FINAL

Site Inspection Report

Army Aviation Support Facility

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
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TABLE OF CONTENTS

Page

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.2.4 Climate ...................................................................................... 2-4

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

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

2.3 History of PFAS Use ............................................................................... 2-5

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

3.1 AOI 1 – Fire Suppression System Releases ............................................. 3-1

3.2 AOI 2 – System Testing Area .................................................................. 3-2

3.3 AOI 3 – Infiltration Gallery ..................................................................... 3-2

3.4 Adjacent Sources ..................................................................................... 3-3

3.4.1 The Electropac Worldwide Inc. (former Vishay Sprague Facility)

 .................................................................................................. 3-3

3.4.2 The Richard M. Flynn Fire Academy ....................................... 3-3

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

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

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

5.1 Pre-Investigation Activities ..................................................................... 5-2

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

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

5.1.3 Source Water and PFAS Sampling Equipment Acceptability.. 5-2

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 ....................................................................................................... 6-4

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

6.5 AOI 3 ....................................................................................................... 6-5

6.5.1 AOI 3 Soil Analytical Results................................................... 6-5

6.5.2 AOI 3 Groundwater Analytical Results.................................... 6-5

6.5.3 Conclusions............................................................................... 6-5

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

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

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

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

7.1.3 AOI 3 ........................................................................................ 7-2
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7.2 Groundwater Exposure Pathway.............................................................. 7-3

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

7.2.2 AOI 2 ........................................................................................ 7-4

7.2.3 AOI 3 ........................................................................................ 7-4

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
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LIST OF FIGURES

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Surface Water Features

Figure 2-5 Groundwater Elevations, 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

Figure 7-3 Conceptual Site Model, AOI 3
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LIST OF TABLES

Table ES-1 Screening Levels (Soil and Groundwater)

Table ES-2 Summary of Site Inspection Findings and Recommendations

Table 5-1 Samples by Medium, Army Aviation Support Facility, Concord, New Hampshire, 

Site Inspection Report

Table 5-2 Soil Boring Depths and Temporary Well Screen Intervals, Army Aviation 

Support Facility, Concord, New Hampshire, Site Inspection Report

Table 5-3 Groundwater Elevation, Army Aviation Support Facility, 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, Army Aviation Support Facility

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

Site Inspection Report, Army Aviation Support Facility

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

Inspection Report, Army Aviation Support Facility

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

Report, Army Aviation Support Facility

Table 8-1 Summary of Site Inspection Findings and Recommendations
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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

AGQS Ambient Groundwater Quality Standards

amsl Above mean sea level

ANG Air National Guard

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

DA Department of the Army

DoD Department of Defense

DOT Department of Transportation

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)

HDPE High-density polyethylene

HFPO-DA Hexafluoropropylene oxide dimer acid

HQ Hazard Quotient

GAC Granular activated carbon
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GPR Ground-penetrating radar

GPS Global positioning system

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 

NGB National Guard Bureau 

ng/L Nanogram(s) per liter

NHDES New Hampshire Department of Environmental Services

NH HB New Hampshire House Bill

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
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SL Screening level

SMR State Military Reservation

TOC Total organic carbon

TPP Technical Project Planning

UCMR 3 Third Unregulated Contaminant Monitoring Rule

UFP Uniform Federal Policy 

USACE US Army Corps of Engineers

USEPA US Environmental Protection Agency

Wood Wood Environment & Infrastructure Solutions, Inc.

WSP WSP USA Environment & Infrastructure Inc.
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EXECUTIVE SUMMARY

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

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

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

memorandum regarding Investigating Per- and Polyfluoroalkyl Substances within the 

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

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

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

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

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

. These compounds are 

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

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

The PA identified three 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 Army Aviation Support Facility (AASF) 

in Concord, New Hampshire and determined that further evaluation under the Comprehensive 

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

AOI 2, and AOI 3. The AASF will also be referred to as the “Facility” throughout this document.

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

26 acres in Concord, New Hampshire. The AASF is located at 26 Regional Drive in Concord, 

Merrimack County, New Hampshire. The Facility is near the southeastern city limits, east of 

Interstate 93 and south of Interstate 393. The area surrounding the AASF 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 portions of the Concord Municipal Airport 

and the NHARNG State Military Reservation (SMR) to the west. Conservation/Public Lands are 

located approximately 0.45 miles to the southeast, adjoining the Soucook River. Operations at 

the AASF include aviation training and maintenance, modification, and repair of rotary-winged 

aircraft.

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

three 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 CERCLA is warranted in a Remedial 

Investigation (RI) for AOI 1, AOI 2, and AOI 3. 

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

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

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

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

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

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

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

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 Fire Suppression 

System Releases Proceed to RI

2 System Testing Area Proceed to RI

3 Infiltration Gallery Proceed to RI

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
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1. INTRODUCTION

1.1 PROJECT AUTHORIZATION

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

Assessments (PAs) and 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 Army Aviation Support Facility (AASF) in Concord, New Hampshire. The AASF 

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 AASF (AECOM Technical Services, Inc. [AECOM] 2019) that 

identified three 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.
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2. FACILITY BACKGROUND

2.1 FACILITY LOCATION AND DESCRIPTION

The AASF is located at 26 Regional Drive in Concord, Merrimack County, New Hampshire 

(Figure 2-1). The Facility is 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°12'33.50"N; 71°30'8.21”W at 346 feet (ft) above mean sea level (amsl).

According to the PA (AECOM 2019), the NHARNG, by and through the Office of the Adjutant 

General, entered into a lease with the city of Concord in 2002 for the use and occupancy of 26 

acres of land adjacent to the Concord Municipal Airport for 50 years. Prior to this time, the 

property was an undeveloped section of the Concord Municipal Airport. The current AASF 

building was constructed in 2004, and in 2004, the NHARNG moved AASF operations to the 

newly constructed AASF from the previous Building K location at the State Military Reservation 

(SMR). The AASF building occupies 98,900 square feet and consists of administrative offices, a 

hangar for the storage and maintenance of helicopters, a building for the maintenance and 

storage of fueling trucks, a jet fuel storage and filling area, and a hangar apron connected to the 

Concord Municipal Airport airfield (Tighe & Bond 2018; AECOM 2019). Construction of a new 

Readiness Center addition to the AASF building began in 2021. Construction is ongoing as of 

November 2022. 

Operations at the AASF include aviation training and maintenance, modification, and repair of 

rotary-winged aircraft. The AASF is closed to the public, with a 6-foot chain-link fence 

surrounding the Facility. Access to the Facility is through a locked gate that requires an 

electronic security badge (AECOM 2019).

2.2 FACILITY ENVIRONMENTAL SETTING

The AASF 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 a 

population of approximately 43,000 people, according to the US Census (US Census 2018; 

AECOM 2019).

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

high of the Facility (approximately 345 ft amsl) is located west of the Main Hangar, on a hill 

constructed for aircraft landing practice. Much of the Facility is paved with either asphalt or 

concrete, with unpaved grassy areas along the boundaries of the Facility.

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

current and future land use. The topography at the Site 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. 
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2.2.1 Geology

Regional geology consists of unconsolidated glacial material overlying igneous and metamorphic 

rocks. The unconsolidated material was 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 (USAEHA 1993; AECOM 2019). Geologic features in the vicinity of 

the Facility are shown on Figure 2-3.

Bedrock in the vicinity consists predominantly of moderately fractured, medium-grained, twomica granite of the Concord Granite Formation. Additional nearby formations (Lower Rangley, 

Upper Rangley, and Perry Mountain Formations) consist of metasedimentary phyllite, schist, and 

quartzite. The bedrock surface generally slopes downward from west to east (GZA 

GeoEnvironmental, Inc. 2010; AECOM 2019).

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

streams that also carried gravel, sand, silt, and clay. The shallowest layer is an approximately 25-

to 50-foot-thick 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 48 ft bgs. The soil was classified as well 

graded sand with varying levels of fines and cobbles overlying primarily poorly graded sand with 

increasing levels of silt with depth as the dominant lithology of the unconsolidated sediments 

below the AASF. Orange banding was observed between 5 and 48 ft bgs. Samples for grain size 

analyses were collected at the three AOIs at locations AOI01-04, AOI02-02, and AOI03-02. The 

results indicate that the soil samples are comprised primarily of sand (64.7% to 85.5%) and silt

(11.0% to 26.1%). 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

Based on investigations at the Electropac Worldwide Inc. site (former Vishay Sprague site), 

located immediately north, and hydraulically upgradient of the AASF, groundwater in the 

vicinity is between 30 and 50 ft below ground surface (bgs) and flows to the west/southwest in 

the overburden toward the Merrimack River, which is located approximately 1 mile 
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west/southwest of the Facility (GZA GeoEnvironmental, Inc. 2018; AECOM 2019). 

Groundwater features in the vicinity of the Facility are shown on Figure 2-3.

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 ft 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).

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

supply wells at the AASF or within a 1-mile radius (EDR 2019; AECOM 2019). A domestic 

well and commercial well are present 0.5 miles and 0.75 miles east of the AASF, respectively. 

Locations of the wells identified in the PA are shown on Figure 2-3.

The AASF is serviced by municipal water from the city of Concord. Third Unregulated 

Contaminant Monitoring Rule (UCMR 3) data were reviewed as part of the PA. PFAS were nondetect for 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 4.5 miles northwest 

of the Facility near the Concord Water Department treatment plant. 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 2019; AECOM 

2019). The Pembroke well field is approximately 1.2 miles southeast of the Facility, on the 

opposite side of the Soucook River. 

Depths to water measured in June 2022 during the SI ranged from 28 to 46 ft bgs. Groundwater 

elevations indicate that local groundwater flow is generally to the southwest; however, localized 

groundwater mounding was observed at AOI01-03, likely due to the proximity of the infiltration 

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

the groundwater flow direction at the AASF is primarily to the southwest. 

2.2.3 Hydrology

The AASF 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 1 mile to the 

west/southwest of the Facility, and the Soucook River, located approximately 0.6 miles to the 

south/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; 
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Concord Monitor 2013; AECOM 2019) and the depth to groundwater in the area (approximately 

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

(AECOM 2019). Surface water features in the vicinity of the Facility are shown on Figure 2-4.

Stormwater at the Facility is collected from the parking lots, the main apron, and landscaped 

areas around the buildings and is discharged into a stormwater pre-treatment system, followed by 

a three-tiered underground infiltration gallery before infiltration to groundwater. The stormwater 

treatment system is located on the west side of the hangar apron. Stormwater from the roof of the 

AASF building is discharged to a separate infiltration gallery located in the northeast corner of 

the property (Tighe & Bond 2018; AECOM 2019).

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, contributing 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 AASF property 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, with unpaved 

grassy areas along the boundaries of the Facility. West of the Main Hangar, there is a hill 

constructed for sloped landing training for the UH-60 (Blackhawk). The AASF is responsible for 

various training activities and aircraft maintenance with an active ARNG lease until 2052. 

Activities and land use within the Facility are not expected to change.

The area surrounding the AASF 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 portions of the Concord Municipal Airport and the SMR to the west. 

Conservation/Public Lands are located approximately 0.45 miles to the southeast, adjoining the 

Soucook River. No additional mapped priority resources are located within a half-mile radius 

(Tighe & Bond 2018; AECOM 2019). Future land use of the surrounding area is anticipated to 

remain the same.

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 AASF. According to Facility personnel, the Grasshopper Sparrow, a Statethreatened grassland bird, is often sighted in the vicinity of the AASF Facility. According to 

Facility personnel, the Karner Blue Butterfly is also known to exist on airport property and is 

monitored and managed by the New Hampshire Fish and Game Department.
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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 Small Whorled Pogonia 

Isotria medeoloides

2.3 HISTORY OF PFAS USE

The PA identified three AOIs where aqueous film-forming foam (AFFF) may have been used, 

stored, disposed, or released historically at the Concord AASF: fire suppression system releases, 

system testing area, and the infiltration gallery. There was one additional documented release of 

AFFF after the PA was finalized. Approximately 100 gallons of a mixture of AFFF and water 

was discharged near the loading dock in June 2021; however, a new AOI was not designated for 

this release since the AFFF was contained within the bounds of AOI 2. A description of each 

AOI is presented in Section 3. 
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Figure 2-1

Facility Location

3

0 1

Miles

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

Facility Data

Facility Boundary

AASF Concord
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Figure 2-2

Facility Topography

3

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Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

NH

AASF Concord

Facility Data

Facility Boundary

Note:

Contour elevation recorded in ft. asml.
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Figure 2-3

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Soucook River

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Data Sources: 

ESRI 2020

AECOM 2019

NHDES 2021

NHARNG 2017

Date:......October 2022

Prepared By:.......WSP

Prepared For:....USACE

)

Hydrology/

Hydrogeology

Groundwater Flow

Direction

River/Stream

Water Body

Wetland

Geology

Concord Granite

Lower Rangley

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Facility Data

Storm Sewer

Retention Basin

Facility Boundary

Former Vishay Sprague Facility

NH

Concord

Well Field

&( Domestic Well

&(

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Wells

&( Public Water Supply Well

&( Abandoned Well

&( Commercial Well

&( Other/Unknown Well

&( Test/Exploration

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Monitoring

Well &(
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Figure 2-4

Surface Water Features

Bow Bog

Brook-Merrimack

River Watershed

Soucook River

Watershed

S ou cook Rive r

Pembroke Rd

Regional Dr

Old Tpk Rd

Loudon Rd

Airport Rd

3

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Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

Hydrology/Hydrogeology

Watershed

Surface Water Flow

Direction

River/Stream

Wetland

Water Body

Facility Data

Facility Boundary

Storm Sewer

Retention Basin

NH
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Figure 2-5

Groundwater Elevations

May 2022

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Canterbury Rd

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Exchange St

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Pembroke Rd

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0 400

Feet

Data Sources: 

ESRI 2020

AECOM 2019

NHDES 2021

NHARNG 2017

Date:......October 2022

Prepared By:.......WSP

Prepared For:....USACE

)

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

Groundwater Elevation Contour

(3-foot interval)

Facility Data

Retention Basin

Facility Boundary

NH

Sample Type

#* Temporary Monitoring Well

Note: Sample location AOI03-01 was not 

used for groundwater elevation contours.
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3. SUMMARY OF AREAS OF INTEREST

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

or released historically. Based on the PA findings, four potential release areas were identified at 

the AASF and grouped into three AOIs identified as: AOI 1 Fire Suppression System Releases, 

AOI 2 System Testing Area, and AOI 3 Infiltration Gallery. The AOIs are shown on Figure 3-1.

3.1 AOI 1 – FIRE SUPPRESSION SYSTEM RELEASES

AOI 1 consists of the Fire Suppression System Releases. Construction on the current AASF 

hangar building was completed in 2004, after which operations moved from the SMR. The 

AASF comprises administrative offices, the AASF Main Hangar, and the Fuel Truck Storage 

Building. At the time of the PA, the Main Hangar and the Fuel Truck Storage Building were 

equipped with fire suppression systems charged with AFFF. The fire suppression system in the 

Main Hangar, which includes a 900-gallon tank of Ansulite 3 % AFFF, is housed in a room on 

the north side of the building near the loading dock. The fire suppression system in the Fuel 

Truck Storage Building, which includes a 200-gallon tank of Ansulite 3% AFFF, is housed in a 

room in the central portion of the west side of the building. The geographic coordinates of the 

Main Hangar are 43°12'33.50"N; 71°30'8.21”W, and the geographic coordinates of the Fuel 

Truck Storage Building are 43°12'30.6"N; 71°30'04.3"W.

Both fire suppression systems (in the Main Hangar and the Fuel Truck Storage Building) were 

originally charged with Aer-O-Lite 3% AFFF in 2005. The system in the Main Hangar was 

tested once after initial installation. In 2008, AASF personnel discovered the AFFF in both fire 

suppression systems did not meet military specifications, and the Aer-O-Lite 3% AFFF was 

subsequently removed and replaced with Ansulite 3% AFFF. Twelve 55-gallon drums of Aer-OLite 3% AFFF were removed from the site and donated to local Fire Departments. Prior to 

transfer, the drums were stored in the hangar Hazardous Materials storage room. The system was 

not tested again after the change to Ansulite 3%. Interviewed personnel indicated that a 

contractor manages system inspections, and the interviewees were not familiar with the 

frequency of inspections.

Two releases of AFFF from the fire suppression systems at the AASF have occurred. The first 

release of AFFF happened on February 4 and 5, 2005. The incident occurred when the AASF 

was hit by lightning during a storm, and stray voltage triggered the fire suppression systems. It 

was estimated that less than 10 gallons of Aer-O-Lite 3% AFFF was released from the Main 

Hangar (on February 4, 2005) and approximately 3.4 gallons was released from the Fuel Truck 

Storage Building (on February 5, 2005). After the release, the doors of the Main Hangar and Fuel 

Truck Storage Building were opened, and the foam was washed out of the buildings and onto the 

apron, from there it was either washed into the drain at the center of the apron or onto the grass 

surrounding the apron. Interviewees also noted foam on the grass on the west side of the 

building, near the AASF offices. Foam washed into the drain at the center of the apron would 

drain west to an underground basin, then into an underground storm water treatment system, and 

then an underground infiltration gallery. The infiltration gallery is located approximately at 

geographic coordinates 43°12'33.1"N; 71°30'19.2"W (National Guard Bureau [NGB], 2002a; 

NGB, 2002b).
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Some foam may have also been rinsed down the trench drains in the hangar bay and wash rack. 

Foam and wastewater washed into the trench drains would have been contained and treated by 

the onsite wastewater management system. Wastewater would have drained into an onsite oilwater separator (OWS), from where the residual water would have entered a holding tank that 

fed into a membrane ultra-filtration system. After passing through the filtration system, the 

wastewater would have then been held in onsite wastewater holding tanks. The concentrate from 

the membrane filtration system, the residual from the OWS, and the wastewater in the holding 

tanks were removed by a contracted disposal facility. No foam or wastewater in the OWS and 

holding tanks were discharged to the municipal sanitary sewer system.

The second release occurred in January 2019, when a fire suppression system pipe in the AASF 

Main Hangar wash rack froze and burst. During this release, the foam extended from the wall to

about half the width (to the center drain) and half the length of the 8,745-square foot wash

rack. The exact quantity of Ansulite 3% AFFF released was unknown. The foam was

contained inside the wash bay and was rinsed down the center trench drain by AASF

personnel, after which it would have been contained in the current AASF wastewater holding 

tanks and removed by a contracted disposal facility, as described above (AECOM 2019).

3.2 AOI 2 – SYSTEM TESTING AREA

AOI 2 is the System Testing Area. According to AASF personnel, the company that installed the 

fire suppression system in the Main Hangar tested the system once in 2005, after the initial 

installation, to ensure proper mixing of AFFF and water flow and pressure. Testing was 

conducted outside the north side of the building by the loading dock, and the mixture was 

discharged to the grass at approximate geographic coordinates 43°12'35.2"N; 71°30'09.9"W. At 

the time, the system was charged with Aer-O-Lite 3% AFFF. The quantity of AFFF released was 

unknown (AECOM 2019).

A second release occurred on June 15, 2021, when AFFF was released to concrete and a grassy 

area on the east side of the loading dock. Emergency Response Actions were immediately 

implemented, and Clean Harbors was mobilized to remove the AFFF. 

3.3 AOI 3 – INFILTRATION GALLERY

AOI 3 is the Infiltration Gallery. According to engineering drawings, the infiltration gallery is 

located 4 ft bgs (NGB 2002c; AECOM 2019). As described above, after the first release of AFFF 

from the fire suppression systems occurred on the weekend of February 4 to 5, 2005, the doors of 

the Main Hangar and Fuel Truck Storage Building were opened, and the foam was washed out of 

the buildings and onto the apron, from where it was either washed into the drain at the center of 

the apron or onto the grass surrounding the apron. Interviewees also noted foam on the grass on 

the west side of the building, near the AASF offices. Foam washed into the drain at the center of 

the apron would drain west to an underground basin, then into an underground storm water 

treatment system, and then an underground infiltration gallery. The infiltration gallery is located 

approximately at geographic coordinates 43°12'33.1"N; 71°30'19.2"W (National Guard Bureau 

[NGB], 2002a; NGB, 2002b).
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Some foam may have also been rinsed down the trench drains in the hangar bay and wash rack. 

Foam and wastewater washed into the trench drains would have been contained and treated by 

the onsite wastewater management system. Wastewater would have drained into an onsite OWS 

from where the residual water would have entered a holding tank that fed into a membrane ultrafiltration system. After passing through the filtration system, the wastewater would have then 

been held in onsite wastewater holding tanks. The concentrate from the membrane filtration 

system, the residual from the OWS, and the wastewater in the holding tanks were removed by a 

contracted disposal Facility. No foam or wastewater in the holding tanks or the OWS were 

discharged to the municipal sanitary sewer system.

After the second release of AFFF from the fire suppression systems occurred in January 2019,

the foam was contained inside the wash bay and was rinsed down the center trench drain by

AASF personnel, after which it would have been contained in the current AASF wastewater 

holding tanks (AECOM 2019).

3.4 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. 

3.4.1 The Electropac Worldwide Inc. (former Vishay Sprague Facility)

The Electropac Worldwide Inc. site (former Vishay Sprague site), located immediately north, 

and hydraulically upgradient of the AASF. 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. 

3.4.2 The Richard M. Flynn Fire Academy

The Richard M. Flynn Fire Academy, also known as the New Hampshire Fire Academy, is 

located 1.3 miles due east of the AASF. 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, at the time there were no standards for PFAS in soil or surface water 

in New Hampshire (Nobis Group 2018; AECOM 2019). It should be noted that although there 

were no standards for PFAS in soil or surface water in New Hampshire in 2018, the New 

Hampshire Legislature signed New Hampshire House Bill (NH HB) 1264 into law establishing 

Maximum Contaminant Levels (MCLs) and Ambient Groundwater Quality Standards (AGQS) 

for PFOA (12 nanograms per liter (ng/L), PFOS (15 ng/L), PFHxS (18 ng/L), and PFNA (11 

ng/L) in July of 2020.
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The types and quantities of AFFF used or stored at the academy currently or historically are not 

known. However, because the Fire Academy has confirmed releases of PFAS and is located 

hydraulically up- or cross-gradient from the AASF, it is considered an adjacent off-Facility

source of PFAS (AECOM 2019).
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Figure 3-1

Areas of Interest

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Reservation (PA and SI Reports 

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3

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Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

Facility Data

Area of Interest (AOI)

Potential PFAS Release

Facility Boundary

Retention Basin

Wells

&( Monitoring Well

&( Geothermal Well

&( Abandoned Well

&( Commercial Well

&( Domestic Well

&( Domestic Drinking Water Well

&( Other/Unknown Well

&( Test/Exploration

Hydrology/Hydrogeology

Groundwater Flow Direction

Surface Water Flow Direction

Wetland

Watershed

River/Stream

Water Body

Former Vishay

Sprague Facility

NH
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4. PROJECT DATA QUALITY OBJECTIVES

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

Federal Policy (UFP)-Quality Assurance Project Plan (QAPP) Addendum (EA/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 the AASF (AECOM 2019);

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

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

• 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 48 feet bgs). Offfacility 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). 
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4.5 DATA USABILITY ASSESSMENT

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

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

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

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

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

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

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

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

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

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

requirements of the UFP-QAPP (EA, 2020).
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5. SITE INSPECTION ACTIVITIES

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

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

implemented in accordance with the following approved documents. 

• Final Preliminary Assessment Report, Army Aviation Support Facility, 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, Army Aviation Support Facility, New Hampshire dated May 2022

(EA/Wood 2022)

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

(EA 2021)

• Final Accident Prevention Plan/Site Safety and Health Plan, Army Aviation 

Support Facility, New Hampshire, dated October 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 QSM 

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

• Twenty-eight (28) soil samples from 10 boring locations;

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

• Twenty-one (21) quality assurance (QA)/quality control (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.
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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 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., 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 24 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 pre-cleared 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 AASF, was collected on 6 May 2022, 

prior to mobilization, and analyzed for PFAS by LC/MS/MS compliant with QSM 5.3 Table B15 (DoD, 2020). The results of the sample of the potable water source used for decontamination 
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of drilling equipment during the SI are provided in Appendix F. A discussion of the results is 

presented in the DUA (Appendix A).

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

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

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

UFP-QAPP (PQAPP) (EA 2020).

5.2 HAND AUGER SOIL SAMPLING

Soil samples were collected from two locations, AOI2-02 and AOI2-03, for chemical analysis 

from 0 to 2 ft 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 2021a). 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 Standard Operating 

Procedure 047 Direct-Push Technology Sampling (EA/Wood 2022). A Geoprobe® 7822DT dualtube 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 28 to 46 ft bgs during drilling. Total boring completion 

depths, to accommodate temporary well installation, ranged from 36 to 48 ft 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, 
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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 Duplicates (MSDs) were collected 

at a rate of 5% and analyzed for the same parameters as the accompanying samples. In instances 

when non-dedicated sampling equipment was used, such as a hand auger for the shallow soil 

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

as the soil samples. 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. 

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 
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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/MSDs were collected at a rate of 5% and analyzed for the same 

parameters as the accompanying samples. One FB was collected in accordance with the UFPQAPP Addendum (EA 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 5.6), 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 9 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 (DOT)-approved steel drums and left onsite as directed by Facility personnel. The 

liquid IDW was sampled following the SI fieldwork and is awaiting disposal. 
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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.

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 as municipal waste.

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 AASF 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 AASF, but soil conditions did not warrant the use of HSA drilling 

methods. 
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Table 5-1. Site Inspection Samples by Medium

Army Aviation Support Facility, 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) 5/31/22 0-2 X

AOI01-01-SB-(13-15) 5/31/22 13-15 X

AOI01-01-SB-(43-45) 6/1/22 43-45 X

AOI01-02-SB-(0-2) 5/25/22 0-2 X MS/MSD Collected; Parent Sample 

of (AASF)DUP01

AOI01-02-SB-(13-15) 5/25/22 13-15 X

AOI01-02-SB-(38-40) 5/25/22 38-40 X

AOI01-03-SB-(0-2) 5/31/22 0-2 X

AOI01-03-SB-(13-15) 5/31/22 13-15 X

AOI01-03-SB-(37-39) 5/31/22 37-39 X

AOI01-04-SB-(0-2) 5/26/22 0-2 X X X X MS/MSD Collected; Parent Sample 

of (AASF)DUP02

AOI01-04-SB-(13-15) 5/26/22 13-15 X

AOI01-04-SB-(36-38) 5/26/22 36-38 X

AOI01-05-SB-(0-2) 5/25/22 0-2 X

AOI01-05-SB-(13-15) 5/25/22 13-15 X

AOI01-05-SB-(33-35) 5/25/22 33-35 X

AOI02-01-SB-(0-2) 5/26/22 0-2 X

AOI02-01-SB-(13-15) 5/26/22 13-15 X

AOI02-01-SB-(33-35) 5/26/22 33-35 X

AOI02-02-SB-(0-2) 5/25/22 0-2 X X X X

AOI02-02-SB-(2-5) 5/25/22 2-5 X

AOI02-03-SB-(0-2) 5/25/22 0-2 X

AOI02-03-SB-(2-5) 5/25/22 2-5 X

AOI03-01-SB-(0-2) 6/1/22 0-2 X

AOI03-01-SB-(13-15) 6/1/22 13-15 X

AOI03-01-SB-(35-37) 6/1/22 35-37 X

AOI03-02-SB-(0-2) 6/1/22 0-2 X

AOI03-02-SB-(13-15) 6/1/22 13-15 X

AOI03-02-SB-(35-37) 6/1/22 35-37 X Parent Sample of (AASF)DUP03

(AASF)DUP01 5/25/22 - X

(AASF)DUP02 5/28/22 - X

(AASF)DUP03 6/1/22 - X

Groundwater Samples

AOI01-01-GW-(46) 6/7/22 46 X

AOI01-02-GW-(45) 6/6/22 45 X Parent Sample of (AASF)DUP04

AOI01-03-GW-(45) 6/7/22 45 X

AOI01-04-GW-(41) 6/7/22 41 X
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AOI01-05-GW-(42) 6/6/22 42 X

AOI02-01-GW-(38) 6/3/22 38 X

AOI03-01-GW-(41) 6/7/22 41 X

AASF-01-GW-(34) 6/3/22 34 X

AASF-02-GW-(42) 6/6/22 42 X MS/MSD Collected

AASF-03-GW-(44) 6/3/22 44 X

(AASF)DUP04 6/6/22 - X

Blank Samples

(AASF)EB-01 5/25/22 - X Equipment Blank Collected from 

Sampling Spoon

(AASF)FB-01 5/25/22 - X

(AASF)EB-02 5/25/22 - X Equipment Blank Collected from 

Trowel

(AASF)FB-02 5/26/22 - X

(AASF)EB-03 5/26/22 - X Equipment Blank Collected from 

Sampling Spoon

(AASF)FB-03 5/27/22 - X

(AASF)EB-04 5/27/22 - X Equipment Blank Collected from 

Sampling Spoon

(AASF)FB-04 5/31/22 - X

(AASF)EB-05 5/31/22 - X Equipment Blank Collected from 

Trowel

(AASF)FB-05 6/1/22 - X

(AASF)EB-06 6/1/22 - X Equipment Blank Collected from 

Trowel

(AASF)FB-06 6/3/22 - X

(AASF)EB-07 6/3/22 - X Equipment Blank Collected from 

Bladder Pump

(AASF)FB-07 6/6/22 - X

(AASF)EB-08 6/6/22 - X Equipment Blank Collected from 

Bladder Pump

(AASF)FB-08 6/7/22 - X

(AASF)EB-09 6/7/22 - X Equipment Blank Collected from 

Bladder Pump

Notes:

AASF = Army Aviation Support Facility

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

Army Aviation Support Facility, 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 48.0 43-48

AOI01-02 47.5 42.5-47.5

AOI01-03 48.0 43-48

AOI01-04 43.7 38.7-43.7

AOI01-05 40.0 35-40

2 

AOI02-01 40.0 35-40

AOI02-02 5.0 NA

AOI02-03 5.0 NA

3 AOI03-01 44.0 39-44

AOI03-02 44.0 NA

Facility Boundary

AASF-01 36.0 31-36

AASF-02 44.0 39-44

AASF-03 48.0 43-48

Notes:

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

AASF = Army Aviation Support Facility

bgs = below ground surface

 ft = feet

NA = not applicable
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Table 5-3. Groundwater Elevation 

Army Aviation Support Facility, 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)

AOI01-01 341.38 44.00 297.38

AOI01-02 343.13 45.46 297.67

AOI01-03 341.54 42.49 299.05

AOI01-04 343.48 40.75 302.73

AOI01-05 346.30 41.48 304.82

AOI02-01 344.06 37.59 306.47

AOI03-01 342.39 41.32 301.07

AASF-01 343.46 29.49 313.97

AASF-02 344.64 38.02 306.62

AASF-03 342.94 39.30 303.64

Notes: 

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

AASF = Army Aviation Support Facility

btoc = below top of casing

ft = feet

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

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 5-1

Site Inspection Sample Locations

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

!(

!(

!( AOI3

Infiltration

Gallery

AOI2

System

Testing

Area

AOI1

Fire Supression

System Releases

AASF-01

AASF-02

AASF-03

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

AOI02-02

Canterbury Rd

Regional Dr

3

0 500

Feet

Data Sources: 

ESRI 2020

AECOM 2019

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

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

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

)

Facility Data

Area of Interest (AOI)

Facility Boundary

Sample Type

#* Temporary Monitoring Well

!( Soil Boring

Hydrology/Hydrogeology

Surface Water Flow Direction

Groundwater Flow Direction

NH
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6. SITE INSPECTION RESULTS

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

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

through 6.6. Tables 6-2 through 6-6 present results in soil or groundwater for the relevant 

compounds. Tables that contain all results are provided in Appendix F, and the laboratory 

reports are provided in Appendix G. 

6.1 SCREENING LEVELS

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

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

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

follows this DoD policy. Should the maximum 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

bgs = below ground surface

ft = feet

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

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

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

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

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

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

because 15 ft bgs 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: Fire Suppression System Releases. The soil and groundwater results are summarized in 

Table 6-2 through Table 6-5. 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 five 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 AOI01-05, 

with duplicate soil samples collected at AOI01-02 and AOI01-04. Soil was also sampled from 

shallow subsurface soil (13 to 15 ft bgs) and deep subsurface soil intervals (33 to 45 ft bgs) from 

boring locations AOI01-01 through AOI01-05. 

PFOS was detected in surface soil at concentrations exceeding its SL. PFOA was detected in 

surface soil at concentrations below its SL. PFOS was detected in surface soil at two of the five 
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locations at concentrations of 0.21 J and 15 J μg/kg and exceeded at one location (AOI01-03). 

PFOA was detected in two of the five locations at concentrations at concentrations of 0.34 J and 

0.35 J μg/kg. PFBS, PFHxS, and PFNA were not detected in any of the surface soil samples.

PFOS was detected in shallow subsurface soil at concentrations below its SL. PFOS was 

detected in one of the five locations at a concentration of 0.53 J μg/kg. PFBS, PFHxS, PFOA, 

and PFNA were not detected in any of the shallow subsurface soil samples.

PFOS was detected in deep subsurface soil in one of the five locations at a concentration of 0.22 

J μg/kg. PFBS, PFHxS, PFOA, and PFNA were not detected in the deep subsurface soil samples.

6.3.2 AOI 1 Groundwater Analytical Results 

Groundwater samples were collected from five 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 through AOI01-

05. PFNA and PFOA were detected at concentrations exceeding their respective SLs. PFBS, 

PFHxS, and PFOS were detected at concentrations below their respective SLs. PFNA was 

detected at one of the five locations (AOI01-03) at a concentration of 14 ng/L, which exceeded 

its SL. PFOA was detected in three of the five locations at concentrations ranging from 0.88 J to 

100 J+ ng/L and exceeded at one location (AOI01-03). PFBS was detected in two of the five 

locations at concentrations ranging from 0.44 J to 0.65 J ng/L. PFHxS was detected in one of the 

five locations at a concentrations of 0.66 J ng/L. PFOS was not detected in any of the 

groundwater samples associated with AOI 1. 

Groundwater samples were also collected from three temporary wells associated with Facility 

boundary during the SI, AASF-01, AASF-02, and AASF-03. Based on the synoptic groundwater 

elevations collected during the SI, AASF-01 is located upgradient of AOI 1, AOI-2, and AOI 3. 

AASF-02 and AASF-03 are located cross-gradient of AOI 1. PFOA was detected in groundwater 

at all three locations ranging in concentration from 0.97 J to 13 ng/L and exceeded the SL at one 

location (AASF-01). PFBS was detected at one of three locations at a concentration of 1.3 J 

ng/L. PFHxS was detected at one of three locations at a concentration of 3.7 ng/L. PFNA was 

detected at two of three locations ranging in concentrations from 0.55 J ng/L to 0.98 J ng/L. 

PFOS was not detected. 

6.3.3 Conclusions

Based on the results of the SI, PFOS was detected in surface soil above its SL. PFNA and PFOA

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. The 

detections in the wells located upgradient and cross-gradient of AOI 1, indicate that there is 

potential that an off-Facility source may be impacting the groundwater.
Site Inspection Report

Army Aviation Support Facility, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-4

6.4 AOI 2 

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

AOI 2: System Testing Area. The soil and groundwater results are summarized in Table 6-2

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 three 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 through AOI02-03. Soil 

was also sampled from shallow subsurface soil (2 to 15 ft bgs) from boring locations AOI02-01 

through AOI02-03 and a deep subsurface soil interval (33 to 35 ft bgs) from boring location

AOI02-01. 

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

PFNA was detected in all three locations at concentrations ranging from 0.38 J+ to 2.4 J+ μg/kg. 

PFOA was detected in all three locations at concentrations ranging from 2.0 J+ to 6.4 J+ μg/kg. 

PFBS, PFHxS, and PFOS were not detected in the surface soil samples.

PFNA and PFOA were detected in shallow subsurface soil at concentrations below their 

respective SLs. PFNA was detected in two of the three locations at concentrations ranging from 

0.61 J to 6.2 μg/kg. PFOA was detected in all three locations at concentrations ranging from 0.63 

to 1.9 μg/kg. PFBS, PFHxS, and PFOS were not detected in the shallow subsurface soil samples.

PFBS, PFHxS, PFOA, PFOS, and PFNA were not detected in the deep subsurface soil sample.

6.4.2 AOI 2 Groundwater Analytical Results 

Groundwater samples were collected from one temporary well associated with AOI 2 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 location AOI02-01. PFOA exceeded 

its SL with a concentration of 25 ng/L. PFBS was detected below its SL at a concentration of 

0.53 J ng/L, PFHxS was detected below its SL at a concentration of 1.5 J ng/L. PFNA was 

detected below its SL at a concentration of 1.9 ng/L. PFOS was not detected in groundwater. 

6.4.3 Conclusions

PFOA was detected in groundwater at a concentration above its SL. PFNA and PFOA were 

detected in soil below their respective SLs. Based on the exceedances of the SLs in groundwater, 

further evaluation at AOI 2 is warranted. 
Site Inspection Report

Army Aviation Support Facility, New Hampshire Version: FINAL

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

6.5 AOI 3 

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

AOI 3: Infiltration Gallery. The soil and groundwater results are summarized in Table 6-2

through Table 6-5. Soil and groundwater results are presented on Figures 6-1 through Figure 6-

7.

6.5.1 AOI 3 Soil Analytical Results

Soil samples were collected from two boring locations associated with AOI 3 during the SI. 

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

6-5 summarize the soil results.

Surface soil (0 to 2 ft bgs) was sampled from boring locations AOI03-01 and AOI03-02, with a 

duplicate surface soil sample collected at AOI03-02. Soil was also sampled from shallow 

subsurface soil (13 to 15 ft bgs) and deep subsurface soil intervals (35 to 37 ft bgs) from boring 

locations AOI03-01 and AOI03-02. 

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

PFOA was detected in one of the two locations with a concentration of 0.52 J+ μg/kg (0.45 J+ in 

the duplicate sample). PFOS was detected in one of the two locations with a concentration of 

0.36 J+ μg/kg (0.32 J in the duplicate sample). PFBS, PFHxS, and PFNA were not detected in

either of the surface soil samples.

PFBS, PFHxS, PFOA, PFOS, and PFNA were not detected in either of the shallow subsurface 

soil samples.

PFBS, PFHxS, PFOA, PFOS, and PFNA were not detected in either of the deep subsurface soil 

samples.

6.5.2 AOI 3 Groundwater Analytical Results 

Groundwater samples were collected from one temporary well associated with AOI 3 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 location AOI03-01. PFNA and 

PFOA were detected at concentrations exceeding their respective SLs. PFNA exceeded its SL 

with a concentration of 7.1 ng/L. PFOA exceeded its SL with a concentration of 6.1 ng/L. PFOS

was detected below its SL at a concentration of 0.6 J ng/L. PFBS and PFHxS were not detected 

in the groundwater sample.

6.5.3 Conclusions

Based on the results of the SI, PFNA and PFOA were detected in groundwater at concentrations 

above their respective SLs. PFOA and PFOS were detected in soil below their SL. Based on the 

exceedances of the SLs in groundwater, further evaluation at AOI 3 is warranted.
Site Inspection Report

Army Aviation Support Facility, New Hampshire Version: FINAL

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

This page intentionally left blank
Table 6-2

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil

Site Inspection Report

Concord AASF

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual 

PFBS 1900 ND U ND U ND U PFHxS 130 ND U ND U ND U PFNA 19 ND U ND U ND U PFOA 19 0.35 J ND U ND U PFOS 13 0.21 J 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 soil are

based on residential scenario for direct 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 AbbreviationsAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date 5/31/2022 5/25/2022 5/25/2022 

Sample ID AOI01-01-SB-(0-2) AOI01-02-SB-(0-2) (AASF) DUP01 

Area of Interest

Depth

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

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

Location ID AOI01-01 AOI01-02 AOI01-02-Duplicat

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

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil

Site Inspection Report

Concord AASF

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 direct 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 AbbreviationsAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date

Sample ID

Area of Interest

Depth

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

Location ID

Result Qual Result Qual Result Qual 

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

2.4 J+ 2.2 0.38 J+ 6.4 J+ 3.8 2.0 J+ 

ND U ND U ND U 

5/26/2022 5/25/2022 5/25/2022 

AOI02-01-SB-(0-2) AOI02-02-SB-(0-2) AOI02-03-SB-(0-2

AOI02-01 AOI02-02 

AOI02 

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

AOI02-03 

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 AASF

Analyte OSD Screening Level 1 Result Qual Result Qual Result 

PFBS 25000 ND U ND U ND PFHxS 1600 ND U ND U ND PFNA 250 ND UJ ND U ND PFOA 250 ND UJ ND U ND PFOS 160 ND U ND U 0.53 

Notes ChGray Fill Detected concentration exceeded OSD Screening Levels PF

PF

References PF

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated PF

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s PF

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soil

are based on Industrial/Commercial Composite Worker scenario for direct 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 kilogramAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

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

Depth 13 - 15 ft 13 - 15 ft 13 - 1

Area of Interest AOI

Sample Date 5/31/2022 5/25/2022 5/31/2

Sample ID AOI01-01-SB-(13-15) AOI01-02-SB-(13-15) AOI01-03-S

Location ID AOI01-01 AOI01-02 AOI0

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 AASF

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 direct 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 kilogramAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

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

Depth

Area of Interest

Sample Date

Sample ID

Location ID

Result Qual Result Qual Result 

ND U ND U ND ND U ND U ND ND U 0.61 J 6.2 

0.63 1.9 1.4 

ND U ND U ND 

CPPPPP

13 - 15 ft 2 - 5 ft 2 - 5 

5/25/2

AOI02 

5/26/2022 5/25/2022 

AOI02-01 AOI02-02 AOI02

AOI02-01-SB-(13-15) AOI02-02-SB-(2-5) AOI02-03-

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 AASF

Analyte Result Qual Result Qual Result Qual Result Qual Result Qual R

PFBS ND U ND U ND U ND U ND U NPFHxS ND U ND U ND U ND U ND U NPFNA ND U ND U ND U ND U ND U NPFOA ND U ND U ND U ND U ND U NPFOS ND U ND U 0.22 J ND U ND U N

Notes ChemGray Fill PFB

PFH

References PFN

1. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated PFO

for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s PFO

Regional Screening Level Calculator. HQ=0.1. May 2022. The screening levels for soilare based on Industrial/Commercial Composite Worker scenario for direct 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 kilogramAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date 5/31/2022 5/25/2022 5/31/2022 5/26/2022 5/25/2022 

Sample Name AOI01-01-SB-(43-45) AOI01-02-SB-(38-40) AOI01-03-SB-(37-39) AOI01-04-SB-(36-38) AOI01-05-SB-(33-35) AO

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

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

Area of Interest

Depth

AOI01 

43 - 45 ft 38 - 40 ft 37 - 39 ft 36 - 38 ft 33 - 35 ft 

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

Army Aviation Support Facility, New Hampshire Version: FINAL

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

This page intentionally left blank
Table 6-5

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

Concord AASF

Analyte OSD Screening Level 1 Result Qual Result Qual Result Qual 

PFBS 601 0.65 J ND U ND U PFHxS 39 ND U ND U ND U PFNA 6 ND U ND U ND U PFOA 6 1.5 J ND U ND U PFOS 4 ND U 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. Groundwater screening levelsbased on residential scenario for direct ingestion of groundwater.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 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 AbbreviationsAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

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

Sample ID AOI01-01-GW-(46) AOI01-02-GW-(45) (AASF)DUP04 

Water, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

Area of Interest 

Location ID AOI01-01 AOI01-02 AOI01-02-Duplicate 

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

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report

Concord AASF

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.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 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 AbbreviationsAASF Army Aviation Support FacilityAOI 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 boringUSEPA United States Environmental Protection AgencyQual interpreted qualifier

Sample Date

Sample ID

Water, PFAS by LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

Area of Interest

Location ID

Result Qual Result Qual Result 

0.53 J ND U ND 

1.5 J ND U ND 1.9 7.1 0.98 

25 6.1 13 

ND U 0.6 J ND 

6/7/2022 6/7/2022 

AOI02-01-GW-(38) AOI03-01-GW-(41) AASF

AOI02-01 AOI03-01 A

AOI02 AOI03 

EA Engineering, Science, and Technology, Inc., PBC 
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.....................Octob e r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................USACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Army National Guard Site Inspections

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-1

PFOS Detections in Soil

!(

!(

!!( !(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-02

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

!(

!(

!( !(

!(

!(

!(

!(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI03-02

Canterbury Rd

Regional Dr

Sh a llow (0-2') De e p (33-45') 3

)

NOTES:

PFAS = Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFOS = pe rflu oroocta ne su lfonic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re de picte d w ith a ye llow h a lo.

!(

!(

!( !(

!(

!(

!(

!(

!(

!(

AOI02-02

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

Hydrology/Hydrogeology

Su rfa ce W a te r Flow Dire ction

Grou ndw a te r Flow Dire ction

Inte rm e dia te (2-15')

N H

0 200

Fe e t

0 200

Fe e t

0 200

Fe e t

PFOS Results (μg/kg)

!( N D (N on-De te ct)

!( >N D - 13

!!( >13 -160

!!( >160 - 1,600

!!( >1,600
Site Inspection Report

Army Aviation Support Facility, New Hampshire Version: FINAL

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

This page intentionally left blank
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.................Octob e r 2022

Pre pa re d By:..................W SP

Pre pa re d For:..............USACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Army National Guard Site Inspections

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-2

PFOA Detections in Soil

!(

!(

!(

!(

!(

!(

!(

!(!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI1-05

AO0I2-01

AOI03-01

AOI02-02

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI03-02

Canterbury Rd

Regional Dr

Sh a llow (0-2') De e p (33-45') 3

)

!(

!(

!(

!(

!(

!(

!(

!(!(

!(

AOI02-02

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

Hydrology/Hydrogeology

Grou ndw a te r Flow Dire ction

Su rfa ce W a te r Flow Dire ction

Inte rm e dia te (2-15')

N H

0 200

Fe e t

NOTES:

PFAS = Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFOA = pe rflu oroocta noic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e Se cre ta ry of De fe nse

(OSD) Scre e ning Le ve l (SL) a re de picte d w ith a ye llow h a lo.

PFOA Results (μg/kg)

!( N D (N on-De te ct)

!( >N D - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500
Site Inspection Report

Army Aviation Support Facility, New Hampshire Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 6-18

This page intentionally left blank
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.....................Octob e r 2022

Pre pa re d By:.......................W SP

Pre pa re d For:...................USACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Army National Guard Site Inspections

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-3

PFBS Detections in Soil

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-02

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI03-02

Canterbury Rd

Regional Dr

Sh a llow (0-2') De e p (33-45') 3

)

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

AOI02-02

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

Hydrology/Hydrogeology

Grou ndw a te r Flow Dire ction

Su rfa ce W a te r Flow Dire ction

Inte rm e dia te (2-15')

N H

0 200

Fe e t

NOTES:

PFAS = Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFBS = pe rflu orob u ta ne su lfonic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re de picte d w ith a ye llow h a lo.

PFBS Results (μg/kg)

!( N D (N on-De te ct)

!( >N D - 10

!( >10 - 1,900

!!( >1,900 - 25,000

!!( >25,000
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Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.....................Octob e r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................USACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Army National Guard Site Inspections

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-4

PFHxS Detections in Soil

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-02

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI03-02

Canterbury Rd

Regional Dr

Sh a llow (0-2') De e p (33-45') 3

)

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

AOI02-02

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

Hydrology/Hydrogeology

Grou ndw a te r Flow Dire ction

Su rfa ce W a te r Flow Dire ction

Inte rm e dia te (2-15')

N H

0 200

Fe e t

NOTES:

PFAS = Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFHxS = pe rflu oroh e xa ne su lfonic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e Se cre ta ry of De fe nse (OSD)

Scre e ning Le ve l (SL) a re de picte d w ith a ye llow h a lo.

PFHxS Results (μg/kg)

N D (N on-De te ct)

>N D - 13

>13 -160

>160 - 1,600

>1,600

!(

!(

!(

!!(

!!(
Site Inspection Report

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This page intentionally left blank
Da ta Sou rce s: 

ESRI 2020

AECOM 2020

Da te :.....................Octob e r 2022

Pre pa re d By:........................W SP

Pre pa re d For:....................USACE

Facility Data

Are a of Inte re st (AOI)

Pote ntia l PFAS Re le a se

Fa cility Bou nda ry

Army National Guard Site Inspections

Site Inspection Report

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-5

PFNA Detections in Soil

!(

!(

!(

!(

!(

!(

!(

!(!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-02

AOI02-03

AOI03-02

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!(

!(

!(

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI03-02

Canterbury Rd

Regional Dr

Sh a llow (0-2') De e p (33-45') 3

)

!(

!(

!(

!(

!(

!(

!(

!(!(

!(

AOI02-02

A0I01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

AOI02-03

AOI03-02

Hydrology/Hydrogeology

Grou ndw a te r Flow Dire ction

Su rfa ce W a te r Flow Dire ction

Inte rm e dia te (2-15')

N H

0 200

Fe e t

NOTES:

PFAS = Pe r- a nd Polyflu oroa lkyl Su b sta nce s

PFN A = pe rflu oronona noic a cid

N D = N on-De te ct

(μg /Kg ) = Microg ra m (s) pe r Kilog ra m

Exce e da nce s of Th e Office of th e Se cre ta ry of De fe nse

(OSD) Scre e ning Le ve l (SL) a re de picte d w ith a ye llow h a lo.

PFNA Results (μg/kg)

!( N D (N on-De te ct)

!( >N D - 19

!!( >19 - 250

!!( >250 - 2,500

!!( >2,500
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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

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-6

PFOS, PFOA, and PFBS Detections in Groundwater

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

AASF-01

AASF-02

AASF-03

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!( !(

!(

!(

!(

AASF-01

AASF-02

AASF-03

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

Canterbury Rd

Regional Dr

PFOS PFBS

3

)

!!(

!(

!(

!(

!(

!!( !(

!(

!!(

!!(

AASF-01

AASF-02

AASF-03

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

Canterbury Rd

Regional Dr

Hydrology/Hydrogeology

Groundwater Flow Direction

Surface Water Flow Direction

PFOA

NH

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.

0 200

Feet

0 200

Feet

0 200

Feet

PFOS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 4

!!( >4 - 40

!!( >40 - 70

!!( >70

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

PFOA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

PFBS Results (ng/L)

ND (Non-Detect)

>ND - 100

>100 - 601

>601 - 1,000

>1,000

!(

!(

!(

!!(

!!(
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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

Army Aviation Support Facility (AASF)

Concord, New Hampshire

Figure 6-7

PFHxS and PFNA Detections in Groundwater

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

AASF-01

AASF-02

AASF-03

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

Canterbury Rd

Regional Dr

!(

!(

!(

!(

!(

!!(

!(

!(

!(

!!(

AASF-01

AASF-02

AASF-03

AOI01-01

AOI01-02

AOI01-03

AOI01-04

AOI01-05

AOI02-01

AOI03-01

Canterbury Rd

Regional Dr

3

)

Hydrology/Hydrogeology

Groundwater Flow Direction

Surface Water Flow Direction

NH

0 200

Feet

0 200

Feet

PFHxS PFNA

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)

!!( >1000

!!( >100 - 1000

!!( >6 - 100

!( >ND - 6

PFHxS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 39

!!( >39 - 100

!!( >100 - 1000

!!( >1,000
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7. EXPOSURE PATHWAYS

The Conceptual Site Model (CSM) for each AOI, revised based on the SI findings, is presented 

on Figure 7-1 through Figure 7-3. 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:

1. Contaminant source;

2. Environmental fate and transport;

3. Exposure point;

4. Exposure route; and

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) and

construction workers, and outside the Facility boundary includes recreational users and residents.

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. 

7.1.1 AOI 1 

AOI 1 includes the Fire Suppression System Releases. Both the Main Hangar and the Fuel Truck 

Storage Building at AASF are equipped with AFFF fire suppression systems. Two releases have 
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occurred since the Facility was opened. In 2005, a lightning strike triggered the release of the 

suppression systems in both the Main Hangar and Fuel Truck Storage Building. It was estimated 

that less than 10 gallons of Aer-O-Lite 3% AFFF were released from the AASF Main Hangar 

and that approximately 3.4 gallons were released from the Fuel Truck Storage Building. 

The second release occurred in the Main Hangar in January 2019, when a fire suppression 

system pipe froze and burst in the wash rack. The foam was contained inside the wash bay and 

was rinsed down the center trench drain. The foam and wastewater from the trench drain were 

contained and treated by the onsite wastewater management system. Residual water was 

removed and disposed of by a contracted disposal Facility (AECOM 2019).

PFOS was detected in surface soil at AOI 1 above its SL. 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. PFOS was detected in subsurface soil at AOI 1 below its SL. Construction 

workers could contact constituents in 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 System Testing Area. According to AASF personnel, the fire suppression system in 

the Main Hangar was tested once in 2005, after the initial installation, to ensure proper mixing of 

AFFF and water flow and pressure. Testing was conducted outside the north side of the building 

by the loading dock, and the mixture was discharged to the grass. The system was charged with 

Aer-O- Lite 3% AFFF, but the quantity of AFFF released is unknown. Additionally, a second 

release occurred on June 15, 2021, when AFFF was released to a grassy area on the east side of 

the loading dock. Emergency Response Actions were immediately implemented, and Clean 

Harbors was mobilized to remove the AFFF (AECOM 2019). 

PFNA and PFOA were detected in surface soil at AOI 2 at concentrations below their respective 

SLs. Facility workers and construction workers could contact constituents in surface soil via 

incidental ingestion and inhalation of dust. Therefore, the surface soil exposure pathway for 

facility workers and construction workers are potentially complete. PFNA and PFOA were

detected in subsurface soil at AOI 2. Construction workers could contact constituents in 

subsurface soil via incidental ingestion and inhalation of dust; therefore, the subsurface soil 

exposure pathway for construction workers is potentially complete. 

The CSM is presented in Figure 7-2.

7.1.3 AOI 3 

AOI 3 is the Infiltration Gallery. The stormwater system and infiltration gallery were installed 

circa 2004, when the new AASF was constructed. Stormwater runoff from the main apron is 

collected in a drain at the center of the apron and discharged into a stormwater pre-treatment 

system, followed by a three-tiered underground infiltration gallery. According to engineering 
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drawings, the infiltration gallery is located 4 ft bgs (NGB 2002c; AECOM 2019). According to 

interviews with NHARNG personnel, foam from the 2005 fire suppression system releases in the 

Main Hangar and the Fuel Truck Storage Building was washed into the drain and surrounding 

grass.

PFOA and PFOS were detected in surface soil at AOI 3 at concentrations below their respective 

SLs. Facility workers and construction workers could contact constituents in surface soil via 

incidental ingestion and inhalation of dust. Therefore, the surface soil exposure pathway for 

facility workers and construction workers are potentially complete. PFBS, PFHxS, PFOA, PFOS, 

and PFNA were not detected in subsurface soil at AOI 3; therefore, the subsurface soil exposure 

pathway for construction workers is incomplete. 

The CSM is presented in Figure 7-3.

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 

PFNA and PFOA were detected above their respective SLs in groundwater samples collected at 

AOI 1. Depths to water measured at AASF in June 2022 during the SI ranged from 28 to 46 ft 

bgs. Due to the depth of groundwater at the site, the groundwater ingestion exposure pathway for 

construction workers is considered incomplete. 

Potable water at the AASF is provided by public water distribution lines; therefore, the pathway 

for ingestion of shallow groundwater by site workers is incomplete. A domestic well and 

commercial well are present 0.5 miles and 0.75 miles east of the AASF respectively (EDR 2019; 

AECOM 2019). Based on groundwater flow direction to the south/southwest, these two wells 

are not considered downgradient from the AASF. Relevant compounds were detected above their 

respective SLs in groundwater at the downgradient boundary of the facility; therefore, the 

pathway for ingestion of shallow groundwater by off-Facility residents is potentially complete.

The Merrimack River is located approximately 0.8 miles to the west/southwest (downgradient), 

and the Soucook River is located approximately 0.6 miles to the south/southeast (cross gradient). 

It is not known if there is offsite groundwater discharge to surface water bodies (the Soucook 

River, Merrimack River, or their tributaries). Based on the depth to groundwater and the depth of 

the Merrimack River (5 to 40 ft bgs), groundwater interaction with the river may be possible 

downgradient of the Facility (GZA GeoEnvironmental, Inc. 2018; AECOM 2019). 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. 
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7.2.2 AOI 2 

PFOA was detected above their SL in the groundwater sample collected at AOI 2. Depths to 

water measured at AASF in June 2022 during the SI ranged from 28 to 46 ft bgs. Due to the 

depth of groundwater at the site, the groundwater ingestion exposure pathway for construction 

workers is considered incomplete. 

Potable water at the AASF is provided by public water distribution lines; therefore, the pathway 

for ingestion of shallow groundwater by site workers is incomplete. A domestic well and 

commercial well are present 0.5 miles and 0.75 miles east of the AASF respectively (EDR 2019; 

AECOM 2019). Based on groundwater flow direction to the south/southwest, these two wells 

are not considered downgradient from the AASF. Relevant compounds were detected above their 

respective SLs in groundwater at the downgradient boundary of the facility; therefore, the 

pathway for ingestion of shallow groundwater by off-Facility residents is potentially complete.

The Merrimack River is located approximately 0.8 miles to the west/southwest (downgradient), 

and the Soucook River is located approximately 0.6 miles to the south/southeast (cross gradient). 

It is not known if there is offsite groundwater discharge to surface water bodies (the Soucook 

River, Merrimack River, or their tributaries). Based on the depth to groundwater and the depth of 

the Merrimack River (5 to 40 ft bgs), groundwater interaction with the river may be possible 

downgradient of the site (GZA GeoEnvironmental, Inc. 2018; AECOM 2019). 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 2 is presented in Figure 7-2. 

7.2.3 AOI 3 

PFNA and PFOA were detected above their respective SLs in groundwater samples collected at 

AOI 3. Depths to water measured at AASF in June 2022 during the SI ranged from 28 to 46 ft 

bgs. Due to the depth of groundwater at the site, the groundwater ingestion exposure pathway for 

construction workers is considered incomplete. 

Potable water at the AASF is provided by public water distribution lines; therefore, the pathway 

for ingestion of shallow groundwater by site workers is incomplete. A domestic well and 

commercial well are present 0.5 miles and 0.75 miles east of the AASF respectively (EDR 2019; 

AECOM 2019). Based on groundwater flow direction to the south/southwest, these two wells 

are not considered downgradient from the AASF. Relevant compounds were detected above their 

respective SLs in groundwater at the downgradient boundary of the facility; therefore, the 

pathway for ingestion of shallow groundwater by off-Facility residents is potentially complete.

The Merrimack River is located approximately 0.8 miles to the west/southwest (downgradient), 

and the Soucook River is located approximately 0.6 miles to the south/southeast (cross gradient). 

It is not known if there is offsite groundwater discharge to surface water bodies (the Soucook 

River, Merrimack River, or their tributaries). Based on the depth to groundwater and the depth of 

the Merrimack River (5 to 40 ft bgs), groundwater interaction with the river may be possible 

downgradient of the site (GZA GeoEnvironmental, Inc. 2018; AECOM 2019). Therefore, the 
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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 3 is presented in Figure 7-3. 
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REC

Huma

Curr

Human 

Activities

Groundwater/Surface Water Interaction

Leaching/Infiltration

Inhalation of 

Dust

AOI 1

Fire Suppression 

System Releases

Potential 

releases from fire 

suppression 

system releases

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 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS

Figure 7-1

Conceptual Site Model

AASF
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REC

Huma

Curr

Human 

Activities

Groundwater/Surface Water Interaction

Leaching/Infiltration

Inhalation of 

Dust

AOI 2

System Testing 

Area

Potential 

releases from 

system testing 

area

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 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS

Figure 7-2

Conceptual Site Model

AASF
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REC

Huma

Curr

Human 

Activities

Groundwater/Surface Water Interaction

Leaching/Infiltration

Inhalation of 

Dust

AOI 3

Infiltration Gallery

Potential 

releases from 

infiltration gallery

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 

insignificant.

3. Dermal contact exposure pathway is incomplete for PFAS

Figure 7-3

Conceptual Site Model

AASF
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8. SUMMARY AND OUTCOME

This section summarizes SI activities and findings. The most significant findings are summarized 

in this section and are reproduced directly or abstracted from information contained in this 

report. The outcome provides general and comparative interpretations of the findings relative to 

the SLs. 

8.1 SI ACTIVITIES

The SI field activities 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 (Wood/EA 2022), except as previously noted in Section 5.9.

To fulfill the project DQOs set forth in the approved SI UFP-QAPP Addendum (EA/Wood,

2022), 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-eight (28) soil samples from 10 boring locations;

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

• Twenty-one (21) 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, AOI 2, and AOI 3. Based on the CSMs developed and revised based on the 

SI findings, there is potential for exposure to receptors from AOI 1, AOI 2, and AOI 3 from 

sources on the Facility resulting from historical DoD activities. There is also a potential that an 

off-Facility source may be impacting the groundwater.

Sample chemical analytical concentrations collected during the SI were compared against the 

project SLs in soil and groundwater, as described in Table 6-1. The following bullets summarize 

the SI results relative to the SLs: 

At AOI 1:

• PFNA and PFOA were detected in groundwater at concentrations above their 

respective SLs with maximum concentrations of 14 and 100 J+ ng/L, respectively, 

at AOI01-03. Other relevant compounds were detected below their respective SLs

in groundwater samples from AOI 1. 
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• PFOS was detected in surface soil above the SL, with a maximum concentration 

of 15 J μg/kg at AOI01-03. Other relevant compounds were also detected below 

their respective SLs in soil samples from AOI 1.

• Based on the results of the SI, further evaluation of AOI 1 is warranted in the RI. 

At AOI 2:

• PFOA was detected in groundwater at concentrations above the SL with

maximum concentration of 25 ng/L at AOI02-01. Other relevant compounds were 

also detected below their respective SLs in the groundwater sample from AOI 2. 

• Relevant compounds were detected in soil in the AOI 2 source area at 

concentrations below SLs. 

• Based on the results of the SI, further evaluation of AOI 2 is warranted in the RI. 

At AOI 3:

• PFNA and PFOA were detected in groundwater at concentrations above their 

respective SLs with maximum concentrations of 7.1 and 6.1 ng/L, respectively, at 

AOI03-01. PFOS was also detected below its SL in the groundwater sample from 

AOI 3. 

• PFOA and PFOS were detected in soil in the AOI 3 source area at concentrations 

below SLs. 

• Based on the results of the SI, further evaluation of AOI 3 is warranted in the RI. 

At the Facility Boundary:

• PFOA was detected at a concentration above the SL in groundwater on the 

upgradient Facility boundary in sample AASF-01, which suggests potential 

contributions from an off-Facility source. Samples AASF-02 and AASF-03 had 

concentrations of relevant compounds below the SLs and were also located cross

gradient on the upgradient Facility boundary. 

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

AOI

Potential Release 

Area

Soil – 

Source Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary Future Action

1 Fire Suppression 

System Releases Proceed to RI

2 System Testing Area Proceed to RI

3 Infiltration Gallery Proceed to RI

Legend:

 = Detected; exceedance of screening levels

 = Detected; no exceedance of screening levels

 = Not detected
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