FINAL

Preliminary Assessment Report

Rio Rancho

Rio Rancho, New Mexico

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

August 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Rio Rancho Facility Maintenance Shop #3A

Rio Rancho, New Mexico

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Table of Contents

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

1. Introduction ........................................................................................................................ 4

1.1 Authority and Purpose .............................................................................................. 4

1.2 Preliminary Assessment Methods ............................................................................. 4

1.3 Report Organization .................................................................................................. 5

1.4 Facility Location and Description............................................................................... 5

1.5 Facility Environmental Setting ................................................................................... 6

1.5.1 Geology ......................................................................................................... 6

1.5.2 Hydrogeology ................................................................................................. 6

1.5.3 Hydrology ....................................................................................................... 7

1.5.4 Climate ........................................................................................................... 7

1.5.5 Current and Future Land Use ......................................................................... 7

2. Fire Training Areas ........................................................................................................... 11

3. Non-Fire Training Areas ................................................................................................... 12

3.1 Hazardous Materials Storage Lockers .................................................................... 12

4. Emergency Response Areas ............................................................................................ 14

5. Adjacent Sources ............................................................................................................. 15

6. Preliminary Conceptual Site Model .................................................................................. 16

6.1 AOI: Hazardous Materials Storage Lockers 1 and 2 ................................................ 16

7. Conclusions ..................................................................................................................... 20

7.1 Findings .................................................................................................................. 20

7.2 Uncertainties ........................................................................................................... 20

7.3 Potential Future Actions .......................................................................................... 21

8. References ...................................................................................................................... 23
PFAS Preliminary Assessment Report

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Figures

Figure ES-1 Summary of Findings

Figure ES-2 Preliminary Conceptual Site Model, Rio Rancho, New Mexico

Figure 1-1 

Figure 1-2 

Figure 1-3 

Figure 3-1 

Figure 6-1 

Figure 6-2 

Figure 7-1 

Facility Location

Groundwater Features

Surface Water Features

Non-Fire Training Areas

Area of Interest

Preliminary Conceptual Site Model, Rio Rancho, New Mexico

Summary of Findings

Tables

Table ES-1 

Table 7-1

Table 7-2

Table 7-3

AOIs at Rio Rancho

AOIs at Rio Rancho

Sources of Uncertainties

PA Findings Summary

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
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Acronyms and Abbreviations

ac-ft acre-feet

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI

ARNG

Area of Interest

Army National Guard

CERCLA

CFR

Comprehensive Environmental Response, Compensation, and

LiabilityAct

Code of Federal Regulations

CSM conceptual site model

CST Civilian Support Team

DLA Defense Logistics Agency

EDRTM Environmental Data Resources, Inc.TM

°F degrees Fahrenheit

FMS Facility Maintenance Shop

FTA Fire Training Areas

HA Health Advisory

HDPE high-density polyethylene

NMARNG New Mexico Army National Guard

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

POD Point of Diversion

RCRA Resource Conservation and Recovery Act

SI Site Inspection

UCMR3 Unregulated Contaminant Monitoring Rule 3

US United States

USACE United States Army Corps of Engineers

USEPA

yr

United States Environmental Protection Agency

year
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Executive Summary

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

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

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

(PFAS)-containing materials was completed for the New Mexico ARNG (NMARNG) Rio Rancho

facility (also referred to as the “facility”) in Rio Rancho, New Mexico, to identify areas of known or

potential releases known as Areas of Interest (AOIs) and possible exposure pathways to

receptors. 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 PA site visit on 01 October 2019 and completed visual site inspections at

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

disposed; 

· Interviewed current NMARNG personnel including environmental managers and operations

staff during the site visit;

· Identified AOIs and developed a preliminary conceptual site model (CSM) to summarize

potential source-pathway-receptor linkages of potential PFAS in soil, groundwater, surface

water, and sediment for each AOI.

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

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

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

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

performed in 2016 had method detection limits that were higher than currently achievable. Thus,

it is possible that low concentrations of PFAS were not detected during the UCMR3 but might be

detected if analyzed today.

During the PA, one AOI related to potential PFAS release was identified at Rio Rancho based on

PA data. The AOI is shown on Figure ES-1 and described in Table ES-1 below:

Table ES-1: AOIs at Rio Rancho

Area of Interest Name Used by Potential Release Dates

AOI Hazardous Materials

Storage Lockers 1 & 2 NMARNG Mid-2000s – present

Based on the PA findings, direct interviewee knowledge of releases at this facility, and a lack of

robust institutional knowledge regarding historical activities concerning AFFF use and storage at

the facility, there is potential for exposure to PFAS contamination in media at or near the facility.

A summary of PA findings is shown on Figure ES-1, and the preliminary CSM for Rio Rancho is

shown on Figure ES-2.
Rio Rancho

FMS#3A

AOI 1

Concrete

Lagoon

Oil/Water

Separator

Haz Mat

Storage 1

Haz Mat

Storage 2

CLIENT

REVISED

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ARNG

GIS BY

CHK BY

GC

MW

4/10/2020

4/10/2020

NOTES Preliminary Assessment for PFAS at Rio Rancho, NM

1:5,400

4/10/2020 ­ Figure ES-1

PM RG 4/10/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 225 450 900

Feet

Legend

Potential PFAS

Release Area

Facility Boundary

2
Media

SOURCE PATHWAY RECEPTOR

AOI 1 Potential Use or

Spill

PFAS in

Surface Soil

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

Site

Worker

Construction

Worker Resident Trespasser

/

/ /

LEGEND

/ / / /

/ / / /

/ / /

Figure ES-2

Preliminary Conceptual Site Model

Rio Rancho, New Mexico

Potential

Off-Facility

Source Not

under

Control of

ARNG

Notes:

1. The residential receptor refers to an off-facility

receptor.

2. Human consumption of agricultural products

potentially affected by PFAS is possible

/

/ / /

/

/

3
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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 suspected impacted facilities that used per- and poly-fluoroalkyl

substances (PFAS). PFAS is most commonly used in aqueous film forming foam (AFFF)

discharged as part of firefighting activities, 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. 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 lifetime 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. The HA is 70 parts per trillion for PFOA and

PFOS, individually or combined.

This document presents the findings of a PA for PFAS-containing materials at the New Mexico

ARNG (NMARNG) Rio Rancho facility (also referred to as the “facility”) in Rio Rancho, New

Mexico, in accordance with the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), as amended, the National Oil and Hazardous Substances Pollution

Contingency Plan (40 Code of Federal Regulations [CFR] Part 300), and Army requirements and

guidance.

This PA documents the known fire training areas (FTAs) as well as other locations where PFAS

may have been released into the environment at the facility. 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 following tasks were performed as part 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 PA site visit on 01 October 2019 and completed visual site inspections

(VSIs) at locations where PFAS-containing materials were suspected of being stored, used,

or disposed;
PFAS Preliminary Assessment Report

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· Interviewed current NMARNG personnel including environmental managers and operations

staff during the site visit;

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

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

groundwater, surface water, and sediment for each AOI.

1.3 Report Organization

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

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

of each are as follows:

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

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

· Section 2 – Fire Training Areas: describes the FTAs at the facility identified during the site

visit

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

at the facility identified during the site visit

· Section 4 – Emergency Response Areas: describes areas of potential AFFF discharge at

the facility, specifically in response to emergency situations

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

facility that are not under the control of ARNG

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

transport and receptors at the facility

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

PA

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

The NMARNG Rio Rancho facility is located in the north central portion of the Albuquerque New

Mexico Metropolitan Statistical Area of New Mexico and currently resides on approximately 120

acres of land. The land is owned by the State of New Mexico and was acquired by the State

Armory Board in 1987. The facility contains the Facility Maintenance Shop (FMS) #3, a readiness

center, the 64th Civilian Support Team (CST), and areas used for tactical training (Appendix A).

The facility is located approximately 25 miles north of downtown Albuquerque, in Sandoval

County, which is near the center of the New Mexico. The land was acquired in 1987 by the State

Armory Board through a special warranty deed with the NMARNG as training site and Hawk

Battalion between 1987 and 1995. Additional structures (the readiness Center and FMS-3

buildings) were constructed and opened in 1994, as the Hawk Missile System was phased out

(Figure 1-1).
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1.5 Facility Environmental Setting

Rio Rancho is approximately 5,300 feet above mean sea level. The approximate geographic

coordinates for the center of the facility are 106°39'9.547"W; 35°22'19.323"N. The facility consists

of three buildings, a readiness center, the FMS-3 building, a CST, a training area, and a ROPES

obstacle course.

1.5.1 Geology

The facility lies in the Albuquerque Basin, one of the largest and deepest basins in the Rio Grande

rift. The fill material in the Albuquerque Basin is mostly Cenozoic fill deposits of the Santa Fe

Group. The Santa Fe Group was deposited during the middle Miocene to early Pleistocene

epochs. During that time the Albuquerque Basin received alluvial sediment from the adjacent

highlands and fluvial sediments from Northern New Mexico and southern Colorado (Fox et. Al.,

1995). For the Albuquerque area, alluvial deposits came from the Sandia Mountains providing

weathered granitic and limestone material. The fluvial deposits from the north consisted of

volcanic rock fragments (Fox et. Al., 1995). Volcanic material was also deposited by wind and

basalt flows from nearby volcanoes, just to the west of Albuquerque, in late the Pleistocene and

Holocene eras (Figure 1-2) (Holliday et. al., 2006). These processes resulted in thousands of feet

of sediment that lay under Albuquerque, providing a porous space for water to accumulate

(Reardon, 2012).

1.5.2 Hydrogeology

Rio Rancho resides within the Santa Fe Group aquifer system of the Albuquerque Basin. The

groundwater has been deposited in three main phases. The lower Santa Fe group was created

by dune fields and small streams draining into playa lakes and mud flats. The sediments in this

group yield low volumes of poor-quality water. Deposits in the upper Santa Fe group come from

drainage of the ancestral Rio Grande and the tributaries of that river. Most of the potable water in

the region comes from these later deposits, which lie 1.2 miles of the eastern boundary of the

basin. Finally, the modern Rio Grande cut down into the Santa Fe group sediments to create the

present river valley (Connell, 2012). Groundwater depth in the area is approximately 1000 feet

below ground surface (Bartolino & Cole 2002). Groundwater flow direction is generally to the

southeast (Stephens & Associates, 2017).

An EDRTM report conducted a well search for a 1-mile radius surrounding the facility (Appendix

A). Using additional online resources, such as state and local Geographic Information System

databases, wells were researched to a 4-mile radius of the facility. The City of Rio Rancho water

supply consists entirely of groundwater withdrawn from the Santa Fe Group aquifer. Rio Rancho

has 17 wells currently in operation and diverts about 13,000 acre-feet per year (ac-ft/yr). Three of

these municipal wells are located within 1-mile west and upgradient of the facility. These wells are

part of Point of Diversion ([POD] number 06745), with each well having the POD suffix POD38,

POD39, and POD40, respectively. They are drilled into the Rio Grande POD Basin, and Middle

Rio Grande POD Subbasin; no information about their total depths was available in the attached

EDRTM report or the online well database (New Mexico Office of the State Engineer, 2020). The

remaining city wells used for municipal water are located south of the facility, several miles away.

Because Rio Rancho pulls the water from deep wells, the supply is not as susceptible to climate

change, drought, or human-caused degradation as a surface water supply (Stephens &

Associates, 2017). Rio Rancho has an emergency water shortage ordinance for times of drought

or limited supply and can presently store up to 41 million gallons of water. The City of Rio Rancho

has a 26,039 ac-ft/yr water rights diversion permit (Permit No. RG-6745 et.al., and Declaration
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No. RG26259). As part of the pumping permit, Rio Rancho is required to purchase 728 ac-ft of

water rights per 5-year period. To date, Rio Rancho has purchased more water rights than

required for the current time frame.

1.5.3 Hydrology

The Rio Grande River is the largest water body in the region and is approximately 8 miles east of

the facility. The inner valley of the Rio Grande contains a complex network of irrigation canals,

ditches, and drains. In general, the Rio Grande flows from north to south through Sandoval

County. The cities of Bernalillo, Rio Rancho, Albuquerque, Los Lunas, and Belen discharge

treated effluent directly into the river (Bartolino & Cole 2002). Water features near the facility are

shown in Figure 1-3.

Since 2001, the City of Rio Rancho has been working to expand its water resources. The Aquifer

Injection Project, the first of its kind in New Mexico, allows Rio Rancho to inject purified water

back into the aquifer and store it for future use. This water recharges the aquifer to maintain it as

a drinking water source now and for future generations (Rio Rancho, 2019).

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 HA within 20 miles of the facility.

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

performed in 2016 had method detection limits that were higher than currently achievable. Thus,

it is possible that low concentrations of PFAS were not detected during the UCMR3 but might be

detected if analyzed today.

1.5.4 Climate

The climate in north-central New Mexico is categorized as semi-arid (Us Geological Survey

[USGS], 2002) receiving about 12 inches of precipitation per year. Highest rainfall (about 2 inches

per month) usually occurs in August (National Oceanic Atmospheric Administration [NOAA],

2019). Most of the moisture that Rio Rancho receives comes from the Gulf of Mexico during the

North American Monsoon season. (USGS, 2002). July is the hottest month averaging 78.1

degrees Fahrenheit (°F), while January is the coldest month, averaging 34.3 °F (NOAA, 2019).

There is a diurnal temperature difference greater than 25 °F for every month of the year. The

immediate Albuquerque metro area receives an average of 9.6 inches of snowfall per winter,

which can increase considerably in surrounding higher elevations (NOAA, 2019).

1.5.5 Current and Future Land Use

Presently, Rio Rancho consists of three buildings: a readiness center, the FMS-3 building, and

CST, as wells as a training area. Future land use is not anticipated to change.
RIO RANCHO

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1/13/2020 ­ Figure 1-1

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12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

0 1 2 4

Miles

Legend

Facility Boundary

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NOTES Preliminary Assessment for PFAS at Rio Rancho, NM

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1/14/2020 ­ Figure 1-2

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12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 0.5 1 2

Miles

Legend

Facility Boundary

Water Body

Wetlands

Pipeline

Canal/Ditch

River/Stream

Inferred Groundwater

Flow Direction

Geology

Alluvium

Clastic

Wells

A! Unknown/Other

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9
Jemez River

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12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 0.5 1 2

Miles

Legend

Facility Boundary

Water Body

Wetlands

Connector

Pipeline

Canal/Ditch

River/Stream

Surface Water Flow

DIrection

10
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2. Fire Training Areas

No FTAs were identified within or around the Rio Rancho facility during the PA through interviews

or EDRTM reports. Interviews with personnel who had less than 10 years of recollection of activities

at Rio Rancho and online researched yielded little information regarding possible fire training

activities at Rio Rancho. There is little to no information on activities during the timeframe in which

the Rio Rancho facility was a Hawk missile site. The Rio Rancho Fire and Rescue Department

provides emergency services to the facility. Interview records appear in Appendix B.
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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. One non-FTA where AFFF

was stored was identified during the PA. A description of the non-FTA is presented below, and the

non-FTA is shown on Figure 3-1. Interview records with relevant information appear in Appendix

B, and photographs appear in Appendix C.

3.1 Hazardous Materials Storage Lockers

The hazardous materials storage lockers, located in the southern portion of the facility, housed

two containers of AFFF for an unknown period of time (Figure 3-1). The lockers are located in the

segment of the facility designated as the FMS-3. According to personnel interviews, two 10-gallon

containers of AFFF were found in hazardous waste storage locker 1 sometime in early 2019. Both

containers, which are classified as Fiberboard or plastic drums, barrels, or kegs (DF) in the

Uniform Hazardous Waste Manifest (Appendix A), were found half empty with evidence of a

small amount of product around the cap. There is no evidence or recollection of these containers

being used or transported to the site, and no leaks or spills have been reported. The containers

were described as small high-density polyethylene (HDPE) “poly” 10-gallon closed head drums

by interviewed personnel and were stored in a hazmat storage locker that was in good condition,

with no evidence or corrosion or damage that would compromise the integrity of the locker. Once

these containers were discovered, they were moved to an adjacent hazmat storage locker

(hazardous waste storage locker 2) designated for transport through the Defense Logistics

Agency (DLA ) as non- Resource Conservation and Recovery Act (RCRA) non-hazardous waste.

This secondary storage locker was also in good condition, with no evidence of corrosion or

damage that would compromise the integrity of the locker. The containers of AFFF were

dispatched via a third-party carrier (Envirokleen – EPA ID Number: TXR000084068), with the

waste code N/H Out54091, on 08 April 2019. The weight of the product listed on the Uniform

Hazardous Waste Manifest is 60 pounds. There was no evidence of PFAS-containing substances

ever having been stored or used within the FMS-3 building itself, and the fire sprinkler system

within the FMS uses water only as seen in the attached photo log (Appendix C).
Haz Mat

Storage 1 Haz Mat

Storage 2

Rio Rancho

FMS#3A Concrete

Lagoon

Oil/Water Separator

CLIENT

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NOTES Preliminary Assessment for PFAS at Rio Rancho, NM

1:3,600

4/10/2020 ­ Figure 3-1

PM RG 4/10/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 150 300 600

Feet

Legend

Potential PFAS

Release Area

Facility Boundary

Wetlands

River/Stream

13
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4. Emergency Response Areas

No emergency response areas were identified within the boundaries of the facility during the PA

through interviews, previous investigations, online research, and the EDRTM report (Appendix A).

Personnel Interviewed during the PA site visit stated that no incidents have occurred on site that

required fire suppression within their scope of recollection and knowledge of about 10 years

(Appendix B), and the City of Rio Rancho Fire & Rescue Department provides emergency

response to the facility. Interviews were conducted with personnel whose firsthand knowledge of

events dates from 2014 through present day. It is unknown if emergency responses occurred prior

to 2014.
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5. Adjacent Sources

Information acquired during PA interviews (Appendix B), internet research, and data presented

in the EDRTM report (Appendix A) indicated that no adjacent off-facility sources of PFAS exist

near Rio Rancho. The surrounding area is primarily rural residential land.
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6. Preliminary Conceptual Site Model

Based on the PA findings, one potential release area was identified at Rio Rancho or adjacent

areas as a result of NMARNG actions and will be considered an AOI. The AOI location is shown

on Figure 6-1. A CSM includes three components necessary for potentially complete exposure

pathways related to a site: (1) source, (2) pathway, and (3) receptor. If any of these elements are

missing, the pathway is considered incomplete.

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

via the dermal contact pathway may occur, and current risk practice suggests it is a negligible

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

continue to be the subject of PFAS toxicological study. Receptors for Rio Rancho include site

workers, construction workers, and trespassers. The CSM indicates which specific receptors

could potentially be exposed to PFAS.

6.1 AOI: Hazardous Materials Storage Lockers 1 and 2

The hazardous materials storage lockers, located in the southern portion of the facility, near the

FMS-3 building, housed two containers of a PFAS-containing substance for an unknown period

of time (Figure 6-1). Personnel indicated that two 10-gallon HDPE “poly” drums of PFAScontaining substance were found in hazardous waste storage locker 1 sometime in early 2019.

Both of these containers, which are classified as Fiberboard or plastic drums, barrels, or kegs

(DF) in the Uniform Hazardous Waste Manifest (Appendix A), were found half empty, with

evidence of a small amount of product around the cap. Interview information can be found in

Appendix B. There are no records indicating when or from whom these containers of AFFF

product were acquired. Additionally, there is no evidence or recollection of these containers being

used or transported to the site, and no leads as to the extent of the use of this product. No leaks

or spills concerning AFFF have been reported at the facility. The containers were stored in a

hazmat storage locker that was in good condition, with no evidence or corrosion or damage that

would compromise the integrity of the locker. Once these containers were discovered, they were

moved to an adjacent hazmat storage locker (hazardous waste storage locker 2) designated for

transport through DLA as non-RCRA non-hazardous waste. This secondary storage locker was

also in good condition, with no evidence of corrosion or damage that would compromise the

integrity of the locker. The containers of AFFF were dispatched via a third-party carrier

(Envirokleen – EPA ID Number: TXR000084068), with the waste code N/H Out54091, on 08 April

2019. The weight of the product listed on the Uniform Hazardous Waste Manifest is 60 pounds.

The AOI encompasses the hazardous materials lockers, which are within close proximity to one

another, and the immediate area in between and surrounding these two lockers. If AFFF were

used or spilled within the containers, the spill would have been considered entirely contained, as

both hazardous materials storage lockers are in good condition, with no signs of leaks or damage.

If the AFFF containers were used or spilled outside of the hazardous materials storage lockers,

then the product may have traveled to an oil water separator, which leads to the concrete lagoon

located on the southeast corner of the facility, and evaporated. If there were any leakage in this

chain of transport, ground disturbing activities in this area could result in construction worker, site

worker, and trespasser exposure to potential PFAS contamination via inhalation of dust of

ingestion of surface soil. PFAS are water soluble and can migrate readily from soil to groundwater

or surface water via leaching and run-off. Groundwater depth in the area is approximately 1000

feet below ground surface (Bartolino & Cole 2002). The city of Rio Rancho currently sources its

water supply entirely from groundwater and the Aquifer Injection Project and has 17 wells currently

in operation. Groundwater flows southeast, and surface water flows generally east-northeast.
PFAS Preliminary Assessment Report

Rio Rancho Facility Maintenance Shop #3A

Rio Rancho, New Mexico

17

There are no known drinking water sources downgradient of the facility. The preliminary CSM for

the AOI is shown on Figure 6-2.
Haz Mat

Storage 1 Haz Mat

Storage 2

Rio Rancho

FMS#3A

AOI 1

Concrete

Lagoon

Oil/Water Separator

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MW

4/10/2020

4/10/2020

NOTES Preliminary Assessment for PFAS at Rio Rancho, NM

1:3,600

4/10/2020 ­ Figure 6-1

PM RG 4/10/2020

12420 Milestone Center Drive

Germantown, MD 20876

Area of interest

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 150 300 600

Feet

Legend

Area of Interest

Potential PFAS

Release Area

Facility Boundary

Wetlands

River/Stream

18
Media

SOURCE PATHWAY RECEPTOR

AOI 1 Potential Use or

Spill

PFAS in

Surface Soil

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

Site

Worker

Construction

Worker Resident Trespasser

/

/ /

LEGEND

/ / / /

/ / / /

/ / /

Figure 6-2

Preliminary Conceptual Site Model

Rio Rancho, New Mexico

Potential

Off-Facility

Source Not

under

Control of

ARNG

Notes:

1. The residential receptor refers to an off-facility

receptor.

2. Human consumption of agricultural products

potentially affected by PFAS is possible

/

/ / /

/

/

19
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20

7. Conclusions

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

storage of AFFF and other PFAS-related activities at Rio Rancho. The PA findings are based on

the information presented in Appendix A, Appendix B, and Appendix C.

7.1 Findings

One AOI related to potential PFAS release was identified at Rio Rancho during the PA (Figure 7-

1) and is described in Table 7-1 below:

Table 7-1: AOIs at Rio Rancho

Area of

Interest Name Used by PotentialRelease Dates Determination

AOI Hazardous Materials

Storage Lockers 1 & 2 NMARNG Mid-2000s topresent

Potential PFAS

release

The AOI is the hazardous materials storage lockers 1 & 2, where NMARNG discovered two

previously opened 10-gallon containers of PFAS-containing substance were found in hazardous

waste storage locker 1 sometime in early 2019 and then moved to hazardous waste storage

locker 2 to be transported. Both of these containers, which are classified as Fiberboard or plastic

drums, barrels, or kegs (DF) in the Uniform Hazardous Waste Manifest, were found half empty,

with evidence of a small amount of product around the cap. Based on the PA findings and

interviews with employees whose knowledge spans from 2014 to present, data gaps exist

regarding historical activities concerning AFFF use and storage at the facility from when the facility

opened to 2014. As such, there is potential for exposure to PFAS contamination in soil and

airborne soil particulate in the event that releases occurred.

The summary of findings is presented in Figure 7-1.

7.2 Uncertainties

A number of information sources were evaluated 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, other non-traditional activities, or on its disposition. There is no historically

documented use of PFAS-containing materials at the Rio Rancho by NMARNG staff.

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 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 AFFF were first used, and a reliance on personal recollection. Inaccuracies

may arise in potential AFFF discharge locations, discharge dates, discharge volumes, and PFAS

concentration. 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 personnel were interviewed, multiple persons were interviewed

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

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

Table 7-2: Sources of Uncertainties

Location Source of Uncertainty

AOI 1 Hazardous Materials Storage

Locker 1 and 2

It is uncertain if PFAS were used or leaked

from the two half-filled containers found in the

hazardous materials building. There are no

records or recollection of these containers

being acquired or used, as direct interviewee

knowledge only spans from 2014 to present

day, but when they were found by facility

personnel, each 10-gallon container was only

approximately half full.

7.3 Potential Future Actions

Table 7-3 summarizes the rationale used to determine if the AOI should be considered for further

investigation under the CERCLA process and undergo an SI.

Table 7-3: PA Findings Summary

Area of Interest AOI Location Rationale Potential Future

Action

AOI 1 Hazardous

Materials Storage

Lockers 1 & 2

35°22'14.00"N; 

106°39'04.49"W

Potential release

from two 10-gallon

containers of AFFF

discovered half full,

with product on

around the cap.

Proceed to an SI

focusing on soil.

ARNG will evaluate the need for an SI at AOI 1 at the Rio Rancho based on the potential

receptors, the potential migration of PFAS contamination off the facility, and the availability of

resources.
Rio Rancho

FMS#3A

AOI 1

Concrete

Lagoon

Oil/Water

Separator

Haz Mat

Storage 1

Haz Mat

Storage 2

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

MW

4/10/2020

4/10/2020

NOTES Preliminary Assessment for PFAS at Rio Rancho, NM

1:5,400

4/10/2020 ­ Figure 7-1

PM RG 4/10/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

0 225 450 900

Feet

Legend

Potential PFAS

Release Area

Facility Boundary

22
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8. References

Bartolino, James R., and Cole, James C. 2002. Ground-Water Resources of the Middle Rio

Grande Basin, New Mexico. United States Geological Survey (USGS).

https://pdfs.semanticscholar.org/6959/518ed9078c7d63d9f2847e6a2496b930d940.pdf?

_ga=2.130037127.987026424.1576024007-899776365.1576024007

Connell, Sean D. 2012. GEOLOGY, GROUNDWATER, AND GEOLOGIC HAZARDS IN THE

ALBUQUERQUE BASIN, NEW MEXICO. New Mexico Bureau of Geology and Mineral

Resources – Albuquerque Office.

http://www.agiweb.org/environment/publications/mapping/graphics/newmexico.pdf

Fox, Douglas G. et. al. 1995. Ecology, Diversity, and Sustainability of the Middle Rio Grande

Basin. United States Department of Agriculture. Chapter 4, 52-79

Holliday et. al. 2006. Geoarchaeology of the Boca Negra Wash Area, Albuquerque Basin, New

Mexico, USA. Geoarchaeology: 765-802.

National Oceanic and Atmospheric Administration (NOAA). 2019. Climate Data Online

Database. https://www.ncdc.noaa.gov/cdo-web/datatools/normals

National Oceanic and Atmospheric Administration (NOAA). 2019. NowData – NOAA Online

Weather Data. https://www.nws.noaa.gov/climate/xmacis.php?wfo=abq.

New Mexico Office of the State Engineer. 2020. OSE Points of Diversion. http://geospatialdataose.opendata.arcgis.com/datasets/ose-points-of-diversion

Reardon, Molly. 2012. The Rio Grande Rift: Albuquerque Basin.

http://academic.emporia.edu/aberjame/student/reardon3/RIFT%20NEW2.html. ES 767

Global Tectonics Emporia State University.

Rio Rancho. 2019. Rio Rancho Pure – New Mexico’s First Aquifer Injection Project. City of Rio

Rancho, New Mexico. https://rrnm.gov/4024/Rio-Rancho-Pure

Stephens & Associates, Inc. 2017. City of Rio Rancho Source Water Protection Plan Public

Water System #NM3537326. City of Rio Rancho.

https://rrnm.gov/DocumentCenter/View/71938/City-of-Rio-Rancho-SWPP_2-22-

2017?bidId=

US Environmental Protection Agency (USEPA), 1991. Guidance for Performing Preliminary

Assessments under CERCLA. EPA/540/G91/013.

United States Geological Survey (USGS). 2002. Ground-Water Resources of the Middle Rio

Grande Basin, New Mexico. United States Geological Survey. Page 9.
PFAS Preliminary Assessment Report

Rio Rancho Facility Maintenance Shop #3A

Rio Rancho, New Mexico

Appendix A

Data Resources
PFAS Preliminary Assessment Report

Rio Rancho Facility Maintenance Shop #3A

Rio Rancho, New Mexico

Data Resources will be provided separately on CD. Data Resources for Rio Rancho facility

include:

Rio Rancho Online Research

• 1956 Rosenweig, A., New Mexico Geological Society, Southeastern Sangre de Cristo 

Mountains

• 1994 Keller, G. Randy and Cather, Steven M, Basins of the Rio Grande Rift: Structure, 

Stratigraphy, and Tectonic Setting. Geological Society of America, Inc.

• 1995 United States Department of Agriculture Forest Service, Ecology Diversity and 

Sustainability of the Middle Rio Grande Basin

• 2012 Connel, Sean D., Geology, Groundwater, and Geologic Hazards in the Albuquerque 

Basin, New Mexico

• 2012 Reardon, Molly., The Rio Grande Lift: Albuquerque Basin

• 2017 City of Rio Rancho Source Water Protection Plan Public Water System #NM3537326

• 2018 City of Rio Rancho Land Ownership Map

• 2019 City of Rio Rancho, Rio Rancho Pure – New Mexico’s First Aquifer Injection Project

• N.d. USGS Bernalillo NW 7.5-minute Quadrangle

Rio Rancho Facility Information

• 2014 NMARNG Installation Atlas

Rio Rancho EDRTM Report

• 2019 Rio Rancho FMS Environmental Data Resources, Inc.TM Report
PFAS Preliminary Assessment Report

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Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

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Appendix B.1

Interview Records


PFAS Preliminary Assessment Report

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Rio Rancho, New Mexico

Appendix B.2

Visual Site Inspection Checklists


PFAS Preliminary Assessment Report

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Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

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Rio Rancho, New Mexico

Appendix C

Photographic Log
PFAS Preliminary Assessment Report

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Rio Rancho, New Mexico

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Rio Rancho Facility Maintenance Shop Rio Rancho, New Mexico

Photograph No. 1

Description:

Facing South. Water sprinkler 

system in FMS.

Photo Date: 10/01/2019 1323

Photograph No. 2

Description:

Facing South. Hazmat Storage 

Locker 1 where PFAS 

containers were found.

Photo Date: 10/01/2019 1325
PFAS Preliminary Assessment Report

Rio Rancho Facility Maintenance Shop #3A

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APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS Rio Rancho Facility Maintenance Shop Rio Rancho, New Mexico

Photograph No. 3

Description:

Facing Southeast. Hazmat 

Storage Locker 2 where PFAS 

containers were moved to be 

picked up by Envirokleen.

Photo Date: 10/01/2019 1324

Photograph No. 4

Description:

Facing Southeast. Inside of 

Hazmat Storage Locker 2.

Photo Date: 10/01/2019 1325