FINAL

Preliminary Assessment Report

High Altitude Aviation Training Site, 

Gypsum, Colorado

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

October 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNLCASSIFIED
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

i

Table of Contents

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

1. Introduction ........................................................................................................................ 5

1.1 Authority and Purpose .............................................................................................. 5

1.2 Preliminary Assessment Methods ............................................................................. 5

1.3 Report Organization .................................................................................................. 6

1.4 Facility Location and Description............................................................................... 6

1.5 Facility Environmental Setting ................................................................................... 7

1.5.1 Geology ......................................................................................................... 7

1.5.2 Hydrogeology ................................................................................................. 8

1.5.3 Hydrology ....................................................................................................... 8

1.5.4 Climate ......................................................................................................... 9

1.5.5 Current and Future Land Use ......................................................................... 9

2. Fire Training Areas ........................................................................................................... 14

2.1 Flight Ramp FTA ..................................................................................................... 14

3. Non-Fire Training Areas ................................................................................................... 16

3.1 Building 1214 .......................................................................................................... 16

3.2 HAZMAT Storage Area ............................................................................................ 16

3.3 Flight Ramp ............................................................................................................ 17

3.4 Parking Apron/Taxiway ............................................................................................ 17

4. Emergency Response Areas ............................................................................................ 19

5. Adjacent Sources ............................................................................................................. 20

5.1 Vail Valley Jet Center .............................................................................................. 20

5.2 Eagle County Regional Airport ................................................................................ 20

5.3 Eagle County Regional Airport Fire Department ...................................................... 21

5.4 Gypsum Fire Protection District............................................................................... 22

5.5 Town of Gypsum WWTP ......................................................................................... 22

6. Preliminary Conceptual Site Model .................................................................................. 24

6.1 AOI 1 Parking Apron/Taxiway .................................................................................. 24

6.2 AOI 2 HAZMAT Storage Area .................................................................................. 25

6.3 AOI 3 Building 1214 ................................................................................................ 25

7. Conclusions and Data Uncertainty ................................................................................... 30

7.1 Findings .................................................................................................................. 30

7.2 Uncertainties ........................................................................................................... 30

7.3 Potential Future Actions .......................................................................................... 31

8. References ...................................................................................................................... 34
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

ii

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, HAATS, CO

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 2-1 Fire Training Area

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model for AOI 1 (Parking Apron) and AOI 2

(HAZMAT Storage Area)

Figure 6-3 Preliminary Conceptual Site Model, AOI 3 (Building 1214

Figure 7-1 Summary of Findings

Tables

Table ES-1 AOIs at HAATS

Table 7-1 AOIs at HAATS

Table 7-2 No Suspected Release Areas

Table 7-3 Sources of Uncertainty

Table 7-4 PA Findings Summary

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Conceptual Site Model Information
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

iii

Acronyms and Abbreviations

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AMEC AMEC Earth and Environmental, Inc.

AOI Area of Interest

ARFF Aircraft Rescue and Firefighting

ARNG Army National Guard

CAF Compressed Air Foam

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CFR Code of Federal Regulations

COARNG Colorado Army National Guard

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.

EGE Eagle County Regional Airport

ERWVFA Eagle River watershed valley-fill aquifer

FAA Federal Aviation Administration

FTA fire training area

GA general aviation

HAATS High Altitude Aviation Training Site

HAZMAT Hazardous materials

NOAA National Oceanic and Atmospheric Administration

OWS Oil-water separator

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VVJC Vail Valley Jet Center

WWTP Wastewater treatment plant
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

1

Executive Summary

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

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

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

(PFAS)-containing materials was completed for the High Altitude Aviation Training Site (HAATS; 

also referred to as the “facility”), in Gypsum, Colorado, to assess potential PFAS release areas

and exposure pathways to receptors. The performance of this PA included the following tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility;

· Conducted telephone interviews on 18 December 2019 with current Colorado ARNG

(COARNG) personnel, including the Environmental Protection Specialist, the Facility Unit

Environmental Compliance Officer, and the Western Region Maintenance Supervisor

stationed at the facility;

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

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

groundwater, surface water, and sediment for each AOI.

No documented releases of PFAS-containing materials were identified nor did interviewees recall

any undocumented release AFFF at the facility; however, three AOIs related to potential PFAS 

release were identified at HAATS based on PA data (Figure ES-1) and are summarized in Table

ES-1 below:

Table ES-1: AOIs at HAATS

Area of Interest Name Used by Potential Release Dates

AOI 1 Parking Apron/Taxiway COARNG 2013 – present

AOI 2 HAZMAT Storage Area COARNG 2013 – present

AOI 3 Building 1214 COARNG 2013 – present

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

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

inhalation; in subsurface soil to construction workers via ingestion and inhalation; and in surface

water and sediment to off-facility residents and recreational users via ingestion. Additionally,

commercial and domestic wells located cross-gradient and downgradient of HAATS create a

potentially complete pathway for PFAS exposure to off-facility residents via ingestion of

groundwater. The preliminary CSM for HAATS, which presents the potential receptors and media

impacted, is shown on Figure ES-2.

The HAATS facility is located within the larger Eagle County Regional Airport (EGE) property, and

several adjacent sources of potential PFAS release were identified within the airport property and

surrounding areas including: the EGE runway, EGE Fire Station 10, Vail Valley Jet Center Hangar

areas, the Gypsum Fire Protection District fire station, and the Town of Gypsum Wastewater

Treatment Plant. It is possible that a potential PFAS release at one of the adjacent sources
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

2

identified may have contributed to PFAS within soil, groundwater, surface water, or sediment at

the HAATS facility, the airport property, and surrounding areas.

Based on the United States (US) Environmental Protection Agency (USEPA) Unregulated

Contaminant Monitoring Rule 3 (UCMR3) data it was indicated that no PFAS were detected in a

public water system above the USEPA’s lifetime Health Advisories (HAs) within 20 miles of the

facility. The HA is 70 parts per trillion for PFOS and PFOA, individually or combined. PFAS

analyses performed in 2016 had method detection limits that were higher than currently

achievable. Thus, it is possible that low concentrations of PFAS were not detected during the

UCMR3 but might be detected if analyzed today.
EGE Fire

Station 10

Gypsum Fire

Protection

District

EGE Runway

7/25

Town of

Gypsum WWTP

EGE Commercial

Terminal

Vail Valley

Jet Center Hangar

Vail Valley Jet

Center Hangar

Flight Ramp FTA

Flight Ramp

Building 1214 Parking Apron/Taxiway

HAZMAT Storage

Vail Valley Jet Center - Building 1213A

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center

AOI 1

AOI 2

AOI 3

CasperSchumm Ditch

Stremme and Gates Ditch

Gypsum

Cree k

CKP Ditch

Eagle River

CKP Ditch

Spring Creek

AlkaliCreek

Chatfield and Bartholomew Ditch

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipe

0 750 1,500 3,000

Feet

­ Figure ES-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at HAATS, CO

4/8/2020

4/8/2020

4/8/2020

MS

JW

RG

GIS BY

CHK BY

PM

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

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

4/8/2020

1:18,000

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\CO\HAATS_figures\Fig_ES-1_HAATS_Summary.mxd

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Parking

Apron/Taxiway

Building 

1214

HAZMAT

Storage

Flight Ramp FTA

Flight Ramp

AOI 1

AOI 2

AOI 3

3
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – AOI 3

Potential AFFF

releases from TriMax units stored

outside, the fire

suppression

system, and water

salutes

PFAS in

Surface

Soil / Paved

Surfaces /

Sanitary

Sewers

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure ES-2

Preliminary Conceptual Site Model

HAATS, CO

Potential

Off-Facility

Source Not

under

Control of

ARNG

Tresspasser/

Recreational User

Tresspasser/

Recreational User

Notes:

1. The resident and recreational user

receptors refer to an off-site resident and

recreational user.

2. The site worker and construction worker

receptors refer only to COARNG HAATS site and

construction workers.

3. Dermal contact exposure pathway is

incomplete for PFAS.

Flow-Chart Stops

4
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

5

1. Introduction

1.1 Authority and Purpose

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

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

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

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

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

Order W912DR17F0192, issued 11 August 2017.

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

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

form of aqueous film forming foam (AFFF) released as part of firefighting activities, although other

PFAS sources are possible. In addition, the ARNG is assessing businesses or operations adjacent

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

PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing

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

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

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

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

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

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

PFOA, individually or combined.

This report presents the findings of a PA for PFAS-containing materials at High Altitude Aviation

Training Site (HAATS) (also referred to as the “facility”), in Gypsum, Colorado, in accordance with

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as

amended, the National Oil and Hazardous Substances Pollution Contingency Plan (40 Code of

Federal Regulations [CFR] Part 300), and Army requirements and guidance.

This PA documents locations where PFAS-containing materials may have been released into the

environment at HAATS. The term PFAS will be used throughout this report to encompass all PFAS

chemicals being evaluated, including PFOS and PFOA, which are key components of AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility;

· Conducted telephone interviews on 18 December 2019 with current Colorado ARNG

(COARNG) personnel, including the Environmental Protection Specialist, the Facility Unit

Environmental Compliance Officer, and the Western Region Maintenance Supervisor

stationed at the facility;
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

6

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

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

groundwater, surface water, and sediment for each AOI.

1.3 Report Organization

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

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

of each are as follows:

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

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

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

identified during interviews

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

at the facility identified during interviews

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

facility, specifically in response to emergency situations

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

facility that are not under the control of ARNG

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

and receptors for the AOIs and the facility

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

PA

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

The HAATS property encompasses approximately 20 acres leased from the Eagle County

Regional Airport (EGE) for COARNG use in the town of Gypsum, within Eagle County, Colorado

(Figure 1-1). The facility includes hangar space, classrooms, administrative areas, hazardous

material storage, a parking apron and taxiway, and is designed to train military pilots in high

altitude mountainous terrain. The facility and surrounding airport property are zoned as a planned

unit development (AMEC Earth and Environmental, Inc., [AMEC], 2010). Real property

documents for the facility are included in Appendix A.

The COARNG HAATS facility originally included Building 1213A, which is no longer maintained

or operated by the COARNG. Building 1213A was constructed in the 1970s and was used as the

main hangar for the Mountain Flying Service until the building was leased to the COARNG in 1990

for use as a HAATS facility. In 2013, the COARNG moved their HAATS facility to Building 1214,

following completion of its construction, and Building 1213A was transferred to the Vail Valley Jet
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

7

Center (VVJC). Currently, the VVJC maintains operations of Building 1213A, and Building 1214

serves at the COARNG HAATS facility main hangar.

The original EGE runway was built in the 1930s as an emergency landing strip and was dedicated

in 1947 to provide general aviation (GA) services. Today, EGE is a publicly owned facility

consisting of 632 acres; EGE continues to operate as a commercial airport and is subject to

Federal Aviation Administration (FAA) guidance (EGE, 2014).

1.5 Facility Environmental Setting

HAATS and the area surrounding the larger EGE complex are a mix of industrial and commercial

properties, undeveloped land, agricultural land, and residential areas. The Eagle River is located

approximately 0.5 miles north of the COARNG property and flows west, and Highway 6 is located

approximately 400 feet north of the facility. The HAATS facility sits within the Eagle River Valley

on the western slope of the Colorado Rocky Mountains. Topography across the site has been

graded to drain to the northwest, and the greater area surrounding the facility generally slopes

northwest towards the Eagle River (AMEC, 2010).

Most of the HAATS facility is paved with asphalt or concrete, with the exception of some gravel

and grassy areas surrounding the improved portions of the facility. The HAATS property is

bounded on the north side by a chain-link fence. Sanitary sewer service and potable water are

provided to the facility by the Town of Gypsum.

The adjoining properties to the east, west, and south are all included within the Eagle County

Airport, which is zoned as a planned unit development. The VVJC Maintenance Hangar, which

formerly operated as the COARNG HAATS facility, is located immediately to the east. The

property to the west includes the air traffic control tower. The runway and taxiways are located to

the south of the HAATS property. The Eagle County Airport commercial terminal is located further

to the south, across the runway. The property to the north, between the facility and Highway 6, is

undeveloped and zoned as industrial (AMEC, 2010).

1.5.1 Geology

According to the 1978 Geologic Map of the Leadville Quadrangle compiled for the US Geological

Survey (USGS), the primary geologic unit occurring in the vicinity of the HAATS facility is the

unconsolidated gravel and alluvium deposited as stream, terrace, and outwash material during

the Quaternary Period (USGS, 1978). The much older Eagle Valley Evaporite, a series of gypsum,

anhydrite, and interbedded siltstone and dolomite, make up the valley walls not far from the

HAATS facility and likely lie beneath the unconsolidated surficial deposits at the facility. Local

geologic units are shown on Figure 1-2.

Based on soil survey data published by the US Department of Agriculture (USDA) Natural

Resources Conservation Service (NRCS), the primary soil type at the subject property is the

Dotsero sandy loam, which forms on terraces and toes of mountain slopes through the weathering

of colluvium derived from basalt and other igneous rocks. The Dotsero sandy loam forms with 1

to 12 percent slopes and is typically well drained with moderate infiltration rates and high

conductivity. Runoff is classified as low, and the frequency of flooding or ponding is low to none.

The depth to the water table in the soil type is greater than 80 inches (USDA, 2019).
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

8

1.5.2 Hydrogeology

Groundwater flow direction at the HAATS facility is unknown; however, the inferred groundwater

flow direction in the vicinity of the facility is likely to the northwest due to topography and the

influence of the Eagle River (Figure 1-2). According to a well database search performed as part

of a Phase I Environmental Assessment of the HAATS facility in 2010, the depth to groundwater

in the vicinity of the facility varies from 32 to 86 feet below ground surface. The depth to

groundwater measured in the closest alluvial well is 86 feet below ground surface (AMEC, 2010).

The Town of Gypsum overlies the Eagle River watershed valley-fill aquifer (ERWVFA). The

ERWVFA is an unconfined aquifer found within the alluvial deposits along the Eagle River and its

tributaries, starting near the town of Vail, CO and heading west to Dotsero, CO (USGS, 2009).

Being unconfined, recharge of the aquifer across HAATS occurs through direct infiltration of

precipitation and/or irrigation and drainage ditch water. Deep groundwater at HAATS is found in

bedrock aquifers comprised of the hydrogeologic units associated with the Eagle Basin-Central

Colorado Trough. The uppermost group includes the Weber Aquifer, Maroon-Minturn Aquifer, and

the Belden-Molas confining unit. The primary water-bearing rock type in this group is sandstone

(Barkmann et al., 2020).

Potable and non-potable water is provided to EGE and its tenants through the Town of Gypsum; 

no onsite wells provide drinking water to COARNG personnel. Potable water provided is used for

drinking water at HAATS, and non-potable water is strictly used for irrigation. The water is owned

by the Town of Gypsum and stored in various large water tanks throughout the town. Gypsum

receives its water from three main sources: Mosher Springs, Gypsum Creek, and the Eagle River.

Most of the known intake points associated with Mosher Springs and Gypsum Creek are

unaffected by potential PFAS releases at the HAATS facility because they are located upstream

from the creek’s confluence with the Eagle River. Gypsum Creek’s Norgaard Water Treatment

Plant and associated intake point; however, are located approximately two miles west and

potentially downgradient of the facility. Additionally, the locations of the Eagle River intake, which

is mentioned in the 2016 Town of Gypsum water quality report and the airport master plan, as well

as the T2 well identified in the town water quality report are unknown.

The airport receives its water through several water mains located on the south side of the airfield

to support the commercial terminal area and on the north airfield to support the HAATS and GA

hangars (EGE, 2014). EDRTM report conducted a well search for a 1-mile radius surrounding the

facility (Appendix A). Using additional online resources, such as state and local GIS databases,

wells were researched to a 4-mile radius of the facility. Numerous wells of various use exist in all

directions surrounding the facility.

Based on the United States Environmental Protection Agency (USEPA) Unregulated Contaminant

Monitoring Rule 3 (UCMR3) data, no PFAS were detected in a public water system above the

USEPA lifetime Health Advisory (HA) within 20 miles of the facility. The HA is 70 parts per trillion

for PFOS and PFOA, individually or combined. PFAS analyses performed in 2016 had method

detection limits that were higher than currently achievable. Thus, it is possible that low

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

today.

1.5.3 Hydrology

There are no surface water bodies located within the HAATS facility property boundary, but there

are several nearby surface water areas designated by the US Fish and Wildlife Service (USFWS)
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

9

National Wetlands Inventory (USFWS, 2019). The “Chattfield and Bartholomew Ditch” is

designated as a freshwater emergent wetland or as riverine habitat, depending on location, and

encroaches on the southern and western boundaries of the facility. The “CKP Ditch” is also

designated as both freshwater emergent wetland and riverine habitat depending on location, and

it encroaches on the northern and western boundaries of the facility as well (USFWS, 2019).

Nearby surface water bodies are shown on Figure 1-3.

The HAATS 2017 Spill Prevention, Control, and Countermeasure Plan indicates that surface

runoff flow generally flows to the northwest, with some local flow to the southwest, on the flight

ramp to the immediate south of Building 1214 (COARNG, 2014). The facility also includes two

stormwater inlets on the north side of Building 1214 and an oil-water separator (OWS) near the

northeast corner of Building 1214. Surface water entering the stormwater inlets passes the OWS

and discharges to the storm system to the north that directs flow towards Eagle River (COARNG,

2014).

Stormwater runoff across the airport property drains to the north and west, into the Eagle River,

towards the Town of Gypsum. The EGE stormwater system is composed of open channels and

pipes directing the flow of water, and drainage basins to collect runoff. The majority of the airport

drains to the northwest, while the eastern edge of the airfield drains east before turning north

towards the Eagle River (EGE, 2014).

Sanitary services are provided through the Town of Gypsum, Public Works Department.

Wastewater is collected and processed through the Town’s nitrification/de-nitrification wastewater

treatment plant (WWTP) located approximately 2.6 miles west of the HAATS facility (EGE, 2014).

Sludge disposal is performed by a third party contractor.

Flood Insurance Rate Maps for Eagle County and the region immediately surrounding the airport

indicate that no flood zones are located within airport property. The nearest flood zone is north of

the airport by approximately one half mile (EGE, 2014).

1.5.4 Climate

Data from the EGE weather station indicate that the annual average temperature between 1981

and 2010 was 44.7 degrees Fahrenheit (oF) (National Oceanic and Atmospheric Administration

[NOAA], 2020). The warmest months are July and August, with normal daily average

temperatures of 67.2oF and 66.0oF, respectively. January is the coldest month, with an average

temperature of 21.3oF. Average annual precipitation measured from 1981 to 2010 at the airport

was 11.31 inches, with the most rain occurring July through September (NOAA, 2020). The

average annual snowfall for EGE, as reported by the Western Regional Climate Center, is 48

inches (Western Regional Climate Center, 2020). The majority of snowfall occurs between

December and January.

1.5.5 Current and Future Land Use

HAATS is the primary training center for ARNG helicopter pilots conducting high-altitude flying in

flying in mountainous terrain and/or high temperatures. HAATS is the only Department of Defense

Aviation Training site for high altitude power management environmental training. The facility

trains over 400 aircrews annually from all branches and components for the National Guard

Bureau and Fort Rucker as well as active Army, Army Reserves and International military

aircrews. The facility was recently expanded to add entirely new features and amenities, with the

ability for continued expansion. Future use of the HAATS facility is anticipated to remain the same.
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

10

EGE is the major conduit for commercial airline passengers to and from the Vail Valley. The

airport’s location provides access to the heart of the Colorado Rocky Mountains and is a short

drive to the Vail & Beaver Creek Ski Resorts, making EGE a primary gateway for tourists during

both winter and summer seasons (EGE, 2014). Future use of EGE is anticipated to remain the

same.
HAATS

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

JW

1/13/2020

1/13/2020

NOTES Preliminary Assessment for PFAS at HAATS, CO

1:63,360

1/13/2020 ­ Figure 1-1 PM RG 1/13/2020

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

Legend

Facility Boundary

^_

0 0.5 1 2

Miles

11
!5

A!

A!

A!

A!

!5 A!

A!

A! A!

A!

!P

!C(

A!

!P

!P

!P

!P

!P

!P

!5

!P

!P

!P

!P

!P

!P

!P

!P

!P

!P

!5

!P

!P

!5

!P !5

!5

!5

!P

!P

!5!5!5!5

!5

!P

!P

!P

!P

!P !P

!P

!P

!P !P

!P!P

!P

!P

!P

!P

!P

!P

!P

!P

!P

!P

Stremme and Gates Ditch

G yp sum

Cree k

CKP Ditch

Spring Creek

Casper Schumm Ditch

Daggett

and Parker D i ct

h

Alk ali Creek

McBrayer Ditch

Chatfield and Bar th olomew Dit ch

Eagle River

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JW

5/14/2020

5/14/2020

NOTES Preliminary Assessment for PFAS at HAATS, CO

1:31,680

5/14/2020 ­ Figure 1-2 PM RG 5/14/2020

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

Legend

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipe

Inferred Groundwater Flow

Direction

Geology

Gravels and Alluviums

Basalt Flows and assciated

tuff

Evaporitic Facies

Wells

!P Domestic Well

!P Commercial Well

!5 Industrial Well

!5 Irrigation Well

A! Monitoring/Sampling Well

!C( Municipal

0 0.25 0.5 1

Miles

Norgaard Water Treatment Plant

12
Cottonwoo d

Cre e k

Stremme an d Gates Ditc

CKP Ditch

h

Caspe r Schum m Ditch

Alkali Creek

Spring Creek

Eagle River

McHattenCreek

CKP Ditch

Daggett

and ParkerD i tch

Alk ali Creek

Chatfield and Bartholom ewDitch

Lower

Gypsum Creek

Watershed

Cottonwood

Creek

Watershed

Spring

Creek-Eagle

River Watershed

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JW

3/10/2020

3/10/2020

NOTES Preliminary Assessment for PFAS at HAATS, CO

1:31,680

3/10/2020 ­ Figure 1-3 PM RG 3/10/2020

12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

Legend

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipe

Surface Water Flow Direction

0 0.25 0.5 1

Miles

13
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

14

2. Fire Training Areas

FTAs are considered areas where deliberate discharge of AFFF or other firefighting materials is

performed for purposes of training personnel. One COARNG FTA was identified at the HAATS

facility during the PA through interviews and review of the EDRTM report for a 1-mile radius

surrounding the facility (Appendix A). Using additional online resources, such as state and local

GIS databases, wells were researched to a 4-mile radius of the facility. The FTA is shown on

Figure 2-1. According to interviewees, the EGE Fire Department responds to emergencies across

the airport property; however, the fire department performs their fire training activities in Denver,

Colorado. The EGE Fire Department Fire Station 10 is located south, across the runway from the

HAATS facility and is discussed in Section 5.

2.1 Flight Ramp FTA

HAATS facility personnel stated during interviews that annual fire training is performed near the

southeastern corner of Building 1214 on the flight ramp. The fire training involves the lighting of

diesel fuel in a drip pan and the subsequent extinguishing of the flames using ABC dry chemical

handheld fire extinguishers. According to interviewees whose collective tenure span the entire

history of the new HAATS facility (2013-present), no AFFF has ever been used during the annual

fire training. Records are not kept to document the annual training. Mobile Tri-MaxTM 30 Cold

Compressed Air Foam (CAF) fire extinguishers that contain AFFF are stored at the HAATS facility,

but they have never been used for fire training purposes. The extinguishers are capable of using

Class A foams, which do not include PFAS, but facility personnel stated that the Tri-MaxTM units

contain AFFF. Photographs of the Tri-MaxTM units, which were provided by COARNG, are included

in Appendix A. The Flight Ramp FTA is not considered a potential PFAS release area.
Stremme and Gates Ditch

CKP Ditch

Chatfield and Bartholomew Ditch

Flight

Ramp FTA

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JW

2/28/2020

2/28/2020

NOTES Preliminary Assessment for PFAS at HAATS, CO

1:3,600

2/28/2020 ­ Figure 2-1 PM RG 2/28/2020

12420 Milestone Center Drive

Germantown, MD 20876

Fire Training Area

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Canal/Ditch

0 150 300 600

Feet

15
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

16

3. Non-Fire Training Areas

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

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

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

features obtained during the PA are included in Appendices A and B. Several non-FTAs where

AFFF could have been stored and/or released at HAATS were identified during the PA. A

description of each non-FTA is presented below, and the non-FTAs are shown on Figure 3-1.

3.1 Building 1214

Construction of Building 1214 was completed in 2013, and the building is located on the western

end of the COARNG property. The building serves as the HAATS main hangar and includes

classroom areas, administrative office areas, and billets. The building is constructed with an AFFF

suppression system that contains Buckeye Premium 3% Military Specification AFFF concentrate.

Although the Safety Data Sheet for the AFFF product indicates that it does not contain PFOS or

PFOA, it is unknown whether it may contain or degrade into other PFAS compounds. The size of

the AFFF tank serving the fire suppression system is unknown. A data sheet for the AFFF product

is included in Appendix A. A 55-gallon drum containing the same AFFF concentrate product is

also stored within Building 1214. According to facility personnel whose collective tenure span the

entire history of Building 1214, the fire suppression system has never been tested in a manner

that released AFFF, nor has it been used in response to an emergency. The fire suppression

system is tested annually in an enclosed manner that cycles the AFFF concentrate without a

release. Regular maintenance of the alarm, pumps, and valves is also conducted without release.

Fueling of aircraft stored in Building 1214 occurs on the flight ramp south of Building 1214. Facility

personnel stated that fuel spills in the area are uncommon, and that AFFF is not used as a

precautionary measure in response to fuel spills. The EGE Fire Department responds to

emergencies at the HAATS facility, but no emergencies have occurred at Building 1214 requiring

emergency response.

Floor drains in Building 1214 connect to municipal sanitary sewers. Surface runoff that does not

enter floor drains at Building 1214 flows generally to the northwest, except on the southern side

of the building, where it flows southwest. Although AFFF is stored indoors at Building 1214, and

the fire suppression system undergoes regularly scheduled maintenance, the building has been

identified as a location for further PFAS investigation due to the storage of materials that

potentially contain PFAS.

3.2 HAZMAT Storage Area

Hazardous materials (HAZMATs) stored by the COARNG at the HAATS facility are kept in the

HAZMAT storage area located on the north side of Building 1214. The area is also used for the

storage of waste, and an aboveground storage tank containing diesel fuel is also staged in the

area. According to facility personnel, one Tri-MaxTM 30 Cold CAF fire extinguisher containing AFFF

is stored in the HAZMAT storage area; however, the Tri-MaxTM has never been used. The Tri-MaxTM

unit is in good condition, has no history of spills or leaking, and is inspected monthly for integrity; 

however, based on the corrosive nature of AFFF and the storage of the Tri-MaxTM outside, it is

possible that AFFF may have been released to the HAZMAT storage area. Tri-MaxTM inspection

records were not available for inclusion in this PA report. No emergencies requiring the use of the
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

17

Tri-MaxTM have occurred in the HAZMAT storage area, or anywhere else on the HAATS facility.

Additionally, COARNG personnel do not train with the Tri-MaxTM units. The EGE Fire Department

responds to emergencies at the facility. The type and concentration of AFFF stored within the unit

is unknown. A fire hydrant is also stationed adjacent to the HAZMAT storage area for use in

response to an emergency.

Due to the corrosive nature of AFFF and the storage of the Tri-MaxTM fire extinguisher outside, the

HAZMAT storage area is has been identified as a location for further PFAS investigation.

3.3 Flight Ramp

The Flight Ramp is located on the south side of Building 1214. The ramp is used for aircraft

maintenance as well as fueling and defueling. Fueling of the aircrafts is contracted to the VVJC.

According to interviewees, fuel spills are not responded to with precautionary AFFF discharge at

the HAATS facility. No incidents requiring AFFF use in response have occurred on the Flight

Ramp. Annual fire training with ABC dry chemical fire extinguishers is performed on the east end

of the ramp near the gravel area and taxiway.

Due to the non-use of the Tri-MaxTM fire extinguishers and absence of emergencies occurring on

the Flight Ramp requiring AFFF use, the Flight Ramp has not been identified as a location for

further PFAS investigation.

3.4 Parking Apron/Taxiway

The HAATS facility parking apron is located southeast of Building 1214 and is circumvented by a

taxiway. The apron is used for aircraft staging and maintenance. According to interviewees, no

incidents requiring AFFF use in response have occurred on the parking apron. Four Tri-MaxTM

wheeled mobile fire extinguishers containing AFFF are staged on the taxiway on the north side of

the parking apron. According to facility personnel, the Tri-MaxTM units are in good condition, have

no history of leaks or spills, have never been used at the HAATS facility, and are inspected

monthly for integrity; however, based on the corrosive nature of AFFF and the storage of the TriMaxTM units outside, it is possible that AFFF may have been released to the Parking Apron area.

Monthly inspection records for the Tri-MaxTM extinguishers were not made available for this PA

report. The type and concentration of AFFF stored within the Tri-MaxTM extinguishers are unknown.

Occasionally, water salutes are performed for retiring pilots on the taxiway on the southside of the

parking apron. The salutes involve EGE fire department firetrucks spraying water across the

taxiway while a grounded aircraft is taxiing. The water sprayed during the salutes likely travels

across the taxiway and parking apron on the HAATS property. Only water is sprayed during the

water salutes; however, it is possible the water is sprayed from EGE firetrucks that also store

AFFF.

Due to the corrosive nature of AFFF and the storage of the Tri-MaxTM units outside, and the

performance of water salutes across the facility’s southern taxiway, the Parking Apron has been

identified as a location for further PFAS investigation.
Parking Apron/Taxiway

HAZMAT

Storage

Flight Ramp

Building 1214

Stremme and Gates Ditch

CKP Ditch

Chatfield and Bartholomew Ditch

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

JW

4/8/2020

4/8/2020

NOTES Preliminary Assessment for PFAS at HAATS, CO

1:3,600

4/8/2020 ­ Figure 3-1 PM RG 4/8/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

Base Map: Source: Esri, DigitalGlobe, GeoEye,

Earthstar Geographics, CNES/Airbus DS, USDA, USGS,

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Canal/Ditch

0 150 300 600

Feet

18
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

19

4. Emergency Response Areas

COARNG staff confirmed that no known incidents requiring AFFF fire suppression have occurred

during their collective tenure spanning 32 years at the current and former HAATS facility.

Emergency responses to crashes sometimes require flame suppression, which may result in the

release of PFAS to the environment in the form of AFFF.
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

20

5. Adjacent Sources

Several potential off-facility sources of PFAS adjacent to the HAATS facility, not under the control

of the COARNG, were identified during the PA through interviews, review of the EDRTM report for

a 1-mile radius surrounding the facility (Appendix A), and historical document review. Using

additional online resources, such as state and local GIS databases, wells were researched to a

4-mile radius of the facility. A description of each potential adjacent source is presented below,

and the sources are shown on Figure 5-1

5.1 Vail Valley Jet Center

EGE has one fixed base operator on the airfield, the VVJC. The VVJC main hangar is located

south of the runway and east of the EGE commercial terminal. Services performed at the VVJC

include aircraft line service, apron parking, hangar storage space, on-site catering, and flight

planning. The VVJC also provides aircraft fueling along with aircraft maintenance and deicing.

The VVJC owns and operates two aboveground fuel storage tanks on the north airfield GA Apron

to support its fueling services, which includes fueling for HAATS aircraft operations. The VVJC

also occupies the former HAATS facility, Building 1213A. The VVJCs operation of Building 1213A

began in 2013, when the current HAATS facility finished construction. Building 1213A was

previously occupied by the COARNG and served as the former HAATS facility between 1990 and

2013. The VVJC currently uses Building 1213A for additional hangar space.

Information provided from an interview with the EGE Fire Department firefighter indicates that

Building 1213A had an AFFF bladder system that was never used or tested; however, COARNG 

personnel stated during telephone interviews that no known AFFF was ever used or stored in the

building. The tenure of COARNG personnel interviewed span the use of both the current and

former HAATS facility over 32 years.

It is unknown whether the main VVJC hangar space located on the south side of the runway uses

an AFFF suppression system, or whether AFFF has ever been used or stored in the area in

general. Due to the lack of available data surrounding both VVJC areas, they are considered

potential PFAS release areas.

5.2 Eagle County Regional Airport

EGE is a publicly owned facility consisting of 632 acres that operate as a commercial airport, and

its airfield configuration consists of one active runway, designated as Runway 7/25, that is

positioned nearly east/west. The asphalt taxiway system consists of one full length parallel

taxiway on the south side of Runway 7/25, one partial parallel taxiway on the north side, and

several connector taxiways. There are several aprons serving different needs at EGE. Both the

Commercial Aviation Apron and the GA Apron for the fixed base operators at the airport are

located south of the runway. There are two aprons located on the north side of Runway 7/25.

These aprons include the COARNG apron, which supports the HAATS facility, as well as an

additional GA Apron to the east of the HAATS facility, serving the associated GA hangars and the

VVJC.

The EGE commercial terminal was constructed in 1996, but the runway was dedicated for GA

services in 1947. The terminal is located on the west end of the main Commercial Aviation Apron.

Five airlines currently lease space throughout the terminal: American, Continental, Delta, United,

and United Express
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

21

EGE has several hangars on the airfield. VVJC provides the majority of hangar space on the main

GA Apron with four hangars. There is also one additional privately-owned corporate hangar on

the east end of the main GA Apron. On the GA Apron north of the runway, there are nine mediumsized hangars that are either airport or privately owned. In addition to the hangars, there are ten

airport-owned, T-Hangar style aircraft storage units.

Representatives of EGE were not interviewed as a part of this PA. As such, it is unknown whether

the any of the EGE facility hangars store or use AFFF or any other known PFAS-containing

materials.

A review of available information online indicated that several crashes have occurred at EGE. In

1983, a Learjet 25D was unable to stop on the snowy runway and continued down a 15-foot bank

and ran into a small ravine. No fire resulted from the crash. In 2005, a Gates Learjet 35A crashed

and came to rest in a shallow ravine approximately 331 feet north of the runway. The crash fire

was responded to by EGE Fire Department. In 2010, a Dassault Falcon 20C aborted its takeoff

attempt, was unable to stop on the runway, and eventually came to a rest on snow-covered terrain

beyond the runway. No fire resulted from the crash. In 2015, an amateur-built aircraft crashed into

a VVJC hangar and came to rest on the hangar parking ramp; no fires occurred. In 2017, a private

Cessna crashed onto a small road east of the EGE runway; it is unknown whether a fire occurred 

during the crash. It is unknown if AFFF were used in response to any of these crashes, whether

as an extinguishant for fires or as a precautionary measure. Summary reports available for the

crashes are included in Appendix A.

The EGE Fire Station 10, which is located on the south side of the EGE runway and west of the

commercial terminal, responds to emergencies at the airport and for airport tenants, including

COARNG. Due to the lack of available data regarding responses to crashes on the EGE runway

and its surrounding areas, and the propensity for runways to be used during nozzle testing and

fire training by airport fire departments, Runway 7/25 is considered a potential PFAS release area.

5.3 Eagle County Regional Airport Fire Department

The EGE Fire Station 10 is located south of the runway at the southwest corner of the EGE

Commercial Apron. The building was built in 1989 and serves as the administrative offices for

EGE staff, as well as the airport administration office, maintenance facility, and operations center.

Storage for airport snow removal equipment is located both inside the fire station and outside,

immediately adjacent to the west end of the building. Maintenance on equipment occurs at the

fire station inside the vehicle bays. There is additional storage for fire department equipment on

the north airfield, in storage buildings located between the HAATS facility and the GA hangars to

the east; however, firefighters with the EGE Fire Department stated that Aircraft Rescue and

Firefighting (ARFF) equipment has only ever been stored in the fire station on the south side of

the runway.

As a commercial airport, the EGE Fire Department must comply with FAA safety and emergency

requirements, including ARFF services. To comply with FAA ARFF requirements, the EGE Fire

Department has four active ARFF response vehicles for aircraft emergencies. According to the

2014 EGE Master Plan, these vehicles include one 2006 Oshkosh Striker 3000, one 1988

Oshkosh T-1500, one 1993 Oshkosh T-1500, and one 2004 Tote ARFF foam trailer (EGE, 2014).

According to interviewees, the EGE Fire Department trains in Denver, Colorado; however, it is 

unknown whether the fire department has ever trained within the EGE airport property, or whether
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

22

it has ever been necessary to use AFFF in response to an emergency on EGE property. According

to the EGE master plan, the fire department performs vehicle maintenance at Fire Station 10 ; 

however, it is unclear if any other maintenance, such as nozzle tests, are performed elsewhere at

the airport. Due to the likelihood that AFFF has been stored and/or released at the fire station as

a result of training and maintenance exercises, Fire Station 10 is considered a potential PFAS

release area.

5.4 Gypsum Fire Protection District

The Gypsum Fire Protection District is a combination fire department comprised of full-time and

part-time personnel as well as volunteer firefighters serving the Town of Gypsum. The Gypsum

Fire Protection District fire station is located approximately 2 miles west of the HAATS facility, in

the Town of Gypsum. It is unknown whether the fire department stores or uses AFFF during

training or emergency response. Given the tendency for local fire departments to store AFFF for

emergency purposes, it is possible AFFF is stored at the Gypsum Fire Protection District fire

station. It is also unclear whether the fire department performs vehicle maintenance, such as

nozzle tests, at the fire station. Due to the likelihood that AFFF has been stored and/or released

at the fire station as a result of potential training and maintenance, the Gypsum Fire Protection

District fire station is considered a potential PFAS release area.

5.5 Town of Gypsum WWTP

There are no WWTPs located at the COARNG HAATS facility. The Town of Gypsum WWTP is

the nearest WWTP and is located approximately 2.6 miles to the west, along the Eagle River.

WWTPs are not usually a primary potential release area of PFAS, but sludges and liquids from

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

contamination. No known PFAS releases have occurred at the HAATS facility, but AFFF releases

may have occurred elsewhere on the larger EGE property and could have resulted in the migration

of PFAS in water to the Town of Gypsum WWTP. If undocumented releases of AFFF have entered

floor drains at the HAATS facility, then it is possible the facility has contributed to PFAS migration

to and through the WWTP. The WWTP uses nitrification/de-nitrification technology to treat

wastewater. Sludge generated at the WWTP is removed and disposed of by a third party

contractor. The location of disposed sludge is unknown. Due to the potential for AFFF releases to

have occurred elsewhere on the EGE property and in the town of Gypsum, the WWTP is

considered a potential PFAS release area.
EGE Fire

Station 10

Gypsum Fire

Protection

District EGE Runway

7/25

Town of

Gypsum WWTP

EGE Commercial

Terminal

Vail Valley

Jet Center Hangar

Vail Valley Jet

Center Hangar

Vail Valley Jet Center -

Building 1213A

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center

Stremme and Gates Ditch

Gy psum

C

er

ek

CKP Ditch

Spring Cre ek

Casper Schumm Ditch

Alkali Creek

Chatfield and Bartholomew D itch

Eagle River

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipeline

0 1,100 2,200 4,400

Feet

­ Figure 5-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at HAATS, CO

2/28/2020

2/28/2020

2/28/2020

MS

JW

RG

GIS BY

CHK BY

PM

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

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

2/28/2020

1:16,510

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\CO\HAATS_figures\Fig_5-1_HAATS_Adjacent_Sources.mxd

Adjacent Sources

12420 Milestone Center Drive

Germantown, MD 20876

23
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

24

6. Preliminary Conceptual Site Model

Based on the PA findings, two AOIs were identified at the COARNG HAATS facility: AOI 1 Parking

Apron/Taxiway and AOI 2 HAZMAT Storage Area. The AOI locations are shown on Figure 6-1.

The following sections describe the CSM components and the specific preliminary CSM

developed for the AOIs. A CSM identifies three components necessary for an exposure pathway:

(1) source, (2) pathway, (3) receptor. If any of these elements are missing, the pathway is

considered incomplete.

In general, the potential PFAS exposure pathways are ingestion and inhalation. Human exposure

via the dermal contact pathway may occur, and current risk practice suggests it is an insignificant

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

continue to be the subject of PFAS toxicological study (National Ground Water Association, 2018).

Receptors at the HAATS facility include site workers, construction workers, trespassers and offfacility recreational users. The preliminary CSM diagram for the HAATS facility indicates which

specific receptors could potentially be exposed to PFAS

6.1 AOI 1 Parking Apron/Taxiway

AOI 1 includes the HAATS facility parking apron and taxiway where potential PFAS releases may

have occurred. Although no PFAS releases are known to have occurred since the construction of

the HAATS facility in 2013, the storage of Tri-MaxTM units outdoors on the parking apron and the

history of water salutes performed at the AOI may have led to environmental releases of AFFF.

If any releases of AFFF occurred on the parking apron, they would have occurred on the paved

apron surface and may have migrated to the unpaved or gravel surfaces surrounding the parking

apron depending on the location of the release. As such, it is possible that PFAS infiltrated

subsurface soil via cracks in pavement, joints between areas that are paved with different

materials, and surface soil in the unpaved and gravel areas surrounding the apron. If AFFF

released at the AOI infiltrated surface soil, then surface soil presents a potential pathway for PFAS

exposure to site workers, construction workers, and trespassers via ingestion and inhalation if

any PFAS has been released. If AFFF infiltrated subsurface soil, then ground-disturbing activities

may result in PFAS exposure to construction workers via ingestion and inhalation. Accidental

ingestion of groundwater during ground-disturbing activities is not considered a potential pathway

for exposure to PFAS due to the depth to groundwater at the HAATS facility.

Stormwater runoff at HAATS generally flows to the northwest with some local flow to the

southwest on the flight ramp near the northeast corner of AOI 1. Surface water runoff migrating

off-facility ultimately flows towards the Eagle River. As such, off-facility recreational users of the

Eagle River could ingest PFAS if any is present. Because the locations of the potential Eagle

River intake and T2 well are unknown, it is possible that PFAS migrating off-facility via surface

water may impact these water sources. As such, there is a potential pathway for PFAS exposure

to residents via ingestion of surface water if any PFAS has been released.

PFAS are water soluble and can migrate readily from soil to groundwater via leaching. Potable

and non-potable water are provided to EGE and its tenants (including the HAATS facility) through

the Town of Gypsum; no onsite wells provide drinking water to COARNG personnel. Two

commercial wells exist within several hundred feet of the facility to the north and northwest, and

two domestic wells and a commercial well exist within approximately 0.5 miles to the northeast.

Because of the presumed flow of groundwater north towards the Eagle River, these wells may be
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

25

cross-gradient or downgradient of the facility. As such, groundwater is considered a potential

exposure pathway for PFAS to off-facility residents using the domestic wells.

The AOI location is shown on Figure 6-1 and the preliminary CSM diagram for AOI 1 is shown in

Figure 6-2.

6.2 AOI 2 HAZMAT Storage Area

AOI 2 includes the HAATS facility HAZMAT storage area where potential PFAS releases may

have occurred. Although no PFAS releases are known to have occurred since the construction of

the HAATS facility in 2013, the storage of one Tri-MaxTM unit outdoors in the HAZMAT storage

area may have led to environmental releases of AFFF.

If any releases of AFFF occurred in the HAZMAT storage area, they may have occurred on paved,

grassy or gravel surfaces depending on the location of the release. As such, it is possible that

PFAS infiltrated subsurface soil via cracks in pavement, joints between areas that are paved with

different materials, and surface soil in the unpaved and gravel areas. As such, surface soil

presents a potentially exposure pathway for PFAS to site workers, construction workers, and

trespassers via ingestion and inhalation. Ground-disturbing activities may result in PFAS

exposure to construction workers via ingestion and inhalation of subsurface soil; however, they

are unlikely to create a pathway for construction workers to PFAS via ingestion of groundwater

due to the depth to groundwater at the HAATS facility.

Stormwater runoff at the AOI generally flows northwest but may also enter two stormwater inlets

on the north side of Building 1214. Surface water entering the stormwater inlets passes through

the OWS and discharges to the storm system to the north that directs flow towards Eagle River.

As such, off-facility recreational users of the Eagle River and residents may be exposed to PFAS

via ingestion.

PFAS may migrate readily from the surface to groundwater through infiltration. Groundwater at

the facility may flow towards commercial and domestic wells to the northwest and northeast. The

wells may be cross-gradient or downgradient of the facility depending on the local flow of

groundwater. As such, groundwater is considered a potential exposure pathway for PFAS to offfacility residents using the domestic wells. Groundwater may also discharge as surface water to

the Eagle River, presenting another pathway for PFAS exposure to recreational users of the Eagle

River.

The AOI location is shown on Figure 6-1 and the preliminary CSM diagram for AOI 2 is shown in

Figure 6-2.

6.3 AOI 3 Building 1214

AOI 3 comprises Building 1214, which is constructed with an AFFF suppression system that

contains Buckeye Premium 3% Military Specification AFFF concentrate. The building also stores

one 55-gallon drum containing the same AFFF product. No known AFFF releases have occurred

at Building 1214 since its construction, but it is conservatively considered an AOI based on the

potential for undocumented releases.

If any releases of AFFF occurred at AOI 3, they presumably occurred within the confines of the

building. Building 1214 floor drains connect to municipal sanitary sewers. AFFF entering sanitary

sewers may migrate to the Town of Gypsum WWTP and ultimately be discharged to the Eagle
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

26

River. As a result, downstream recreational users of the Eagle River may be exposed to PFAS in

surface water and sediment. Because the locations of the potential Eagle River intake and T2 well

are unknown, it is also possible that PFAS discharged as effluent from the WWTP may impact

these water sources. As such, surface water presents a potential exposure pathway for PFAS to

residents via ingestion.

PFAS is not expected to have escaped the Building 1214 confines based on the lack of known

AFFF system releases. Any AFFF releases are presumed to be of low volume and confined to

the tank room. As such, AFFF is not expected to have migrated to surface or subsurface soil

surrounding or beneath the building. PFAS is also not expected to have migrated to groundwater

as a result of potential AFFF releases at AOI 3.

The AOI location is shown on Figure 6-1 and the preliminary CSM diagram for AOI 3 is shown in

Figure 6-3.
!5

A!

A!

A!

A!

!5

A!

A!

A! A!

A!

!P

!C(

A!

!P

!P

!P

!P

!P

!5

!P

!P

!P

!P

!P

!5

!P

!P

!5

!P !5

!5

A!

!5

!P

!P

!P

!5 !5 !5 !5

!5

!P

!P

!P

!P

!P !P

!P

!P

!P !P

!P!P

!P

!P

!P

!P

!P

!P

!P

!P

EGE Fire

Station 10

Gypsum Fire

Protection

District

EGE Runway

7/25

Town of

Gypsum WWTP

EGE Commercial

Terminal

Vail Valley

Jet Center Hangar

Vail Valley Jet

Center Hangar

Flight Ramp FTA

Flight Ramp

Parking Apron/Taxiway

Building 1214

HAZMAT Storage

Vail Valley Jet Center -

Building 1213A

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center

AOI 1

AOI 2

AOI 3

Lower Gypsum

Creek

Watershed

Spring Creek-Eagle

River Watershed

Outlet Eagle

River

Watershed

Stremme and Gates Ditch

G y psum

Creek

CKP Ditch

Spring Creek

Casper Schumm Ditch

Alkali Creek

Chatfield and Bartholomew D itch

Eagle River

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipe

!P Domestic Well

!P Commercial Well

!5 Industrial Well

!5 Irrigation Well

A! Monitoring/Sampling Well

!C( Municipal

0 690 1,380 2,760

Feet

­ Figure 6-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at HAATS, CO

4/8/2020

4/8/2020

4/8/2020

MS

JW

RG

GIS BY

CHK BY

PM

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

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

4/8/2020

1:16,560

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\CO\HAATS_figures\Fig_6-1_HAATS_AOIs.mxd

Area of Interest

12420 Milestone Center Drive

Germantown, MD 20876

27
Media

SOURCE PATHWAY RECEPTOR

AOI 1 – AOI 2

Potential AFFF

release from TriMax units stored

outside and

water salutes

PFAS in

Surface

Soil / Paved

Surfaces

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure 6-2

Preliminary Conceptual Site Model

AOI 1 (Parking Apron) and AOI 2 (HAZMAT Storage Area)

Potential

Off-Facility

Source Not

under

Control of

ARNG

Tresspasser/

Recreational User

Tresspasser/

Recreational User

Notes:

1. The resident and recreational user

receptors refer to an off-site resident and

recreational user.

2. The site worker and construction worker

receptors refer only to COARNG HAATS site and

construction workers.

3. Dermal contact exposure pathway is

incomplete for PFAS.

Flow-Chart Stops

28
Media

SOURCE PATHWAY RECEPTOR

AOI 3

Potential AFFF

releases from

fire suppression

system

PFAS in

Sanitary

Sewers

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident

Site

Worker

Construction

Worker Resident

/ / / /

/ / / /

LEGEND

/ / / /

/ / / /

/ / / /

Figure 6-3

Preliminary Conceptual Site Model

AOI 3 (Building 1214)

Potential

Off-Facility

Source Not

under

Control of

ARNG

Tresspasser/

Recreational User

Tresspasser/

Recreational User

Notes:

1. The resident and recreational user

receptors refer to an off-site resident and

recreational user.

2. The site worker and construction worker

receptors refer only to COARNG HAATS site and

construction workers.

3. Dermal contact exposure pathway is

incomplete for PFAS.

Flow-Chart Stops

29
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

30

7. Conclusions and Data Uncertainty

This report presents a summary of available information gathered during the PA on the use and

storage of AFFF and other PFAS-related activities at the COARNG HAATS facility. The PA findings

are based on personnel interviews, environmental investigations and reports, and historical

documents (Appendix A and Appendix B).

7.1 Findings

Three AOIs related to potential PFAS releases were identified at the HAATS facility based on PA

data (Figure 7-1) and is summarized in Table 7-1 below:

Table 7-1: AOIs at HAATS

Area of Interest Name Used by Potential Release Dates

AOI 1 Parking

Apron/Taxiway

COARNG 2013 – present

AOI 2 HAZMAT

Storage Area

COARNG 2013 – present

AOI 3 Building 1214 COARNG 2013 – present

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

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

inhalation; in subsurface soil to construction workers via ingestion and inhalation; and in surface

water and sediment to off-facility residents and recreational users via ingestion. Additionally,

commercial and domestic wells located cross-gradient and downgradient of HAATS create a

potentially complete pathway for PFAS exposure to off-facility residents via ingestion of

groundwater.

Several adjacent sources of potential PFAS release were identified within the EGE airport

property and surrounding areas. It is possible that a potential PFAS release at one of the adjacent

sources identified may have contributed to PFAS within soil, groundwater, surface water, or

sediment at the airport property and surrounding areas, including the HAATS facility. Potential

adjacent sources are shown on Figure 7-1.

The following areas discussed in Section 2 and Section 3 were determined to have no suspected

PFAS releases to the environment (Table 7-1):

Table 7-2: No Suspected Release Areas

No Suspected

Release Area Used by Rationale for No Suspected Release Determination

Flight Ramp COARNG Readily available information indicates no evidence of

AFFF stored or use at this location.

7.2 Uncertainties

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

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

HAATS, Gypsum, Colorado

31

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

records were not typically kept by the COARNG on the storage, use, or disposition of AFFF.

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

environmental reports, EDRsTM and interviews. Interviews of personnel with direct knowledge of

a facility generally provided the most useful insights regarding a facility's historical and current

PFAS-containing materials. Sometimes, the provided information was vague or conflicted with

other information sources. For example, information provided from an interview with the EGE Fire

Department firefighter indicated that the adjacent Building 1213A had an AFFF bladder system

that was never used or tested; however, COARNG personnel stated during telephone interviews

that no known AFFF was ever used or stored in the building. Gathered information has a degree

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

direct knowledge, the time passed since PFAS were first used by the ARNG (1969 to present),

and a reliance on personal recollection. Inaccuracies may arise in potential PFAS storage

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

PFAS may enter the environment continually evolves.

In order to minimize the level of data limitations, readily available data regarding storage of PFAS

were reviewed, tenured personnel were interviewed, multiple persons were interviewed for the

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

Table 7-2 summarizes the limitations in data associated with areas identified within the COARNG

property:

Table 7-3: Sources of Uncertainties

Location Source of Uncertainty

Building 1214 The size of the AFFF tank serving the building fire suppression system is

unknown, and the total volume of AFFF stored within the facility is

unknown. Inspection and maintenance records for the AFFF fire

suppression system were not made available during this PA, and the fire

suppression system condition is based on interviewee-provided

information. It is also uncertain whether the AFFF concentrate product

stored in Building 1214 contains any PFAS compounds.

HAZMAT

Storage Area

The type and concentration of AFFF stored within the Tri-MaxTM unit stored

in the Hazmat storage area are unknown.

Parking

Apron/Taxiway

The type and concentration of AFFF stored within the Tri-MaxTM units stored

on the parking apron are unknown. It is also unknown whether water

salutes performed on the taxiway south of the parking apron are performed

with fire department vehicles that also use AFFF, or whether water from

these salutes migrates onto the COARNG property.

Town of

Gypsum WWTP

No documentation stating that effluent from the Town of Gypsum WWTP

discharges to the Eagle River was obtained for this PA, but effluent is

presumably discharged to the Eagle River based on the WWTP location.

7.3 Potential Future Actions

Interviews with HAATS facility personnel, whose collective tenure span 32 years at the current

and former HAATS facility, and records indicate that current or former ARNG activities have not

resulted in PFAS releases at the HAATS facility. Based on the storage of AFFF Tri-MaxTM units

outside and the history of water salutes performed however, incidental PFAS releases may have
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

32

occurred at the facility. Based on the preliminary CSM developed for the AOIs, there is potential

for PFAS to be exposed to human receptors (see Section 7.1). Table 7-4 summarizes the

rationale used to determine if the AOIs should be considered for further investigation under the

CERCLA process and undergo an SI.

Table 7-4: PA Findings Summary

Area of Interest AOI Location Rationale Potential Future

Action

AOI 1 Parking

Apron/Taxiway

39°38'41.54"N; 

106°54'48.54"W

Potential AFFF releases from

Tri-Max units stored outside.

Proceed to an SI, focus

on soil and groundwater.

AOI 2 HAZMAT

Storage Area

39°38'45.51"N; 

106°54'55.54"W

Potential AFFF releases from

Tri-Max units stored outside.

Proceed to an SI, focus

on soil and groundwater.

AOI 3 Building

1214

39°38'43.50"N; 

106°54'56.06"W

Potential AFFF releases from

fire suppression system and

drum.

Proceed to an SI, focus

on surface water.

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

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

Station 10

Gypsum Fire

Protection

District

EGE Runway

7/25

Town of

Gypsum WWTP

EGE Commercial

Terminal

Vail Valley

Jet Center Hangar

Vail Valley Jet

Center Hangar

Flight Ramp FTA

Flight Ramp

Building 1214 Parking Apron/Taxiway

HAZMAT Storage

Vail Valley Jet Center - Building 1213A

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center Hangar

Vail Valley

Jet Center

AOI 1

AOI 2

AOI 3

CasperSchumm Ditch

Stremme and Gates Ditch

Gypsum

Cree k

CKP Ditch

Eagle River

CKP Ditch

Spring Creek

AlkaliCreek

Chatfield and Bartholomew Ditch

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipe

0 750 1,500 3,000

Feet

­ Figure 7-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Preliminary Assessment for PFAS at HAATS, CO

4/8/2020

4/8/2020

4/8/2020

MS

JW

RG

GIS BY

CHK BY

PM

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

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

4/8/2020

1:18,000

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\CO\HAATS_figures\Fig_7-1_HAATS_Summary.mxd

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Parking

Apron/Taxiway

Building 

1214

HAZMAT

Storage

Flight Ramp FTA

Flight Ramp

AOI 1

AOI 2

AOI 3

33
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

34

8. References

AMEC, 2010. Phase I Environmental Site Assessment; HAATS Facility – Gypsum, Colorado. April

2010.

Barkmann, Peter E., Lauren D. Broes, Martin J. Palkovic, John C. Hopkins, Kenneth Swift Bird,

Lesley A. Sebol, and F. Scot Fitzgerald, 2020. ON-010 Colorado Groundwater Atlas.

Geohydrology. January 8, 2020. https://coloradogeologicalsurvey.org/water/coloradogroundwater-atlas/. (Accessed February 2020).

COARNG, 2017. Spill Prevention, Control and Countermeasure Plan; High Altitude Aviation 

Training Site. August 2017.

EGE, 2014. Eagle County Regional Airport Master Plan. February 11, 2014.

https://www.flyvail.com/about/master-plan. (Accessed January 2020).

House Bill 19-1279, 2019 Regular Session (Co. 2019). Concerning the use of Perfluoroalkyl and

Polyfluoroalkyl Substances, and, in Connection Therewith, Making an Appropriation.

http://leg.colorado.gov/bills/hb19-1279. Approved June 3, 2019.

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

Practice. January.

National Oceanic and Atmospheric Administration, 2020. Data Tools: 1981-2010 Normals.

https://www.ncdc.noaa.gov/cdo-web/datatools/normals. (Accessed January 2020).

United States Department of Agriculture (USDA), 2019. Natural Resources Conservation Service

Web Soil Survey. https://websoilsurvey.nrcs.usda.gov/app/. (Accessed February 2020).

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

Preliminary Assessments under CERCLA. September.

United States Fish and Wildlife Service (USFWS), 2019. National Wetlands Inventory Mapper.

https://www.fws.gov/wetlands/data/mapper.html. (Accessed December 2019).

United States Geological Survey (USGS), 1978. Geologic Map of the Leadville 1o x 2o

Quadrangle, Northwestern Coloroado, Compiled by Tweto, Ogden, Moench, R.H., and Reed,

J.C.. https://ngmdb.usgs.gov/Prodesc/proddesc_9855.htm. (Accessed February 2020).

USGS, 2009. Groundwater Quality, Age, and Probability of Contamination, Eagle River

Watershed Valley-Fill Aquifer, North-Central Colorado, 2006–2007. Scientific Investigations

Report 2009–5082. https://pubs.usgs.gov/sir/2009/5082/. (Accessed February 2020).

Western Regional Climate Center, 2020. Cooperative Climatological Data Summaries: NOAA

Cooperative Stations – Temperature and Precipitation. https://wrcc.dri.edu/cgibin/cliMAIN.pl?co2454. (Accessed January 2020).
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

Appendix A

Data Resources
PFAS Preliminary Assessment Report

HAATS, Gypsum, CO

Data resources will be provided separately on CD. Data resources for HAATS include:

Facility Real Property Documents

• 2016 HAATS Facility Parcel Consolidation Lease Amendment

Background Information Sources

• 2010 Phase I Environmental Site Assessment for the HAATS Facility – Gypsum, Colorado

• 2016 Town of Gypsum Drinking Water Quality Report

• 2017 HAATS Spill Prevention, Control and Countermeasure Plan

• 2019 EGE Fire Department Interview Questionnaire

• 2019 HAATS Facility Personnel Interview Questionnaire

EDRTM Report

• 2020 HAATS EDRTM Report 

Facility PFAS Material Information

• Buckeye Premium 3% Military Specification AFFF Concentrate Data Sheet

• Buckeye C6-3% Mil Spec AFFF Safety Data Sheet

• HAATS Facility Tri-Max 30 Unit Label Photograph

• HAATS Facility Tri-Max 30 Unit Photograph

Aircraft Crash Reports

• 2005 National Transportation Safety Board Aviation Accident Final Report; Accident

Number DEN05LA111

• 2010 National Transportation Safety Board Aviation Accident Final Report; Accident

Number CEN10LA093

• 2015 National Transportation Safety Board Aviation Accident Final Report; Accident

Number CEN15FA257
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

Appendix B.1

Interview Records
ARNG Preliminary Assessments for PFAS

Telephone Interviews

Colorado ARNG Facilities: Fort Carson, HAATS, Buckley AASF

18 December 2019

1000 to 1145 hrs

Name Affiliation Facility Role

ARNG NA

CPT ARNG NA

USACE NA

USACE NA

AECOM NA

AECOM NA

AECOM NA

Arcadis NA

Arcadis NA

CPT COARNG Environmental Protection Specialist

COARNG Environmental Compliance Manager

CPT COARNG 153rd Military Police Battalion Sustainment Officer

SGT COARNG Unit Environmental Compliance Officer

SSG COARNG 1157

th Engineer Company Supply Sergeant 

COARNG Environmental Protection Specialist (retired)

1SG COARNG Unit Environmental Compliance Officer at HAATS

COARNG Western Region Maintenance Supervisor at HAATS

COARNG Facility Maintenance Supervisor at Buckley AFB

HAATS Discussion:

1SG (32 years’ experience) – Building 1213A is the former HAATS but is no 

longer owned/operated by the COARNG; it was turned over to the Vail Valley Jet Center. The 

COARNG HAATS property no longer encompasses that hangar. Building 1213A was first 

occupied by the COARNG circa 1990. It did not have an AFFF system, or AFFF storage at the 

time. It was previously used as a hangar for non-DoD purposes.

Building 1214 is the current HAATS, which was first occupied by the COARNG in 2013 after its 

construction. The building has an AFFF suppression system that uses Buckeye 3% AFFF 

concentrate. There have been no known AFFF system tests that resulted in the release of AFFF. 

AFFF is cycled annually in an enclosed manner for maintenance. The system test 

alarm/pump/valves also undergo regular maintenance, but no known releases have occurred. A 55-

gallon drum of Buckeye 3% AFFF concentrate is also stored within Building 1214. The building 

is connected to sanitary system sewers.

Eagle County has a fire department located at the airport that is the first responder to emergencies 

at HAATS as well as the larger airport property. The fire department has never had to respond to 

an emergency at HAATS with AFFF. The county fire department performs their fire training in 
Denver, CO. No crashes have occurred at the HAATS facility that would require AFFF response. 

It is unknown whether any significant crashes have occurred elsewhere on the airport property.

5 mobile fire extinguishers (trimaxes) are stored at the HAATS facility 1 trimax is stored near the 

hazardous material storage on the north side of Building 1214, the other 4 are stored on the taxiway 

on the north side of the flight ramp near the gravel area. The trimaxes will be emptied into 55-

gallon drums for disposal in the future. They all appear in good shape, and have no history of spills 

or leaking. They are inspected monthly for integrity.

Annual fire training is performed on the flight ramp/taxiway area near the southeastern corner of 

Building 1214. The training involves the lighting of diesel fuel in a drip pan and extinguish the 

flames with ABC fire extinguishers. No AFFF is used.

Fueling of HAATS aircraft is performed on the ramp south of Building 1214. The work is 

contracted to Vail Valley Jet Center who provides the fuel. Fuel spills are rare, and no AFFF has 

ever been used in response to a fuel spill.

Water salutes are performed for retiring pilots occasionally on the HAATS facility. The event 

involves fire trucks spraying water across the flight ramp/taxiway during the landing of an aircraft. 

Water is likely sprayed onto the HAATS facility from fire trucks. 

– The former HAATS building was occupied by COARNG in 1990. Prior to that, it 

was used as a private hangar space. It was renovated for COARNG use, but the type and contents 

of the prior suppression system are unknown. Mr. has observed the former HAATS in recent

(“last few”) years and observed no AFFFF.

There are no metal plating or industrial laundry facilities at HAATS. There have been no known 

creative/non-technical uses of AFFF at HAATS.

CPT (2009-present) – The HAATS facility is served by the by the Town of Gypsum 

public utilities/drinking water. There are no monitoring wells at the facility. Depth to water and 

other information may be available in 2010 ESA. 

Summary:

• There is no known use or accidental release of AFFF at HAATS. 

• AFFF is stored in the Building 1214 fire suppression system and in a 55 gallon drum stored 

in Building 1214. 

• Trimax units are stored at the facility near the hazardous material storage area and the flight 

ramp. The trimaxes contain AFFF.

• The airport fire department, which may have AFFF, has never used AFFF at HAATS. 

• The former HAATS, which is no longer a part of the COARNG property, has never stored 

AFFF to the knowledge of interviewees. No known use has occurred at the former HAATS. 
PFAS Preliminary Assessment Report

HAATS, Gypsum, Colorado

Appendix B.2

Conceptual Site Model Information
Preliminary Assessment – Conceptual Site Model Information

Site Name:

Why has this location been identified as a site?

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

Training Events

Have any training events with AFFF occurred at this site?

If so, how often?

How much material was used? Is it documented?

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

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

pathways to larger water bodies?

Surface Water:

Surface water flow direction?

Average rainfall?

Any flooding during rainy season?

Direct or indirect pathway to ditches?

Direct or indirect pathway to larger bodies of water?

Does surface water pond any place on site?

Any impoundment areas or retention ponds?

Any NPDES location points near the site?

How does surface water drain on and around the flight line?

High Altitude Aviation Training Site (HAATS)

The site is located at an airport and stores aviation assets.

Yes, the facility is located at the Eagle County Regional Airport (EGE)

No

NA

NA

Generally north towards Eagle River

11.31 inches

None

Direct (stormwater networks, drainage ditches)

Indirect (stormwater network connects to Eagle River)

No

No

Unknown

To the north
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction?

Depth to groundwater?

Uses (agricultural, drinking water, irrigation)?

Any groundwater treatment systems? 

Any groundwater monitoring well locations near the site?

Is groundwater used for drinking water?

Are there drinking water supply wells on installation?

Do they serve off-post populations?

Are there off-post drinking water wells downgradient 

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present?

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

Do we understand the fate of sludge waste?

Is surface water from potential contaminated sites treated?

Equipment Rinse Water

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

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

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

3. Other?

Inferred to flow north

86 ft bgs

Groundwater not used on facility.

No at HAATS

Yes

No

No

NA

Commercial and domestic wells located downgradient

No, wastewater is transferred to the Gypsum WWTP

NA

The location of sludge disposal is unknown

The town of Gypsum WWTP potentially treats PFAS-laden water offsite in the town of Gypsum

HAATS does not store firetrucks, but does have Tri-Max units. They are inspected monthly

for integrity. No known washing/rinsing occurs.

Nozzle testing does not occur.
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker 

Construction Worker 

Recreational User

Residential 

Child 

Ecological

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

Documentation

Ask for Engineering drawings (if applicable).

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

No known releases, no potential receptors

No known releases, no potential receptors

No known releases, no potential receptors

No known releases, no potential receptors

No known releases, no potential receptors

No known releases, no potential receptors

Residential areas approximately 1 miles west, elementary and high schools approximately 1.5 miles west, and

Former HAATS facility was located approximately 900 ft east of the current building, which

is now operated by the Vail Valley Jet Center. The current HAATS was constructed in 2013.