS Combined Support Maintenance Shop

DA Department of the Army

DoD Department of Defense

DPT Direct-push technology

DQI Data quality indicator

DQO Data quality objective

DUA Data Usability Assessment

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

EDR Environmental Data Resources, Inc.

EIS Extraction internal standards

ELAP Environmental Laboratory Accreditation Program

EM Engineer Manual

EB Equipment Blank 

FB Field blank

FedEx Federal Express

ft Foot (feet)

GAC Granular activated carbon

GPR Ground-penetrating radar

HDPE High-density polyethylene

HFPO-DA Hexafluoropropylene oxide dimer acid

HQ Hazard Quotient
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

IDW Investigation-derived waste

ITRC Interstate Technology Regulatory Council

LC/MS/MS Liquid chromatography tandem mass spectrometry

LCS Laboratory control sample 

LCSD Laboratory control sample duplicate

LOQ Limit of quantification

MCL Maximum Contaminant Level

MIL-SPEC military specification

MS Matrix spike

MSD Matrix spike duplicate

NELAP National Environmental Laboratory Accreditation Program 

ng/L Nanogram(s) per liter

NHDES New Hampshire Department of Environmental Services

No. Number

OSD Office of the Secretary of Defense

OWS Oil-water separator 

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

ppt parts per trillion

PVC polyvinyl chloride

QA Quality assurance

QAPP Quality Assurance Project Plan

QC Quality control

QSM Quality Systems Manual

RI Remedial investigation 

RPD Relative percent difference

SI Site Inspection

SL Screening level

SMR State Military Reservation

SOP Standard Operating Procedure

TCRA Time Critical Removal Action
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

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

TOC Total organic carbon

TPP Technical Project Planning

UFP Uniform Federal Policy 

USACE U.S. Army Corps of Engineers

USAEHA U.S. Army Environmental Hygiene Agency

USEPA U.S. Environmental Protection Agency

Wood Wood Environment & Infrastructure Solutions, Inc.

WSP WSP USA Environment & Infrastructure Inc.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC ES-1

EXECUTIVE SUMMARY

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

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

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

memorandum regarding Investigating Per- and Polyfluoroalkyl Substances within the 

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

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

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

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

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1

. These compounds are 

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

Screening Levels (SLs) are provided below in Table ES-1.

The PA identified two Areas of Interest (AOIs) where PFAS-containing materials may have been

used, stored, disposed, or released historically (see Table ES-2 for AOI locations). The objective 

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

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 SLs for the 

relevant compounds. This SI was completed at the State Military Reservation (SMR) in Concord, 

New Hampshire and determined that further investigation is warranted for AOI 1: Former Army 

Aviation Support Facility (AASF). SMR will also be referred to as the “Facility” throughout this 

document. 

The Facility, operated by New Hampshire ARNG (NHARNG), encompasses approximately 50

acres in Concord, New Hampshire. The SMR is located at 1 Minuteman Way, Concord, New 

Hampshire. The area surrounding the SMR includes residential and commercial properties to the 

north, the Concord Municipal Airport to the south, commercial and light industrial properties to 

the east, and additional residential neighborhoods to the west. Conservation/Public Lands are 

located approximately 0.8 miles to the southeast, adjoining the Soucook River. The SMR 

currently serves as the headquarters for the NHARNG.

The PA identified two AOIs for investigation during the SI phase. SI sampling results from the 

two AOIs were compared to OSD SLs. Table ES-2 summarizes the SI results for each AOI. 

Based on the results of this SI, further evaluation under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) is warranted in a Remedial Investigation 

(RI) for AOI 1, and no further action is warranted for AOI 2.

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.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC ES-2 

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

Analyte2

Residential

(Soil)

(μg/kg)1 

(0-2 feet bgs)

Industrial / Commercial

Composite Worker

(Soil)

(μg/kg)1 

(2-15 feet 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. July 2022. Risk Based Screening Levels in Groundwater and 

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

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

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

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

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

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

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

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

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

PFAS.

Abbreviations: 

μg/kg = microgram(s) per kilogram

bgs = below ground surface

ng/L = nanogram(s) per liter

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

AOI

Potential Release 

Area

Soil – 

Source Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary Future Action

1 Former AASF Proceed to RI

2 Former Camp LaBonte Not applicable No further action

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Project No. 634250383 1-1

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 the six 

compounds presented in the memorandum regarding Investigating Per- and Polyfluoroalkyl 

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

2022) from the Office of the Secretary of Defense (OSD) dated 6 July 2022. The six compounds 

listed in the OSD memorandum are referred to as “relevant compounds” throughout this 

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

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

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1. The ARNG performed 

this SI at the State Military Reservation (SMR) in Concord, New Hampshire. The SMR is also

referred to as the “Facility” throughout this report.

The SI project elements were performed in accordance with the Comprehensive

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

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

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

compliance with U.S. Department of Army (DA) requirements and guidance for field 

investigations.

1.2 SITE INSPECTION PURPOSE

A PA was performed at the SMR (AECOM Technical Services, Inc. [AECOM] 2019) that 

identified two Areas of Interest (AOIs) where PFAS-containing materials may have been used, 

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

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

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

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

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

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

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

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

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

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

in the absence of other PFAS.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 1-2

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-1

2. FACILITY BACKGROUND

2.1 FACILITY LOCATION AND DESCRIPTION

The SMR is located at 1 Minuteman Way in Concord, Merrimack County, New Hampshire, 

approximately 0.5 miles north-northwest from the Concord Municipal Airport terminal (Figure 

2-1). The Facility property occupies approximately 50 acres on the east side of the Merrimack 

River, near the southeastern city limits, east of Interstate 93, and south of Interstate 393. The 

approximate center of the property is located at geographic coordinates 43°12'35.89"N; 

71°30'43.74" W at 363 feet above mean sea level (amsl, AECOM, 2019).

The property was originally known in the late 1800s as the State Military Campground for the 

New Hampshire State Militia; additionally, it was known in 1886 as "Camp Langdon.” In 1885, 

the State of New Hampshire entered into a 99-year lease with the City of Concord for use and 

development of the grounds on which the National Guard trained. Additional parcels of the 

property were deeded or leased to the City of Concord in 1911, 1937, 1942, and 1954, and the 

State of New Hampshire formally acquired the property in 1959 (The Louis Berger Group, Inc., 

2006; AECOM, 2019). The property is currently owned by the State of New Hampshire and is 

used for state operations of the NHARNG. The SMR currently serves as the headquarters for the 

NHARNG. Facilities at the SMR include a warehouse, a maintenance shop, Joint Force Offices, 

the Concord Armory, and a Civil Support Teams building (Tighe & Bond, 2018; AECOM 2019).

An Army Aviation Support Facility (AASF) was located at the SMR in Building K from the 

1960s to 2004. Typical activities conducted at the AASF included maintenance and repair of 

fixed-wing and rotary aircraft, storage and dispensing of fuel, and mechanical servicing and 

cleaning of helicopter interiors and exteriors (NHARNG, 1996; AECOM, 2019). The initial 

building for the AASF hangar (later known as the Ground Power Annex) was designed in 1959 

and constructed between 1960 and 1961. Aerial photographs show that the initial building was 

present in 1960, 1967, and 1969. According to interviews with former AASF personnel, Bell 

helicopters and TH-55 helicopters were present at the SMR in the 1960s. In 1974, an addition to 

the original building was constructed to create Building K (The Louis Berger Group, Inc., 2006; 

AECOM, 2019). AASF operations continued at Building K until 2004, at which time operations 

were moved to a new AASF located at 26 Regional Drive, 0.5 mile to the east. The former 

Building K was incorporated into the current Joint Force Headquarters building.

The SMR is completely secured by a 6-foot fence, which consists of chain-link fence secured by 

a brick column and ornamental iron fencing barrier. Access to the Facility is through monitored 

gates at the perimeter of the Facility on Pembroke Road and on Minuteman Way via Regional 

Drive.

2.2 FACILITY ENVIRONMENTAL SETTING

The SMR is located within the Merrimack Valley in southern New Hampshire, within the 

Eastern New England Upland Physiographic Province of the Appalachian Highlands. The New 

England Upland consists of a maturely dissected plateau with narrow valleys, and the entire area 

was greatly modified by glaciation. The City of Concord developed along the Merrimack River 

and lies fully within the Merrimack River watershed (AECOM, 2019). The City of Concord has 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-2

a population of approximately 43,000 people, according to the 2017 US Census (US Census, 

2018; AECOM, 2019).

The following sections include information on soil, hydrogeology, hydrology, climate, and 

current and future land use. The topography at the Facility is shown on Figure 2-2. The regional 

geology and groundwater features are shown on Figure 2-3. The regional surface water features 

are shown on Figure 2-4. Groundwater elevations and contours are presented on Figure 2-5.

2.2.1 Geology

Regional geology consists of unconsolidated glacial material overlying igneous and metamorphic 

rocks that were deposited during the Wisconsin stage of glaciation, of the Pleistocene Epoch 

during the Quaternary Period. The weight of the ice caused differential depressions of the land 

surface during the Pleistocene Epoch. The southeastward flow of glacial ice scoured the rock 

surface, and as the ice melted, it deposited a thick blanket of glacial till in many areas. Meltwater 

streams deposited a variety of ice-contact sands and gravels upon portions of the till sheet (U.S. 

Army Environmental Hygiene Agency [USAEHA], 1993). Geologic features near the Facility 

are shown on Figure 2-3.

The unconsolidated material, which is mainly ground moraine, was originally subglacial till, that 

was left scattered over the ground after the ice melted. A ground moraine consists of scattered 

boulders combined with cobbles, gravel, pebbles, sand, silt, and clay, with some areas of ice

contact stratified drift. This stratified drift was derived from englacial and subglacial meltwater 

streams that also carried gravel, sand, silt, and clay (USAEHA, 1993; Stone & Webster 

Environmental Technology & Services, 1998; AECOM, 2019).

Numerous environmental investigations have been conducted nearby the subject property for the 

Former Vishay Sprague Site, located at 70 Pembroke Road (approximately 0.4 miles east of the 

subject property). These investigations have indicated that the local geology is underlain by up to 

about five feet of fill overlying a relatively thick sequence (about 160 to 200 feet [ft]) of glacial 

deposits overlying granitic bedrock. Bedrock in the vicinity consists predominantly of 

moderately fractured, medium-grained, two-mica granite. The bedrock surface generally slopes 

downward from west to east (GZA GeoEnvironmental, Inc., 2010; AECOM, 2019).

In the immediate vicinity of the Facility, overlying bedrock is an approximately 25- to 50-footthick lacustrine deposit consisting of very dense, thinly interbedded silt, silt and clay, and fine 

sand. This stratum is overlain by an approximately 50- to 60-foot-thick section of glacial till 

consisting of very dense, fine to medium sand with clayey silt and gravel. Lacustrine sediments 

similar to those underlying the glacial till overlie the glacial till with thicknesses ranging from 

about 15 to 40 ft. Outwash deposits consisting predominantly of fine sand top the overburden 

stratigraphy with a thickness ranging from about 50 to 85 ft (GZA GeoEnvironmental, Inc., 

2010; AECOM, 2019).

During the SI, borings were advanced between 5 and 60 ft below ground surface (bgs). The soil 

was classified predominately as sand with varying percentages of fines and gravel. Samples for 

grain size analyses were collected at the two AOIs at locations AOI01-04 and AOI02-02. The 

results indicate that the soil samples are comprised primarily of sand (65.4 percent [%] to 64.7%, 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-3

respectively) and fines (29.2% and 29.1 %, respectively) with some gravel (5.4% and 6.2%, 

respectively). These results and Facility observations are consistent with the reported 

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

results are presented in Appendix F.

2.2.2 Hydrogeology

The overburden hydrogeology in the area generally consists of a dual hydrogeologic unit system 

separated by the glacial till stratum. The upper unit consists of the saturated lacustrine and/or 

outwash deposits overlying glacial till, whereas the lower unit consists of the lacustrine deposits 

underlying the glacial till. Hydraulic communication between the upper and lower units is likely, 

with the glacial till forming only a partial aquitard. The upper overburden unit is unconfined, 

with the resultant groundwater surface at a pressure equal to atmospheric. The lower unit is 

partially confined by the glacial till, with the resultant groundwater surface at a pressure greater 

than atmospheric. Groundwater elevations within the upper unit are typically observed to be 

about 10 to 15 feet higher than those of the lower unit, indicating a loss in total head through the 

glacial till aquitard, and a vertically downward component of groundwater flow (GZA 

GeoEnvironmental, Inc., 2010; AECOM, 2019).

A site investigation was conducted in 1997 at the SMR to evaluate the presence or absence of 

metals and volatile organic compounds in soil and groundwater associated with several potential 

contamination areas (former Drywells A, B, and C; former UST and Pumphouse R; and 

Upgradient areas of concern). The site investigation report stated that all detected constituents 

were below applicable screening levels and recommended no further action. During the SI, 

groundwater was encountered from approximately 41 feet to 51 feet (Stone & Webster 

Environmental Technology & Services, 1998; AECOM, 2019). Based on investigations at the 

nearby Former Vishay Sprague Site, groundwater in the vicinity is expected to be 30 to 50 feet 

below ground surface (bgs) (GZA GeoEnvironmental, Inc., 2018). Both investigations indicated 

that overburden groundwater flow was to the west-southwest, toward the Merrimack River, 

which is located 0.8 miles to the west/southwest. Groundwater features in the vicinity of the 

Facility are shown on Figure 2-3.

Static groundwater elevations measured in June 2022 during the SI ranged from 40.8 to 54.0 feet 

bgs. Groundwater elevation contours from the SI are presented on Figure 2-5 and indicate the 

groundwater flow direction at the SMR is primarily to the west/southwest.

The Environmental Data Resources, Inc. (EDR) Radius Map report did not identify any public 

supply wells at the SMR or within a 1-mile radius (EDR, 2019; AECOM, 2019). One domestic 

well and one commercial well were identified in the EDR Radius Map approximately 0.5 miles 

to the east, and side gradient of the Facility. Additionally, four wells were identified on the 

Facility and according to ARNG personnel, the wells were used for a geothermal system that is 

no longer in use, however, have not been officially decommissioned. Locations of the wells are 

shown on Figure 2-3. 

Water at the SMR is supplied by municipal water from the City of Concord. Third Unregulated 

Contaminant Monitoring Rule data were reviewed as part of the PA. PFAS were non-detect for 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-4

the Concord Water Department treatment plant, which is located 4.3 miles northwest of the 

Facility, on the west side of the Merrimack River (USEPA, 2017; AECOM, 2019). 

The primary water source for the Concord community is Penacook Lake, located 4 miles

northwest of the Facility, on the west side of the Merrimack River. During dry periods, the lake 

is supplemented with water from Contoocook River Pump Station, which is located further 

northwest of Penacook Lake. Additionally, a groundwater well field adjacent to the Soucook 

River in Pembroke is maintained as an emergency water source (City of Concord, 2019c). The 

Pembroke well field is approximately 1.6 miles southeast of the Facility, on the opposite side of 

the Soucook River. None of these drinking water resources are anticipated to be hydraulically 

downgradient from the Facility.

2.2.3 Hydrology

The SMR is located within the central portion of the Merrimack River watershed, which 

stretches from central New Hampshire into Northeastern Massachusetts. The nearest major 

surface water bodies are the Merrimack River, located approximately 0.8 miles to the west of the 

Facility, and the Soucook River, located approximately 1 mile to the southeast. The Merrimack 

River is popular for recreational use, including boating, canoeing, rowing, and fishing (New 

Hampshire Department of Environmental Services [NHDES], 2017; AECOM, 2019). Based on 

the depth of the Merrimack River (5 to 40 ft or more; Concord Monitor, 2013; AECOM, 2019) 

and the depth to groundwater in the area (estimated to be 30 to 50 ft bgs), it is possible that 

groundwater to surface water discharge may occur at points along the river downgradient of the 

site. No wetlands exist within the vicinity of the Facility. Surface water features in the vicinity of 

the Facility are shown on Figure 2-4.

The topography of the Facility and in the surrounding area is relatively flat. Much of the Facility 

is paved with either asphalt or concrete, with unpaved grassy areas along the boundaries of the 

Facility. Surface water in the general vicinity flows westerly towards the Merrimack River. 

Stormwater at the SMR is currently managed utilizing a series of drainage basins and trenches 

for infiltration, which allow the majority of stormwater to infiltrate into the ground onsite. The 

Combined Support Maintenance Shop (CSMS) and unit vehicle parking area are outfitted with 

oil-water separator (OWS)-equipped catch basin drains that precede discharge to the Concord 

municipal storm drain system on Airport Road. The drainage within the storm drain system from 

Airport Road flows westward down Loudon Road and then to the Merrimack River, which is 

approximately 0.5 miles to the west of the SMR. Storm drains in the northeast corner of the SMR 

are also connected to the Concord municipal storm drainage system. In the northern portion of 

the Facility, stormwater runoff flows into scattered catch basins that discharge to the storm drain 

in Pembroke Road. This stormwater also flows westward into the storm drain system on Loudon 

Road and ultimately to the Merrimack River (VHB, 1993; Stone & Webster Environmental 

Technology & Services, 1998; AECOM, 2019).

From the 1970s to approximately 2006, drywells were used to manage stormwater at the SMR. 

Historic reports for the SMR indicate that 14 drywells were present at the Facility. Seven of the 

drywells (DW-1 through DW-7) were located downgradient of the UH-60 helicopter pads and 

may have received drainage from these areas. According to Facility personnel, two of the 

drywells formerly received drainage from the refueling area (DW-9 and DW-10), and one 

received drainage downgradient of the Ground Power Annex (DW-8). Drywells DW-1 through 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-5

DW-10 were installed in the 1972 to 1974 timeframe (Jacques Whitford Company, Inc., 2003; 

AECOM, 2019). DW-A was located north-northwest from the blacktop driveway at the Airport 

Road gate, northeast of the boundary fence. DW-B was located 20 feet southeast from the 

southeast wall of the former AASF building (Building K). DW-C was located 160 feet southwest 

from the southeast corner of the former AASF building. An additional unnamed drywell was 

located on the northwest side of former Building K and southwest of DW-8 (labeled as DW-Z in 

the PA and in this document). Some of the drywells were removed or filled in the 1990s (Stone 

& Webster Environmental Technology & Services, 1998). According to interviews with 

NHARNG personnel, the remainder of the drywells were removed in 2006, with the exception of 

DW-1, which is still present at the Facility (shown on Figure 2-5).

2.2.4 Climate

The Facility lies within the humid continental climate zone, which is characterized by long, cold, 

snowy winters, very warm (and at times humid) summers, and relatively brief autumns and 

springs. The monthly daily average temperature ranges from a high of 31 degrees Fahrenheit (°F) 

in January to 82°F in July. In winter, successive storms deliver light to moderate snowfall 

amounts, which contribute to the relatively reliable snow cover. Summer can bring stretches of 

humid conditions as well as thunderstorms, and there is an annual average of 12 days of 90°F 

highs. Average annual precipitation is approximately 41 inches (US Climate Data, 2019; 

AECOM, 2019).

2.2.5 Current and Future Land Use

The Facility is zoned “industrial” by the City of Concord. The Facility is fenced with restricted 

access. Much of the Facility is paved with either asphalt or concrete. Approximately 15 acres of 

the SMR is a fully vegetated Pine Barrens Habitat area, which was created as mitigation to 

compensate for the habitat loss at the AASF currently located at 26 Regional Drive, Concord, 

New Hampshire. The SMR currently serves as the headquarters for the NHARNG. Facilities at 

the SMR include a warehouse, a maintenance shop, Joint Force Offices, the Concord Armory, 

and a Civil Support Teams building (Tighe & Bond, 2018; AECOM, 2019). Activities and land 

use within the Facility are not expected to change.

The area surrounding the SMR includes residential and commercial properties to the north, the 

Concord Municipal Airport to the south, commercial and light industrial properties to the east, 

and additional residential neighborhoods to the west. Conservation/Public Lands are located 

approximately 0.8 miles to the southeast, adjoining the Soucook River. Future land use of the 

surrounding area is not anticipated to change.

2.2.6 Sensitive Habitat and Threatened/Endangered Species

A wildlife survey has not occurred at the Facility; however, NHARNG is tracking locations of

rare plants at the SMR. According to Facility personnel, the Grasshopper Sparrow, a Statethreatened grassland bird, is often sighted in the vicinity of the SMR Facility. Additionally, the 

Pitch Pine woodland habitat on the SMR is permanently protected by the NHARNG in support 

of restoration efforts.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-6

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

species in Merrimack County, New Hampshire (US Fish and Wildlife Services, 2022):

Insects: Karner Blue Butterfly Lycaeides melissa samuelis (endangered); Monarch Butterfly 

Danaus plexippus (candidate)

Mammals: Northern Long-eared Bat Myotis septentrionalis (threatened)

Flowering Plants: Northeastern Bulrush Scirpus ancistrochaetus (endangered); Small Whorled 

Pogonia Isotria medeoloides (threatened)

2.3 HISTORY OF PFAS USE

The PA identified two AOIs where PFAS were potentially released to soil and groundwater, 

within the boundary of the SMR. The former AASF and former Camp Labonte AOIs were 

identified based on preliminary data and inferred groundwater flow direction. 

The former AASF was located at the SMR from the 1960s to 2004. Typical activities conducted 

at the AASF (Building K) included maintenance and repair of fixed-wing and rotary aircraft, 

storage and dispensing of fuel, and mechanical servicing and cleaning of helicopter interiors and 

exteriors (NHARNG, 1996; AECOM, 2019). AOI 1 is comprised of multiple sub-areas within 

the former AASF where PFAS may have been released; the former AASF hangar, the former fire 

truck parking area, the former washing platform (known as the “washrack”), former aircraft 

parking area, and the former Tri-MaxTM training area. Additionally, drywells which were present 

throughout the Facility may act as a secondary source of PFAS to the environment where

located proximate to a potential PFAS release.

One documented release of aqueous film forming foam (AFFF) from the former AASF hangar 

(Building K) fire suppression system occurred in 1999. Additionally, a second release of AFFF 

from the fire suppression system was recalled by one interviewee on an unknown date. After the 

releases, the foam was either washed into a trench drain inside the hangar or washed out of the 

hangar onto the apron to the east of the building, from there it would have entered the municipal 

sewer system; however, unintentional releases may have occurred to the nearby grassy areas 

(AECOM, 2019).

Former AASF personnel indicated that foam was used on two fire trucks at the SMR between the 

late 1960s and 1992. Both fire trucks were regularly parked in a crash/rescue bay on the north 

side of former Building K. Because the dates of use of the fire trucks overlap with the use of 

AFFF, there is the potential for the foam to have contained PFAS (AECOM, 2019). Unintended 

spills or releases of foam from the fire trucks may have occurred in the parking bay or to the 

asphalt outside the bay if the fire trucks were parked outside. Additionally, when the second fire 

truck was in use (pre- 1977 to 1992), foam was sprayed on the pavement at the former AASF 

(Building K) and then rinsed into the storm drains (AECOM, 2019). The location of the former 

fire truck parking bay is shown on Figure 3-1.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-7

According to NHARNG personnel, aircraft maintenance was conducted inside the hangar at 

Building K but aircraft washing was conducted outside at the washing platform, also known as a 

washrack. There is the potential for unintended spills or releases of PFAS from the washing 

platform or the associated rinsate after washing aircraft or fire trucks.

Six Tri-MaxTM mobile fire extinguishers were stored outside on the former AASF apron (one 

beside each helicopter) during the time that helicopters were stationed at the SMR. Given the 

long-term storage of the Tri-MaxTM extinguishers in a non-climate-controlled environment, there 

is the potential for unintended spills or releases of PFAS from the extinguishers (AECOM, 

2019). Additionally, the tanks would be periodically emptied as part of training exercises that 

occurred north of the former runway.

According to former AASF personnel, two fire trucks with foam capabilities were present at the 

SMR between the late 1960s and 1992. When the first fire truck was in use (late 1960s to pre1977), foam was used for training on the grass and gravel to the north of the former Camp 

Labonte, at the SMR, at approximate geographic coordinates 43°12'38.9"N; 71°30'40.1"W

(AECOM, 2019). However, no additional information was available on whether the foam 

contained AFFF. Because the first fire truck was potentially in use after the introduction of 

AFFF, a release of PFAS in the former Camp Labonte area is possible.

A description of each AOI is presented in Section 3.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-8

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-1

Insert Figure 2-1. Facility Location

Add size and orientation of figure; the flysheet immediately following figure should match size 

and orientation of figure.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-2

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 2-1

Facility Location

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Facility Data

Facility Boundary

State Military 

Reservation
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-4

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 2-2

Facility Topography

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Facility Data

Facility Boundary

State Military 

Reservation

Note:

Contour elevation recorded in ft. asml.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-6

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 2-3

Groundwater Features

&

&

&

&

(

(

(

(

& &

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&& &

&

&

&

&

&

&

&

&

&

&&

&

&

&

&

&

&

&

&

&

( (

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(( (

(

(

(

(

(

(

(

(

(

((

(

(

(

(

(

(

(

(

(

&

&

&

&

(

(

(

(

&

&

&

&

&

& &

&

&

&&&&

&

&

(

(

(

(

(

( (

(

(

((((

(

(

&

&

(

(

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

&

&

&

&

(

(

(

(

& &

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&& &

&

&

&

&

&

&

&

&

&

&&

&

&

&

&

&

&

&

&

&

( (

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(( (

(

(

(

(

(

(

(

(

(

((

(

(

(

(

(

(

(

(

(

&

&

&

&

(

(

(

(

&

&

&

&

&

& &

&

&

&&&&

&

&

(

(

(

(

(

( (

(

(

((((

(

(

&

&

(

(

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

& &

&

&

&

&

&

&

&

&

&

&

&

&

&

&

&

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

( (

(

(

(

(

(

(

(

(

(

(

(

(

(

(

(

&(&(&(&(

&(&(

&(

FrenchsBroo k

Bowen Brook

W ood s Br o ok

B ow Brook

Mill Brook

Merrimack River

So ucook R iver

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Hydrology/

Hydrogeology

Groundwater Flow

Direction

River/Stream

Water Body

Wetland

Geology

Concord Granite

Lower Rangley

Formation

Upper Rangley

Formation

Perry Mountain

Formation

Facility Data

Facility

Boundary

Wells

&( Geothermal Well

&( Other/Unkown Well

&( Abandoned Well

&( Agricultural Well

&( Commercial Well

&( Domestic Well

Monitoring Well

&( Public Water

Supply Well

&(
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-8

This page intentionally left blank
Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 2-4

Surface Water Features

Bow Bog

Brook-Merrimack

River Watershed

Soucook River

Watershed

Merrimack River

Soucook River

3

0 0.5

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Hydrology/Hydrogeology

Surface Water

Flow Direction

Wetland

Watershed

River/Stream

Water Body

Facility Data

Storm Sewer Line

Facility Boundary

Retention Basin
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

 

EA Engineering, Science, and Technology, Inc., PBC 2-10

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-1 

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, six potential release areas were identified at 

SMR and grouped into two AOIs identified as: AOI 1 Former AASF and AOI 2 Former Camp 

LaBonte. These AOIs are described below and shown on Figure 3-1. 

3.1 AOI 1 – FORMER ARMY AVIATION SUPPORT FACILITY

AOI 1 is the Former AASF, including the former main AASF hangar (former Building K) fire 

suppression system releases, the former fire truck parking area, the former washing platform, the 

former aircraft parking apron, the dry wells, and the Tri-MaxTM training area. Potential PFAS 

release mechanisms within this AOI are described below. 

The former AASF was located at the SMR from the 1960s to 2004. Typical activities conducted 

at the AASF (Building K) included maintenance and repair of fixed-wing and rotary aircraft, 

storage and dispensing of fuel, and mechanical servicing and cleaning of helicopter interiors and 

exteriors (NHARNG, 1996; AECOM, 2019). AOI 1 is comprised of multiple sub-areas within 

the former AASF where PFAS may have been released; the former AASF hangar, the former fire 

truck parking area, the former washing platform (known as the “washrack”), former aircraft 

parking area, and the former Tri-MaxTM training area. Additionally, drywells, which were 

present throughout the AASF, may act as a secondary source of PFAS to the environment, where

located proximate to a potential PFAS release.

Former AASF Hangar 

The first building for the AASF hangar was constructed between 1960 and 1961, and helicopters 

were present at the SMR in the 1960s. In 1974, an addition to the original building was 

constructed to create Building K (The Louis Berger Group, Inc., 2006; AECOM, 2019). The 

Aircraft Maintenance Hangar was located in the center of former Building K, at approximate 

geographic coordinates 43°12'37.4"N; 71°30'46.6"W (AECOM, 2019). 

According to interviews with former personnel, a fire suppression system was installed in the 

hangar in 1994. No fire suppression system was present prior to this time, despite aircraft 

operations beginning in the 1960s. The system was charged with 3% AFFF from 1994 to 2004. 

No additional information on the type of AFFF, frequency of testing, or system maintenance was 

available. The system was removed in 2004, when operations were moved to the new AASF at 

26 Regional Drive, located 0.5 miles to the east of the Facility. The majority of former Building 

K was demolished at that time, except for the main hangar. The current Building 1 was 

constructed by November 2007, around the former hangar. The former hangar is now used as a 

large drill and assembly hall for the Joint Force Headquarters. 

One documented release of AFFF from the fire suppression system occurred on 23 July 1999. 

According to interviewees, a fire was triggered using a lighter to ignite accelerants located in the 

Communications Room of Building K. The amount of AFFF released is unknown. After the 

release, the foam was either washed into a floor drain trench inside the hangar or washed out of 

the hangar onto the apron to the east of the building. The trench drain inside the hangar led to a 

1,000-gallon OWS located outside the building, and then to the municipal sewer system, per the 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-2 

terms and conditions of City of Concord Industrial Discharge Permit No. H-37 (VHB, 1993; 

NHARNG, 1996; AECOM, 2019). The location of the 1,000-gallon OWS is presumed to be on 

the southwest side of former Building K, based on historic figures from the 1998 SI Report 

(Stone & Webster Environmental Technology & Services, 1998; AECOM, 2019). Foam washed 

onto the apron would have entered a catch basin that discharged to the municipal sewer system. 

The location of the former AASF (Building K) fire suppression system release is shown on 

Figure 3-1. 

A second release of AFFF from the fire suppression system was recalled by one interviewee, 

during the PA, who stated the hangar quickly filled up with foam. However, the date of this 

incident and the quantity of AFFF released was unknown. The foam from this release is 

presumed to have been managed in the same manner as the first release.

Former Fire Truck Parking Area

Former AASF personnel indicated that two fire trucks were used at the SMR during AASF 

operations. The first was a former 1940s vintage LaFrance fire truck, which moved to the SMR 

from Manchester Airport in the 1960s. The vintage LaFrance fire truck was removed from the 

Facility sometime prior to 1977 (the exact date is unknown). The second fire truck was tankmounted on a deuce and a half truck, which was introduced to the SMR sometime prior to 1977 

and was removed from the site in 1992. Both fire trucks were regularly parked in a crash/rescue 

bay on the north side of former Building K, at approximate geographic coordinates 

43°12'38.2"N; 71°30'47.0"W (AECOM, 2019). 

Interviewees indicated that foam was used by both fire trucks. Although interviewees recalled 

that two types of foam were used, no additional information was available on the dates of foam 

use, the type of foam used, or whether the foam contained AFFF. Because the dates of use of the 

fire trucks overlap with the use of AFFF, there is the potential for the foam to have contained 

PFAS. Unintended spills or releases of foam from the fire trucks may have occurred in the 

parking bay or to the asphalt outside the bay if the fire trucks were parked outside. Additionally, 

former AASF personnel indicated that when the second fire truck was in use (pre- 1977 to 1992), 

foam was sprayed on the pavement at the former AASF (Building K) and then rinsed into the 

storm drains. The location of the former fire truck parking bay is shown on Figure 3-1. 

Former Washing Platform (“Washrack”) 

During the former AASF operations, aircraft maintenance and washing was conducted outside at 

the washing platform (known as the “washrack”). The washrack was located at approximate 

geographic coordinates 43°12'39.1"N; 71°30'45.3"W (AECOM, 2019). Rinsate generated in the 

washrack was collected in a blocked sump at that location and pumped into a mobile holding 

tank. The holding tank was then wheeled into the hangar’s maintenance area and pumped into 

the same floor drain trench at the front of the hangar, which led to a 1,000-gallon OWS located 

outside the building, and then to the municipal sewer system (VHB, 1993; NHARNG, 1996). 

However, there is the potential for unintended spills or releases of PFAS from the washrack after 

washing aircraft or fire trucks. No documentation or information were available on the type, 

quantity, and concentration of AFFF, which may have been released from the washrack. The 

location of the former washrack is shown on Figure 3-1. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-3 

Former Aircraft Parking Area

According to interviews with former AASF personnel, six Tri-MaxTM mobile fire extinguishers 

were stored outside on the former AASF (Building K) apron (one beside each helicopter) during 

the time that helicopters were stationed at the SMR (from the 1960s to 2004). The center of the 

parking apron was approximately located at geographic coordinates 43°12'37.8"N; 71°30'43.1"W 

(AECOM, 2019). No spills or releases were reported from the Tri-MaxTM extinguishers, and 

interviewees could not confirm if routine inspections were performed on the tanks. Given the 

long-term storage of the Tri- MaxTM extinguishers in a non-climate-controlled environment, 

there is the potential for unintended spills or releases of PFAS from the extinguishers. No 

additional documentation or information were available on the type, quantity, and concentration 

of AFFF stored in the Tri-MaxTM extinguishers. All Tri-MaxTM mobile fire extinguishers were 

removed from the Facility and sent for disposal in approximately 2004. The area is now a 

parking lot. The former aircraft parking area is shown on Figure 3-1. 

Former Tri-MaxTM Training Area

The Tri-MaxTM mobile fire extinguishers used at the former aircraft parking area would be 

periodically discharged as part of training exercises that occurred in an area south of the aircraft 

parking area and north of the former runway. No information on the frequency of training or 

discharge volumes was available. The approximate location of the former Tri-MaxTM training 

area is shown on Figure 3-1. 

Former and Current Drywells 

From the 1970s to approximately 2006, drywells were used to drain stormwater at the SMR. 

According to historic records (as noted below), there were 14 drywells at the SMR. There is 

potential for AFFF from the hangar fire suppression system release in 1999, or from unintended 

spills or releases in the other identified areas, to have entered the drywells. Thus, the drywells 

may be secondary sources of PFAS. Some of the drywells were removed or filled in the 1990s 

(Stone & Webster Environmental Technology & Services, 1998; AECOM, 2019). According to 

interviews with NHARNG personnel, the remainder of the drywells were removed shortly before 

construction began on Building 1 (Joint Force Headquarters) in 2007, with the exception of DW1, which is still present at the Facility.

• DW-1 through DW-10 - Seven of the drywells (DW-1 through DW-7) were located 

downgradient of the former UH-60 helicopter pads and may have received drainage 

from these areas. According to Facility personnel, two of the drywells formerly 

received drainage from the refueling area (DW-9 and DW-10), and one received 

drainage downgradient of the Ground Power Annex (DW-8). Drywells DW-1 through 

DW-10 were installed in the 1972 to 1974 timeframe (AECOM, 2019). The base of 

DW-8 was approximately 14 feet in diameter and 17 feet in depth. The remaining dry 

wells ranged from 10 to 15 feet deep and from 7 to 10 feet in diameter (Jacques 

Whitford Company, Inc., 2003; AECOM, 2019). Downgradient impacts to soil and 

groundwater from DW-1 through DW-10 were evaluated in a 2003 Limited Site 

Investigation (Jacques Whitford Company, Inc., 2003), and a monitoring well (MW1) was installed adjacent to DW-8 to investigate a known release of No. 2 Fuel Oil. 

Petroleum-contaminated soils were subsequently removed from DW-8 and 

transported to Loudon, NH as non-hazardous waste in September 2004. A Certificate 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-4

of No Further Action for the drywells was issued on 17 December 2004 (NHDES, 

2004). However, PFAS were not evaluated as part of the drywell investigation.

• DW-A was located 18 feet north-northwest from the blacktop driveway at the Airport 

Road gate, and 8.5 feet northeast from the boundary fence (Stone & Webster 

Environmental Technology & Services, 1998; AECOM, 2019). DW-A was two-ft in 

diameter and was constructed of brick and concrete. DW-A was constructed 

subsurface (2 ft bgs) and had a two-foot square steel cover to keep the soil out (Stone 

& Webster Environmental Technology & Services, 1998; AECOM, 2019). A catch 

basin that was located adjacent to and south of Building Q connected to DW-A. Past 

releases of liquid hazardous wastes reportedly occurred, draining into an OWS. Some 

waste from the OWS was routed to a former waste oil underground storage tank

(Tank No. 8). The potentially contaminated water from the OWS was allowed to 

drain into the catch basin and then flowed through a 4-inch pipe into DW-A. DW-A 

was excavated and removed in June 1994, and the New Hampshire Department of 

Environmental Services recommended no further action at this location (USAEHA, 

1994; AECOM, 2019).

• DW-B was located 20 feet southeast of the southeast wall of the former AASF 

building (Building K). Before 1992, wash water from the service bay floor, which 

contained oils and greases from airplane repair and maintenance, was collected in a 

sump, discharged into a catch basin, and then discharged into DW-B. After 1992, the 

drains inside the former AASF maintenance bays were blocked off, and the wash 

water was pumped into wheeled holding tanks, which were transported to the CSMS, 

where they emptied into the OWS. This OWS is connected to the Concord publicly 

owned treatment works. DW-B was located directly below the catch basin, which also 

received drainage from the roof of the former AASF (Building K). According to a site 

plan, DW-B drained into a storm drain pipeline, which flowed to a combination storm 

drain and sanitary sewer main on Airport Road. A portion of the water in DW-B 

possibly drained into the soil (USAEHA, 1993; USAEHA, 1994; Stone & Webster 

Environmental Technology & Services, 1998; AECOM, 2019).

• DW-C was located 160 feet southwest of the southeast corner of the former AASF 

building (Building K) and 170 feet northwest from Building R, the JP-8 (formerly JP4) pumphouse. Formerly, the catch basin leading to DW-C reportedly had water 

ponded on the ground surface within a diameter of approximately 40 feet. DW-C was 

plugged and then could not drain or drained very slowly. In the fall of 1993, DW-C 

was filled, and a solid, pre-cast concrete catch basin was installed on top of it. This 

catch basin currently flows into a new pipeline, which was constructed in early 1994, 

and is connected to the Airport Road storm drain. Since this change occurred, water 

ponding at the surface of the catch basin has not been observed (USAEHA, 1994; 

Stone & Webster Environmental Technology & Services, 1998; AECOM, 2019).

• An additional unnamed drywell (labeled as DW-Z in the PA and this document) was 

identified on figures from the 1998 SI Report, located on the northwest side of former 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-5

Building K (southwest of DW-8) and extends from a former septic system (Stone & 

Webster Environmental Technology & Services, 1998; AECOM, 2019).

3.2 AOI 2 – FORMER CAMP LABONTE

AOI 2 is the Former Camp Labonte. The Former Camp Labonte was used by the NHARNG as a 

Weekend Training Site for many years and originally served as the New Hampshire Military 

Academy for Officer Candidate School prior to the State of New Hampshire’s acquisition of the 

current New Hampshire National Guard Training Site property in Center Strafford in 1985.

According to former AASF personnel, two fire trucks were used at the SMR during AASF 

operations. The first fire truck was a former 1940s vintage LaFrance fire truck, which was 

moved to the SMR from Manchester Airport in the 1960s. The vintage LaFrance fire truck was 

removed from the Facility sometime prior to 1977 (the exact date is unknown). The second fire 

truck was tank-mounted on a deuce and a half truck, which was introduced to the SMR sometime 

prior to 1977 and was removed from the Facility in 1992.

Interviewees indicated that foam was used by both fire trucks. When the first fire truck was in 

use (late 1960s to pre-1977), foam was used for training on the grass and gravel to the north of 

the former Camp Labonte on the SMR, at approximate geographic coordinates 43°12'38.9"N; 

71°30'40.1"W (Figure 5-1, AECOM, 2019). As stated in the AOI 1 discussion above, when the 

second fire truck was in use (pre-1977 to 1992), foam was sprayed on the pavement at the former

AASF (Building K), but not in the Camp LaBonte area.

According to former AASF personnel, two types of foam were used on the fire trucks. The older 

of the two foams contained animal-based ingredients (potentially blood or fat). The second type 

of foam was referred to as a “civilian foam” that came in 5-gallon containers from a local Fire 

Department (either the Concord Fire Department or the Franklin Fire Department). No additional 

information was available on the dates of foam use, the type of foam used, or whether the foam 

contained AFFF. Because the first fire truck was potentially in use after the introduction of AFFF 

in firefighting foams, a release of PFAS-containing AFFF at the former Camp Labonte area is 

possible.

The former Camp Labonte was located to the south of the parking lot that is behind the Concord 

Readiness Center and previously had five small training huts and seven larger training huts. All 

the five small training huts and some of the larger training huts were demolished sometime in the 

mid-to-late 1990s. In 2008, two of the remaining larger training huts were combined into one 

building and the other remaining huts were demolished. That building now serves as a Karner 

Blue Butterfly Captive Rearing Building, which is leased to the New Hampshire Fish and Game 

Department. The area is also part of the 15 acres of fully vegetated Pine Barrens Habitat, which 

was created as mitigation to compensate for the habitat loss at the AASF currently located at 26 

Regional Drive, Concord, New Hampshire.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-6

3.3 ADJACENT SOURCES

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

control of the NHARNG. A description of each off-Facility source is presented below and shown 

on Figure 3-1. 

3.3.1 Electropac Worldwide Inc. Site (former Vishay Sprague Facility)

The Electropac Worldwide Inc. site (former Vishay Sprague site) at 70 Pembroke Road is 

located approximately 1/3-mile east, cross gradient, of the SMR. This Facility is included on the 

NHDES PFAS Sampling Map as a site with a positive PFAS detection; however, the type and 

concentrations of PFAS were not identified. 

3.3.2 The Richard M. Flynn Fire Academy

The Richard M. Flynn Fire Academy (Fire Academy) is located 1.5 miles due east, cross 

gradient, of the SMR. Class B foam has been used on the Fire Academy site through 

approximately 175 training courses dating back to 1994. In June and August 2018, 

environmental samples were collected at the Academy at the request of NHDES. PFOS was 

detected in groundwater at concentrations ranging from 190 parts per trillion (ppt) to 18,000 

ppt and PFOA was detected at concentrations ranging from 120 ppt to 2,200 ppt, with a 

maximum total of 20,200 ppt for combined PFOA/PFOS. Elevated concentrations of PFAS 

compounds were also detected in soil samples and adjacent surface water samples from the 

Soucook River; however, there were no standards for PFAS in soil or surface water in New 

Hampshire in 2018 (Nobis Group, 2018; AECOM, 2019). On July 23, 2020, the NH 

Legislature signed NH House Bill 1264 into law establishing Maximum Contaminant Levels 

(MCLs) and Ambient Groundwater Quality Standards for PFOA (12 ppt and 12 nanograms per 

liter (ng/L), PFOS (15ppt and 15 ng/L), PFHxS (18ppt and 18 ng/L) and PFNA(11 ppt and 11 

ng/L).

The types and quantities of AFFF used or stored at the Fire Academy currently or historically 

are not known. However, because the Fire Academy has confirmed releases of PFAS and is 

located outside the boundary of the SMR, it is considered an adjacent off-Facility source of 

PFAS (AECOM, 2019).
Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 2-5 

Groundwater Elevations

June 2022 

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

!

AASF Hangar

Releases

Former Tri-Max

Training Area

Former

FireTruck

Parking

Former Aircraft

Parking Area

Former Camp

LaBonte

Former

Washing

Platform

AOI01-01

295.53

AOI01-04

294.85

AOI01-05

294.24

AOI01-06

293.09

AOI01-07

295.2

AOI01-08

296.05

AOI02-03

296.32

SMR-02

285.57

SMR-03

298.35

DW-1

Not Contoured

SMR-01

289.20

286

298

296

2

94

292

290

288

3

0 500

Feet

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Facility Data

Area of Interest (AOI)

Potential PFAS Release

Facility Boundary

Sample Type

! Drywell

! Temporary Monitoring Well

(No Soil Samples)

Hydrology/Hydrogeology

Surface Water Flow

Direction

Groundwater Flow Direction

Groundwater Elevation

Contour (2-Foot Interval)
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 3-8

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 4-1

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/Wood, 2022), the 

objective of the SI is to identify whether there has been a release to the environment at the AOIs 

identified in the PA. For each AOI, ARNG determines if further investigation is warranted, a 

removal action is required to address immediate threats, or whether no further action is 

warranted. This SI evaluated groundwater and soil for the presence or absence of relevant 

compounds at each of the sampled AOIs.

4.1 PROBLEM STATEMENT

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

samples have concentrations of the relevant compounds above the OSD risk-based SLs. The SLs 

are presented in Section 6.1 of this Report.

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for SMR (AECOM, 2019)

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

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

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

parameters measured at the time of sampling.

4.3 STUDY BOUNDARIES

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

and 2-2). The scope of the SI was bounded vertically by the depth of temporary monitoring wells 

installed within groundwater, where encountered (maximum depth of 60 feet bgs). Off-Facility 

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

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

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

resources were available to complete the study.

4.4 ANALYTICAL APPROACH

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

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

the National Environmental Laboratory Accreditation Program (NELAP; Certificate Number 

021). Data were compared to applicable SLs within this document and decision rules as defined 

in the UFP-QAPP Addendum (EA/Wood, 2022). 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 4-2

4.5 DATA USABILITY ASSESSMENT

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

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

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

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

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

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

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

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

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

associated data validation reports. These data are of sufficient quality to meet the objectives and 

requirements of the UFP-QAPP (EA/Wood, 2022).
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-1

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, SMR, New Hampshire, dated November 

2019 (AECOM, 2019)

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

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

Installations, Nationwide, dated December 2020 (EA, 2020)

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

Addendum, SMR, New Hampshire dated May 2022 (EA/Wood, 2022)

• Final Programmatic Accident Prevention Plan, Revision 1, dated November 2021

(EA, 2020)

• Final Accident Prevention Plan/Site Safety and Health Plan, SMR, New

Hampshire, dated November 2021 (EA/Wood, 2021). 

The SI field activities were conducted from 24 May to 13 June 2022 and consisted of 

utility clearance, direct-push technology (DPT) boring and soil sample collection, 

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

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

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

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

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

Systems Manual (QSM) Version 5.3 Table B-15 to fulfill the project DQOs:

• Twenty-five (25) soil samples from 9 boring locations;

• Ten (10) grab groundwater samples from 10 temporary well locations;

• Twenty-six (26) quality assurance (QA)/QC samples.

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

presents the list of samples collected for each medium. Field documentation is provided 

in Appendix B. A log of Daily Notice of Field Activity was completed throughout the SI 

field activities, which is provided in Appendix B1. Sampling forms are provided in 

Appendix B2, land survey data are provided in Appendix B3, and investigation-derived 

waste (IDW) placement locations are provided in Appendix B4. Additionally, a 

photographic log of field activities is provided in Appendix C.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-2

5.1 PRE-INVESTIGATION ACTIVITIES

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

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

water. Details of these activities are presented below.

5.1.1 Technical Project Planning

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

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

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

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

beginning with defining overall project objectives, including DQOs, and formulating a sampling 

approach to address the AOIs identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 22 April 2022, prior to SI field activities. The

combined TPP Meeting 1 and 2 was conducted in general accordance with EM 200-1-2. The 

stakeholders for this SI included ARNG, USACE, NHARNG, NHDES, and representatives

familiar with the Facility, the regulations, and the community. Stakeholders were provided the 

opportunity to make comments on the technical sampling approach and methods at the combined 

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

the UFP-QAPP Addendum (EA/Wood, 2022). 

A TPP Meeting 3 was held after the field event 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 results and findings, and future actions, where warranted. 

5.1.2 Utility Clearance

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

Environment & Infrastructure Solutions, Inc. (Wood), contacted the Utility Notification Center

to notify them of intrusive work at the Facility. WSP contracted Advanced Technologies Utility 

Locating Corp., a private utility location service, to perform utility clearance at the Facility. 

Utility clearance was performed at each of the proposed boring locations on 23 May 2022 with

input from the WSP field team. General locating services and ground-penetrating radar (GPR) 

were used to complete the clearance. Additionally, the first 5 feet of each boring were precleared by WSP’s drilling subcontractor, Parratt Wolff, Inc., 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 confirmed to meet 

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

activities. A sample from a potable water source at the SMR, was collected on 6 May 2022, prior 

to mobilization, and analyzed for PFAS by LC/MS/MS compliant with QSM 5.3 Table B-15 

(DoD, 2020). The results of the sample of the potable water source used for decontamination of 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-3

drilling equipment during the SI are provided in Appendix F. A discussion of the results is 

presented in the Data Usability Assessment (Appendix A).

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

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

environment was provided in the Standard Operating Procedures (SOPs) appendix to the

Programmatic UFP-QAPP (EA, 2020). 

5.2 HAND AUGER SOIL SAMPLING

Soil samples were collected from two locations for chemical analysis from 0 to 2 ft below 

ground surface (bgs) and 3 to 5 ft bgs using a hand auger. All soil sample locations are shown on 

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

the PA (AECOM, 2019) and as agreed upon by stakeholders during the TPP and review of the 

UFP-QAPP Addendum (EA/Wood, 2022). Non-dedicated sampling equipment (i.e., hand auger) 

was decontaminated between sampling locations. 

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

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

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

the laboratory and analyzed for PFAS (LC/MS/MS compliant with QSM Version 5.3 Table B15) in accordance with the UFP-QAPP Addendum. QC samples and analysis were performed as 

described in the UFP-QAPP Addendum (EA/Wood, 2022).

5.3 SOIL BORINGS AND SOIL SAMPLING

Soil samples were collected via DPT drilling methods in accordance with SOP 047 Direct-Push 

Technology Sampling (EA/Wood, 2022). A Geoprobe® 7822DT dual-tube sampling system was 

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

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

locations are shown on Figure 5-1, and boring sample depths are provided in Table 5-1. Several 

boring locations were adjusted within a 50-feet offset for reasons including drill rig access, 

utility avoidance and bias toward sampling within observed drainage features.

Three discrete soil samples were collected for chemical analysis from each soil boring: one 

sample at the surface (0 to 2 ft bgs) and two subsurface soil samples. One subsurface soil sample 

was collected approximately 1 ft above the groundwater table, and one collected at the mid-point 

between the surface and the groundwater table (not to exceed 15 ft bgs). Groundwater was 

encountered at depths ranging from 41 to 56 ft bgs during drilling. Total boring completion 

depths, to accommodate temporary well installation, ranged from 44 to 60 bgs. 

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

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

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

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

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

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-4

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

recorded. The boring logs are provided in Appendix E. 

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

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

standard COC procedures to the laboratory and analyzed for PFAS (LC/MS/MS compliant with 

QSM Version 5.3 Table B-15), total organic carbon (TOC, EPA Method 9060A), pH (EPA 

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

Addendum (EA/Wood, 2022). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. Matrix Spike (MS)/matrix spike duplicate (MSD) samples 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. A temperature blank was placed in each cooler for use in 

confirming that samples were preserved at or below 6 degrees Celsius (°C) during shipment. 

DPT borings were converted to temporary wells, which were subsequently abandoned after 

sampling and surveying in accordance with the UFP-QAPP Addendum (EA/Wood, 2022). After 

removal of the casings, boreholes were abandoned using bentonite chips. Borings were installed 

in grass areas to avoid disturbing concrete or asphalt surfaces.

5.4 TEMPORARY WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Temporary wells were installed using a GeoProbe® DT7822 dual-tube sampling system. Once 

the borehole was advanced to the desired depth, a temporary well was constructed of a 5-ft

section of 1-inch Schedule 40 poly-vinyl chloride (PVC) screen with sufficient casing to reach 

the ground surface. New PVC pipe and screen were used at each location to avoid cross 

contamination between locations. The screen intervals for the temporary wells are provided in 

Table 5-2.

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

groundwater to infiltrate and recharge the temporary well screen intervals. After the recharge 

period, groundwater samples were collected using a bladder pump with PFAS-free HDPE tubing. 

The temporary 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. Additionally, a subsample of each groundwater sample was collected in a 

separate container, and a shaker test was completed to identify if there were any foaming. No 

foaming was noted in any of the groundwater samples.

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

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

standard COC procedures to the laboratory and analyzed for PFAS by LC/MS/MS compliant 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-5

with QSM Version 5.3 Table B-15 in accordance with the UFP-QAPP Addendum (EA/Wood, 

2022). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. MS/MSD samples were collected at a rate of 5% and analyzed for 

the same parameters as the accompanying samples. One field blank (FB) was collected in 

accordance with the UFP-QAPP Addendum (EA/Wood, 2022). In instances when non-dedicated 

sampling equipment was used, such as a bladder pump, one EB was collected a day and analyzed 

for the same parameters as the groundwater samples. A temperature blank was placed in each 

cooler for use in confirming that samples were preserved at or below 6°C during shipment. 

Following well surveying (described below in Section 5.7), temporary wells were abandoned in 

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

backfilling the hole with bentonite chips. 

5.5 SYNOPTIC WATER LEVEL MEASUREMENTS

Synoptic water level elevation measurements were collected from the newly installed temporary 

monitoring wells prior to sampling. Water level measurements were taken from the survey mark 

on the northern side of the well casing. Groundwater elevation data is provided in Table 5-3. A 

groundwater flow contour map is provided as Figure 2-5.

5.6 SURVEYING

The northern side of each new temporary well casing was surveyed following guidelines 

provided in the SOPs provided in the SI QAPP Addendum (EA/Wood, 2022). Positions were 

collected in the applicable Universal Transverse Mercator zone projection with World Geodetic 

System 1984 datum (horizontal) and North American Vertical Datum 1988 (vertical). Surveying 

data were collected on 13 June 2022 and are provided in Appendix B3. 

5.7 INVESTIGATION-DERIVED WASTE

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

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

the UFP-QAPP Addendum (EA/Wood, 2022). 

Soil IDW (i.e., soil cuttings) generated during the SI activities were returned to the borehole 

from which they originated. The soil IDW was not sampled and assumes the characteristics of 

the associated soil samples collected from that source location.

Liquid IDW generated during SI activities (purge water, decontamination fluids) were treated 

using granular activated carbon (GAC) and contained in two labeled, 55-gallon Department of 

Transportation approved steel drums and left onsite as directed by Facility personnel. The liquid 

IDW was sampled following the SI fieldwork and is awaiting disposal. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-6

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

location where IDW was placed. The IDW placement locations are displayed on the figure in 

Appendix B6.

The IDW disposal is being managed under a separate contract (EA Engineering, Science, and 

Technology, Inc., 2021). Specifics on the disposal of liquid IDW and the GAC will be addressed 

in an IDW Technical Memorandum.

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

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

field activities were disposed of off-site at a licensed solid waste landfill

5.8 LABORATORY ANALYTICAL METHODS

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

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

Soil samples were also analyzed for TOC using EPA Method 9060A, pH by EPA Method 

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

5.9 Deviations from SI UFP-QAPP Addendum

Deviations from the UFP-QAPP Addendum occurred based on conditions encountered during 

field activities. These deviations were discussed between EA, ARNG, and USACE. The 

deviations from the UFP-QAPP Addendum are noted below: 

• Multiple sample locations were moved into grassy areas to avoid disturbing the rare 

plants and paved/concrete areas that are located at the SMR as directed by NHARNG.

Some of these changes placed the sample locations within the historic release locations. 

• Borings were advanced via DPT instead of Hollow Stem Auger (HSA) drilling methods 

at all locations designated for soil and groundwater sample collection. An HSA was 

deployed to the SMR, but soil conditions did not warrant the use of HSA drilling 

methods. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-7 

Table 5-1. Site Inspection Samples by Medium

State Military Reservation, Concord, New Hampshire

Site Inspection Report

Sample 

Identification

Sample 

Collection 

Date

Sample Depth

(ft bgs)

PFAS(LC/MS/MS compliant with QSM 5.3 Table B-15)TOC(EPA Method 9060A)pH (EPA Method 9045D)Grain Size (ASTM D422)

Comments

Soil Samples

AOI01-01-SB-(0-2) 5/24/22 0-2 X

AOI01-01-SB-(13-15) 5/24/22 13-15 X

AOI01-01-SB-(40) 5/24/22 40 X

AOI01-02-SB-(0-2) 6/8/22 0-2 X

AOI01-02-SB-(13-15) 6/8/22 13-15 X

AOI01-02-SB-(40-42) 6/8/22 40-42 X

AOI01-03-SB-(0-2) 6/8/22 0-2 X

AOI01-03-SB-(13-15) 6/8/22 13-15 X

AOI01-03-SB-(40-42) 6/8/22 40-42 X

AOI01-04-SB-(0-2) 6/7/22 0-2 X

AOI01-04-SB-(13-15) 6/7/22 13-15 X

AOI01-04-SB-(42-44) 6/7/22 42-44 X

AOI01-05-SB-(0-2) 6/6/22 0-2 X X X X Parent Sample of (SMR)-

DUP04

AOI01-05-SB-(13-15) 6/6/22 13-15 X

AOI01-05-SB-(39-41) 6/6/22 39-41 X

AOI01-06-SB-(0-2) 6/2/22 0-2 X

AOI01-06-SB-(13-15) 6/2/22 13-15 X

AOI01-06-SB-(44-46) 6/2/22 44-46 X

AOI01-07-SB-(0-2) 6/2/22 0-2 X

AOI01-07-SB-(13-15) 6/2/22 13-15 X

AOI01-07-SB-(42-44) 6/2/22 42-44 X

AOI02-01-SB-(0-2) 6/1/22 0-2 X X X X Parent Sample of (SMR)-

DUP02

AOI02-01-SB-(2-5) 6/1/22 3-5 X

AOI02-02-SB-(0-2) 6/1/22 0-2 X

AOI02-02-SB-(2-5) 6/1/22 3-5 X Parent Sample of (SMR)-

DUP03; MS/MSD Collected

(SMR)-DUP02 6/1/22 - X

(SMR)-DUP03 6/1/22 - X

(SMR)-DUP04 6/6/22 - X

Groundwater Samples

AOI01-01-GW-(45) 6/7/22 45 X

AOI01-04-GW-(45) 6/9/22 45 X

AOI01-05-GW-(47) 6/10/22 47 X

AOI01-06-GW-(49) 6/8/22 49 X

AOI01-07-GW-(45) 6/10/22 45 X
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-8 

Sample 

Identification

Sample 

Collection 

Date

Sample Depth

(ft bgs)

PFAS(LC/MS/MS compliant with QSM 5.3 Table B-15)TOC(EPA Method 9060A)pH (EPA Method 9045D)Grain Size (ASTM D422)

Comments

AOI01-08-GW-(45) 6/9/22 45 X

AOI02-03-GW-(44) 6/8/22 44 X

SMR-01-GW-(54) 5/31/22 54 X Parent sample of (SMR)-

DUP01; MS/MSD Collected 

SMR-02-GW-(57) 6/8/22 57 X

SMR-03-GW-(45) 6/8/22 45 X

(SMR)-DUP01 5/31/22 - X

Blank Samples

(SMR)-EB-01 5/24/22 - X Equipment Blank Collected 

from Stainless Steel Trowel

(SMR)-FB-01 5/24/22 - X

(SMR)-EB-02 5/31/22 - X Equipment Blank Collected 

from Water Level Meter

(SMR)-FB-02 5/31/22 - X

(SMR)-EB-03 6/1/22 - X Equipment Blank Collected 

from Hand Auger

(SMR)-FB-03 6/1/22 - X

(SMR)-EB-04 6/2/22 - X Equipment Blank Collected 

from Stainless Steel Spoon

(SMR)-FB-04 6/2/22 - X

(SMR)-EB-05 6/6/22 - X Equipment Blank Collected 

from Stainless Steel Trowel

(SMR)-FB-05 6/6/22 - X

(SMR)-EB-06 6/7/22 - X Equipment Blank Collected 

from Water Level Meter

(SMR)-FB-06 6/7/22 - X

(SMR)-EB-07 6/7/22 - X Equipment Blank Collected 

from Stainless Steel Spoon

(SMR)-FB-07 6/8/22 - X

(SMR)-EB-08 6/8/22 - X Equipment Blank Collected 

from Stainless Steel Trowel

(SMR)-FB-08 6/9/22 - X

(SMR)-EB-09 6/8/22 - X Equipment Blank Collected 

from Bladder Pump

(SMR)-FB-09 6/10/22 - X

(SMR)-EB-10 6/9/22 - X Equipment Blank Collected 

from Water Level Meter

(SMR)-EB-11 6/10/22 - X Equipment Blank Collected 

from Water Level Meter

Notes:

SMR = State Military Reservation

ASTM = American Society for Testing and Materials

bgs = below ground surface

EB = equipment blank

FD = field duplicate

FB = field blank

LC/MS/MS = Liquid Chromatography Mass Spectrometry

MS/MSD = matrix spike/ matrix spike duplicate

QSM = Quality Systems Manual

TOC = total organic carbon

USEPA = United States Environmental Protection Agency
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-9 

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

State Military Reservation, Concord, New Hampshire

Site Inspection Report

Area of Interest Boring Location

Soil Boring Depth

(ft bgs)

Temporary Well 

Screen Interval

(ft bgs)

1 

AOI01-01 44.0 39.0-44.0

AOI01-02 44.0 -

AOI01-03 44.0 -

AOI01-04 48.0 43.0-48.0

AOI01-05 48.0 43.0-48.0

AOI01-06 52.0 47.0-52.0

AOI01-07 48.0 44.0-48.0

AOI01-08 48.0 43.0-48.0

2 

AOI02-01 5.0 -

AOI02-02 5.0 -

AOI02-031 48.0 42.0-47.0

Facility Boundary

SMR-01 56.0 51.0-56.0

SMR-02 60.0 55.0-60.0

SMR-03 48.0 43.0-48.0

Notes:

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

bgs = below ground surface
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-10

Table 5-3. Groundwater Elevation 

State Military Reservation, Concord, New Hampshire

Site Inspection Report

Monitoring Well 

ID

Top of Casing Elevation

(ft NAVD88)

Depth to Water

(ft btoc)

Groundwater Elevation

(ft NAVD 88)

AOI01-01 339.17 43.64 295.53

AOI01-04 340.68 45.83 294.85

AOI01-05 340.67 46.43 294.24

AOI01-06 341.45 48.36 293.09

AOI01-07 341.55 46.35 295.20

AOI01-08 338.53 42.48 296.05

AOI02-03 340.96 44.64 296.32

SMR-01 340.65 51.45 289.20

SMR-02 341.20 55.63 285.57

SMR-03 342.77 44.42 298.35

Notes: 

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

btoc = below top of casing

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

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 3-1

Areas of Interest

&(

&(

&(

&(

&(&(&(

&(

&(

&(

&(

&(

&(

&(

&(&(&(

&(

&(

&(

&(

&(

&(

&(

&(

&(

Bow Bog

Brook-Merrimack

RiverWatershed

Soucook River

Watershed Former Tri-Max

Training Area

AASF Hangar

Releases

Former Aircraft

Parking Area

AOI 2

Former Camp

LaBonte

Loudon Road Fire

Training Area

Former

FireTruck

Parking

Former

Washing

Platform

City of Concord

Fire Department,

Heights Station

AASF Concord (PA Report

under separate cover)

Concord

Municipal

Airport

AOI1

Former Army Aviation 

Support Facility

Merrimack River

Merrimack River

Soucook River

Pembroke Rd

Regional Dr

Hazen Dr

Airport Rd

Loudon Rd

3

0 0.5

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Facility Data

Area of Interest (AOI)

Potential PFAS Release

Facility Boundary

Hydrology/Hydrogeology

Watershed

Water Body

Wetland

River/Stream

Wells

&( Monitoring Well

&( Geothermal Well

&( Domestic Well

&( Domestic Drinking Water Well

&( Other/Unknown Well

&( Test/Exploration
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 5-12

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 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 for each AOI is provided in Sections 6.3

and 6.4. SLs for relevant compounds, for both soil and groundwater, are presented in Table 6-1. 

Tables 6-2 through 6-6 present results in soil or groundwater for the relevant compounds. Tables 

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

Appendix G. 

 

6.1 SCREENING LEVELS

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

SLs for soil and groundwater, as described in a memorandum from the OSD (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 will 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)

Analyte2

Residential 

(Soil)

(μg/kg)1 

0-2 ft bgs

Industrial / Commercial

Composite Worker 

(Soil)

(μg /kg) 1 

2-15 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. July 2022. Risk Based Screening Levels in Groundwater and Soil using 

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

(HQ)=0.1. May 2022. 

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

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

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

because HFPO-DA is generally not a component of military specification MIL-SPEC AFFF and based on 

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

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

concern in the absence of other PFAS.

Abbreviations:

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 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-2

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

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

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

results (2 to 15 feet bgs). The SLs are not applied to deep subsurface soil results (>15 feet bgs) 

because 15 feet is the anticipated limit of construction activities.

6.2 SOIL PHYSICOCHEMICAL ANALYSES

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

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

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

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

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

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

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

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

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

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

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

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

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

2018). 

6.3 AOI 1

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

AOI 1: Former AASF. The soil and groundwater results are summarized in Table 6-2 through 

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

6.3.1 AOI 1 Soil Analytical Results

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

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

6-4 summarize the soil results.

Surface soil (0 to 2 ft bgs) was sampled from boring locations AOI01-01 through AOI01-07. 

Shallow subsurface soil (2 to 15 ft bgs) was sampled from boring locations AOI01-01 through 

AOI01-07. Deep subsurface soil (39 to 46 ft bgs) was sampled from boring locations AOI01-01

through AOI01-07. 

PFOS was detected in surface soil at concentrations exceeding the SL. PFHxS, PFNA, and 

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

was detected at all seven locations at concentrations that ranged from 1.1 microgram per 

kilogram (μg/kg) to 210 μg/kg and exceeded the SL at three locations (AOI01-01, AOI01-02, 

and AOI01-03). PFHxS was detected at two of seven locations at concentrations of 0.39 J μg/kg 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-3

and 0.58 J μg/kg. PFNA was detected at one location at a concentration of 0.28 J μg/kg. PFOA 

was detected at three of seven locations at concentrations that ranged from 0.22 μg/kg to 0.72 

μg/kg. PFBS was not detected in any of the surface soil samples. 

PFHxS, PFOA, and PFOS were detected in shallow subsurface soil at concentrations below their 

respective SLs. PFHxS was detected at two of seven locations at concentrations that ranged from 

0.31 μg/kg to 0.39 J μg/kg. PFOA was detected at two of seven locations at concentrations that 

ranged from 0.25 J μg/kg to 0.30 J μg/kg. PFOS was detected at one location at a concentration 

of 6.0 μg/kg. PFBS and PFNA were not detected in any of the shallow subsurface soil samples.

PFHxS, PFOA, PFOS, PFBS, and PFNA were not detected in any of the deep subsurface soil 

samples.

6.3.2 AOI 1 Groundwater Analytical Results 

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

the SI. Figure 6-6 and Figure 6-7 present the ranges of detections in groundwater. Table 6-5 

summarizes the groundwater results.

Groundwater was sampled from temporary monitoring well locations AOI01-01, AOI01-04

through AOI01-08, and SMR-01 through SMR-03. SMR-03 was located upgradient of AOI 1

and SMR-01 and SMR-02 were located downgradient of AOI 1. PFHxS, PFOA, and PFOS were 

detected in groundwater at concentrations exceeding their respective SLs. PFBS, and PFNA were 

detected at concentrations below their respective SLs. PFHxS was detected at seven of nine

locations at concentrations that ranged from 1.3 J ng/L to 160 ng/L and exceeded the SL at three 

locations (AOI01-04, AOI01-6, and SMR-02). PFHxS was detected in the upgradient sample 

(SMR-03) below its SL. PFOA was detected at seven of nine locations at concentrations that 

ranged from 1.7 J ng/L to 34 ng/L and exceeded the SL at five locations (AOI01-04, AOI01-05, 

AOI01-06, SMR-01 [and its duplicate], and SMR-02). PFOA was detected in the upgradient 

sample (SMR-03) below its SL. PFOS was detected in six of nine locations at concentrations that 

ranged from 13 ng/L to 280 ng/L and exceeded its SL at six locations (AOI01-01, AOI01-04, 

AOI01-05, AOI01-06, SMR-01 [and its duplicate], and SMR-02). PFBS was detected in eight of 

nine locations at concentrations that ranged from 0.6 J ng/L to 20 ng/L and was detected in the 

upgradient sample (SMR-03). PFNA was detected in three of nine locations at concentrations 

that ranged from 0.82 J ng/L to 1.4 J ng/L.

6.3.3 Conclusions

Based on the results of the SI, PFOS was detected in surface soil at concentrations above the SL. 

PFHxS, PFOA, and PFOS were detected in groundwater at concentrations above their respective 

SLs. Based on the exceedances of the SLs in soil and groundwater, further evaluation at AOI 1 is 

warranted. 

6.4 AOI 2 

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

AOI 2: Former Camp LaBonte. The soil and groundwater results are summarized in Table 6-2
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-4

through Table 6-5. Soil and groundwater results are presented on Figures 6-1 through Figure 6-

7.

6.4.1 AOI 2 Soil Analytical Results

Soil samples were collected from two boring locations associated with AOI 2 during the SI. 

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

6-4 summarize the soil results.

Surface soil (0 to 2 ft bgs) was sampled from boring locations AOI02-01 and AOI02-02. Soil 

was sampled from shallow subsurface soil (2 to 5 ft bgs) from boring locations AOI02-01 and 

AOI02-02. Soil was not sampled from deep subsurface soil intervals for boring locations AOI02-

01 and AOI02-02.

PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in the surface soil samples. 

PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in the shallow subsurface soil 

samples.

6.4.2 AOI 2 Groundwater Analytical Results 

A groundwater sample was collected from one temporary well associated with AOI 2 during the 

SI. Figure 6-6 and Figure 6-7 presents the ranges of detections in groundwater. Table 6-5

summarizes the groundwater results.

PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in the groundwater sample.

6.4.3 Conclusions

Based on the results of the SI, PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in soil 

or groundwater and further evaluation at AOI 2 is not warranted. 
Table 6-2

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual Result Qual R

PFBS 1900 ND U ND U ND U ND U PFHxS 130 ND U 0.39 J 0.58 J ND U PFNA 19 ND U ND U 0.28 J ND U PFOA 19 ND U 0.23 J 0.72 ND U PFOS 13 16 210 27 2.0 J 

Notes Gray Fill Detected concentration exceeded OSD Screening Levels 

References 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated 

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s 

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil are

based on residential scenario for incindental ingestion of contaminated soil.

Interpreted Qualifiers

J = Estimated concentration.J+ = The result is an estimated quantity, but the result may be biased high.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected and was reported as less than the limit of detection.  However, the associated numerical value is approximate.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)OSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

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

AOI01-02 AOI01-03 AOI01-04

Area of Interest

Depth

Location ID AOI01-01 

AOI

Sample ID AOI01-01-SB-(0-2) AOI01-02-SB-(0-2) AOI01-03-SB-(0-2) AOI01-04-SB-(0-2) AO

Sample Date 5/24/2022 6/8/2022 6/8/2022 6/7/2022 

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

EA Engineering, Science, and Technology, Inc., PBC 
Table 6-2

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1

PFBS 1900PFHxS 130PFNA 19PFOA 19PFOS 13

NotesGray Fill Detected concentration exceeded OSD Screening LevelsReferences1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil are

based on residential scenario for incindental ingestion of contaminated soil.

Interpreted QualifiersJ = Estimated concentration.J+ = The result is an estimated quantity, but the result may be biased high.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected and was reported as less than the limit of detection.  However, the associated numerical value is approximate.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)OSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Area of Interest

Depth

Location ID

Sample ID

Sample Date

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

Result Qual Result 

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

Chemical AbbreviationsPFBS perfluorobutanesulfoPFHxS perfluorohexanesulfoPFNA perfluorononanoic acPFOA perfluorooctanoic acPFOS perfluorooctanesulfo

AOI

0 - 2 ft 

AOI02-01-SB-(0

AOI02-01-SB-(0-2)

AOI02-01

(SMR)D

6/1/2022 6/1/2

0 - 2 

EA Engineering, Science, and Technology, Inc., PBC 
Table 6-3

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

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual R

PFBS 25000 ND U ND U ND U PFHxS 1600 ND U 0.39 J 0.31 PFNA 250 ND U ND U ND U PFOA 250 0.25 J 0.3 J ND PFOS 160 6.0 ND U ND U 

Notes Gray Fill Detected concentration exceeded OSD Screening Levels References 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated 

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s 

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soilare based on Industrial/Commercial Composite Worker scenario for incindental ingestionof contaminated soil.Interpreted Qualifiers

J = The result is an estimated quantity.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected and was reported as less than the limit of detection.  However, the associated numerical value is approximate.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)OSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date 5/24/2022 6/8/2022 6/8/2022 

Area of Interest

Depth

13 - 15 ft 13 - 15 ft 13 - 15 ft 

Location ID AOI01-01

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

AOI01-02 AOI01-03 

Sample ID AOI01-01-SB-(13-15) AOI01-02-SB-(13-15) AOI01-03-SB-(13-15) A

EA Engineering, Science, and Technology, Inc., PBC 
Table 6-3

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

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1

PFBS 25000PFHxS 1600PFNA 250PFOA 250PFOS 160

NotesGray Fill Detected concentration exceeded OSD Screening LevelsReferences1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculatedfor PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soilare based on Industrial/Commercial Composite Worker scenario for incindental ingestionof contaminated soil.Interpreted Qualifiers

J = The result is an estimated quantity.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected and was reported as less than the limit of detection.  However, the associated numerical value is approximate.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)OSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date

Area of Interest

Depth

Location ID

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

Sample ID

Result Qual Result 

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

Chemical AbbreviationsPFBS PFHxS PFNA PFOA PFOS 

6/1/2022 6/1/

AOI

AOI02-01-SB-(2-5) AOI02-0

2 - 5 ft 2 - 

AOI02-01

EA Engineering, Science, and Technology, Inc., PBC 
Table 6-4

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

Site Inspection Report

 Concord SMR

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual Result 

PFBS 25000 ND U ND U ND U ND PFHxS 1600 ND U ND U ND U ND PFNA 250 ND U ND U ND U ND PFOA 250 ND U ND U ND U ND PFOS 160 ND U ND U ND U ND 

Notes Gray Fill Detected concentration exceeded OSD Screening Levels References 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated 

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s 

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soilare based on Industrial/Commercial Composite Worker scenario for incindental ingestionof contaminatedsoil.Interpreted Qualifiers

U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected and was reported as less than the limit of detection.  However, the associated numerical value is approximate.Acronyms and Abbreviationsμg/kg microgram(s) per kilogramAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)OSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Location ID

Sample Date 5/24/2022 6/8/2022 6/8/2022 6/7/202

AOI01-03 AOI01-

AOI01-03-SB-(40-42) AOI01-04-SB

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

Area of Interest

Depth

AOI0

40 ft 40 - 42 ft 40 - 42 ft 42 - 44 

AOI01-01 AOI01-02 

Sample ID AOI01-01-SB-(40) AOI01-02-SB-(40-42) 

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

State Military Reservation, New Hampshire Version: FINAL

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

This page intentionally left blank
Table 6-5

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual 

PFBS 601 0.91 J 7.3 9.3 PFHxS 39 3.6 76 32 PFNA 6 0.82 J 1.4 J 1.2 J PFOA 6 4.0 20 13 PFOS 4 69 51 13 

Notes Gray Fill Detected concentration exceeded OSD Screening Levels 

References 

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated 

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s 

Regional Screening Level Calculator. HQ=0.1 . May 2022. Groundwater screening levelsbased on residential scenario for direct ingestion of groundwater.Interpreted Qualifiers

J = Estimated concentration.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and AbbreviationsAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)ng/L nanogram(s) per literOSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Water, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

Area of Interest A

Sample Date 6/7/2022 6/9/2022 6/10/2011 

Sample ID AOI01-01-GW-(45) AOI01-04-GW-(45) AOI01-05-GW-(47) 

Location ID AOI01-01 AOI01-04 AOI01-05 

EA Engineering, Science, and Technology, Inc., PBC 
Table 6-5

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

Concord SMR

Analyte OSD Screening Level 1

PFBS 601PFHxS 39PFNA 6PFOA 6PFOS 4

NotesGray Fill Detected concentration exceeded OSD Screening LevelsReferences1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s

Regional Screening Level Calculator. HQ=0.1 . May 2022. Groundwater screening levelsbased on residential scenario for direct ingestion of groundwater.Interpreted QualifiersJ = Estimated concentration.U = The analyte was not detected at a level greater than or equal to the adjusted DL.UJ = The analyte was not detected at a level greater than or equal to the adjusted DL.  However, the reported adjusted DL is approximate and may be inaccurate or imprecise.Acronyms and AbbreviationsAOI Area of InterestDUP duplicateHQ Hazard QuotientID identificationLCMSMS liquid chromatography with tandem mass spectrometryLOD limit of detectionLOQ limit of quantitationND analyte not detected above the LOD (LOD values are presented in Appendix F)ng/L nanogram(s) per literOSD Office of the Secretary of the DefenseQSM Quality Systems ManualPFAS per- and polyfluoroalkyl substancesSB soil boringSMR State Military ReservationUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Water, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

Area of Interest

Sample Date

Sample ID

Location ID

Result Qual Result Qual Result 

ND U 5.9 5.7 ND U 31 28 ND U ND U ND ND U 15 16 ND U 19 18 

AOI02 

6/8/2022 5/31/2022 5/3

AOI02-03-GW-(44) SMR-01-GW-(54) (SMR

AOI02-03 SMR-01 SMR-01

EA Engineering, Science, and Technology, Inc., PBC 
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.....................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nd a ry

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 6-1

PFOS Detections in Soil

!!(

!!(

!!( !(

!(

!(

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07 AOI02-01

AOI02-02

002

A

Buchanan

St

Burns

Av

002 B

Hazen

Dr Ramp

Blodgett St

Heights Rd

Brandy Ln

Old Tpk Rd

Thomas St

Quincy St

Ormand St

Russell St

Lawrence St Ext

Grover St

Dover St

Greeley St

Regional Dr

Lawrence St

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07 002

A

Burns Av

Buchanan

St

002 B

Grant St

Hazen

Dr Ramp

Blodgett St

Heights Rd

Brandy Ln

Thomas St

Quincy St

Ormand St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Sha llow (0-2') De e p (39-46') 3

)

NH

NOTES:

PFOS = pe rflu oroocta ne su lfonic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m (s) pe r Kilog ra m

Exce e d a nce s of the OSD SL a re d e picte d

with a ye llow ha lo.

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI02-02

AOI02-01

AOI01-07

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-02

AOI01-01

Airport Rd

Loudon Rd

Pembroke Rd

Prescott St

Regional Dr

Greeley St

Lawrence St

Dover St

Grover St

Russell St

Old Tpk Rd

Quincy St

Ormand St

Lawrence St Ext

002 B

Thomas St

Brandy Ln

Heights Rd

Hazen Dr Ramp

Hydrology/Hydrogeology

Su rfa ce W a te r Flow Dire ction

Grou nd wa te r Flow Dire ction

Inte rm e d ia te (2-15')

PFOS Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 13

!!( >13 -160

!!( >160 - 1,600

!!( >1,600
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

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

This page intentionally left blank
Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :.....................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 6-2

PFOA Detections in Soil

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI02-01

AOI02-02

Heights Rd

Brandy Ln

Grant St

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Prescott St

Regional Dr

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

Brandy Ln

Thomas St

Quincy St

Ormand St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Sha llow (0-2') De e p (39-46') 3

)

NH

NOTES:

PFAS = Pe r- a nd Polyfluoroa lkyl Substa nce s

PFOA = pe rfluoroocta noic a cid

ND = Non-De te ct

(μ g /Kg ) = M icrog ra m (s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re d e picte d w ith a ye llow ha lo.

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI02-02

AOI02-01

AOI01-07

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-02

AOI01-01

Heights Rd

Grant St

Brandy Ln

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Hydrology/Hydrogeology

Surfa ce W a te r Flow Dire ction

Ground w a te r Flow Dire ction

Inte rm e d ia te (2-15')

0 250

Fe e t

0 250

Fe e t

0 250

Fe e t

PFOA Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

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

This page intentionally left blank
Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :.....................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 6-3

PFBS Detections in Soil

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI02-01

AOI02-02

Heights Rd

Brandy Ln

Grant St

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Prescott St

Regional Dr

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

Heights Rd

Brandy Ln

Thomas St

Quincy St

Ormand St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Sha llow (0-2') De e p (39-46') 3

)

NH

NOTES:

PFAS = Pe r- a nd Polyfluoroa lkyl Substa nce s

PFBS = pe rfluorobuta ne sulfonic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m (s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re d e picte d w ith a ye llow ha lo.

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI02-02

AOI02-01

AOI01-07

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-02

AOI01-01

Heights Rd

Grant St

Brandy Ln

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Hydrology/Hydrogeology

Surfa ce W a te r Flow Dire ction

Ground w a te r Flow Dire ction

Inte rm e d ia te (2-15')

0 250

Fe e t

0 250

Fe e t

0 250

Fe e t

PFBS Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 10

!( >10 - 1,900

!!( >1,900 - 25,000

!!( >25,000
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-18

This page intentionally left blank
Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :.....................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 6-4

PFHxS Detections in Soil

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI02-01

AOI02-02

Heights Rd

Brandy Ln

Grant St

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Prescott St

Regional Dr

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

Heights Rd

Brandy Ln

Thomas St

Quincy St

Ormand St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Sha llow (0-2') De e p (39-46') 3

)

NH

NOTES:

PFAS = Pe r- a nd Polyfluoroa lkyl Substa nce s

PFHxS = pe rfluorohe xa ne sulfonic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m (s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re d e picte d w ith a ye llow ha lo.

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI02-02

AOI02-01

AOI01-07

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-02

AOI01-01

Heights Rd

Grant St

Brandy Ln

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Hydrology/Hydrogeology

Surfa ce W a te r Flow Dire ction

Ground w a te r Flow Dire ction

Inte rm e d ia te (2-15')

0 250

Fe e t

0 250

Fe e t

0 250

Fe e t

PFHxS Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 13

!( >13 -160

!!( >160 - 1,600

!!( >1,600
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-20

This page intentionally left blank
Da ta Source s: 

ESRI 2020

AECOM 2020

Da te :.....................Octobe r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................U SACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bound a ry

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation 

Concord, New Hampshire

Figure 6-5

PFNA Detections in Soil

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI02-01

AOI02-02

Heights Rd

Brandy Ln

Grant St

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Prescott St

Regional Dr

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI01-06

AOI01-07

Heights Rd

Brandy Ln

Thomas St

Quincy St

Ormand St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Sha llow (0-2') De e p (39-46') 3

)

NH

NOTES:

PFAS = Pe r- a nd Polyfluoroa lkyl Substa nce s

PFNA = pe rfluoronona noic a cid

ND = Non-De te ct

(μg /Kg ) = M icrog ra m (s) pe r Kilog ra m

Exce e d a nce s of The Office of the Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re d e picte d w ith a ye llow ha lo.

!(

!(

!(

!(

!(

!(

!( !(

!(

AOI02-02

AOI02-01

AOI01-07

AOI01-06

AOI01-05

AOI01-04

AOI01-03

AOI01-02

AOI01-01

Heights Rd

Grant St

Brandy Ln

Thomas St

Ormand St

Quincy St

Russell St

Old Tpk Rd

Grover St

Lawrence St Ext

Dover St

Greeley St

Lawrence St

Regional Dr

Prescott St

Pembroke Rd

Loudon Rd

Airport Rd

Hydrology/Hydrogeology

Surfa ce W a te r Flow Dire ction

Ground w a te r Flow Dire ction

Inte rm e d ia te (2-15')

0 250

Fe e t

0 250

Fe e t

0 250

Fe e t

PFNA Results (μg/kg)

!( ND (Non-De te ct)

!( >ND - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-22

This page intentionally left blank
Data Sources:

ESRI 2020

AECOM 2020

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

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

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

Facility Data

Area of Interest (AOI)

Potential PFAS Release

Facility Boundary

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation

Concord, New Hampshire

Figure 6-6

PFOS, PFOA, and PFBS Detections in Groundwater

!!(

!!(!!( !!(

!(

!(!(

!!(

!!(

!(

AOI01-01

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI02-03

SMR-01

SMR-02

SMR-03

Ormand St

Newton Av

002 A

Russell St

Robinson St

Grover St

Lawrence St Ext

Heights Rd

Quincy St

Hazen Dr Ramp

Sullivan St

Dover St

Greeley St

Ripley St

Grant St Burns Av Prescott St

Old Tpk Rd

Regional Dr

Lawrence St

Hazen Dr

Pembroke Rd

Loudon Rd

Airport Rd

!(

!(

!(

!(

!(

!(!(

!(

!(

!(

AOI01-01

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI02-03

SMR-01

SMR-02

SMR-03

Ormand St

Newton Av

002 A

Russell St

Robinson St

Grover St

Lawrence St Ext

Heights Rd

Quincy St

Hazen Dr Ramp

Sullivan St

Dover St

Greeley St

Ripley St

Grant St Burns Av Prescott St

Old Tpk Rd

Regional Dr

Lawrence St

Hazen Dr

Pembroke Rd

Loudon Rd

Airport Rd

0 200

Feet

PFOS

3

PFBS (ng/L)

!( ND (Non-Detect)

!( >ND - 100

!( >100 - 601

!!( >601 - 1,000

!!( >1,000

)

NH

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

River/Stream

!(

!!!(

!( !!(

!(

!(!(

!!(

!!(

!(

AOI01-01

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

SMR-01

SMR-02

AOI02-03 SMR-03

Ormand St

Newton Av

002 A

Russell St

Robinson St

Grover St

Lawrence St Ext

Heights Rd

Quincy St

Hazen Dr Ramp

Sullivan St

Dover St

Greeley St

Ripley St

Grant St Burns Av Prescott St

Old Tpk Rd

Regional Dr

Lawrence St

Hazen Dr

Pembroke Rd

Loudon Rd

Airport Rd

0 200

Feet

0 200

Feet

PFOS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 4

!!( >4 - 40

!!( >40 - 70

!!( >70

PFOA PFBS

PFOA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

NOTES:

PFAS = Per- and Polyfluoroalkyl Substances

PFOS = perfluorooctanesulfonic acid

PFOA = perfluorooctanoic acid

PFBS = perfluorobutanesulfonic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD)

Screening Level (SL) are depicted with a yellow halo.
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-24

This page intentionally left blank
Data Sources: 

ESRI 2020

AECOM 2020

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

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

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

Facility Data

Area of Interest (AOI)

Potential PFAS Release

Facility Boundary

Army National Guard Site Inspections

Site Inspection Report

State Military Reservation

Concord, New Hampshire

Figure 6-7

PFHxS and PFNA Detections in Groundwater

!(

!!(

!(

!!(

!(

!(

!(

!(

!!(

!(

AOI01-01

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI02-03

SMR-01

SMR-02

SMR-03

002 B

Newton Av

Blodgett St

Hazen Dr Ramp

Buchanan St

Heights Rd

Grover St

Thomas St

Lawrence St Ext

Quincy St

Russell St

Dover St

Greeley St

Grant St

Lawrence St

Loudon Rd

Regional Dr

Pembroke Rd

Airport Rd

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-04

AOI01-05

AOI01-06

AOI01-07

AOI01-08

AOI02-03

SMR-01

SMR-02

SMR-03

002 B

Newton Av

Blodgett St

Buchanan St

Hazen Dr

Grover St

Heights Rd

Hazen Dr Ramp

Thomas St

Lawrence St Ext

Russell St

Quincy St

Dover St

Grant St

Greeley St

Lawrence St

Regional Dr

Loudon Rd

Pembroke Rd

Airport Rd

0 400

Feet

0 400

Feet

PFHxS PFNA 3

)

NH

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

NOTES:

PFAS = Per- and Polyfluoroalkyl Substances

PFHxS = Perfluorohexanesulfonic acid

PFNA = Perfluorononanoic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD) Screening Level

(SL) are depicted with a yellow halo.

PFNA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 100

!!( >100 - 1000

!!( >1000

PFHxS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 39

!!( >39 - 100

!!( >100 - 1000

!!( >1,000
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-26

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-1

7. EXPOSURE PATHWAYS

The Conceptual Site Model (CSM) for each AOI, revised based on the SI findings, is presented 

on Figure 7-1 and Figure 7-2. Please note that while the CSM discussion assists in determining 

if a receptor may be impacted, the decision to move from SI to RI or interim action is determined 

based upon exceedances of the SLs for the relevant compounds and whether the release is more 

than likely attributable to the DoD. A CSM presents the current understanding of the Facility

conditions with respect to known and suspected sources, potential transport mechanisms and 

migration pathways, and potentially exposed human receptors. A human exposure pathway is 

considered potentially complete when the following conditions are present. SLs are presented in 

Section 6.1 of this report.

1. Contaminant source

2. Environmental fate and transport

3. Exposure point

4. Exposure route

5. Potentially exposed populations. 

If any of these elements are missing, the pathway is incomplete. The CSM figures use an empty 

circle symbol to represent an incomplete exposure pathway. Areas with no identified complete 

pathway generally warrant no further action. However, the pathway is considered potentially 

complete if the relevant compounds are detected, in which case the CSM figure uses a half-filled 

circle symbol to represent a potentially complete exposure pathway. Additionally, a completely 

filled circle symbol is used to indicate when a potentially complete exposure pathway has 

detections of the relevant compounds above the SLs. Areas with an identified potentially 

complete pathway and a complete pathway may warrant further investigation. Although the 

CSMs indicate whether potentially complete exposure pathways may exist, the recommendation 

for future study in a RI or no action at this time is based on the comparison of the SI analytical 

results for the relevant compounds to the SLs.

In general, the potential routes of exposure to the relevant compounds are ingestion and 

inhalation. Human exposure via the dermal contact pathway may occur, and current risk practice 

suggests it is an insignificant pathway compared to ingestion; however, exposure data for dermal 

pathways are sparse and continue to be the subject of toxicological study. The receptors 

evaluated are consistent with those listed in EPA guidance for risk screening (EPA, 2001). 

Receptors at the Facility include site workers (e.g., Facility staff and visiting soldiers),

construction workers, off-Facility residents and recreational users outside the Facility boundary.

7.1 SOIL EXPOSURE PATHWAY

The SI results in soil were used to determine whether a potentially complete pathway exists 

between the source and potential receptors at each AOI based on the aforementioned criteria. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-2

7.1.1 AOI 1 

AOI 1 is the Former AASF, including the former main AASF hangar (former Building K) fire

suppression system releases, the former fire truck parking area, the former washing platform, the 

former aircraft parking apron, the dry wells, and the Tri-MaxTM training area.

PFOS was detected in surface soil at AOI 1 at concentrations above the SL. Additionally, 

PFHxS, PFNA, and PFOA were detected in surface soil below the SL at AOI 1. Site 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. PFHxS, PFOA, and PFOS were detected in

shallow subsurface soil at AOI 1 below the SL. Construction workers could contact constituents 

in shallow subsurface soil via incidental ingestion and inhalation of dust; therefore, the 

subsurface soil exposure pathway for construction workers is potentially complete. The CSM for 

AOI 1 is presented on Figure 7-1.

7.1.2 AOI 2 

AOI 2 is the Former Camp Labonte. According to former AASF personnel, two fire trucks with 

foam capabilities were present at the SMR between the late 1960s and 1992. When the first fire 

truck was in use (late 1960s to pre-1977), foam was used for training on the grass and gravel to 

the north of the former Camp Labonte. The first fire truck was potentially in use after the 

introduction of AFFF. 

PFOA, PFOS, PFHxS, PFNA, and PFBS were not detected in surface or subsurface soil at AOI 

2; therefore, the soil exposure pathway for Facility workers and construction workers is 

incomplete. The CSM is presented in Figure 7-2.

7.2 GROUNDWATER EXPOSURE PATHWAY

The SI results in groundwater were used to determine whether a potentially complete pathway 

exists between the source and potential receptors at each AOI based on the aforementioned 

criteria. 

7.2.1 AOI 1 – Former AASF

PFHxS, PFOA, and PFOS were detected at concentrations exceeding their respective SLs and 

PFBS, and PFNA were detected at concentrations below their respective SLs. Due to the depth 

of groundwater at the Facility, the groundwater ingestion exposure pathway for construction 

workers is considered incomplete. Relevant compounds were detected above their respective SLs 

in groundwater at the downgradient boundary of the Facility; ho; therefore, the pathway for 

ingestion of shallow groundwater by off-Facility residents is potentially complete. The exposure 

concentration for downgradient, off-Facility residents is unknown. Groundwater interaction may 

be possible for the Merrimack River located approximately 0.8 miles to the west/southwest 

(downgradient), therefore, the ingestion exposure pathway for offsite surface water and sediment 

is considered potentially complete for recreational users. Human consumption of fish potentially 

affected by PFAS from the river is also possible. The CSM for AOI 1 is presented on Figure 7-1. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-3

7.2.2 AOI 2 – Former Camp LaBonte

PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in the groundwater sample from AOI 

2, therefore ingestion exposure for construction workers, nearby residents, and recreational users 

is incomplete. The CSM is presented in Figure 7-2. 

7.3 SURFACE WATER AND SEDIMENT EXPOSURE PATHWAY

There is no surface water located at the SMR, however, stormwater does discharge to the

Concord municipal storm drain system on Airport Road. The drainage within the storm drain 

system from Airport Road flows westward down Loudon Road and then to the Merrimack River, 

which is approximately 0.5 miles to the west of the SMR. Storm drains in the northeast corner of 

the SMR are also connected to the Concord municipal storm drainage system. In the northern 

portion of the site, stormwater runoff drains into scattered catch basins that discharge to the 

storm drain in Pembroke Road. This stormwater also flows westward into the storm drain system 

on Loudon Road and ultimately to the Merrimack River (VHB, 1993; Stone & Webster 

Environmental Technology & Services, 1998; AECOM, 2019). Stormwater has the potential to 

transport AFFF or PFAS-impacted soils to water bodies. No surface water or sediment samples 

were collected as part of the SI. 

7.3.1 AOI 1 – Former AASF

PFHxS, PFNA, PFOA, and PFOS were detected in surface soil at AOI 1. Due to the presence of 

PFAS in soil, there is the potential for stormwater to transport PFAS-impacted soil particles to 

the Merrimack River and expose the potential recreational user by ingestion of surface water.

The CSM for AOI 1 is presented on Figure 7-1.

7.3.1 AOI 2 – Former Camp LaBonte

PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in any of the surface soil samples at 

AOI 2, therefore ingestion exposure for the recreational user is incomplete. The CSM is 

presented in Figure 7-2. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-4

This page intentionally left blank
REC

Huma

Curr

Human 

Activities

Precipitation/

Run-Off

Leaching/Infiltration

Inhalation of 

Dust

AOI 1

Former AASF

Potential 

releases from 

former AASF

PFAS in 

surface soil 

and 

groundwater

Potential Unidentified 

On-Facility Source 

or 

Potential Off-Facility 

Source Not Under 

Control of ARNG

Site 

Worker3

Constructio

Worker3 

Site 

Worker

Constructio

Worker

Airborne 

Soil 

Particulate

Surface 

Soil at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

SOURCE

Source Release Mechanism Media

PATHWAY

Transport

and Migration Media Exposure Routes

LEGENDFlow Chart ContinuesIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Notes:1. The resident refers to off-site receptors2. Inhalation of dust for off-site receptors is likely insignificant3. Dermal contact exposure pathway is incomplete for PFAS4. No current active construction at the Facility

Figure 7-1

Conceptual Site Model

SMR
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

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

This page intentionally left blank
REC

Huma

Curr

Human 

Activities

Precipitation/

Run-Off

Leaching/Infiltration

Inhalation of 

Dust

AOI 2

Former Camp

LaBonte

Potential 

releases from 

former AASF

PFAS in 

surface soil 

and 

groundwater

Potential Unidentified 

On-Facility Source 

or 

Potential Off-Facility 

Source Not Under 

Control of ARNG

Site 

Worker3

Constructio

Worker3 

Site 

Worker

Constructio

Worker

Airborne 

Soil 

Particulate

Surface 

Soil at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Ingestion

Ingestion

Ingestion

Ingestion

SOURCE

Source Release Mechanism Media

PATHWAY

Transport

and Migration Media Exposure Routes

LEGENDFlow Chart ContinuesIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Notes:1. The resident refers to off-site receptors2. Inhalation of dust for off-site receptors is likely insignificant3. Dermal contact exposure pathway is incomplete for PFAS4. No current active construction at the Facility

Figure 7-2

Conceptual Site Model

SMR
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 7-8

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

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

The SI field activities at the Facility were conducted from 24 May to 13 June 2022. The SI field 

activities included soil and groundwater sampling. Field activities were conducted in accordance 

with the UFP-QAPP Addendum (EA/Wood, 2022), except as previously noted in Section 5.9. 

To fulfill the project DQOs set forth in the approved SI UFP-QAPP Addendum (EA 2021), 

samples were collected and analyzed for a subset of PFAS by LC/MS/MS compliant with QSM 

5.3 Table B-15 as follows. 

• Twenty-five (25) soil grab samples from 9 boring locations

• Ten (10) grab groundwater samples from 10 temporary well locations

• Twenty-six (26) QA/QC samples.

An SI is conducted when the PA determines an AOI exists based on probable use, storage, and/or 

disposal of PFAS-containing materials. The SI includes multi-media sampling at AOIs 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 CSMs were refined to assess whether a potentially complete pathway 

exists between the source and potential receptors for potential exposure at the AOIs, which are 

described in Section 7.

8.2 OUTCOME

Based on the results of this SI, further evaluation under CERCLA in the form of a RI is 

warranted for AOI 1, but further evaluation is not warranted for AOI 2 (see Table 8-1). Based on 

the CSMs developed and revised based on the SI findings, there is potential for exposure to 

receptors from AOI 1 from sources on the Facility resulting from historical DoD activities.

Sample chemical analytical concentrations collected during the 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 SLs is as follows:

At AOI 1:

• PFOS was detected in surface soil at concentrations exceeding the SL. PFHxS, PFNA, and 

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

detected in all seven locations with a maximum concentration of 210 μg/kg. PFHxS, PFOA, 

and PFOS were detected in shallow subsurface soil at concentrations below their respective 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 8-2

SLs. PFHxS, PFOA, PFOS, PFBS, and PFNA were not detected in any of the deep 

subsurface soil samples.

• PFHxS, PFOA, and PFOS were detected in groundwater at concentrations exceeding their 

respective SLs. PFBS and PFNA were detected at concentrations below their respective SLs. 

PFHxS was detected in seven of nine locations at concentrations that ranged from 1.30 ng/L 

to 160 ng/L. PFOA was detected in seven of nine locations at concentrations that ranged 

from 1.70 ng/L to 34.0 ng/L. PFOS was detected in six of nine locations at concentrations 

that ranged from 13 ng/L to 280 ng/L. 

• Relevant compounds were detected in upgradient monitoring well SMR-03 at concentrations 

below their respective SLs. PFOS and PFOA were detected in the downgradient Facility 

boundary wells (SMR-02, SMR-01) at concentrations above their respective SLs. PFHxS 

was detected in downgradient Facility boundary well SMR-02 at a concentration above the 

SL.

Based on the results of the SI, further evaluation of AOI 1 is warranted in the RI.

At AOI 2:

• PFHxS, PFNA, PFBS, PFOA, and PFOS were not detected in any of the soil or groundwater 

samples from AOI 2.

Based on the results of the SI, further evaluation at AOI 2 is not warranted. 

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 an AOI should 

be considered for further investigation under CERCLA and undergo an RI. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 8-3 

Table 8-1. Summary of Site Inspection Findings and Recommendations

AOI

Potential PFAS 

Release Area

Soil – 

Source Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary Future Action

1 Former AASF Proceed to RI

2 Former Camp LaBonte Not applicable No further action

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 8-4

This page intentionally left blank
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 9-1

9. REFERENCES

AECOM. 2019. Final Preliminary Assessment Report, State Military Reservation Concord, New 

Hampshire. November.

Assistant Secretary of Defense. 2022. Investigating Per- and Polyfluoroalkyl Substances within 

the Department of Defense Cleanup Program. United States Department of Defense. 6 

July.

Department of the Army (DA). 2016a. EM-200-1-2, Environmental Quality, Technical Project 

Planning Process. 29 February.

. 2016b. Army Guidance to Address Perfluorooctane Sulfonate (PFOS) and 

Perfluorooctanoic Acid (PFOA) Contamination. August.

. 2018. Army Guidance for Addressing Releases of Per-and Polyfluoroalkyl Substances.

September.

DoD. 2019a. Department of Defense (DoD), Department of Energy (DOE) Consolidated Quality

Systems Manual (QSM) for Environmental Laboratories, Version 5.3. May.

. 2019b. General Data Validation Guidelines. November.

. 2020. Data Validation Guidelines Module 3: Data Validation Procedure for Per- and 

Polyfluoroalkyl Substances Analysis by QSM Table B-15. May.

EA, Engineering, Science, and Technology, PBC (EA). 2020. Final Programmatic Uniform 

Federal Policy Quality Assurance Project Plan, Site Inspections for Per- and 

Polyfluoroalkyl Substances Impacted Sites, ARNG Installations, Nationwide. December.

EA Engineering, Science, and Technology, PBC and Wood Environment & Infrastructure 

Solutions, Inc. (EA/Wood). 2021. Accident Prevention Plan/Site Safety and Health Plan 

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

ARNG Installations, Nationwide, State Military Reservation Concord, New Hampshire. 

November.

. 2022. Final Site Inspection Uniform Federal Policy Quality Assurance Project Plan 

(UFP-QAPP) Addendum, State Military Reservation, Concord, New Hampshire, Perand Polyfluoroalkyl Substances Impacted Sites, ARNG Installations, Nationwide. May.

Guelfo, J.L. and C.P. Higgins. 2013. Subsurface transport potential of perfluoroalkyl acids and 

aqueous film-forming foam (AFFF)-impacted sites. Environmental Science and 

Technology 47(9):4164-71. 
Site Inspection Report

State Military Reservation, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 9-2

Higgins, C.P., and R.G. Luthy. 2006. Sorption of perfluorinated surfactants on sediments. 

Environmental Science and Technology 40 (23): 7251-7256. 

ITRC. 2018. Environmental Fate and Transport for Per- and Polyfluoroalkyl Substances. 

March. 

U.S. Environmental Protection Agency (EPA). 1980. Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA). 11 December.

. 1994. National Oil and Hazardous Substances Pollution Contingency Plan (Final Rule).

40 Code of Federal Regulations Part 300; 59 Federal Register 47384. September.

. 2001. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation

Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk 

Assessments). December.

. 2005. Federal Facilities Remedial Site Inspection Summary Guide. 21 July.

. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process

USEPA/240/B-06/001. February.

. 2017. National Functional Guidelines for Organic Superfund Data Review. OLEM 

9355.0-136, EPA-540-R-2017-002. Office of Superfund Remediation and Technology 

Innovation. January.

US Fish and Wildlife Service (USFWS). 2022. Endangered Species. http://ecos.fws.gov/ipac/. 

Accessed 19 October.

Xiao, F., M. F. Simcik, T.R. Halbach, and J.S Gulliver. 2015, Perfluorooctane sulfonate (PFOS) 

and perfluorooctanoate (PFOA) in soils and groundwater of a U.S. metropolitan area: 

Migration and implications for human exposure. Water Research 72:64-74.