FINAL

Preliminary Assessment Report

Ellington Field Army Aviation 

Support Facility 

Houston, Texas

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

July 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

i

Table of Contents

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

1. Introduction ........................................................................................................................ 6

1.1 Authority and Purpose .............................................................................................. 6

1.2 Preliminary Assessment Methods ............................................................................. 6

1.3 Report Organization .................................................................................................. 7

1.4 Facility Location and Description............................................................................... 7

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

1.5.1 Geology ......................................................................................................... 8

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

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

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

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

2. Fire Training Areas ........................................................................................................... 13

3. Non-Fire Training Areas ................................................................................................... 14

3.1 Wash Rack Area ..................................................................................................... 14

3.2 Flight Line ............................................................................................................... 14

3.3 Hangar .................................................................................................................... 15

3.4 Landfills .................................................................................................................. 15

4. Emergency Response Areas ............................................................................................ 17

5. Adjacent Sources ............................................................................................................. 19

5.1 Brio Superfund Site ................................................................................................. 19

5.2 TXANG Old Fire Station .......................................................................................... 19

5.3 TXANG New Fire Station ........................................................................................ 19

5.4 Stormwater Discharge Outfalls................................................................................ 20

5.5 TXANG Aircraft Parking Apron ................................................................................ 20

5.6 TXANG Hangars 1382 and 1394 ............................................................................ 20

5.7 NASA ...................................................................................................................... 20

6. Preliminary Conceptual Site Model .................................................................................. 22

6.1 AOI 1 Wash Rack ................................................................................................... 22

6.2 AOI 2 Flight Line ..................................................................................................... 22

7. Conclusions ..................................................................................................................... 27

7.1 Findings .................................................................................................................. 27

7.2 Uncertainties ........................................................................................................... 27

7.3 Potential Future Actions .......................................................................................... 28

8. References ...................................................................................................................... 30
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

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Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, AOI 1 AFFF Release at Wash Rack at

Ellington Field AASF

Figure ES-3 Preliminary Conceptual Site Model, AOI 2 AFFF Release at Flight Line at

Ellington Field AASF

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 4-1 Emergency Response Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Preliminary Conceptual Site Model, AOI 1 AFFF Release at Wash Rack at

Ellington Field AASF

Figure 6-3 Preliminary Conceptual Site Model, AOI 2 AFFF Release at Flight Line at

Ellington Field AASF

Figure 7-1 Summary of Findings

Tables

Table ES-1: AOIs at Ellington Field AASF

Table 7-1: AOIs at Ellington Field AASF

Table 7-2: Uncertainties

Table 7-3: Rationale

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

iii

Acronyms and Abbreviations

AECOM

AASF

AFFF

AGPU

ANGB

AOI

ARNG

bgs

CERCLA

CSM

DoD

EDRTM

oF

FTA

GCAS

ITRC

HA

NASA

OWS

ng/l

PA

PFAS

PFOA

PFOS

ppt

SI

TCEQ

TXANG

TXARNG

UCMR3

US

USACE

USEPA

VSI

AECOM Technical Services, Inc.

Army Aviation Support Facility

aqueous film forming foam

aircraft ground power unit

Air National Guard Base

area of interest

Army National Guard

below ground surface

Comprehensive Environmental Response, Compensation, and Liability

Act

conceptual site model

Department of Defense

Environmental Data Resources, Inc.TM

degrees Fahrenheit

fire training area

Gulf Coast Aquifer System

Interstate Technology Regulatory Council

Health Advisory

National Aeronautics and Space Administration

Oil-water separator

nanograms per liter

Preliminary Assessment

per- and poly-fluoroalkyl substances

perfluorooctanoic acid

perfluorooctanesulfonic acid

parts per trillion

Site Inspection

Texas Commission on Environmental Quality

Texas Air National Guard

Texas Army National Guard

Unregulated Contaminant Monitoring Rule 3

United States

United States Army Corps of Engineers

United States Environmental Protection Agency

visual site inspection
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

1

Executive Summary

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

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

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

(PFAS)-containing materials was completed for Ellington Field Army Aviation Support Facility

(AASF) (also referred to as the “facility”) in Houston, Texas, to assess potential PFAS release

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

tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility;

· Conducted a 1-day site visit on 26 April 2019 and completed visual site inspections (VSIs) at

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

disposed;

· Interviewed personnel during the site visit who were associated with Ellington Field AASF

activities, including the Ellington Field AASF Maintenance Supervisor (on site since 1986),

Texas Air National Guard (TXANG) Base Environmental Manager (on site since 2008), and

the TXANG Fire Chief (on site since 1988);

· Identified areas of interest (AOIs) and developed a preliminary conceptual site model (CSM)

to outline the potential release, pathway, and receptors of PFAS for Ellington Field AASF.

Two suspected PFAS releases were identified during the PA, as described below. These releases

constitute two AOIs identified at Ellington Field AASF. The AOIs are shown in Figure ES-1 and

summarized in Table ES-1 below.

Table ES-1: AOIs at Ellington Field AASF

Area of

Interest

Description Used by Release Dates

AOI 1

Releases during AFFF fire extinguisher

training with mobile carts at the wash rack; 

discharged to OWS, and then to the

sanitary sewer system.

TXARNG

and TXANG 1990s - 2009

AOI 2

Releases during AFFF fire extinguisher

training with mobile carts at the flight line.

Surface runoff flows to stormwater

discharge outfall 005 and eventually flows

to Horsepen Bayou.

TXARNG

and TXANG 1990s - 2009

Based on the reported AFFF releases at these AOIs, there is potential for exposure to PFAS

contamination in media at or near the facility. The preliminary CSMs for AOI 1 and AOI 2, which

present the potential receptors and media impacted, are shown on Figure ES-2 and Figure ES-3,

respectively. Based on the US Environmental Protection Agency (USEPA) Unregulated

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

public water system above the USEPA Health Advisory (HA) within 20 miles of the facility. PFAS

analyses performed in 2016 had method detection limits that were higher than currently
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

2

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

UCMR3 but might be detected if analyzed today.
TXANG Hangar 1382

TXANG Hangar 1394

TXANG Old

Fire Station

Stormwater Discharge

Outfall 001

Coast Guard

Wash Rack

Hangar

Stormwater Discharge

Outfall 005

Aviation Ground Power

Unit (AGPU) Fire

Flight Line

TXANG New

Fire Station

TXANG Aircraft

Parking Apron

AOI 1

AOI 2

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

4/14/2020

4/14/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:7,200

4/14/2020 ­ Figure ES-1 PM RG 4/14/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

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

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

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\TX\Ellington_Field_PA_Figures\Fig_ES-1_Ellington_Field_Summary.mxd

0 300 600 1,200

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Canal/Ditch

Brio Superfund

Site

NASA

3
Media

SOURCE PATHWAY RECEPTOR

AOI 1

Wash Rack

AFFF Release

during AFFF

fire

extinguisher

training

PFAS in

Surface Soil

near Wash

Rack

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

particulate

Surface Soil

at AOI

Surface

Water/

sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

/ / /

/ /

LEGEND

/ /

/ / /

Figure ES-2

Preliminary Conceptual Site Model

AOI 1 AFFF Release at Wash Rack at Ellington Field AASF

Potential

Off-Facility

Source Not

under

Control of

ARNG

/

/

/

/

/

/ /

/

/

Note:

1. The residential receptor

refers to an off-facility

receptor.

/

4
Media

SOURCE PATHWAY RECEPTOR

AOI 2 Flight

Line

AFFF Release

during AFFF fire

extinguisher

training

AFFF

collects in

storm water

Discharge

Outfall 005

Human

Activities

Precipitation/

Run-Off

allows AFFF

to eventually

reach

Horsepen

Bayou

Leaching/

Infiltration

Airborne Soil

particulate

Surface Soil

at AOI

Surface

Water/

sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

/ / /

/ /

LEGEND

/ /

/ / /

Figure ES-3

Preliminary Conceptual Site Model

AOI 2 AFFF Release at Flight Line at Ellington Field AASF

Potential

Off-Facility

Source Not

under

Control of

ARNG

/

/

/

/

/

/ /

/

/

Note:

1. The residential receptor

refers to an off-facility

receptor.

/

5
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

6

1. Introduction

1.1 Authority and Purpose

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

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

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

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

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

Order W912DR17F0192, issued 11 August 2017.

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

that used per- and poly-fluoroalkyl substances (PFAS), primarily releases of aqueous film forming

foam (AFFF) although other sources of PFAS are possible. In addition, the ARNG is assessing

businesses or operations adjacent to the ARNG facility (not under the control of ARNG) that could

potentially be responsible for a PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing

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

framework at both federal and state levels continues to evolve. The US Environmental Protection

Agency (USEPA) issued drinking water Health Advisories (HAs) for PFOA and PFOS in May 2016,

but there are currently no promulgated national standards regulating PFAS in drinking water.

This report presents findings of a PA for PFAS-containing materials at Ellington Field Army

Aviation Support Facility (AASF) (also referred to as the “facility”) in Houston, Texas, in

accordance with the Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA), as amended, the National Oil and Hazardous Substances Pollution Contingency Plan

(40 Code of Federal Regulations Part 300), and Army requirements and guidance.

This PA documents the locations where PFAS were historically stored and reportedly released

into the environment at Ellington Field AASF. The term PFAS will be used throughout this report

to encompass all PFAS chemicals being evaluated, including PFOS and PFOA, which are key

components of AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility;

· Conducted a 1-day site visit on 26 April 2019 and completed visual site inspections (VSIs) at

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

disposed;

· Interviewed personnel during the site visit who were associated with Ellington Field AASF

activities, including the Ellington Field AASF Maintenance Supervisor (on site since 1986),

the Texas Air National Guard (TXANG) Base Environmental Manager (on site since 2008),

and the TXANG Fire Chief (on site since 1988);

· Identified areas of interest (AOIs) and developed a preliminary conceptual site model (CSM)

to outline the potential release, pathway, and receptors of PFAS for Ellington Field AASF.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

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1.3 Report Organization

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

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

of each are:

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

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

· Section 2 – Fire Training Areas: describes the potential or suspected fire training areas

(FTAs) at the facility identified during the site visit

· Section 3 – Non-Fire Training Areas: describes other locations of potential or suspected

PFAS releases at the facility identified during the site visit

· Section 4 – Emergency Response Areas: describes areas of suspected or potential AFFF

release at the facility, specifically in response to emergency situations

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

that are not under the control of ARNG

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

and receptors at the AOIs

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

PA

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

Ellington Field AASF was built in the 1970s. Texas ARNG (TXARNG) staff interviewed during the

site visit have worked at the facility as early as 1986. Ellington Field AASF is home to the 149th

Attack Reconnaissance Battalion of the TXARNG and occupies the northwest corner of Ellington

Field. The southern portion of Ellington Field has been leased to the National Aeronautics and

Space Administration (NASA) by the City of Houston. The Ellington Field airfield is jointly used by

Department of Defense (DoD) and private parties (147 CES/CEV, June 2013). Ellington Field was

officially inactivated by the Air Force in 1976, and all Air Force Reserve squadrons were

transferred to other military facilities; however, the TXARNG, TXANG, US Army Reserve, US Navy

Reserve, US Marine Corps Reserve, US Coast Guard, and the Civil Air Patrol still maintain a

military presence at the base. The facility is located 16 miles southeast of downtown Houston and

is 11 miles west of Trinity Bay (Figure 1-1). In 2009, the Air Force issued a permit with a term

expiring in 2039 (Appendix A) for the TXARNG’s use of approximately 17.6 acres of land and

facilities at Ellington Field Air National Guard Base (ANGB), Harris County, Texas.

1.5 Facility Environmental Setting

Ellington Field AASF is located in south-eastern Texas, approximately 32 miles northwest of the

Gulf of Mexico. The facility is situated near Horsepen Bayou, which feeds into Clear Lake, which

then flows into Trinity Bay and Galveston Bay.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

8

1.5.1 Geology

The Houston area is located in the Gulf Coast Plain physiographic province. The Gulf Coast Plain

includes depositional environments ranging from fluvial, fluvial-deltaic, barrier-strand plain, and

bay-estuary lagoon. Underlying Tertiary and Quaternary units were deposited in coastal

environments similar to active processes today. Geologic outcrops in the area of Houston and

Harris County consist primarily of the Pleistocene Beaumont Formation and more recent

Quaternary alluvium along surface water channels (Figure 1-2). The Beaumont Formation, also

called the Beaumont Clay, is typically described as poorly bedded, calcareous clay of various

colors, containing discontinuous stringers and beds of silt and fine sand. Total thickness of the

Beaumont Clay ranges from about 500 feet in Harris County to about 700 feet in the vicinity of

Galveston (Leidos, 2018).

1.5.2 Hydrogeology

The primary hydrogeologic unit present in the Gulf Coast Plain physiographic province is the Gulf

Coast Aquifer System (GCAS). The GCAS framework includes the shallower Chicot aquifer, which

is composed of the Pleistocene, Lissie, and Willis formations, and a deeper Evangeline aquifer,

which is composed of the upper and lower Pliocene-age Goliad formation (Figure 1-2). The GCAS

consists of complex interbedded clays, silts, sands, and gravels of Cenozoic age, which are

hydrologically connected to form a large, leaky, artesian aquifer system. This system comprises

four major components consisting of the following generally recognized water-producing

formations. The deepest formation is the Catahoula, which contains groundwater near the outcrop

in relatively restricted sand layers. Above the Catahoula is the Jasper aquifer, which is primarily

contained within the Oakville sandstone. The Burkeville confining layer separates the Jasper from

the overlying Evangeline aquifer, which is contained within the Fleming and Goliad sands. The

Chicot aquifer, or upper component of the GCAS, consists of the Lissie, Willis, and Beaumont

formations, and overlying alluvial deposits. Not all formations are present throughout the system,

and nomenclature often differs from one end of the system to the other. Maximum total sand

thickness ranges from 700 feet in the south to 1,300 feet in the northern extent. The average

depth of groundwater at the facility is typically around 10 feet below ground surface (bgs) and

generally flows to the east (Leidos, 2018).

The facility’s drinking water is supplied by the City of Houston. A query of the Texas Water

Development Board Submitted Driller’s Reports and Groundwater Database identified four

industrial wells, thirty-two (32) monitoring wells, four public supply wells, and one domestic well

within a 1-mile radius of the facility. The industrial water supply wells range in depth from 376 feet

to 555 feet bgs. The monitoring wells range in depth from 15 to 90 feet bgs. The public supply

wells range in depth from 391 to 583 feet bgs, and the domestic well is 548 feet bgs. The public

supply wells are owned by Time Warner Cable, BW Grayson Business Park, and the City of

Houston Ellington Field (two wells). Humble Oil & Refining Co. own one domestic well. These

wells are shown on Figure 1-2. Based on the USEPA Unregulated Contaminant Monitoring Rule

3 (UCMR3) data, it was indicated that no PFAS were detected in a public water system above the

USEPA HA within 20 miles of the facility. PFAS analyses performed in 2016 had method detection

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

PFAS were not detected during the UCMR3 but might be detected if analyzed today.

1.5.3 Hydrology

No natural or significant surface water bodies, navigable waterways, or wetlands are present at

the facility (Leidos, 2018). Armand Bayou is located approximately 4.5 miles east of the facility,

and the Houston Ship Channel is located approximately 9 miles north of the facility. Surface water

flow at the facility is dictated by the facility’s man-made surface drainage system, which is shared
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

9

between TXARNG and TXANG, as well as other occupants that reside at Ellington Field Joint

Reserve Base. The system contains multiple ditches/channels for surface flow. Stormwater

moves by open channel flow and underground drainage pipes until the runoff reaches Horsepen

Bayou, located approximately 2 miles southeast of the facility; Horsepen Bayou flows easterly,

eventually combining with Armand Bayou (Figure 1-3) (Leidos, 2018). Stormwater from TXANG

that may contain PFAS, as demonstrated in the TXANG SI Report (Leidos, 2018), is transported

to Horsepen Bayou through the TXARNG facility in the shared drainage system.

1.5.4 Climate

Houston has a humid subtropical climate, with long, hot and humid summers and short, mild

winters. Houston’s proximity to large water bodies brings in warm air for much of the year. Houston

occasionally faces severe tornadoes as well as thunderstorms. The average high temperature in

Houston reaches 95 degrees Fahrenheit (°F) at the peak of August. Winters are mild to cool with

the average daily high temperature above 60°F. Average annual precipitation is 50 inches, with

even distribution over the year (Weather Atlas, 2019).

1.5.5 Current and Future Land Use

The facility currently includes a hangar (Building 1183), which is used to service army aviation

vehicles such as helicopters. East of the hangar is the TXARNG aircraft parking area, where

aircraft are parked and minor maintenance is performed, and further east of the aircraft parking

area is the flight line. North of the hangar is the TXANG’s new fire station (Building 1190), which

is located along the TXARNG facility boundary. South of the hangar is a wash rack. Ellington Field

AASF also includes paved vehicle parking areas, aircraft and equipment parking areas, and

supporting facilities such as sidewalks and administrative buildings.

Current land use in the direct vicinity of Ellington Field AASF includes the Ellington Field Joint

Reserve Base buildings surrounding the facility, a municipal golf course and oil & gas company

to the west, flight lines to the east, and a concrete supplier and various industrial and commercial

buildings as well as residential use to the north. During personnel interviews, it was noted that

TXARNG is planning to expand the AASF Building 1183 and retrofit the hangar with a high

expansion foam AFFF fire suppression system. No other future changes to the current use were

noted during personnel interviews.
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

9/30/2019

9/30/2019

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:63,360

9/30/2019 ­ Figure 1-1 PM RG 9/30/2019

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_1-1_Ellington_Field_Facility_Location.mxd

Legend

Facility Boundary

0 0.5 1 2

Miles

^_

Ellington Field

10
!C(

A!

A!

A!

AA!!

A!

AA

!!AA!!

A!

A!

!5

A!

A!

A!

A!

A!

A!

A!

A!

!C(

A! A!

A!

A!

A!

!5

!P

!C( !C(

!5

!5

A!

A! A!

A! A! A!A!

Horsepen Bayou

Turkey Creek

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

1/7/2020

1/7/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:31,680

1/7/2020 ­ Figure 1-2 PM RG 1/7/2020

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_1-2_Ellington_Field_Groundwater.mxd

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Pipeline

Inferred Groundwater

Flow Direction

Geology

Quaternary Sand and

Silt

Pleistocene Clay and

Silt

Wells

!P Domestic Well

!5 Industrial Well

A! Monitoring Well

!C( Public Supply Well

A! Other Well

0 0.25 0.5 1

Miles

11
Vince Bayou-Buffalo

Bayou Watershed

Clear Creek-Frontal

Galveston Bay

Watershed

Horsepen Bayou

Turkey Creek

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

2/28/2020

2/28/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:31,680

2/28/2020 ­ Figure 1-3 PM RG 2/28/2020

12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

\\URSGermantown.us.ie.urs\Germantown\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_1-3_Ellington_Field_Surface_Water.mxd

0 0.25 0.5 1

Miles

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Pipeline

Surface Water Flow

Direction

12
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

13

2. Fire Training Areas

With the exception of mobile cart extinguisher testing/training at the wash rack area and the flight

line (described in Sections 3.1 and 3.2, respectively), Ellington Field AASF personnel (onsite

since 1986) confirmed there are no current or historical designated FTAs at the facility.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

14

3. Non-Fire Training Areas

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

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

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

features obtained during the PA are included in Appendices A and B. The Ellington Field AASF

is comprised of the hangar, administrative buildings, parking lots, a wash rack area, and flight line.

These non-FTAs were investigated during the PA. These and other areas are described below

and shown on Figure 3-1, with photographs provided in Appendix C.

3.1 Wash Rack Area

TXARNG personnel began training with Tri-MaxTM units in the early 1990s. TXARNG personnel

practiced with Tri-MaxTM units once a year with the TXANG fire department at the wash rack or

the flight line. Training with one or two Tri-MaxTM units occurred each year. To practice using the

Tri-MaxTM units, a metal burn box was set on fire, and the AASF personnel would practice putting

it out. During Tri-MaxTM training at the wash rack, the AFFF would have flowed to the oil-water

separator (OWS), then to the sanitary sewer system. Wastewater discharges to the Metro Central

Waste Treatment Facility at 12815 Galveston Rd, Webster, Texas, approximately 1.8 miles south

of the facility. AFFF discharged at the wash rack may have migrated from the paved area to the

nearby grassy area and infiltrated into soil.

The Tri-MaxTM units were disposed of between 2007 and 2009 due to deteriorating hoses. In

around 2010, AFFF at the facility was donated to the TXANG fire department, and Tri-MaxTM units

were replaced with Purple K units. TXARNG personnel onsite since 1986 are not aware of any

bulk AFFF stored at the facility. No bulk AFFF was discovered on-site during an annual building

inspection conducted by the TXANG fire chief in 2010. Geographic coordinates for the AASF wash

rack are 29°36'39.31"N; 95°10'09.54"W.

3.2 Flight Line

TXARNG personnel practiced with Tri-MaxTM units once a year with the TXANG fire department

at the wash rack or the flight line. Training with one or two Tri-MaxTM units occurred each year. A

metal burn box was set on fire, and the AASF personnel would practice putting it out.

Tri-MaxTM units were stationed on the flight line. AASF personnel interviewed recalled Tri-MaxTM

units being on-site in the early 1990s. Initially the AASF personnel were responsible for

maintaining the Tri-MaxTM units, but that responsibility was later given to the TXANG fire

department, and then to a third-party contractor. One person interviewed recalled there being at

least 10 Tri-MaxTM units at the facility.

At peak operation (before 1995), there were between 30 to 40 helicopters on-site. Historically,

there was one Tri-MaxTM fire extinguisher staged between every two helicopters stored on the

flight line.

Personnel recalled the Tri-MaxTM units rusting frequently; repairs and hydrostatic testing were

performed on the units by an outside contractor. These repairs and tests occurred off site. One

person interviewed recalled training four or five times with the Tri-MaxTM units. The geographic

coordinates for the AASF flight line are 29°36'41.77"N; 95°10'04.34"W.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

15

3.3 Hangar

The hangar (Building 1183; built in the 1970’s) is located adjacent to the flight line and is used for

helicopter maintenance, storage, and training. No fire suppression system is currently installed at

the hangar. No known releases of AFFF have occurred at the hangar. The facility has future

renovation plans to install a high expansion foam AFFF fire suppression system in the hangar.

The geographic coordinates for the hangar are 29°36'41.04"N; 95°10'09.92"W.

3.4 Landfills

During PA interviews, TXARNG staff noted no current or former landfills located at or in the vicinity

of Ellington Field AASF.

Landfills are not usually a primary release area of PFAS, but materials disposed in landfills may

create a secondary source of contamination. Such materials may include sludge from a

wastewater treatment plant that processes PFAS-laden water, used AFFF storage containers, or

products associated with waterproofing uniforms or boots.
Hangar/Building 1183

Wash Rack

Flight Line

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

2/28/2020

2/28/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:4,800

2/28/2020 ­ Figure 3-1 PM RG 2/28/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Area

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

\\URSGermantown.us.ie.urs\Germantown\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_3-1_Ellington_Field_Non-Fire_Training_Area.mxd

0 200 400 800

Feet

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Canal/Ditch

16
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

17

4. Emergency Response Areas

In 1997 an aircraft ground power unit (AGPU) caught fire on the Ellington Field AASF flight line,

and Tri-MaxTM units were used to put the fire out. Figure 4-1 shows the approximate extents of

this emergency response area.
Aviation Ground

Power Unit

(AGPU) Fire

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

10/22/2019

10/22/2019

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

10/22/2019

1:4,800 ­ Figure 4-1 PM RG 10/22/2019

12420 Milestone Center Drive

Germantown, MD 20876

Emergency Response Area

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_4-1_Ellington_Field_Emergency_Response_Area.mxd

0 200 400 800

Feet

Legend

Potential PFAS Release

Facility Boundary

Water Body

Canal/Ditch

18
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

19

5. Adjacent Sources

Figure 5-1 shows the various adjacent sources described in this section. More information about

the analytical results from sampling at various TXANG locations is presented in the SI Report for

PFOS and PFOA at Ellington Field Joint Reserve Base, Houston, Texas (Leidos, 2018), included

in Appendix A.

5.1 Brio Superfund Site

The Brio Superfund Site is located at 2501 Dixie Farm Rd in Friendswood, Texas, approximately

3.5 miles southwest of Ellington Field AASF. The 58-acre Brio Refining, Inc. site was used as a

chemical reprocessing and refining facility from the 1950’s to 1982. Chemical disposal practices

contaminated groundwater, surface soils, and subsurface soils with hazardous chemicals.

Following cleanup, USEPA removed the site from the Superfund program’s National Priorities List

in 2006. Currently, elevated groundwater contaminant concentrations have been reported in the

50-foot sand water bearing zone at the Brio Site, and field work is being completed to investigate

the need for further remedial action (USEPA, Brio Refining, Inc., 2019). There is no known use of

PFAS at the site, and groundwater flow to the east is unlikely to bring contamination from the Brio

Site to Ellington Field.

5.2 TXANG Old Fire Station

The old fire station (Building 694) operated by TXANG from pre-1988 to 2012 reported having

minor leaks of AFFF from crash response trucks and firetrucks over the years (BB&E, Inc., 2016).

The old fire station is located approximately 2,600 feet south of the TXARNG hangar.

A monitoring well was installed adjacent to the old fire station in 2018 to determine PFAS levels

in shallow groundwater. Results indicated estimated PFOS and PFOA levels of 40,000 and 14,000

ppt, respectively. These results are orders of magnitude higher than the USEPA HA of 70 ppt of

combined PFOS and PFOA (Leidos, 2018).

5.3 TXANG New Fire Station

The facility currently receives fire protection from the new TXANG Fire Department fire station,

located just north of the TXARNG hangar, in Building 1190, constructed in 2012. The TXANG Fire

Chief (onsite since 1988) reported their department switched from AFFF with longer-chain (C8)

PFAS to AFFF with short-chain (C6) PFAS in December 2016.

AFFF manufactured with short-chain (C6) fluorotelomer-based PFAS do not contain or breakdown

in the environment to PFOS and other long-chained PFAS and are currently considered lower in

toxicity and have significantly reduced bioaccumulation potential compared to long-chain PFAS.

However, foams made with only short-chain (C6) PFAS may still contain trace quantities (parts

per billion) of PFOA and PFOA precursors as byproducts of the manufacturing process. Current

best management practices suggest that industries that require AFFF use (for example, military

applications) purchase foams that consist of short-chain (C6) PFAS (Interstate Technology

Regulatory Council [ITRC], October 2018).

The TXANG Fire Chief reported that his department has never trained with the AFFF spray from

a firetruck. However, TXANG has conducted joint fire training using AFFF-containing mobile carts

with TXARNG staff at the TXARNG wash rack and flight line from the early 1990s to approximately

2009. The new fire station currently uses fire/crash response vehicles and firetrucks that are
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

20

equipped with AFFF containing short-chain (C6) PFAS but does not currently conduct fire training

exercises involving AFFF with the TXARNG.

In 2018, groundwater sampling results from a monitoring well installed adjacent to the new fire

station indicate estimated levels of PFOS and PFOA of 2,200 and 350 ppt, respectively. These

levels exceed the USEPA HA of 70 ppt of combined PFOS and PFOA (Leidos, 2018).

5.4 Stormwater Discharge Outfalls

Stormwater discharge outfalls were also tested for PFAS in 2018. A surface water sample taken

from stormwater discharge outfall 005 (located in the flight line of TXARNG facility) exceeded the

USEPA HA of 70 ppt, with a combined PFOS and PFOA result of 103 ppt (Leidos, 2018).

5.5 TXANG Aircraft Parking Apron

Groundwater samples from four monitoring wells installed at the aircraft parking apron, north of

TXARNG facility, all exceed the USEPA HA of 70 ppt of combined PFOS and PFOA; results

ranged from 133 to 28,600 ppt of combined PFOS and PFOA (Leidos, 2018).

5.6 TXANG Hangars 1382 and 1394

Hangars 1382 and 1394 both previously contained AFFF in fire suppression systems. The AFFF

fire suppression systems were removed from both hangars. In 2014, the AFFF fire suppression

system in Hangar 1382 was replaced with a high-expansion foam system. Interviews with site

personnel indicate a few minor AFFF releases at both hangars in the past.

Soil samples collected just east of Hangar 1382 had PFOS/PFOA compounds detected, with one

PFOS (2,000 J micrograms per kilogram) exceedance of the USEPA and Texas Commission on

Environmental Quality (TCEQ) screening level in subsurface soil. Groundwater data compared to

screening criteria indicated an exceedance of the USEPA HA for PFOS and PFOA (combined),

with a result of 28,600 nanograms per liter (ng/L). PFOS, PFOA, PFHxS, and PFHpA exceeded

their respective groundwater TCEQ screening levels as well.

Soil samples collected just south of Hangar 1394 had PFOS/PFOA compounds detected but had

no exceedances of the screening criteria for soil. Groundwater data indicated an exceedance of

the USEPA HA for PFOS and PFOA (combined), with a result of 1,783 ng/L. PFOS and PFHxS

exceeded their respective groundwater TCEQ screening levels as well (Leidos, 2018).

5.7 NASA

NASA leases the southern portion of Ellington Field from the City of Houston and hosts various

privately held companies on its property. NASA operations may have contributed PFAS due to the

suspected use of AFFF for firefighting purposes. No personnel from NASA were interviewed, and

AFFF use is unknown.
TXANG Hangar 1382

TXANG Hangar 1394

TXANG Old

Fire Station

Stormwater Discharge

Outfall 001

Stormwater Discharge

Outfall 005

TXANG New

Fire Station

TXANG Aircraft

Parking Apron

NASA

Coast Guard

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

1/9/2020

1/9/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:15,840

1/9/2020 ­ Figure 5-1 PM RG 1/9/2020

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

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

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\TX\Ellington_Field_PA_Figures\Fig_5-1_Ellington_Field_Adjacent_Source.mxd

0 0.125 0.25 0.5

Miles

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

Canal/Ditch

Pipeline

Brio Superfund

Site

21
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

22

6. Preliminary Conceptual Site Model

Based on the PA findings, the AFFF release areas associated with the Ellington Field AASF wash

rack and flight line were identified as AOI 1 and AOI 2, respectively. This section describes the

CSM components and the specific preliminary CSMs developed for the AOIs. The CSM identifies

the three components necessary for a potentially complete exposure pathway: (1) source, (2)

pathway, and (3) receptor. If any of these elements are missing, the pathway is considered

incomplete. The AOIs are shown on Figure 6-1, and the preliminary CSMs for AOI 1 and AOI 2

are presented on Figure 6-2 and Figure 6-3, respectively.

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

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

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

continue to be the subject of PFAS toxicological study. Receptors at Ellington Field AASF include

site workers, construction workers, and trespassers. Secondary receptors include recreational

users and residents outside of the facility boundary. As described below, the preliminary CSMs

for the wash rack and flight line AOIs indicate the specific receptors that could potentially be

exposed to PFAS.

6.1 AOI 1 Wash Rack

AFFF was used at the wash rack during yearly fire training from the early 1990s to approximately

2009. An unknown quantity of AFFF was released during these fire training events, where

reportedly one or two Tri-MaxTM units were used for practice.

Releases at the wash rack would have been conveyed to the OWS, then flowed to the sanitary

sewer system, and ultimately discharged to the Metro Central Waste Treatment Facility, located

approximately 1.8 miles south of the facility. Underground conveyances to the OWS as well as

the OWS itself may have leaks that released PFAS to the subsurface. During training exercises,

AFFF may have migrated from the paved wash rack area to the grassy areas south of the wash

rack and infiltrated into soil. Runoff could also have caused AFFF to migrate to the ditch to the

east of the wash rack, where it would eventually discharge through Stormwater Discharge Outfall

001 at the southern end of the facility. Once inside the box culverts, the stormwater flow continues

south, until the runoff reaches Horsepen Bayou (BB&E, Inc., 2016). Under such scenarios, ground

disturbing activities in these areas could result in site or construction worker exposure to PFAS

via inhalation of dust or ingestion of exposed surface or subsurface soil. Site and construction

workers could also be exposed to PFAS contaminated surface water and sediment. Additionally,

recreational users of Horsepen Bayou and connected water bodies could be exposed to PFAS

contaminated surface water.

Potential PFAS contamination may have further infiltrated to shallow groundwater, which flows to

the east. During the TXANG PFAS SI, four monitoring wells were installed at the downgradient

facility boundary. The concentrations of PFOA/PFOS in all of the wells exceeded the HAs (Leidos,

2018). Therefore, it is likely that PFAS contamination in groundwater has already migrated off the

facility. Four public supply wells and one domestic well were identified within a 1-mile radius of

the facility, according to the Texas Water Development Board Groundwater Database Reports;

however, none of these wells were identified to the east of the facility, which the SI noted is the

direction that shallow groundwater flows.

6.2 AOI 2 Flight Line

AFFF was used at the flight line during fire training from the early 1990s to approximately 2009.

An unknown quantity of AFFF was released during these fire training events.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

23

Based on the nature of the release (during routine training), it appears unlikely that AFFF would

have been discharged to the ground surface outside of the flight line. AFFF released on the flight

line would likely flow to stormwater discharge outfall 005, which is located within the flight line.

TXANG sampled surface water from Stormwater Discharge Outfall 005 during their PFAS SI. The

sample contained 700 ppt PFOA/PFOS (Leidos, 2018). The outfall conveys flow south to

Horsepen Bayou, and then to Armand Bayou (BB&E, 2016). Under such scenarios, ground

disturbing activities in these areas could result in site or construction worker exposure to PFAS

via inhalation of dust or ingestion of exposed surface or subsurface soil. Site and construction

workers could also be exposed to PFAS in surface water and sediment. Additionally, recreational

users of Horsepen Bayou and connected water bodies could be exposed to PFAS in surface

water.

Potential PFAS contamination may have further infiltrated to shallow groundwater, which flows to

the east. The TXANG installed four monitoring wells during the PFAS SI at the downgradient

facility boundary. The concentrations of PFOA/PFOS in all of the wells exceeded the HAs (Leidos,

2018). Therefore, it is likely that PFAS contamination in groundwater has already migrated off the

facility. Four public supply wells and one domestic well were identified within a 1-mile radius of

the AASF, according to the Texas Water Development Board Groundwater Database Reports;

however, none of these wells were located east of the facility.
A!

A!

A!

A!

A!

A!

A!

A! A!

TXANG Hangar 1382

TXANG Hangar 1394

TXANG Old

Fire Station

Stormwater Discharge

Outfall 001

Coast Guard

Wash Rack

Hangar/Building 1183

Stormwater Discharge

Outfall 005

Aviation Ground Power

Unit (AGPU) Fire

Flight Line

TXANG New

Fire Station

TXANG Aircraft

Parking Apron

AOI 1

AOI 2

Clear Creek-Frontal

Galveston Bay

Watershed

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

4/14/2020

4/14/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:7,200

4/14/2020 ­ Figure 6-1 PM RG 4/14/2020

12420 Milestone Center Drive

Germantown, MD 20876

Areas of Interest

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

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

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\TX\Ellington_Field_PA_Figures\Fig_6-1_Ellington_Field_AOIs.mxd

0 300 600 1,200

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Canal/Ditch

Surface Water Flow Direction

Inferred Groundwater Flow Direction

Wells

!P Domestic Well

!5 Industrial Well

A! Monitoring Well

!C( Public Supply Well

A! Other Well

!C(

A!

A!

A!

A!!

A!!

A!!!

A!

!5

A!A!

A! A!

A!

A!

A!

A!

!C(

A!

A!

A!

!5

!P

!C(!C(

!5!5

A!

A!A!

A!

A!

A!A!

Clear Creek-Frontal

Galveston

Bay Watershed

Brio Superfund

Site

NASA

24
Media

SOURCE PATHWAY RECEPTOR

AOI 1

Wash Rack

AFFF Release

during AFFF

fire

extinguisher

training

PFAS in

Surface Soil

near Wash

Rack

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

particulate

Surface Soil

at AOI

Surface

Water/

sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

/ / /

/ /

LEGEND

/ /

/ / /

Figure 6-2

Preliminary Conceptual Site Model

AOI 1 AFFF Release at Wash Rack at Ellington Field AASF

Potential

Off-Facility

Source Not

under

Control of

ARNG

/

/

/

/

/

/ /

/

/

Note:

1. The residential receptor

refers to an off-facility

receptor.

/

25
Media

SOURCE PATHWAY RECEPTOR

AOI 2 Flight

Line

AFFF Release

during AFFF fire

extinguisher

training

AFFF

collects in

storm water

Discharge

Outfall 005

Human

Activities

Precipitation/

Run-Off

allows AFFF

to eventually

reach

Horsepen

Bayou

Leaching/

Infiltration

Airborne Soil

particulate

Surface Soil

at AOI

Surface

Water/

sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

/ / /

/ /

LEGEND

/ /

/ / /

Figure 6-3

Preliminary Conceptual Site Model

AOI 2 AFFF Release at Flight Line at Ellington Field AASF

Potential

Off-Facility

Source Not

under

Control of

ARNG

/

/

/

/

/

/ /

/

/

Note:

1. The residential receptor

refers to an off-facility

receptor.

/

26
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

27

7. Conclusions

Two AOIs were identified at Ellington Field AASF during the PA (Figure 7-1).

7.1 Findings

Based on interviews with current AASF personnel, reported historical AFFF releases are

associated with the AFFF fire extinguisher training at the wash rack and flight line. These releases

indicate the potential for PFAS contamination in surface and subsurface soil to intercept one or

more receptors. No evidence of other accidental or incidental spills or leaks from AFFF storage

containers/areas were identified during the site visit. The remaining buildings associated with the

AASF are not equipped with or store AFFF. The findings of potential AFFF release are

summarized in Table 7-1 below.

Table 7-1: AOIs at Ellington Field AASF

Area of Interest Description Used by Release Dates

AOI 1

Releases during AFFF fire

extinguisher training with

mobile carts at the wash rack; 

discharged to OWS, and then

to the sanitary sewer system.

TXARNG and

TXANG 1990s - 2009

AOI 2

Releases during AFFF fire

extinguisher training with

mobile carts at the flight line.

Surface runoff would flow to

stormwater discharge outfall

005 and eventually flow to

Horsepen Bayou.

TXARNG and

TXANG 1990s - 2009

7.2 Uncertainties

Available information sources were investigated during this PA to determine the potential for

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

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

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

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

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

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

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

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

was incomplete. Gathered information has a degree of uncertainty due to the absence of written

documentation, the limited number of personnel with direct knowledge due to staffing changes,

the time passed since PFAS was first used (1969 to present), and a reliance on personal

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

of releases, and the concentration of AFFF used. There is also a possibility the PA has missed a

source of PFAS, as the science of how PFAS may enter the environment continually evolves.

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

of PFAS were reviewed, current personnel were interviewed, multiple persons were interviewed

for the same potential source area, and potential source areas were visually inspected.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

28

Table 7-2 summarizes the uncertainties associated with the PA:

Table 7-2: Uncertainties

Area of Interest Source of Uncertainty

AGPU Fire The exact location of the AGPU fire is unknown; it is assumed

to have happened somewhere in the general flight line area.

7.3 Potential Future Actions

Based on the documented absence (1986-present) of the release of PFAS-containing materials

at the Hangar, evidence does not indicate that current or former TXARNG activities in this area

contributed PFAS contamination to soil, groundwater, surface water, or sediment at Ellington Field

AASF. The Hangar will not move forward in the CERCLA process.

Interviews (covering 1986 to present) indicate that releases during AFFF fire extinguisher training

at the wash rack (AOI 1) and flight line (AOI 2) may have resulted in potential PFAS releases

identified during the PA. Based on the preliminary CSM developed for the AOIs, there is potential

for receptors to be exposed to PFAS contamination in soil at the AOIs. Table 7-3 summarizes the

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

CERCLA process and undergo an SI.

ARNG will evaluate the need for an SI at AOIs 1 and 2 at Ellington Field AASF based on the

presence of a PFAS release, possible receptors, the migration potential of PFAS contamination

to receptors, and the availability of resources.

Table 7-3: Rationale

Area of

Interest AOI Location Rationale Potential FutureAction

AOI 1:

Wash

Rack

29°36'39.31"N; 

95°10'09.54"W

Releases during AFFF fire extinguisher

training with mobile carts at the wash

rack; discharged to OWS, and then to

the sanitary sewer system. AFFF may

have infiltrated into soil, surface

water/sediment, and groundwater in

surrounding area.

Proceed to an SI,

focus on soil,

surface water/

sediment, and

groundwater

AOI 2:

Flight Line

29°36'39.31"N; 

95°10'09.54"W

Releases during AFFF fire extinguisher

training with mobile carts at the flight line.

Surface runoff would flow to stormwater

discharge outfall 005 and eventually flow

to Horsepen Bayou. AFFF may have

infiltrated into nearby soil, surface

water/sediment, and groundwater.

Proceed to an SI,

focus on soil,

surface water/

sediment, and

groundwater
TXANG Hangar 1382

TXANG Hangar 1394

TXANG Old

Fire Station

Stormwater Discharge

Outfall 001

Coast Guard

Wash Rack

Hangar

Stormwater Discharge

Outfall 005

Aviation Ground Power

Unit (AGPU) Fire

Flight Line

TXANG New

Fire Station

TXANG Aircraft

Parking Apron

AOI 1

AOI 2

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

MC

4/14/2020

4/14/2020

NOTES Preliminary Assessment for PFAS at Ellington Field, TX

1:7,200

4/14/2020 ­ Figure 7-1 PM RG 4/14/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

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

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

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\TX\Ellington_Field_PA_Figures\Fig_7-1_Ellington_Field_Summary.mxd

0 300 600 1,200

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Canal/Ditch

Brio Superfund

Site

NASA

29
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

30

8. References

147 CES/CEV, Mr. Mark A Garcia, Ellington Field Base Environmental Manager. June 2013. ReCertification of Ellington Field Environmental Baseline Survey (EBS), Aug 06 for Building 1183

Hangar Expansion Project 1-149th Attack Reconnaissance Battalion, Texas Army National

Guard.

BB&E. May 2016. Final Perfluorinated Compounds Preliminary Assessment Site Visit Report.

147th Reconnaissance Wing, Ellington Field Joint Reserve Base, Texas Air National Guard,

Houston, Texas.

Interstate Technology Regulatory Council (ITRC). October 2018. Aqueous Film-Forming Foam

(AFFF). https://pfas-1.itrcweb.org/wp-content/uploads/2019/03/pfas-fact-sheet-afff-10-3-18.pdf.

Accessed 12 September 2019.

Leidos. December 2018. Site Inspection Report for Perfluorooctane Sulfonate and

Perfluorooctanoic Acid at Ellington Field Joint Reserve Base, Houston, Texas. 147th Attack Wing

Ellington Field Joint Reserve Base, Texas Air National Guard, Houston, Texas.

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

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

USEPA. Brio Refining, Inc. Friendswood, TX. Superfund Site Cleanup Activities.

https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.cleanup&id=0602

601. Accessed 12 September 2019.

Weather Atlas. 2019. Houston, TX – Detailed climate information and monthly weather forecast.

https://www.weather-us.com/en/texas-usa/houston-climate. Accessed 4 September 2019.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix A

Data Resources
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Data resources will be provided separately on CD. Data resources for Ellington Field AASF

include:

Previous Investigations Completed

· Final Perfluorinated Compounds Preliminary Assessment Site Visit Report. 147th

Reconnaissance Wing, Ellington Field Joint Reserve Base, Texas Air National Guard,

Houston, Texas. May 2016. Prepared by BB&E, Inc.

· Final Site Inspection Report for Perfluorooctane Sulfonate and Perfluorooctanoic Acid at

Ellington Field Joint Reserve Base, Houston, Texas. 147th Attack Wing, Ellington Field Joint

Reserve Base, Texas Air National Guard, Houston, Texas. December 2018. Prepared by

Leidos.

· Re-Certification of Ellington Field Environmental Baseline Survey (EBS), August 2006 for

Building 1183 Hangar Expansion Project, 1-149th Attack Reconnaissance Battalion, Texas

Army National Guard. Prepared by 147 CES/CEV Mr. Mark A. Garcia. 4 June 2013.

Miscellaneous Data Resources

· Department of the Air Force Permit to United States Army for Real Property Located on

Ellington Field, Air National Guard Base, Texas.

· Directive for a New 30-Year Permit, Ellington Field (ANG), TX. Department of the Army,

License for National Guard Purposes, Ellington Air National Guard Base, Harris County,

Texas.

· EDRTM Aerial Photo Decade Package, December 2019. Ellington Field AASF, 11300-11468

Blume Ave, Houston, TX 77034.

· EDRTM Radius Map Report with GeoCheck, December 2019. Ellington Field AASF, 11300-

11468 Blume Ave, Houston, TX 77034.

· EDRTM Certified Sanborn Map Report, December 2019. Ellington Field AASF, 11300-11468

Blume Ave, Houston, TX 77034.
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix B.1

Interview Records















PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix B.2

Visual Site Inspection Checklists

PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

Ellington Field AASF

Houston, TX

Appendix C

Photographic Log
Preliminary Assessment Report

Ellington Field AASF Houston, TX

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Ellington Field AASF Houston, Texas

Photograph No. 1

Description:

Photo facing east of US Coast 

Guard Property and above 

ground holding tank. 

Photograph No. 2

Description: 

Historical aerial photo of 

flight line and AASF. 

Historically, 1 Tri-Max fire 

extinguisher unit was placed 

for every 2 helicopters.