FINAL

Preliminary Assessment Report

New Hampshire National Guard 

Training Site

Center Strafford, New Hampshire

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

December 2019

Prepared for:

Army National Guard Headquarters

111 S. George Mason Drive

Arlington, VA 22204

U.S. Army Corps of Engineers, Baltimore District

2 Hopkins Plaza

Baltimore, MD 21201

Prepared by:

AECOM

12420 Milestone Center Drive, Suite 150

Germantown, MD 20876

aecom.com

Contract Number: W912DR-12-D-0014 

Delivery Order: W912DR17F0192
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Strafford, New Hampshire

i

Table of Contents

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

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

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

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

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

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

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

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

1.5.2 Soils ...............................................................................................................7

1.5.3 Hydrogeology .................................................................................................8

1.5.4 Hydrology .......................................................................................................9

1.5.5 Ecological Setting .........................................................................................10

1.5.6 Climate .........................................................................................................11

1.5.7 Current and Future Land Use .......................................................................12

2. Fire Training Areas ...........................................................................................................17

3. Non-Fire Training Areas ...................................................................................................19

Current and Former Leach Field .............................................................................19

Flammables Shed ...................................................................................................19

Kitchen....................................................................................................................19

4. Emergency Response Areas ............................................................................................21

5. Adjacent Off-Facility Sources ...........................................................................................23

Strafford Fire and Rescue .......................................................................................23

New Hampshire Detections .....................................................................................23

6. Preliminary Conceptual Site Model ..................................................................................25

AOI 1 Current and Former Leach Field ...................................................................25

7. Conclusions .....................................................................................................................29

Findings ..................................................................................................................29

Uncertainty .............................................................................................................29

Potential Future Action ............................................................................................30

8. References ......................................................................................................................33
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Strafford, New Hampshire

ii

Tables

Table 1-1: PFAS Analytical Results from Well #1 and Well #3, March 2017

Table 1-2. Federal and State-Listed Species

Table 7-1: AOI at the New Hampshire National Guard Training Site

Table 7-2: No Suspected Release Areas

Table 7-3: Uncertainties

Table 7-4: PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, New Hampshire National Guard Training

Site

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Area of Interest

Figure 6-2 Preliminary Conceptual Site Model, AOI 1 Former and Current Leach Field

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photograph Log
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Strafford, New Hampshire

iii

Acronyms and Abbreviations

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AGQS ambient groundwater quality standards

amsl above mean sea level

AOI area of interest

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CSM conceptual site model

EA EA Engineering, Science, and Technology, Inc.

EDR Environmental Data Resources, Inc.

ERT Earth Resources Technology, Inc.

FTA fire training area

ITRC Interstate Technology Regulatory Council

HA Health Advisory

MCL maximum contaminant level

NGWA National Ground Water Association

NH New Hampshire

NHARNG New Hampshire Army National Guard

NHDES New Hampshire Department of Environmental Services

NHNGTS New Hampshire National Guard Training Site

NHNHB New Hampshire Natural Heritage Bureau

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

ppt parts per trillion

RSP Recruit Sustainment Program

SDS Safety Data Sheet

SI Site Inspection

T&E threatened and endangered
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Strafford, New Hampshire

iv

UCMR 3 Third Unregulated Contaminant Monitoring Rule

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

VSI visual site inspection
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

1

Executive Summary

The United States (US) Army Corps of Engineers (USACE) Baltimore District, on behalf of the

Army National Guard (ARNG)-Installations and Environment Division, Cleanup Branch,

contracted AECOM Technical Services, Inc. (AECOM) to perform Preliminary Assessments (PAs)

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

(PFOA) Impacted Sites at ARNG Facilities Nationwide. The ARNG is assessing potential effects

on human health-related to processes at facilities that used per- and poly-fluoroalkyl substances

(PFAS), primarily in the form of aqueous film forming foam (AFFF) released as part of firefighting

activities, although other PFAS sources are possible.

AECOM completed a PA for PFAS at the New Hampshire National Guard Training Site (NHNGTS)

in Center Strafford, New Hampshire, to assess potential PFAS release areas and exposure

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

· Reviewed data resources to obtain information relevant to suspected PFAS releases;

· Conducted a site visit on 23 April 2019;

· Interviewed current New Hampshire ARNG (NHARNG) personnel at the NHNGTS during the

site visit, including operations staff and personnel;

· Completed visual site inspections (VSIs) at known or suspected PFAS release locations and

documented with photographs; and

· Developed a preliminary conceptual site model (CSM) to outline the potential release and

pathway of PFAS for the Area of Interest (AOI) and the facility (Figure ES-1)

One AOI related to potential PFAS release were identified at the NHNGTS during the PA. The AOI

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

Table ES-1: AOI at the New Hampshire National Guard Training Site

Area of Interest Name Used by Release Dates

AOI 1 Current and Former

Leach Field NHARNG ~1985-Current

Based on potential release of PFAS-containing liquids at this AOI, there is a potential for exposure

to PFAS contamination in media at or near the facility. The preliminary CSM for the NHNGTS,

which presents the potential receptors and media impacted, is shown on Figure ES-2.
Isinglass

River

Town of Strafford

Fire and

Rescue Station

Unnamed Tribut a ry

CochecoRiiver

NHNGTS

Kitchen

NHNGTS

Flammables

Shed

NHNGTS Current

& Former

Leach Fields

Strafford

Elementary

School

AOI 1

0 450 900 1,800

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

1

2

1 2

Summary of Findings

Figure ES-1

CLIENT

REVISED

SCALE

7/5/2019 MS

AM

7/5/2019

7/5/2019

ARNG

GIS BY

CHK BY

TITLE

PROJECT Preliminary Assessment for PFAS at Stafford National Guard Training Site, NH

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NH\Strafford_NHGTS_Figures\Strafford_NHGTS_PA_Figures\Fig_ES-1_Strafford_NHGTS_Summary.mxd

PM RG 7/5/2019

1:10,800 ­ 12420 Milestone Center Drive

Germantown, MD 20876

Base Map: National Agricultural Imagery Program, 2018

Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan,

0 150 300 600

Feet

2
Media

SOURCE PATHWAY RE

AOI 1 

Potential 

releases from 

leach fields

Human 

Activities

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Hum

C

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayComplete Pathway

Site 

Worker

Cons

W

Site 

Worker

Cons

W

LEGEND

Figure E

Preliminary Concep

New Hampshire Nationa

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

PFAS in 

Subsurface 

Soil

/ 

/ 

/ 

/ 

Precipitation/ 

Run-Off

NOTES1. The resident receptor refers to an offsite resident.2. Human consumption of agriculturalproducts potentially affected by PFAS ispossible.

/
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

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1. Introduction

Authority and Purpose

The United States (US) Army Corps of Engineers (USACE) Baltimore District, on behalf of the 

Army National Guard (ARNG)-Installations and Environment Division, Cleanup Branch, 

contracted AECOM Technical Services, Inc. (AECOM) to perform Preliminary Assessments (PAs) 

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

(PFOA) Impacted Sites at ARNG Facilities Nationwide under Contract Number W912DR-12-D0014, Task Order W912DR17F0192, issued 11 August 2017, and Modification 01 issued 30 

September 2017. The ARNG is assessing potential effects on human health related to processes 

at facilities that used per- and poly-fluoroalkyl substances (PFAS), primarily in the form of aqueous 

film forming foam (AFFF) released as part of firefighting activities, although other PFAS sources 

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

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

PFAS are classified as emerging environmental contaminants that are garnering increasing 

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

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

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

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

Advisories (HAs) of 70 parts per trillion (ppt), individually or combined, for PFOA and PFOS in 

May 2016, but there are currently no promulgated national standards regulating PFAS in drinking 

water (USEPA, 2016a; USEPA, 2016b). In the absence of federal maximum contaminant levels 

(MCLs), some states have adopted their own drinking water standards for PFAS. In June 2019, 

the New Hampshire Department of Environmental Services (NHDES) issued Final Proposed 

MCLs and Ambient Groundwater Quality Standards (AGQS) for four PFAS compounds. The 

drinking water rule amendments were subsequently adopted by the New Hampshire Joint 

Legislative Committee on Administrative Rules to be effective on 30 September 2019 (New 

Hampshire Code of Administrative Rules, 2019). The MCLs/AGQS are as follows:

· PFOA: 12 ppt

· PFOS: 15 ppt

· PFHxS: 18 ppt

· PFNA: 11 ppt

This report presents findings of a PA for PFAS at the New Hampshire National Guard Training 

Site (NHNGTS; also referred to as the “facility”) in Center Strafford, New Hampshire, in 

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

(CERCLA; USEPA, 1980), as amended, the National Oil and Hazardous Substances Pollution 

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

requirements and guidance.

This PA documents the locations where PFAS may have been released into the environment. The 

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

including PFOS and PFOA.

Preliminary Assessment Methods

The performance of this PA included the following tasks: 
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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· Reviewed data resources to obtain information relevant to suspected PFAS releases;

· Conducted a site visit on 23 April 2019;

· Interviewed current New Hampshire ARNG (NHARNG) personnel at the NHNGTS during

the site visit, including operations staff and personnel;

· Completed visual site inspections (VSIs) at known or suspected PFAS release locations and

documented with photographs; and

· Developed a preliminary conceptual site model (CSM) to outline the potential release and

pathway of PFAS for the Area of Interest (AOI) and the facility.

Report Organization

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

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

of each are:

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

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

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

identified during the site visit, if present.

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

facility identified during the site visit.

· Section 4 – Emergency Response Areas: describes areas of AFFF release at the facility,

specifically in response to emergency situations, if present.

· 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 for the AOI and the facility.

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

the PA.

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

Facility Location and Description

The NHNGTS occupies approximately 104.7 acres of land in Center Strafford in the Lakes Region 

of New Hampshire (Figure 1-1). Center Strafford is located approximately 7.5 miles southwest of 

Rochester, New Hampshire, and 24 miles northwest of Portsmouth, New Hampshire, and access 

to Interstate 95. Parker Mountain of the Blue Hill Range is located north of the site and Bow Lake 

is located several miles to the southwest. The Isinglass River is located several miles southeast 

(Diversified Technology Consultants, 2005). Center Strafford is a rural residential community with 
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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a total population of approximately 4,114. Strafford County is primarily agricultural and forested 

land with a total population of approximately 130,090 (US Census Bureau, 2018). The 

approximate center of the Property is located at 43°16'42.6" North latitude and 71°07'16.1" West 

longitude at 500 feet above mean sea level (amsl).

The facility was originally developed in 1833 as a boarding school under the name Strafford Union 

Academy. In the early 1900s, the school changed its name to the Austin Cate Academy and 

underwent several improvements over the course of the century. In 1985, the property was sold 

to the State of New Hampshire and was subsequently leased to the NHARNG. The majority of 

the existing buildings onsite were constructed by the Austin Cate Academy but have since been 

renovated by the NHARNG. Five additional buildings have been constructed since the site was 

purchased by the state: three Electronic Skills Trainer buildings, the maintenance shed, and the 

Vehicle Storage Building for the Engineer Detachment.

Currently, the NHNGTS is primarily used for classroom training and small tactical field training by 

the Recruit Sustainment Program (RSP) and NHARNG. The majority of military field training 

occurs during inactive duty training weekends by the NHARNG, typically three weekends per 

month. Facilities at the NHNGTS include a kitchen and dining hall, a drill hall, a running track, 

barracks buildings, and multiple-use operational range areas. The ranges are used for field 

training, land navigation, small arms, and tactical maneuver training. Agricultural lands border the 

installation to the southeast and northwest. The northeast edge of the site and beyond is forested. 

The entire installation, including all ranges, is also open for public recreational use and hunting. 

No barriers or fences mark the installation or range boundaries (ERA, 2008).

Facility Environmental Setting

The following sections describe the environmental setting of the subject property and include 

information on geology, hydrogeology, hydrology, ecological setting, climate, and current and 

future land use.

1.5.1 Geology

Strafford County is situated within the New England Physiographic Province of the Appalachian 

Highlands (Billings, 1980). The site is underlain by Late Devonian Binary Granite. This mediumgrained, gray granite is part of the Hampshire Plutonic series. The surrounding metamorphic 

bedrock is part of the Jenness Pond Schist of the Littleton Formation. Pleistocene deposits 

overlying igneous and metamorphic bedrock consist of glacial till, sand, gravel, and clay. Depth 

to bedrock is approximately 20 feet on the ridge just northeast of the cantonment area. Data on 

depth to bedrock in the lower elevations on site (near the wetlands) are not available (NHARNG, 

2014). Geologic features in the vicinity of the facility are shown on Figure 1-2.

1.5.2 Soils

The cantonment area is primarily underlain by Paxton series soil, a well-drained fine sandy loam 

with a hardpan layer at 16 to 36 inches below ground surface (bgs). This hardpan layer restricts 

movement of water from the surface, creating a high potential for erosion through surface water 

runoff. The range areas are underlain by Gloucester, Paxton, Whitman, and Woodbridge series 

soils, as well as by mucky peat in wetland areas. The soils of the southernmost forested portion 

are of the Paxton series. These soils are well drained and have a much lower potential for erosion 

due to the natural forested vegetation. The soils of the northern forested portion of the site are 

primarily Gloucester series, with Whitman series and muck and peat in the wetlands. Gloucester 

series are excessively drained soils with a potential for erosion. This portion of the site still retains 

its natural vegetation (NHARNG, 2014).
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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1.5.3 Hydrogeology

In general, glacial stratified-drift aquifers made up of layers of sand, gravel, clay, and silt overlying

bedrock are the primary source of groundwater in this region of New Hampshire. Less productive

bedrock aquifers also provide a valuable source of groundwater to some rural water users,

including the NHNGTS (EA, 2018). Temporary monitoring wells installed at the Site in 2006 show

groundwater in the unconsolidated tills of the cantonment area at a depth of approximately 3 feet

bgs near the topographic high point on site (Nobis Engineering, Inc., 2006). In 2013, water levels

measured in test borings within the forested portion of the site showed groundwater ranging from

approximately 10 to 21 feet bgs (Jacobs Engineering Group, 2013). Groundwater features in the

vicinity of the facility are shown on Figure 1-2.

A hardpan soil layer is found just below the surface in the unforested parts of the installation,

which impacts vertical mobility of surface water. Therefore, the infiltration of precipitation to

recharge the shallow aquifer is limited. There are no confining layers between the shallow aquifer

and the bedrock aquifer below. Regional groundwater flow is to the east (ERT, 2008); however, 

localized groundwater flow in the vicinity of the cantonment area is not fully understood. Water

level data for the existing wells in the area were not available for this PA.

Groundwater is the primary source of drinking water in the Center Strafford area. Most, if not all,

drinking water wells penetrate and derive water from the bedrock (ERA, 2008). NHNGTS is

currently served by two private, ARNG-owned drinking water supply wells. Bedrock Well #1 is

approximately 450 feet deep, has a capacity of 20 gallons per minute, and is located 150 feet

north of the Administration Building. Bedrock Well #4 is approximately 605 feet deep, has a

capacity of 25 gallons per minute, and is located 100 feet west of the Administration Building

(NHARNG, 2014). There are institutional wells in Center Strafford less than one mile southeast of

the facility boundary and numerous private domestic drinking water wells surrounding the

installation (Environmental Data Resource, Inc. [EDR], 2019). Locations are of the wells are

shown on Figure 1-2.

The NHARNG sampled the private water supply wells at the NHNGTS (Well #1 and Well #4) for

PFAS in March 2017. Two pre-treatment (pre-filtration) samples were collected, one from each

well, and one post-treatment sample was collected, which consisted of water from both Well #1

and Well #4. Nine of the 18 PFAS compounds analyzed were detected in Well #4 pre-treatment,

with PFOS and PFOA detected at 5.12 and 9.38 ppt, respectively. Only one PFAS compound,

6:2FTS, was detected in Well #1 pre-treatment. All detected compounds were below the New

Hampshire AGQS/MCLs and the USEPA HAs. The PFAS analytical results from March 2017 are

shown on Table 1-1. Additionally, Third Unregulated Contaminant Monitoring Rule (UCMR 3) data

were reviewed as part of the PA; however, no PFAS were detected in a public water system above

the USEPA HA within 20 miles of the facility (USEPA, 2017).
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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Table 1-1: PFAS Analytical Results from Well #1 and Well #3, March 2017

PFAS Compound Well #1

Pre-Treatment1

Well #4

Pre-Treatment1

Well #1/#4

Post-Treatment2

6:2FTS 9.55 - -

8:2FTS - - -

N-ethyl perfluorooctane sulfonamidoacetic

acid (NEtFOSAA) - - -

N-methyl perfluorooctane

sulfonamidoacetic acid (NMeFOSAA) - - -

Perfluorooctanoic acid (PFOA) - 9.38 6.74

Perfluorobutanesulfonic acid (PFBS) - 1.67 1.26

Perfluorobutanoic acid (PFBA) - 3.16 1.97

Perfluorodecanoic acid (PFDA) - - -

Perfluorododecanoic acid (PFDoA) - - -

Perfluoroheptanoic acid (PFHpA) - 2.67 1.75

Perfluorohexanesulfonic acid (PFHxS) - 1.62 1.2

Perfluorohexanoic acid (PFHxA) - 12.5 8.76

Perfluorononanoic acid (PFNA) - 1.17 0.823

Perfluorooctanesulfonic acid (PFOS) - 5.12 3.52

Perfluoropentanoic acid (PFPeA) - 10.3 7.11

Perfluorotetradecanoic acid (PFTeA) - - -

Perfluorotridecanoic Acid (PFTriA) - - -

Perfluoroundecanoic acid (PFUnA) - - -

Notes:

Results are in ppt

1 Source water was sampled from each well from a pre-treatment spigot with a five-minute purge

2

 Post-treatment water was a combination of water from Well #1 and #4 and was sampled from an attached

garden hose after a five-minute purge

1.5.4 Hydrology

The installation lies within the Nippo Brook - Isinglass River sub watershed of the Cocheco River

watershed. Surface water from most of the site flows southeast via a small tributary to the Mohawk

River, which eventually joins the Isinglass River (NHARNG, 2014). The elevation of the Mohawk

River is below the elevation of the surface of the groundwater near the installation. Therefore,

groundwater flow from the installation is likely to flow into the Mohawk River, which acts as

boundary preventing groundwater from the installation interacting with drinking water wells east

of the Mohawk River (ERA, 2008). Surface water features in the vicinity of the facility are shown

on Figure 1-3.

Topography at the NHNGTS is dominated by a ridge that separates the site into two drainage

patterns. The crest of this ridge lies northeast of the cantonment area at the edge of the parade

field and runs northwest to southeast. Based on topography, the cantonment area likely drains to

the southeast, and the operational ranges drain to the northeast (ERA, 2008). A hardpan layer is
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New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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found below the surface of the unforested parts of the site. This low permeability layer restricts

vertical movement of surface water, creating an erosion potential for the site during rain events

(ERA, 2008). There is a small retention basin along the northern boundary of the field which drains

much of the surface water runoff. The swale and retention basin were constructed within the

maneuver training area to channel runoff from the site and prevent erosion, but evidence of

localized erosion can be seen after large rainfall events (EA, 2018).

A number of wetlands have been identified on and off installation as part of the National Wetlands

Inventory [US Fish and Wildlife Service (USFWS), 2007]. Field delineation by the NHARNG

further identified on-installation freshwater wetlands (NHARNG, 2014). These wetlands include

vernal ponds and both intermittent and permanent water bodies. Additionally, a small pond is

located on the northern end of the NHNGTS property (NHARNG, 2018).

Stormwater flow within the cantonment area generally flows in a southerly direction toward New

Hampshire Route 126. There are several storm drain structures, including small diameter cross

culverts, under driveways and drainage pipes exiting isolated catch basins. Stormwater flowing

off the site to the south disperses into drainage channels parallel to New Hampshire Route 126.

The remainder of the property consists of primarily pervious land cover, allowing for infiltration of

precipitation. Stormwater runoff follows the training site’s topography overland and generally flows

in a northerly direction, draining to the wetland complex or the tributary to the Mohawk River (EA,

2018).

1.5.5 Ecological Setting

A 2003 Vegetation Mapping and Floristic Inventory of the facility by the New Hampshire Natural

Heritage Bureau (NHNHB) identified three general vegetation classes at the NHNGTS: developed

area, cultural (human modified and actively managed) vegetation, and natural vegetation. The 14

acres of developed cantonment area consist of native and non-native turf grass which is mowed

regularly. The 26 acres of culturally-modified vegetation consists primarily of the turf species with

a mixture of such plants as clover and common timothy. This part of the installation is cut for hay

once a year by a local farmer (NHARNG, 2014).

The remaining 65 acres of natural vegetation (undisturbed habitat) consist of general forested

upland and five wetland classifications. The forested upland is a mixture of hardwood and conifer

trees with such species as Eastern Hemlock, White Pine, American Beech, Red Oak, and Red

Maple (NHARNG, 2014). There are approximately 20 acres of mapped wetlands in the northern,

forested portion of the property. The wetlands types, as classified by USFWS, include palustrine

emergent, palustrine forested/shrub, and palustrine unconsolidated bottom (pond) (NHARNG,

2014).

The forested portion of the site serves as protected habitat for federally listed threatened and

endangered (T&E) species and other special status species (EA, 2018). New Hampshire statelisted faunal species include 27 endangered and 12 threatened species (USFWS, 2008; NHNHB, 

2004; NHNHB, 2011). Table 1-1 presents a list of federal and state-listed species known to occur

within the Town of Strafford, as well as those species observed at the NHNGTS. The small

whorled pogonia, grassleaf goldenrod, hairy-fruited sedge, eastern meadowlark, American

kestrel, and spotted turtle are the only listed species known to occur at the NHNGTS (EA, 2018).

One spotted turtle was reportedly observed on NHNGTS during an amphibian and reptile survey;

however, no other sightings of this species have been recorded and the reported sighting was not

verified. Suitable habitat exists on NHNGTS to support this species. Although no insect surveys

have been conducted at NHNGTS, the presence of the wetland complex at NGNGTS and the

documented presence of ringed boghaunter in the immediate vicinity of NHNGTS make the

presence of this species a potential likelihood (EA, 2018).
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

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Table 1-2. Federal and State-Listed Species

Common Name Scientific Name State Status Federal Status

BIRDS

American kestrel* Falco sparverius SC -

Bald eagle Haliaeetus leucocephalus T M

Common loon Gavia immer T -

Eastern meadowlark* Sturnella magna SC -

FISH

Branded sunfish Enneacanthus obesus SC -

Bridled shiner Notropis bifrenatus T -

PLANTS

Awlwort* Subularia aquatic spp. americana E -

Goodenough’s sedge* Carex nigra E -

Grassleaf goldenrod* Euthamia caroliniana T -

Hairy-fruited sedge* Carex trichocarpa E -

Inflated sedge* Carex bullata E -

Poplar hawthorn* Crataegus populnea - -

Reversed bladderwort* Utricularia resupinata E -

River bank quillwort* Isoetes riparia var. canadensis E -

Small whorled pogonia* Isotria medeoloides T T

REPTILES

Blanding’s turtle Emydoidea blandingii E -

Smooth green snake Opheodrys vernalis SC -

Spotted turtle** Clemmys guttata T -

Wood turtle Glyptemys insculpta SC -

INVERTEBRATES

Ringed boghaunter Williamsonia lintnen E -

Notes

E = Endangered; Danger of extinction throughout range

T = Threatened; Likely to become endangered in foreseeable future throughout range

SC = Special concern; Species could become threatened in the foreseeable future if conservation 

actions are not taken or that were recently recovered from the endangered or and threatened category

M = Monitored under the USFWS Post-Delisting Monitoring Plan for Bald Eagle; Maintains protection

under MBTA

Bold * Species observed at the NHNGTS

Bold ** Species reportedly observed at NHNGTS, but sighting not verified

* Historical listing (not recorded in the last 20 years)

Sources: NHNHB, 2004; EA, 2018

1.5.6 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 average maximum temperature ranges from 83°Fahrenheit (°F) in July to 31°F in

January. The average minimum temperature ranges from 58°F in July to 14°F in January. In

winter, successive storms deliver light to moderate snowfall amounts, contributing to the relatively
PFAS Preliminary Assessment Report

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12

reliable snow cover. Summer can bring stretches of humid conditions, as well as thunderstorms.

Average annual rainfall is 46 inches (US Climate Data, 2019).

1.5.7 Current and Future Land Use

The current use of the NHNGTS is for classroom training and small tactical field training by two

primary tenants, the NHARNG. Most training by these organizations occurs in classrooms within

the cantonment area. It is estimated that about 12,000 soldiers are trained on site per year for a

day or more. Additional users include the state and county police, who do limited canine training,

run the county Drug Abuse Resistance Education program, and host the New Hampshire Teen

Institute. The facility is also open for public recreational use and hunting. The NHARNG does not

regulate hunting on the facility but estimates that there are less than 20 hunters per year (ERA,

2008). Future land use on the facility is anticipated to remain the same.

The area surrounding the facility largely remains agricultural and rural in nature. The area is zoned

entirely as Residential-Agricultural and includes a mixture of old farmland/open fields, forested

wetlands, single-family homes, and minor municipal development. Municipal town buildings, the

Strafford School, and the Hill Library are located within 0.25 miles of the site (NHARNG, 2014).

Future land use in the immediate area is not expected to change and will remain rural in character.
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Facility Location

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

Intermap, increment P Corp., NRCAN, Esri Japan, METI,

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New Hampshire 

National Guard 

Training Site

^_

012 0.5

Miles

Legend

Facility Boundary

13
&<

&<

!5

!P !P

!P

!P

!P

!5

!P !P !P

!5 A!

!P

!P

!P

!P !P

Unname d Tri butary

Is inglass River

Mohawk River

Co checo Riiver

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Groundwater Features

Well Data Provided by EDR Report.

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0 0.25 0.5 1

Miles

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Inferred Groundwater Flow

Direction

Geology

Biotite Tonalite

Concord Granite

Littleton Formation

Smalls Falls Formation

Perry Mountain Formation

Rangley Formation

Wells

!P Domestic Well

!5 Institutional Well

A! Unknown Well

&<

NHNGTS Water Supply

Well

14
Nippo

Brook-Isinglass

River Watershed

Long Pond

Watershed

Big River

Watershed

Kenneth

Hill Pond

Unna m ed Tributa ry

Is inglass Rive r

Mohawk River

Co checo Riiver

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Surface Water Features

Base Map:

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0 0.25 0.5 1

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Water Body

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River/Stream

Surface Water Flow

Direction

15
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2. Fire Training Areas

No FTAs were identified at the NHNGTS during the PA. Interviewees confirmed that the facility is

supported by the Town of Strafford Fire and Rescue and that firefighting training has never

occurred on the property (Appendix B).
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3. Non-Fire Training Areas

Three non-FTAs were included in the VSI during the PA. A description of each is presented below 

and their locations are shown on Figure 3-1. Photographs of each non-FTA appear in Appendix 

C. 

Current and Former Leach Field

The existing NHNGTS utilizes a single common leach field for wastewater disposal for the entire 

facility, which was originally built in 1993. Septic tanks are located outside each building, and then 

individual building sewage is collected by gravity sewers and conveyed to the leach field via a 

single pump station and twin force mains (Diversified Technology Consultants, 2005). The leach 

field piping is located below ground surface. 

According to interviews with NHNGTS personnel and the NHARNG, the Austin Cate Academy 

leach field was utilized for waste water at the NHNGTS prior to 1993. Engineering drawings 

indicate the current leach field was built in the same location as the former leach field. The 

approximate geographic coordinates for the current and former leach field are 43°16'31.9"N; 

71°07'28.8"W.

According to NHNGTS personnel, the floors in the kitchen and drill hall are polished with Centi 

Finish floor polish. The floor polish is mixed with water in a bucket, and after polishing is complete, 

the unused mixture is dumped down the drain in each respective building. The mixture would 

subsequently be transported through the site’s septic system to the leach field and released to 

the subsurface. The Centi Finish bottle and Safety Data Sheet (SDS) maintained by the NHNGTS 

indicate the formula is proprietary; however, some floor polishes are known to contain PFAS 

(Interstate Technology Regulatory Council [ITRC], 2017). The SDS was dated 2012, but 

interviewees were unaware of when use of the Centi Finish began. It is likely that floor polish has 

been used in buildings since the NHARNG occupied the buildings (Centi Finish or possibly other 

brands).

Because liquids potentially containing PFAS were dumped into the waste system that lead to the 

leach field, the current and former leach field is considered potential release area.

Flammables Shed

The Flammables Shed at the NHNGTS was inspected as part of the VSI. Because there were no 

AFFF or PFAS-containing liquids stored there, and the fire extinguisher was a chemical class, the 

Flammables Shed is not considered a potential release area.

Kitchen

The kitchen at the NHNGTS was inspected as part of the VSI. Two hood fire suppression systems 

and two fire extinguishers were noted. However, because the hood fire suppression systems and 

the fire extinguishers in the kitchen were wet chemical or Class K, the kitchen is not considered 

a potential release area.
NHNGTS

Kitchen

NHNGTS

Flammables Shed

NHNGTS Current &

Former Leach Fields

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Non-Fire Training Areas

Base Map: National Agricultural Imagery Program, 2018

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0 175 350 700

Feet

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Potential PFAS Release

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Facility Boundary

20
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4. Emergency Response Areas

No emergency response areas were identified within the facility during the PA through interviews

or the EDR Report (EDR, 2019). The Town of Strafford Fire and Rescue would handle any

potential fire or emergency response incident at the NHNGTS.
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5. Adjacent Off-Facility Sources

Two potential off-facility sources of PFAS within 4 miles of the NHNGTS were identified during the 

PA. Descriptions of the off-facility sources are presented below and are shown on Figure 5-1. 

Interview records are included in Appendix B.

Strafford Fire and Rescue

The Town of Strafford Fire and Rescue Station is located approximately 2 miles south of the 

NHNGTS at 360 Province Road, Strafford, New Hampshire. The approximate geographic 

coordinates for the Fire and Rescue Station are 43°14'29.3"N; 71°08'50.9"W. Strafford Fire and 

Rescue is responsible for responding to emergencies at the NHNGTS.

Fire and Rescue personnel were not interviewed during the PA because the focus of the 

assessment was to evaluate potential PFAS related activities and sources at NHARNG properties, 

not formally assess adjacent sources. Therefore, it is not known if AFFF is used or stored at the 

Fire and Rescue Station currently or historically. Because the presence of AFFF at the Station 

cannot be confirmed, it has been identified as a potential offsite PFAS source area. Figure 5-1

shows the location of the Strafford Fire and Rescue in relation to the NHNGTS. 

New Hampshire Detections 

The NHDES is engaged in an ongoing investigation PFAS in New Hampshire drinking water and 

maintains an online, interactive PFAS Sampling Results map (NHDES, 2019). The PFAS 

Sampling Results map shows two groundwater sample locations within 4 mile radius of the 

NHNGTS, both of which had no detections of PFAS. The data presented in the database are 

under constant revision, as new sites or facilities are added, and the data may not contain all 

potential PFAS detections.
Bow

Lake

Isinglass River

Town of Strafford

Fire and

Rescue Station

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Adjacent Source

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0 175 350 700

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1

1

Legend

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

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6. Preliminary Conceptual Site Model

Based on the PA findings, one AOI was identified at the NHNGTS: AOI 1 Current and Former 

Leach Field. The AOI location is shown on Figure 6-1. The following section describes the 

preliminary CSM components and the specific preliminary CSM developed for the AOI. The 

preliminary 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. Potential receptors at the NHNGTS include site workers, 

construction workers, recreational users, and trespassers. Potential off-post receptors include 

nearby residents.

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. 

 AOI 1 Current and Former Leach Field

AOI 1 is the Former and Current Leach Field. According to interviews with NHNGTS personnel, 

floor polish is used in the kitchen and drill hall, and after polishing is complete, the unused polish 

mixture is dumped down the drain in each respective building. Although the brand used by the 

NHNGTS has a proprietary formula, and therefore PFAS content cannot be confirmed, some floor 

polishes are known to contain PFAS (ITRC, 2017). Drains in the buildings lead to septic tanks 

located outside each building, and then individual building sewage is conveyed to the leach field 

(Diversified Technology Consultants, 2005). The current leach field was constructed in 1993, prior 

to which the former Austin Cate Academy leach field was utilized by the NHNGTS. Engineering 

drawings indicate the current leach field was built in the same location as the former leach field. 

Because liquids potentially containing PFAS were dumped into the waste system culminating at 

the leach field, and the piping for the leach field was below the ground surface, there is the 

potential for PFAS to have been released directly to the subsurface soil. Therefore, grounddisturbing activities to subsurface soil could result exposure via inhalation of airborne soil 

particulates for onsite workers, construction workers, recreational users, and trespassers. 

Additionally, it could result in onsite construction worker exposure via ingestion of subsurface soil. 

Therefore, the inhalation and ingestion pathways for these receptors are considered potentially 

complete for AOI 1.

Groundwater is the primary source of drinking water in the Center Strafford area. Most, if not all, 

drinking water wells penetrate and derive water from the bedrock (ERA, 2008). NHNGTS is 

currently served by two public water supply wells, there are two municipal wells in Center Strafford 

less than one mile southeast of the facility boundary, and there are numerous domestic drinking 

water wells surrounding the installation (Figure 1-2). Additionally, there are agricultural areas in 

the vicinity that may produce products for human consumption. Although regional groundwater 

flow is to the east, localized groundwater flow in the vicinity of the cantonment area is not fully 

understood; therefore, it is not clear if the existing water supply wells with PFAS detections are 

downgradient of the leach field.

PFAS are water soluble and can migrate readily from soil to groundwater, which is estimated to 

be 10 to 20 feet bgs. Because potential PFAS releases to subsurface soil at AOI 1 may have 

occurred, PFAS may migrate from the subsurface soil to the groundwater via leaching. Therefore, 

the ingestion exposure pathway for groundwater is considered potentially complete for site 

workers, onsite and offsite construction workers, and nearby offsite residents. The preliminary 

CSM for AOI 1 is shown on Figure 6-2.
Isinglass

River

Nippo

Brook-Isinglass

River Watershed

Town of Strafford

Fire and

Rescue Station

&<

&<

!5

!P

!P

!P

!5

!P

!P

!5 A!

!P

!P Unnamed Tribut a ry

CochecoRiiver

Nippo

Brook-Isinglass

River Watershed

NHNGTS

Kitchen

NHNGTS

Flammables

Shed

NHNGTS Current

& Former

Leach Fields

AOI 1

0 450 900 1,800

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow Direction

Inferred Groundwater Flow Direction

!P Domestic Well

!5 Institutional Well

A! Unknown Well

&<

NHNGTS Water Supply Well

1

2

1 2

Area of Interest

Figure 6-1

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26
Media

SOURCE PATHWAY RE

AOI 1 

Potential 

releases from 

leach fields

Human 

Activities

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Hum

C

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayComplete Pathway

Site 

Worker

Cons

W

Site 

Worker

Cons

W

LEGEND

Figure 

Preliminary Concep

AOI1 Former and Cur

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

PFAS in 

Subsurface 

Soil

/ 

/ 

/ 

/ 

Precipitation/ 

Run-Off

NOTES1. The resident receptor refers to an offsite resident.2. Human consumption of agriculturalproducts potentially affected by PFAS ispossible.

/
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7. Conclusions

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

storage, and potential release of PFAS at the NHNGTS. The PA findings are based on the 

information presented in Appendix A and Appendix B.

Findings

One AOI related to a PFAS releases was identified (Table 7-1) at the NHNGTS during the PA 

(Figure 7-1).

Table 7-1: AOI at the New Hampshire National Guard Training Site

Area of

Interest Name Used by Potential ReleaseDates

AOI 1 Former and Current

Leach Field NHARNG ~1985 - Current

Based on the potential PFAS releases at this AOI, there is potential for exposure to PFAS 

contamination in media at or near the facility. The preliminary CSM for AOI 1 is shown on Figure 

6-2, which presents the potential receptors and media impacted.

The following areas discussed in Section 2 through Section 5 were determined to have no 

suspected PFAS release to the environment (Table 7-2).

Table 7-2: No Suspected Release Areas

No Suspected

Release Area Used by Rationale for No SuspectedRelease Determination

Flammables Shed NHARNG No AFFF or PFAS-containing liquids stored in shed; the

fire extinguisher was chemical class.

Kitchen NHARNG Hood fire suppression systems and the fire extinguishers

in the kitchen were wet chemical or Class K.

Uncertainty

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

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

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

were not typically kept by the facility or available during the PA on the use of PFAS-containing 

materials. 

The conclusions of this PA are predominantly based on the information provided during interviews 

with personnel who had direct knowledge of potential PFAS use at the facility. Sometimes the 

provided information was vague. 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 were first used (1969 to present), and a reliance 

on personal recollection. Inaccuracies may arise in potential PFAS release locations. There is 

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

the environment continually evolves.
PFAS Preliminary Assessment Report

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

of PFAS were reviewed, multiple persons were interviewed for the same potential source area, 

and potential source areas were visually inspected. Table 7-3 summarizes the uncertainties 

associated with the PA.

Table 7-3: Uncertainties

Area of Interest Source of Uncertainty

AOI 1: Former and

Current Leach Field

Because the Centi Finish floor polish contents are proprietary, it is not

definitively known whether the product contains PFAS. If PFAS are

present in the floor polish, the type and concentration are unknown.

Additionally, the exact quantities and dates of floor polish used are not

documented. Although it is likely that floor polish has been used in

buildings since 1985, the other brands used (and whether they contain

PFAS) are not known.

Additionally, the construction details of the former leach field from the

Austin Cate Academy are unknown. The former leach field would have

been utilized by the NHARNG from 1985 to 1993, when the current

leach field was constructed.

Finally, although regional groundwater flow is to the east, localized

groundwater flow in the vicinity of the cantonment area is not fully

understood; therefore, it is not clear if the existing water supply wells

with PFAS detections are downgradient of the leach field. Water level

data for the existing wells in the area were not available for this PA.

Potential Future Action

The degree of uncertainties associated with the interviews and data collected during the PA 

indicate that current or former ARNG activities may have resulted in potential PFAS releases at 

the one AOI identified during the PA. Based on the preliminary CSM developed for the AOI, there 

is potential for receptors to be exposed to PFAS contamination in subsurface soil and groundwater 

at this AOI. Table 7-4 summarizes the rationale used to determine if the AOI should be considered 

for further investigation under the CERCLA process and undergo a SI. 

ARNG evaluates the need for an SI at the NHNGTS based on the presence of a PFAS release, 

possible receptors, and the migration potential of PFAS contamination to receptors. 

Table 7-4: PA Findings Summary

Area of

Interest

AOI

Location Rational PotentialFuture Action

AOI 1 Current

and Former

Leach Field

43°16'31.9"N;

71°07'28.8"W

Potential for PFAS-containing liquids

dumped in NHNGTS building drains to be

released from the leach field.

Proceed to an SI,

focus on

subsurface soil

and groundwater
Isinglass

River

Town of Strafford

Fire and

Rescue Station

Unnamed Tribut a ry

CochecoRiiver

NHNGTS

Kitchen

NHNGTS

Flammables

Shed

NHNGTS Current

& Former

Leach Fields

AOI 1

0 450 900 1,800

Feet

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

1

2

1 2

Summary of Findings

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8. References

Billings, Marland, 1980. The Geology of New Hampshire. New Hampshire Division of Forests and

Lands, Department of Resources and Economic Development, Concord, New Hampshire.

Comprehensive Environmental, Inc., 2005. NH National Guard Strafford Training Site Water

Supply System Vulnerability Assessment.

Diversified Technology Consultants, 2005. Draft Environmental Assessment Real Property

Development Plan New Hampshire National Guard Training Site. February.

EA, 2018. Draft 2018 Operational Range Assessment Periodic Review Binder, New Hampshire

Army National Guard. October.

EDR, 2019. The EDR Radius MapTM Report with GeoCheck®; Aerial Photo Decade Package; 

and Certified Sanborn® Map Report; New Hampshire National Guard Training Site, 1151

Parker Mountain Road, Strafford, NH 03884. May.

ERT, 2008. Final Operational Range Assessment Program, Phase I Qualitative Assessment

Report, New Hampshire National Guard Training Site, Center Strafford, New Hampshire.

April.

ITRC, 2017. History and Use of Per- and Polyfluoroalkyl Substances (PFAS). PFAS Fact Sheets.

Accessed May 16 2019 at https://pfas-1.itrcweb.org/fact-sheets/. November.

Jacobs Engineering Group, 2013. Geotechnical Design Report for New Hampshire Army National

Guard, Central Strafford Baffled Range Designs (Pistol and Small Arms) – 31 Meter Range,

Strafford, New Hampshire, Project NO. 12-004. 27 August.

New Hampshire Code of Administrative Rules, Chapter Env-Dw 700, Water Quality: Standards,

Monitoring, Treatment, Compliance, and Reporting; Env-Dw 701.03, Env-Dw 705.06, EnvDw 707.06, Env-Dw 712.23 through Env-Dw 712.30. Effective 30 September 2019.

NHARNG, 2014. Final Integrated Natural Resources Management Plan for the New Hampshire

National Guard Training Site. January.

NHDES, 2019. NHDES PFAS Sample Map. Accessed May 15 2019 at

http://nhdes.maps.arcgis.com/apps/View/index.html?appid=66770bef141c43a98a445c54a

17720e2&extent=-73.5743,42.5413,-69.6852,45.4489.

NHNHB, 2004. Vegetation Mapping and Floristic Inventory of the New Hampshire National Guard

Training Site in Center Strafford, NH. New Hampshire Department of Resources and

Economic Development.

Nobis Engineering, Inc., 2006. Env-WM 1600 Level I Site Investigation, Strafford New

HampshireArmy National Guard Training Site.

US Census Bureau, 2018. QuickFacts: Strafford Country, New Hampshire; United States.

Accessed May 2 2019 at https://www.census.gov/quickfacts/fact/table/straffordcounty

newhampshire,US/PST045218.

US Climate Data, 2019. Climate Rochester - New Hampshire. Accessed May 2 2019 at

https://www.usclimatedata.com/climate/rochester/new-hampshire/united-states/usnh0416.

USEPA, 1980. Comprehensive Environmental Response, Compensation, and Liability Act

(CERCLA).
PFAS Preliminary Assessment Report

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Center Strafford, New Hampshire

34

USEPA, 1991. Guidance for Performing Preliminary Assessments under CERCLA. September.

USEPA, 1994. National Oil and Hazardous Substances Pollution Contingency Plan (Final Rule).

40 CFR Part 300; 59 Federal Register 47384. September.

USEPA, 2016a. Drinking Water Health Advisory for Perfluorooctanoic Acid (PFOA). Office of

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. EPA

Document Number: 822-R-16-005. May.

USEPA, 2016b. Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS). Office of

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. EPA

Document Number: 822-R-16-004. May.

USEPA, 2017. UCMR 3 (2013-2015) Occurrence Data by State. Occurrence Data for the

Unregulated Contaminant Monitoring Rule. Accessed 9 July 2019 at

https://www.epa.gov/dwucmr/occurrence-data-unregulated-contaminant-monitoring-rule.

January.
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Data Resources
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Strafford, New Hampshire

Data resources will be provided separately on CD. Data resources for the New Hampshire 

National Guard Training Site include:

Environmental Data Resources Report

• 2019 The EDR Radius MapTM Report with GeoCheck®; Aerial Photo Decade Package; and

Certified Sanborn® Map Report; New Hampshire National Guard Training Site, 1151 Parker 

Mountain Road, Strafford, NH 03884.

Previous Investigations

• Diversified Technology Consultants, 2005. Draft Environmental Assessment Real Property 

Development Plan New Hampshire National Guard Training Site. February.

• EA Engineering, Science, and Technology, Inc., 2018. Draft 2018 Operational Range 

Assessment Periodic Review Binder, New Hampshire Army National Guard. October.

• Earth Resources Technology, Inc., 2008. Final Operational Range Assessment Program, 

Phase I Qualitative Assessment Report, New Hampshire National Guard Training Site, 

Center Strafford, New Hampshire. April.

• John Milner Associates, Inc., 2010. District Survey Area Form, New Hampshire National 

Guard Training Site, Center Strafford, New Hampshire. 

Facility Drawing

• Jones and Beach Engineers, Inc., 2011. Site Overview Plan, Map 11, Lot 39, Drawing 

Number AB1, Sheet 1 of 16, New Hampshire National Guard Training Site, NH Rte. 126, 

Ctr Strafford, NH. February 1.

Regulations, Advisories, and Orders

• NHDES, 2019. New Hampshire Code of Administrative rules, Chapter Env-Dw 700, Water 

Quality: Standards, Monitoring, Treatment, Compliance, and Reporting; NH Env-Dw 701.03, 

NH Env-Dw 705.06, NH Env-Dw 707.06, NH Env-Dw 712.23 through NH Env-Dw 712.30. 

30 September.
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Appendix B.1

Interview Records




PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Appendix B.2

Visual Site Inspection Checklists




PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

New Hampshire National Guard Training Site

Center Strafford, New Hampshire

Photograph Log
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 01

Description:

NHNGTS Flammables Shed

Orientation:

North

Date 4/23/2019

Time 8:19

Photograph No. 02

Description:

Fire Extinguisher (chemical) 

in NHNGTS Flammables 

Shed (close-up of label).

Orientation:

NA

Date 4/23/2019

Time 8:18

AECOM Page 1 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 03

Description:

Fire Extinguisher (chemical) 

in NHNGTS Flammables 

Shed.

Orientation:

NA

Date 4/23/2019

Time 8:18

Photograph No. 04

Description:

Inside of NHNGTS 

Flammables Shed. No 

additional fire extingushers or 

storage of PFAS-containing 

materials noted.

Orientation:

NA

Date 4/23/2019

Time 8:18

AECOM Page 2 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 05

Description:

CENTIfinish floor polish 

bottle - back.

Orientation:

NA

Date 4/23/2019

Time 8:20

Photograph No. 06

Description:

CENTIfinish floor polish 

bottle - front.

Orientation:

NA

Date 4/23/2019

Time 8:20

AECOM Page 3 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 07

Description:

Fire extinguisher (#1) in the 

NHNGTS kitchen, chemical 

Class K.

Orientation:

NA

Date 4/23/2019

Time 8:24

Photograph No. 08

Description:

Fire extinguisher (#1) in the 

NHNGTS kitchen, chemical 

Class K, close-up of the label.

Orientation:

NA

Date 4/23/2019

Time 8:25

AECOM Page 4 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 09

Description:

Hood fire suppression system 

(#1) in the NHNGTS kitchen, 

wet chemical.

Orientation:

NA

Date 4/23/2019

Time 8:34

Photograph No. 10

Description:

Fire extinguisher (#2) in the 

NHNGTS kitchen, chemical 

Class K.

Orientation:

NA

Date 4/23/2019

Time 8:35

AECOM Page 5 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 11

Description:

Hood fire suppression system 

(#2) in the NHNGTS kitchen, 

wet chemical, located over 

grills. CENTIFinish floor 

polish is used on floor in 

kitchen.

Orientation:

NA

Date 4/23/2019

Time 8:35

Photograph No. 12

Description:

Hood fire suppression system 

(#2) in the NHNGTS kitchen, 

wet chemical, located over 

grills, close-up of top tank 

label.

Orientation:

NA

Date 4/23/2019

Time 8:35

AECOM Page 6 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 13

Description:

Hood fire suppression system 

(#2) in the NHNGTS kitchen, 

wet chemical, located over 

grills, close-up of bottom tank 

label.

Orientation:

NA

Date 4/23/2019

Time 8:35

Photograph No. 14

Description:

View of Bedrock Well #4 

looking Southwest.

Orientation:

Southwest

Date 4/23/2019

Time 8:44

AECOM Page 7 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Photograph No. 15

Description:

View of Bedrock Well #1 

looking Northeast.

Orientation:

Northeast

Date 4/23/2019

Time 8:46

Photograph No. 16

Description:

NHNGTS Drill Hall looking 

East. CENTIFinish floor 

polish is used on floor.

Orientation:

East

Date 4/23/2019

Time 8:45

AECOM Page 8 of 9

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

New Hampshire National Guard 

Training Site

Strafford, New Hampshire

Preliminary Assessment Report

New Hampshire National Guard Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide

Photograph No. 17

Description:

Flow meters and taps for Well 

#4 and Well #1 in NHNGTS 

pump room. March 2017 

groundwater samples for 

PFAS were collected at these 

taps.

Orientation:

West

Date 4/23/2019

Time 8:49

Photograph No. 18

Description:

Flow meters and taps for Well 

#4 and Well #1 in NHNGTS 

pump room. March 2017 

groundwater samples for 

PFAS were collected at these 

taps.

Orientation:

West

Date 4/23/2019

Time 8:49

AECOM Page 9 of 9