FINAL 

Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

November 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

State Military Reservation

Concord, New Hampshire
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

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Table of Contents

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

1. Introduction ........................................................................................................................7

Authority and Purpose ..............................................................................................7

Preliminary Assessment Methods .............................................................................7

Report Organization ..................................................................................................8

Facility Location and Description...............................................................................8

Facility Environmental Setting ...................................................................................9

1.5.1 Geology .........................................................................................................9

1.5.2 Hydrogeology ...............................................................................................10

1.5.3 Hydrology .....................................................................................................11

1.5.4 Climate .........................................................................................................12

1.5.5 Current and Future Land Use .......................................................................12

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

Former Camp LaBonte ...........................................................................................17

Tri-Max Training Area ..............................................................................................17

3. Non-Fire Training Areas ...................................................................................................21

Former AASF Hangar .............................................................................................21

Former Firetruck Parking ........................................................................................21

Former Washing Platform .......................................................................................22

Former Aircraft Parking Area ...................................................................................22

Current and Former Dry Wells ................................................................................22

4. Emergency Response Areas ............................................................................................25

5. Adjacent Off-Facility Sources ...........................................................................................27

Army Aviation Support Facility Concord ..................................................................27

Concord Municipal Airport .......................................................................................27

City of Concord Fire Department.............................................................................27

Richard M. Flynn Fire Academy ..............................................................................28

Loudon Road Fire Training Area .............................................................................28

New Hampshire Detections .....................................................................................29

6. Preliminary Conceptual Site Model ..................................................................................31

AOI 1 Former AASF ................................................................................................31

AOI 2 Former Camp LaBonte .................................................................................32

7. Conclusions .....................................................................................................................37

Findings ..................................................................................................................37

Uncertainty .............................................................................................................37

Potential Future Action ............................................................................................38

8. References ......................................................................................................................41
PFAS Preliminary Assessment Report

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Concord, New Hampshire

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Tables

Table ES-1: AOIs at the State Military Reservation

Table 7-1: AOIs at the State Military Reservation

Table 7-2: Uncertainties

Table 7-3: PA Findings Summary

Figures

Figure ES-1: Summary of Findings

Figure ES-2: Preliminary Conceptual Site Model State Military Reservation

Figure 1-1: Facility Location

Figure 1-2: Groundwater Features

Figure 1-3: Surface Water Features

Figure 2-1: Fire Training Areas

Figure 3-1: Non-Fire Training Areas

Figure 5-1: Adjacent Sources

Figure 6-1: Areas of Interest

Figure 6-2: Preliminary Conceptual Site Model AOI 1 Former AASF

Figure 6-3: Preliminary Conceptual Site Model AOI 2 Former Camp LaBonte

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
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Acronyms and Abbreviations

°F degrees Fahrenheit

AASF Army Aviation Support Facility

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AGQS ambient groundwater quality standard

amsl above mean sea level

AOI area of interest

ARFF Aircraft Rescue and Firefighting

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CSM conceptual site model

CSMS Combined Support Maintenance Shop

EDR Environmental Data Resources, Inc.

FTA fire training area

HA Health Advisory

JP jet propellant

MCL maximum contaminant level

NHARNG New Hampshire Army National Guard

NHDES New Hampshire Department of Environmental Services

NHDOS New Hampshire Department of Safety

OWS oil-water separator

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

SI Site Inspection

SMR State Military Reservation

UCMR 3 Third Unregulated Contaminant Monitoring Rule

US United States

USACE United States Army Corps of Engineers
PFAS Preliminary Assessment Report

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Concord, New Hampshire

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USEPA United States Environmental Protection Agency

UST underground storage tank

VSI visual site inspection
PFAS Preliminary Assessment Report

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Concord, New Hampshire

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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 State Military Reservation (SMR) in Concord, 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 22 April 2019;

· Interviewed current New Hampshire ARNG (NHARNG) personnel at the SMR, NHARNG

environmental managers and operations staff, former employees, and current employees

of the nearby current Army Aviation Support Facility (AASF) during the site visit;

· 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 Areas of Interest (AOIs) and the facility (Figure ES-1).

Two AOIs related to potential PFAS release were identified at the SMR during the PA. The AOIs

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

Table ES-1: AOIs at the State Military Reservation

Area of Interest Name Used by Release Dates

AOI 1 Former AASF NHARNG late 1960s to 2004

AOI 2 Former Camp LaBonte NHARNG late 1960s to pre-1977

Based on actual and potential AFFF releases at these AOIs, there is a potential for exposure to

PFAS contamination in media at or near the facility. The preliminary CSM for the SMR, which

presents the potential receptors and media impacted, is shown on Figure ES-2.
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AASF Hangar Releases

Former Tri-Max Training Area

Former FireTruck Parking

Former Aircraft Parking Area

Former Camp LaBonte

Former Washing Platform

Loudon Road 

Fire Training Area

City of Concord

Fire Department, Heights Station

AASF Concord

(PA Report under separate cover)

Concord Municipal Airport

Merrimack River

AOI 2

AOI 1

0 450 900 1,800

Feet

­ Figure ES-1

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Area of Interest

Potential PFAS Release

Facility Boundary

StreamRiver

Wetland

River/Stream

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Soucook River

Richard M. Flynn

Fire Academy

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Media

SOURCE PATHWAY RECEPTOR

AOI 1 

AOI 2

Releases from Hangar 

Fire Suppression 

System, Washing 

Platform, Firetrucks, 

Tri-Max Storage/

Training; Firetruck 

FTA

PFAS in 

Surface Soil

PFAS in 

Subsurface 

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 Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site Worker Construction Worker Resident Trespasser/ Recreational User

Site Worker Construction Worker Resident Trespasser/ Recreational User LEGEND

Figure ES-2

Preliminary Conceptual Site Model

State Military Reservation

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ /

/ /

/ /

/

/

/

/

/

/

/

/

/

/

/ / /

NOTES

1. The resident receptor refers to an offsite resident. 

2. No surface water bodies were 

identified at the facility, but the surface 

water/sediment pathway is considered 

potentially complete for offsite 

recreational users due to the potential 

for groundwater interaction with the 

downgradient river.

3. Human consumption of fish 

potentially affected by PFAS from the 

downgradient river is possible.

5
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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 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 (AGQSs) 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/AGQSs 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 State Military Reservation (SMR; also 

referred to as the “facility”) in Concord, 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 known locations where PFAS may have been released into the 

environment at the SMR. 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.

Preliminary Assessment Methods

The performance of this PA included the following tasks: 
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· Reviewed data resources to obtain information relevant to suspected PFAS releases;

· Conducted a site visit on 22 April 2019;

· Interviewed current New Hampshire ARNG (NHARNG) personnel at the SMR, NHARNG

environmental managers and operations staff, former employees, and current employees

of the nearby current Army Aviation Support Facility (AASF) during the site visit;

· 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 Areas of Interest (AOIs) 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 AOIs and the facility.

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

the PA.

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

Facility Location and Description

The SMR is located at 1 Minuteman Way in Concord, Merrimack County, New Hampshire, 

approximately 0.5 miles north-northwest from the Concord Municipal Airport terminal (Figure 1-

1). The facility property occupies approximately 50 acres on the east side of the Merrimack River, 

near the southeastern city limits, east of Interstate 93, and south of Interstate 393. The 
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approximate center of the property is located at geographic coordinates 43°12'35.89"N; 

71°30'43.74" W longitude at 363 feet above mean sea level (amsl). 

The property was originally known in the late 1800s as the State Military Campground for the New 

Hampshire State Militia; additionally, it was known in 1886 as "Camp Langdon.” In 1885, the state 

of New Hampshire entered into a 99-year lease with the city of Concord for use and development 

of the grounds on which the National Guard trained. Additional parcels of the property were 

deeded or leased to the city of Concord in 1911, 1937, 1942, and 1954, and the state of New 

Hampshire formally acquired the property in 1959 (The Louis Berger Group, Inc., 2006). The 

property is currently owned by the state of New Hampshire and is used for State operations of 

the NHARNG. The SMR currently serves as the headquarters for the NHARNG. Facilities at the 

SMR include a warehouse, a maintenance shop, Joint Force Offices, the Concord Armory, and a 

Civil Support Teams building (Tighe & Bond, 2018).

An AASF was located at the SMR from the 1960s to 2004. Typical activities conducted at the 

AASF included maintenance and repair of fixed-wing and rotary aircraft, storage and dispensing 

of fuel, and mechanical servicing and cleaning of helicopter interiors and exteriors (NHARNG, 

1996). The initial building for the AASF hangar (later known as the Ground Power Annex) was 

designed in 1959 and constructed between 1960 and 1961. Aerial photographs show that the 

initial building was present in 1960, 1967, and 1969 (Appendix A). According to interviews with 

former AASF personnel, Bell helicopters and TH-55 helicopters were present at the SMR in the 

1960s. In 1974, an addition to the original building was constructed to create Building K (The 

Louis Berger Group, Inc., 2006). AASF operations continued at Building K until 2004, at which 

time operations were moved to a new facility located at 26 Regional Drive, 0.5 mile to the east. 

The SMR is completely secured by a 6-foot fence, which consists of chain-link fence secured by 

a brick column and ornamental iron fencing barrier. Access to the facility is through monitored 

gates at the perimeter of the facility on Pembroke Road and on Minuteman Way via Airport Road.

Facility Environmental Setting

The SMR is located within the Merrimack Valley in southern New Hampshire, within the Eastern 

New England Upland Physiographic Province of the Appalachian Highlands. The New England 

Upland consists of a maturely-dissected plateau with narrow valleys, and the entire area was 

greatly modified by glaciation. The city of Concord developed along the Merrimack River and lies 

fully within the Merrimack River watershed. The city of Concord has a population of approximately 

43,000 people, according to the 2017 census (US Census, 2018).

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

information on geology, hydrogeology, hydrology, climate, and current and future land use.

1.5.1 Geology

Regional geology consists of unconsolidated glacial material overlying igneous and metamorphic 

rocks that was deposited during the Wisconsin stage of glaciation, of the Pleistocene Epoch 

during the Quaternary Period. The weight of the ice caused differential depressions of the land 

surface during the Pleistocene Epoch. The southeastward flow of glacial ice scoured the rock 

surface, and as the ice melted, it deposited a thick blanket of glacial till in many areas. Meltwater 

streams deposited a variety of ice-contact sands and gravels upon portions of the till sheet 

(USAEHA, 1993). Geologic features near the facility are shown on Figure 1-2.

The unconsolidated material, which is mainly ground moraine, was originally subglacial till, that 

was left scattered over the ground after the ice melted. A ground moraine consists of scattered 

boulders combined with cobbles, gravel, pebbles, sand, silt, and clay, with some areas of ice-
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contact stratified drift. This stratified drift was derived from englacial and subglacial meltwater

streams that also carried gravel, sand, silt, and clay. Determination of glacial features and geologic

characterization of the deposits is important. Assumptions may then be made concerning the grain

sizes within the deposit, the bedding, and the sorting. In some areas, unstratified material was

deposited. Knowledge of a particular deposit’s origin is helpful in the prediction of the type and

distribution of the materials within the deposit, which also may give an idea about the occurrence

of groundwater (USAEHA, 1993; Stone & Webster Environmental Technology & Services, 1998).

Numerous environmental investigations have been conducted nearby the subject property for the

Former Vishay Sprague Site, located at 70 Pembroke Road (approximately 0.4 miles west of the

subject property). These investigations have indicated that the local geology is underlain by up to

about five feet of fill overlying a relatively thick sequence (about 160 to 200 feet) of glacial deposits

overlying granitic bedrock. Bedrock in the vicinity consists predominantly of moderately fractured,

medium-grained, two-mica granite. The bedrock surface generally slopes downward from west to

east (GZA GeoEnvironmental, Inc., 2010).

In the immediate vicinity of the facility, overlying bedrock is an approximately 25- to 50-foot-thick

lacustrine deposit consisting of very dense, thinly interbedded silt, silt and clay, and fine sand.

This stratum is overlain by an approximately 50- to 60-foot-thick section of glacial till consisting of

very dense, fine to medium sand with clayey silt and gravel. Lacustrine sediments similar to those

underlying the glacial till overlie the glacial till with thicknesses ranging from about 15 to 40 feet.

Outwash deposits consisting predominantly of fine sand top the overburden stratigraphy with a

thickness ranging from about 50 to 85 feet (GZA GeoEnvironmental, Inc., 2010).

In 1997, an SI was conducted at the SMR, and the soils encountered were typically fine to medium

sands with little coarse sand, varying amounts of silt, and occasionally a trace of clay. The soils

become finer and more compact as the depth increased (Stone & Webster Environmental

Technology & Services, 1998).

1.5.2 Hydrogeology

In 1998, an SI was conducted at the SMR, and groundwater was encountered from approximately

41 feet to 51 feet (Stone & Webster Environmental Technology & Services, 1998). Based on

recent investigations at the nearby Former Vishay Sprague Site, groundwater in the vicinity is

expected to be 30 and 50 feet below ground surface (bgs) (GZA GeoEnvironmental, Inc., 2018).

Both investigations indicated that overburden groundwater flow was to the west-southwest,

toward the Merrimack River, which is located 0.8 miles to the west/southwest. Groundwater

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

The overburden hydrogeology in the area generally consists of a dual hydrogeologic unit system

separated by the glacial till stratum. The upper unit consists of the saturated lacustrine and/or

outwash deposits overlying glacial till, whereas the lower unit consists of the lacustrine deposits

underlying the glacial till. Hydraulic communication between the upper and lower units is likely,

with the glacial till forming only a partial aquitard. The upper overburden unit is unconfined, with

the resultant groundwater surface at a pressure equal to atmospheric. The lower unit is partially

confined by the glacial till, with the resultant groundwater surface potentiometric (at pressure

greater than atmospheric). Groundwater elevations within the upper unit are typically observed to

be about 10 to 15 feet higher than those of the lower unit, indicating a loss in total head through

the glacial till aquitard, and a vertically downward component of groundwater flow (GZA

GeoEnvironmental, Inc., 2010).

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

supply wells at the SMR or within a 1-mile radius (EDR, 2019). One domestic well and one
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commercial well were identified by the EDR Radius Map approximately 0.5 miles to the east of

the facility. Locations of the wells are shown on Figure 1-2.

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

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

Concord Water Department treatment plant, which is located 4.3 miles northwest of the facility,

on the west side of the Merrimack River (USEPA, 2017). The primary water source for the Concord

community is Penacook Lake, located 4 miles northwest of the facility, on the west side of the

Merrimack River. During dry periods, the lake is supplemented with water from Contoocook River

Pump Station, which is located further northwest of Penacook Lake. Additionally, a groundwater

well field adjacent to the Soucook River in Pembroke is maintained as an emergency water source

(city of Concord, 2019c). The Pembroke well field is approximately 1.6 miles southeast of the

facility, on the opposite side of the Soucook River. None of these drinking water resources are

anticipated to be hydraulically downgradient from the subject property.

1.5.3 Hydrology

The SMR is located within the central portion of the Merrimack River watershed, which stretches

from central New Hampshire into Northeastern Massachusetts. The nearest major surface water

bodies are the Merrimack River, located approximately 0.8 miles to the west/southwest of the

facility, and the Soucook River, located approximately 1 mile to the south/southeast. The

Merrimack River is popular for recreational use, including boating, canoeing, rowing, and fishing

(NHDES, 2017). Based on the depth of the Merrimack River (5 to 40 ft or more; Concord Monitor, 

2013) and the depth to groundwater in the area (estimated to be 30 to 50 ft bgs), it is possible

that groundwater to surface water discharge may occur at points along the river downgradient of

the site. No wetlands exist within the vicinity of the facility. Surface water features in the vicinity of

the facility are shown on Figure 1-3.

The topography of the facility and in the surrounding area is relatively flat. Much of the facility is

paved with either asphalt or concrete, with unpaved grassy areas along the boundaries of the

facility. Surface water in the general vicinity drains westerly towards the Merrimack River.

Stormwater at the SMR is currently managed utilizing a series of drainage basins and trenches

for infiltration, which allow the majority of stormwater to infiltrate the ground onsite. Drains in the

Combined Support Maintenance Shop (CSMS) and unit vehicle parking area are supplied with an

oil-water separator (OWS)-equipped catch basin drain before discharge to the Concord municipal

storm drain system on Airport Road. The drainage within the storm drain system from Airport Road

flows westward down Loudon Road and then to the Merrimack River, which is approximately 0.5

miles to the west of the SMR. Storm drains in the northeast corner of the SMR are also connected

to the Concord municipal storm drainage system. In the northern portion of the site, stormwater

runoff drains into scattered catch basins that discharge to the storm drain in Pembroke Road. This

stormwater also flows westward into the storm drain system on Loudon Road and ultimately to

the Merrimack River (VHB, 1993; Stone & Webster Environmental Technology & Services, 1998).

From the 1970s to approximately 2006, drywells were used to dispose of stormwater at the SMR.

Historic reports for the SMR indicate that 14 drywells were present at the facility. Seven of the

drywells (DW-1 through DW-7) were located downgradient of the UH-60 helicopter pads and may

have received drainage from these areas. Two of the drywells formerly received drainage from

the Ground Power Annex (DW-9 and DW-10), and one received drainage downgradient of the

refueling area (DW-8). Drywells DW-1 through DW-10 were installed in the 1972 to 1974

timeframe (Jacques Whitford Company, Inc., 2003). DW-A was located north-northwest from the

blacktop driveway at the Airport Road gate, northeast of the boundary fence. DW-B was located

20 feet southeast from the southeast wall of the former AASF building (Building K). DW-C was

located 160 feet southwest from the southeast corner of the former AASF building. An additional

unnamed drywell was located on the northwest side of former Building K (labeled DW-Z for
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purposes of this report). Some of the drywells were removed or filled in the 1990s (Stone &

Webster Environmental Technology & Services, 1998). According to interviews with NHARNG

personnel, the remainder of the drywells were abandoned in 2006, with the exception of DW-1,

which is still present at the facility.

1.5.4 Climate

The facility lies within the humid continental climate zone, which is characterized by long, cold,

snowy winters, very warm (and at times humid) summers, and relatively brief autumns and

springs. The monthly daily average temperature ranges from a high of 31 degrees Fahrenheit (°F)

in January to 82°F in July. In winter, successive storms deliver light to moderate snowfall amounts,

which contribute to the relatively reliable snow cover. Summer can bring stretches of humid

conditions as well as thunderstorms, and there is an annual average of 12 days of 90°F highs.

Average annual precipitation is approximately 41 inches (US Climate Data, 2019).

1.5.5 Current and Future Land Use

The SMR property is zoned “industrial” by the city of Concord. Much of the facility is paved with

either asphalt or concrete. Approximately 15 acres of the SMR is a fully vegetated Pine Barrens

Habitat area, which was created as mitigation to compensate for the habitat loss at the AASF

facility currently located at 26 Regional Drive, Concord, New Hampshire. The SMR currently

serves as the headquarters for the NHARNG. Facilities at the SMR include a warehouse, a

maintenance shop, Joint Force Offices, the Concord Armory, and a Civil Support Teams building

(Tighe & Bond, 2018). Activities and land use within the facility are not expected to change.

The area surrounding the SMR includes residential and commercial properties to the north, the

Concord Municipal Airport to the south, commercial and light industrial properties to the east, and

additional residential neighborhoods to the west. Conservation/Public Lands are located

approximately 0.8 miles to the southeast, adjoining the Soucook River. Future land use of the

surrounding area is not anticipated to change.
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Facility Location

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Former Vishay Sprague Facility

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Groundwater Features

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12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

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2. Fire Training Areas

Two FTAs were identified at the SMR through interviews. Descriptions of the FTAs are presented 

below, and the FTAs are shown on Figure 2-1. 

Former Camp LaBonte

The Former Camp LaBonte was used by the NHARNG as a Weekend Training Site for many 

years and originally served as the New Hampshire Military Academy for Officer Candidate School 

prior to the state of New Hampshire’s acquisition of the current New Hampshire National Guard 

Training Site property in Center Strafford in 1985.

According to former AASF personnel, two firetrucks were used at the SMR during AASF 

operations. The first firetruck was a former 1940s vintage LaFrance firetruck, which was moved 

to the SMR from Manchester Airport in the 1960s. The vintage LaFrance firetruck was removed 

from the facility sometime prior to 1977 (the exact date is unknown). The second firetruck was 

tank-mounted on a deuce and a half truck, which was introduced to the SMR sometime prior to 

1977 and was removed from the site in 1992. 

Interviewees indicated that foam was used on both firetrucks. When the first firetruck was in use 

(late 1960s to pre-1977), foam was used for training on the grass and gravel to the north of the 

former Camp LaBonte on the SMR, at approximate geographic coordinates 43°12'38.9"N; 

71°30'40.1"W (Figure 2-1). When the second firetruck was in use (pre-1977 to 1992), foam was 

sprayed on the pavement at the former AASF (Building K), but not in the Camp LaBonte area.

According to former AASF personnel, two types of foam were used on the firetrucks. The older of 

the two foams contained animal-based ingredients (potentially blood or fat). The second type of 

foam was referred to as a “civilian foam” that came in 5-gallon containers from a local Fire 

Department (either the Concord Fire Department or the Franklin Fire Department). No additional 

information was available on the dates of foam use, the type of foam used (Class A or Class B), 

or whether the foam contained AFFF. Because the first firetruck was potentially in use after the 

introduction of AFFF in firefighting foams, a release of PFAS-containing AFFF at the former Camp 

LaBonte area cannot be ruled out. 

The former Camp LaBonte was located to the south of the parking lot that is behind the Concord 

Readiness Center and previously had small training huts. Two of the huts currently remain and 

have been joined into one building that now serves as a Karner Blue Butterfly Captive Rearing 

Building, which is leased to the New Hampshire Fish and Game Department. The area is also 

part of the 15 of fully-vegetated Pine Barrens Habitat, which was created as mitigation to 

compensate for the habitat loss at the AASF facility currently located at 26 Regional Drive, 

Concord, New Hampshire.

Tri-Max Training Area

According to interviews with former AASF personnel, six Tri-MaxTM mobile fire extinguishers were 

stored outside on the former AASF apron (one beside each helicopter) during the time that 

helicopters were stationed at the SMR (from the 1960s to 2004). Once expired, the tanks would 

be periodically emptied as part of training exercises that occurred north of the former runway, at 

approximate geographic coordinates 43°12'35.4"N; 71°30'44.3"W (Figure 2-1). The frequency 

and timeframe of training and the volume of AFFF discharged per training event are unknown. 

Additionally, no documentation or information were available on the type, quantity, and 

concentration of AFFF stored in the Tri-MaxTM extinguishers. All Tri-MaxTM mobile fire 
PFAS Preliminary Assessment Report

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extinguishers were removed from the facility and sent for disposal in 2004. The area is now a

parking lot.
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Fire Training Areas

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3. Non-Fire Training Areas

Non-FTAs where AFFF was stored and/or potentially released were identified during the PA. A 

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

Former AASF Hangar 

The former AASF was located at the SMR from the 1960s to 2004. Typical activities conducted at 

the AASF included maintenance and repair of fixed-wing and rotary aircraft, storage and 

dispensing of fuel, and mechanical servicing and cleaning of helicopter interiors and exteriors 

(NHARNG, 1996). As described in Section 1.4, the initial building for the AASF hangar 

constructed between 1960 and 1961, and helicopters were present at the SMR in the 1960s. In 

1974, an addition to the original building was constructed to create Building K (The Louis Berger 

Group, Inc., 2006). The Aircraft Maintenance Hangar was located in the center of former Building 

K, at approximate geographic coordinates 43°12'37.4"N; 71°30'46.6"W. 

According to interviews with former personnel, a fire suppression system was installed in the 

hangar in 1994. No fire suppression system was present prior to this time, despite aircraft 

operations beginning in the 1960s. The system was charged with 3% AFFF from 1994 to 2004. 

No additional information on the type of AFFF, frequency of testing, or system maintenance was 

available. The system was removed in 2004, when operations were moved the new AASF at 26 

Regional Drive, located 0.5 miles to the east of the facility. The majority of former Building K was 

demolished at that time, except for the main hangar. The current Building 1 was built in 2006 

around the former hangar. The former hangar is now used as a large drill and assembly hall.

One documented release of AFFF from the fire suppression system occurred on 23 July 1999. 

According to interviewees, a fire was triggered using a lighter to ignite accelerants located in the 

Communications Room of Building K (Appendix B). The amount of AFFF released is unknown. 

After the release, the foam was either washed into a floor drain trench inside the hangar or washed 

out of the hangar onto the apron to the east of the building. The floor drain trench inside the 

hangar led to a 1,000-gallon OWS located outside the building, and then to the municipal sewer 

system, per the terms and conditions of city of Concord Industrial Discharge Permit No. H-37 

(VHB, 1993; NHARNG, 1996). The location of the 1,000-gallon OWS is presumed to be on the 

southwest side of former Building K, based on historic figures from the 1998 SI Report (Stone & 

Webster Environmental Technology & Services, 1998). Foam washed onto the apron would have 

entered a catch basin that discharged to the municipal sewer system. The location of the former 

AASF (Building K) fire suppression system release is shown on Figure 3-1.

A second release of AFFF from the fire suppression system was recalled by one interviewee, who 

recalled the Hangar filling up quickly with foam. However, the date of this incident and the quantity 

of AFFF released was unknown. The foam from this release is presumed to have been managed 

in the same manner as the first release. 

Former Firetruck Parking

As described in Section 2.1, former AASF personnel indicated that two firetrucks were used at 

the SMR during AASF operations. The first was a former 1940s vintage LaFrance firetruck, which 

moved to the SMR from Manchester Airport in the 1960s. The vintage LaFrance firetruck was 

removed from the facility sometime prior to 1977 (the exact date is unknown). The second firetruck 

was tank-mounted on a deuce and a half truck, which was introduced to the SMR sometime prior 

to 1977 and was removed from the site in 1992. Both firetrucks were regularly parked in a 
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crash/rescue bay on the north side of former Building K, at approximate geographic coordinates 

43°12'38.2"N; 71°30'47.0"W. 

Interviewees indicated that foam was used on both firetrucks. Although interviewees recalled that 

two types of foam were used, no additional information was available on the dates of foam use, 

the type of foam used (Class A or Class B), or whether the foam contained AFFF. Because the 

dates of use of the firetrucks overlap with the use of AFFF, there is the potential for the foam to 

have contained PFAS. Unintended spills or releases of foam from the firetrucks may have 

occurred in the parking bay or to the asphalt outside the bay, if the firetrucks were parked outside. 

Additionally, former AASF personnel indicated that when the second firetruck was in use (pre1977 to 1992), foam was sprayed on the pavement at the former AASF (Building K) and then 

rinsed into the storm drains. The location of the former firetruck parking bay is shown on Figure 

3-1.

Former Washing Platform

During the former AASF operations, aircraft maintenance and washing was conducted outside at 

the washing platform. The washing platform was located at approximate geographic coordinates 

43°12'39.1"N; 71°30'45.3"W. According to the 1998 SI, rinsate generated in the washing platform 

was collected in a blocked sump at that location and pumped into a mobile holding tank. The 

holding tank was then wheeled into the Hangar’s Maintenance Area and pumped into the same 

floor drain trench at the front of the hangar, which led to a 1,000-gallon OWS located outside the 

building, and then to the municipal sewer system (VHB, 1993; NHARNG, 1996). However, there 

is the potential for unintended spills or releases of PFAS from the washing platform after washing 

aircraft or firetrucks. No documentation or information were available on the type, quantity, and 

concentration of AFFF, which may have been released from the washing platform. The location 

of the former washing platform is shown on Figure 3-1.

Former Aircraft Parking Area

According to interviews with former AASF personnel, six Tri-MaxTM mobile fire extinguishers were 

stored outside on the former AASF (Building K) apron (one beside each helicopter) during the 

time that helicopters were stationed at the SMR (from the 1960s to 2004). The center of the 

parking apron was approximately located at geographic coordinates 43°12'37.8"N; 71°30'43.1"W. 

No spills or releases were reported from the Tri-MaxTM extinguishers, and interviewees could not 

confirm if routine inspections were performed on the tanks. Given the long-term storage of the TriMaxTM extinguishers in a non-climate-controlled environment, there is the potential for unintended 

spills or releases of PFAS from the extinguishers. No additional documentation or information 

were available on the type, quantity, and concentration of AFFF stored in the Tri-MaxTM

extinguishers. All Tri-MaxTM mobile fire extinguishers were removed from the facility and sent for 

disposal approximately in 2004. The former aircraft parking area is shown on Figure 3-1.

Current and Former Dry Wells

From the 1970s to approximately 2006, drywells were used to dispose of stormwater at the SMR. 

According to historic records, there were 14 drywells at the SMR. Locations of the drywells are 

shown on Figure 3-1. There is potential for AFFF from the hangar fire suppression system release 

in 1999, or from unintended spills or releases in the other identified areas, to have entered the 

drywells. Thus, the drywells may be secondary sources of PFAS. Some of the drywells were 

removed or filled in the 1990s (Stone & Webster Environmental Technology & Services, 1998). 

According to interviews with NHARNG personnel, the remainder of the drywells were abandoned 

in 2006, with the exception of DW-1, which is still present at the facility. 
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Seven of the drywells (DW-1 through DW-7) were located downgradient of the former UH-60

helicopter pads and may have received drainage from these areas. Two of the drywells formerly

received drainage from the Ground Power Annex (DW-9 and DW-10), and one received drainage

downgradient of the refueling area (DW-8). Drywells DW-1 through DW-10 were installed in the

1972 to 1974 timeframe. The base of DW-8 was approximately 14 feet in diameter and 17 feet in

depth. The remaining dry wells ranged from 10 to 15 feet deep and from 7 to 10 feet in diameter.

Downgradient impacts to soil and groundwater from DW-1 through DW-10 were evaluated in a

2003 Limited Site Investigation (Jacques Whitford Company, Inc., 2003), and a monitoring well

(MW-1) was installed adjacent to DW-8. Petroleum-contaminated soils were subsequently

removed from DW-8 in September 2004. A Certificate of No Further Action for the drywells was

issued on 17 December 2004 (NHDES, 2004). However, PFAS were not evaluated as part of the

drywell investigation.

DW-A was located 18 feet north-northwest from the blacktop driveway at the Airport Road gate,

and 8.5 feet northeast from the boundary fence. DW-A had a two-foot diameter and was

constructed of brick and concrete. DW-A was constructed subsurface (2 ft bgs) and had a twofoot square steel cover to keep the soil out. A catch basin that was located adjacent to and south

of Building Q connected to DW-A. Past releases of liquid hazardous wastes reportedly occurred,

draining into an OWS. Some waste from the OWS was routed to a former waste oil UST (Tank

No. 8). The potentially-contaminated water from the OWS was allowed to drain into the catch

basin and then flowed through a 4-inch pipe into DW-A. DW-A was excavated and removed in

June 1994 (USAEHA, 1994).

DW-B was located 20 feet southeast of the southeast wall of the former AASF building (Building

K). Before 1992, wash water from the service bay floor, which contained oils and greases from

airplane repair and maintenance, was collected in a sump, discharged into a catch basin, and

then discharged into DW-B. After 1992, the drains inside the former AASF maintenance bays were

blocked off, and the wash water was pumped into wheeled holding tanks, which were transported

to the CSMS, where they emptied into the OWS. This OWS is connected to the Concord publiclyowned treatment works. DW-B was located directly below the catch basin, which also received

drainage from the roof of the former AASF (Building K). DW-B drained into a storm drain pipeline,

which flowed to a combination storm drain and sanitary sewer main on Airport Road (USAEHA,

1993; Stone & Webster Environmental Technology & Services, 1998).

DW-C was located 160 feet southwest of the southeast corner of the former AASF building

(Building K) and 170 feet northwest from Building R, the JP-8 (formerly JP-4) pumphouse.

Formerly, the catch basin leading to DW-C reportedly had water ponded on the ground surface

within a diameter of approximately 40 feet. DW-C was plugged and then could not drain or drained

very slowly. In the fall of 1993, DW-C was filled, and a solid, pre-cast concrete catch basin was

installed on top of it. This catch basin currently flows into a new pipeline, which was constructed

in early 1994, and is connected to the Airport Road storm drain. Since this change occurred, water

ponding at the surface of the catch basin has not been observed (USAEHA, 1994; Stone &

Webster Environmental Technology & Services, 1998).

An additional unnamed drywell (labeled DW-Z for purposes of this report) was identified on figures

from the 1998 SI Report, located on the northwest side of former Building K and extends from a

former septic system (Stone & Webster Environmental Technology & Services, 1998).
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Former FireTruck Parking

Former Aircraft Parking Area

Former Washing Platform

DW-1

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Non-Fire Training Areas

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4. Emergency Response Areas

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

or EDR Reports. The City of Concord Fire Department would handle any potential fire or

emergency response incident at the SMR.
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5. Adjacent Off-Facility Sources

Five potential off-facility sources of PFAS adjacent to the SMR were identified during the PA. One 

of these facilities, the AASF Concord, is under the control of the NHARNG, while the remaining 

four are not under the control of the NHARNG. Descriptions of the off-facility sources are 

presented below and are shown on Figure 5-1. Interview records are included in Appendix B.

Army Aviation Support Facility Concord

The AASF Concord is located 0.5 miles east of the SMR, at 26 Regional Drive, Concord, New 

Hampshire, at the Concord Municipal Airport. The geographic coordinates for the AASF Concord 

are 43°12'33.50" N; 71°30'8.21”W. The AASF property is owned by the city of Concord and leased 

to NHARNG by and through the Office of the Adjutant General. 

The new AASF facility opened in 2005, when operations were moved from the former Building K 

at the SMR. Two buildings, the main hangar and the Fuel Truck Storage Building, are currently 

equipped with AFFF fire suppression systems. The ARNG conducted a PFAS PA of the AASF 

under separate title and cover as part of Contract Number W912DR-12-D-0014, Task Order 

W912DR17F0192, issued 11 August 2017, and known releases of AFFF were identified (AECOM, 

2019). Please refer to the PA Report for the AASF for details of those releases. Because the AASF 

has potential releases of PFAS and is located outside the boundary of the SMR, the AASF is 

considered a potential adjacent off-facility source of PFAS. Figure 5-1 shows the location of the 

AASF in relation to the SMR. 

Concord Municipal Airport

The Concord Municipal Airport is located south of the SMR, at 71 Airport Road, Concord, New 

Hampshire. The geographic coordinates for the approximate center of the airport property are 

43o12’9.838”N; 071o30’08.228”W. The airport is a 614-acre general aviation facility and features 

two runways (Runway 17-35 and Runway 12-30). The airport has one fixed base operator, 

Concord Aviation Services, which offers aircraft services and fueling (city of Concord, 2019a). The 

airport has 35,000 square feet of heated hangars and a dozen private T-hangars (city of Concord, 

2019b). It is not known if these hangars have fire suppression systems charged with AFFF. 

According to interviews with the NHARNG, the City of Concord Fire Department is responsible 

for responding to any potential fires or emergency response incidents at the Concord Municipal 

Airport. There is no Aircraft Rescue and Firefighting (ARFF) truck housed at the airport.

Municipal Airport personnel were not interviewed during the PA because the focus of the 

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

properties, and not to formally assess adjacent sources. Therefore, it is not known if AFFF is or 

has been used or stored at the airport currently or historically. Because the presence or absence 

of AFFF at the airport cannot be confirmed, the Concord Municipal Airport has been identified as 

a potential off-site PFAS source area. Figure 5-1 shows the location of the Concord Municipal 

Airport (as a potential PFAS source area) in relation to the SMR. 

City of Concord Fire Department

The City of Concord Fire Department Heights Station is located 0.2 miles northeast of the SMR, 

at 127 Loudon Road, Concord, New Hampshire. The geographic coordinates for the Heights 

Station are 43°12'52.6"N; 71°30'40.3"W. The current facility was dedicated in 1966 and is 

currently the oldest fire station in the city of Concord. The Heights Station is located in the Concord 

Heights District and protects an area that encompasses the entire city of Concord, east of 
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Interstate 93, and north to the area of Sewalls Falls Road, including the Concord Municipal Airport. 

The Heights District also includes the Merrimack and Soucook Rivers, Interstate 93 from Exits 14 

through 17, and the majority of Interstate 393 (city of Concord, 2019d). The City of Concord Fire 

Department is responsible for responding to any potential fires or emergency response incidents 

at the SMR.

Concord Fire Department personnel were not interviewed during the PA; therefore, it is not known 

if AFFF is used or stored at the Heights Station currently or historically. Because the presence or 

absence of AFFF at the station cannot be confirmed, the Concord Fire Department has been 

identified as a potential off-site PFAS source area. Figure 5-1 shows the location of the Heights 

Station (as a potential PFAS source area) in relation to the SMR. 

Richard M. Flynn Fire Academy 

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

1.7 miles east of the SMR, at 98 Smokey Bear Boulevard, Concord, New Hampshire. The 

geographic coordinates for the Fire Academy are 43°12'27.8"N; 71°28'39.1"W. 

The Fire Academy includes an administration/classroom building, an 80-bed dormitory, a four-bay 

fire station, and training grounds (two burn buildings, a flashover simulator, and other props). The 

Fire Academy serves as the Northeast regional training facility for aircraft rescue and firefighting 

personnel (New Hampshire Department of Safety [NHDOS], 2019). Class B foam has been used 

on the Fire Academy site through approximately 175 training courses dating back to 1994. 

According to a news interview with the NHDOS, the academy ceased using foam containing 

PFOS and PFOA in May of 2018 and instead selected a fluorine-free foam for training (Sexton, 

2018).

In June and August 2018, environmental samples were collected at the Academy at the request 

of NHDES. PFOS was detected in groundwater at concentrations ranging from 190 ppt to 

18,000 ppt, and PFOA was detected at concentrations ranging from 120 ppt to 2,200 ppt, with a 

maximum total of 20,200 ppt for combined PFOA/PFOS. Elevated concentrations of PFAS 

compounds were also detected in soil samples and adjacent surface water samples from the 

Soucook River; however, there are currently no standards for PFAS in soil or surface water in 

New Hampshire (Nobis Group, 2018).

Fire Academy personnel were not interviewed during the PA; therefore, the types and quantities 

of AFFF used or stored at the academy currently or historically are not known. However, because 

the Fire Academy has confirmed releases of PFAS and is located outside the boundary of the 

AASF Concord, it is considered an adjacent off-facility source of PFAS. Figure 5-1 shows the 

location of the Richard M. Flynn Fire Academy in relation to the SMR. 

Loudon Road Fire Training Area 

During interviews, NHARNG environmental office personnel indicated that an FTA was formerly 

located on Loudon Road, next to the Douglas N. Everett Arena, located 0.6 miles west of the SMR 

and directly adjacent to the Merrimack River, at 15 Loudon Road, Concord, New Hampshire. The 

approximate geographic coordinates for the former FTA are 43°12'36.1"N; 71°31'31.7"W. 

Interviewees indicated that there was previously a wooden tower at the site that was used for fire 

training and was removed in the late 1990s.

Additionally, former AASF personnel indicated that at least one of the two firetrucks used at the 

former AASF (the second/newer truck) was taken by the NHARNG for training at the Loudon Road 

FTA. Although interviewees confirmed that this firetruck used foam, no additional information was 
PFAS Preliminary Assessment Report

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available on the dates of foam use, the type of foam used (Class A or Class B), or whether the 

foam contained AFFF.

Concord Fire Department personnel were not interviewed during the PA; therefore, it is not known 

if AFFF were used or stored at the Loudon Road FTA historically. Because the presence of AFFF 

at the FTA cannot be confirmed, it has been identified as a potential off-site PFAS source area. 

Figure 5-1 shows the location of the Loudon Road FTA (as a potential PFAS source area) in 

relation to the SMR. However, because groundwater flow in the area is generally southwest, 

towards the Merrimack River, this area is likely side-gradient to the SMR.

New Hampshire Detections 

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

and maintains an online, interactive PFAS Sampling Results map (NHDES, 2019). At the time of 

this PA, the database indicated that PFAS were detected at multiple locations in groundwater, 

soil, and surface water within a 4-mile radius of the AASF Concord. Data shown indicate PFAS 

were detected in groundwater in excess of the New Hampshire AGQSs in groundwater in the 

vicinity of the Richard M. Flynn Fire Academy, approximately 1.7 miles east (side-gradient), near 

the Old Suncook Road Landfill approximately 1.4 miles to the south-southwest (downgradient), 

and at an unidentified location approximately 1 mile to the east (side-gradient). PFAS were 

detected upgradient of the AASF Concord at the Former Vishay Sprague Facility; however, the 

detections were less than the AGQSs. There were no detections greater than the AGQSs within 

approximately 5 miles upgradient of the site. The source of the PFAS at these locations is not 

identified in the database. 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.
Richard M. Flynn

Fire Academy

Loudon Road Fire

Training Area

City of Concord Fire

Department, Heights Station

AASF Concord

(PA Report under separate cover)

Concord Municipal

Airport

Merrimack River

Mill B r ook

Merrimack River

Sou c ook River

Sou c ook River

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10/29/2019

10/29/2019

Preliminary Assessment for PFAS at State Military Reservation, NH

10/29/2019

1:24,600 ­ Figure 5-1 PM RG 10/29/2019

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\NH\State_Military_Reservation_Figures\State_Military_Reservation_PA_Figures\Fig_5-1_State_Military_Reservation_RC_Adjacent_Sources.mxd

0 1,025 2,050 4,100

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Legend

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

30
PFAS Preliminary Assessment Report

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Concord, New Hampshire

31

6. Preliminary Conceptual Site Model

Based on the PA findings, two AOIs was identified at the SMR: AOI 1 Former AASF and AOI 2 

Former Camp LaBonte. The AOI locations are shown on Figure 6-1. The following sections 

describe the preliminary CSM components and the specific preliminary CSMs developed for the 

AOIs. The preliminary CSMs identify the three components necessary for a potentially complete 

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

pathway is considered incomplete. Receptors at the SMR include site workers and construction 

workers. Potential off-post receptors include recreational users of the Merrimack River.

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 is sparse and 

continues to be the subject of PFAS toxicological study. 

AOI 1 Former AASF

AOI 1 is the Former AASF, including the former main AASF hangar (former Building K) fire 

suppression system releases, the firetruck parking bay, the washing platform, the aircraft parking 

apron, the dry wells, and the Tri-MaxTM training area. Potential PFAS release mechanisms within 

this AOI are described below.

· One documented release of AFFF from the former AASF hangar fire suppression system 

occurred in 1999. Additionally, a second release of AFFF from the fire suppression system 

was recalled by one interviewee on an unknown date. After the releases, the foam was 

either washed into a floor drain trench inside the hangar or washed out of the hangar onto 

the apron to the east of the building, from where it would have entered the municipal sewer 

system; however, unintentional releases may have occurred to the nearby grassy areas.

· Former AASF personnel indicated that foam was used on two firetrucks at the SMR 

between the late 1960s and 1992. Both firetrucks were regularly parked in a crash/rescue 

bay on the north side of former Building K. Because the dates of use of the firetrucks 

overlap with the use of AFFF, there is the potential for the foam to have contained PFAS. 

Unintended spills or releases of foam from the firetrucks may have occurred in the parking 

bay or to the asphalt outside the bay, if the firetrucks were parked outside. 

· Aircraft maintenance and washing were conducted outside at washing platform. There is 

the potential for unintended spills or releases of PFAS from the washing platform or the 

associated rinsate after washing aircraft or firetrucks. 

· Six Tri-MaxTM mobile fire extinguishers were stored outside on the former AASF apron 

(one beside each helicopter) during the time that helicopters were stationed at the SMR. 

Given the long-term storage of the Tri-MaxTM extinguishers in a non-climate-controlled 

environment, there is the potential for unintended spills or releases of PFAS from the 

extinguishers. Additionally, the tanks would be periodically emptied as part of training 

exercises that occurred north of the former runway.

Given the known releases from the former fire suppression system and Tri-MaxTM training, and 

potential releases from other identified areas, PFAS were likely released to the surface soil at AOI 

1. There is the potential for this PFAS to have migrated from surface soil to subsurface soil. 

Additionally, PFAS that migrated into the drywells would have been released directly to the 

subsurface soil. Therefore, ground-disturbing activities at AOI 1 could result in site worker and 

construction worker exposure to via ingestion of surface soil or inhalation of soil particles (dust). 
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

32

Ground-disturbing activities to subsurface soil could also result in construction worker exposure 

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

potentially complete for AOI 1.

PFAS are water soluble and can migrate readily from soil to groundwater; therefore, PFAS 

released to soil at AOI 1 may migrate to the groundwater via leaching. However, due to the depth 

of groundwater at the site (estimated to be 30 to 50 ft bgs), the groundwater ingestion exposure 

pathway for construction workers is considered incomplete. Because no public drinking water 

wells were identified within 1 mile downgradient of the facility, the groundwater pathway for nearby 

residents is also considered incomplete.

No surface water bodies were identified at the facility; however, the Merrimack River is located 

approximately 0.8 miles to the west/southwest (downgradient), and the Soucook River is located 

approximately 0.6 miles to the south/southeast (side gradient). It is not known if there is offsite 

groundwater discharge to surface water bodies (the Soucook River, Merrimack River, or their 

tributaries). Based on the depth to groundwater (30 to 50 ft bgs) and the depth of the Merrimack 

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

ingestion exposure pathway for offsite surface water and sediment is considered potentially 

complete for recreational users. Human consumption of fish potentially affected by PFAS from the 

river is also possible. The preliminary CSM for AOI 1 is shown on Figure 6-2.

AOI 2 Former Camp LaBonte

AOI 2 is the Former Camp LaBonte. According to former AASF personnel, two firetrucks with foam 

capabilities were present at the SMR between the late 1960s and 1992. When the first firetruck 

was in use (late 1960s to pre-1977), foam was used for training on the grass and gravel to the 

north of the former Camp LaBonte, at the SMR, at approximate geographic coordinates 

43°12'38.9"N; 71°30'40.1"W. However, no additional information was available on the type of 

foam used (Class A or Class B), or whether the foam contained AFFF. Because the first firetruck 

was potentially in use after the introduction of AFFF, a release of PFAS in the former Camp 

LaBonte area cannot be ruled out.

Given the potential release to surface soil at the Former Camp LaBonte, there is the potential for 

PFAS to have migrated from surface soil to subsurface soil. Therefore, ground-disturbing activities 

at AOI 2 could result in site worker and construction worker exposure to potential PFAS 

contamination via ingestion of surface soil or inhalation of soil particles (dust). Ground-disturbing 

activities to subsurface soil could result in construction worker exposure via ingestion. Therefore, 

the inhalation and ingestion pathways for these receptors are considered potentially complete. 

Although PFAS may migrate from the soil to the groundwater via leaching, the groundwater 

ingestion exposure pathway for construction workers is considered incomplete due to the depth 

to groundwater (30 to 50 ft bgs). Because no public drinking water wells were identified within 1 

mile downgradient of the facility, the groundwater ingestion pathway for nearby residents is also 

considered incomplete.

As described above in Section 6.1, no surface water bodies were identified at the facility. 

However, it is not known whether there is offsite groundwater discharge to downgradient surface 

water bodies (the Soucook River, Merrimack River, or their tributaries). Based on the depth to 

groundwater (30 to 50 ft bgs) and the depth of the Merrimack River 5 to 40 ft bgs), groundwater 

interaction with the river may be possible. Therefore, the ingestion exposure pathway for offsite 

surface water and sediment is considered potentially complete for recreational users of the nearby 

rivers. Human consumption of fish potentially affected by PFAS from the river is also possible. 

The preliminary CSM for AOI 2 is shown on Figure 6-3.
A! A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

AASF Hangar Releases

Former Tri-Max Training Area

Former FireTruck Parking

Former Aircraft Parking Area

Former Camp LaBonte

Former Washing Platform

Loudon Road Fire

Training Area

City of Concord Fire

Department, Heights Station

AASF Concord

(PA Report under separate cover)

Concord Municipal Airport

Bow Bog

Brook-Merrimack

River Watershed

Soucook

River

Watershed

Merrimack River

AOI 2

AOI 1

0 450 900 1,800

Feet

­ Figure 6-1

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Preliminary Assessment for PFAS at the State Military Reservation, NH

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10/30/2019

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Potential PFAS Release

Facility Boundary

StreamRiver

Wetland

River/Stream

Surface Water Flow Direction

Inferred Groundwater Flow

Direction

Wells

A! Monitoring Well

A! Other/Unknown Well

Areas of Interest

12420 Milestone Center Drive

Germantown, MD 20876

Soucook

River

Watershed

Soucook River

Richard M. Flynn

Fire Academy

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2

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PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

34

This Page Intentionally Blank
Media

SOURCE PATHWAY RECEPTOR

AOI 1 

Releases from Hangar 

Fire Suppression 

System, Washing 

Platform, Firetrucks, 

Tri-Max Storage/

Training

PFAS in 

Surface Soil

PFAS in 

Subsurface 

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 Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site Worker Construction Worker Resident Trespasser/ Recreational User

Site Worker Construction Worker Resident Trespasser/ Recreational User LEGEND

Figure 6-2

Preliminary Conceptual Site Model

AOI1 Former AASF

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ /

/ /

/ /

/

/

/

/

/

/ /

/

/

/

/ / /

NOTES

1. The resident receptor refers to an offsite resident. 

2. No surface water bodies were 

identified at the facility, but the surface 

water/sediment pathway is considered 

potentially complete for offsite 

recreational users due to the potential 

for groundwater interaction with the 

downgradient river.

3. Human consumption of fish 

potentially affected by PFAS from the 

downgradient river is possible.

35
Media

SOURCE PATHWAY RECEPTOR

AOI 2

Releases from 

Firetruck FTA

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 Transport and Migration Media Exposure Routes

Inhalation of 

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors: 

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site Worker Construction Worker Resident Trespasser/ Recreational User

Site Worker Construction Worker Resident Trespasser/ Recreational User LEGEND

Figure 6-3

Preliminary Conceptual Site Model

AOI2 Former Camp LaBonte

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ /

/ /

/ /

/

/

/

/

/

/

/

/

/

/

/ / /

NOTES

1. The resident receptor refers to an offsite resident. 

2. No surface water bodies were 

identified at the facility, but the surface 

water/sediment pathway is considered 

potentially complete for offsite 

recreational users due to the potential 

for groundwater interaction with the 

downgradient river.

3. Human consumption of fish 

potentially affected by PFAS from the 

downgradient river is possible.

36
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

37

7. Conclusions

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

storage, and potential release of AFFF and other PFAS-related activities at the SMR. The PA 

findings are based on the information presented in Appendix A and Appendix B.

Findings

Two AOIs related to a PFAS releases were identified (Table 7-1) at the SMR during the PA (Figure 

7-1).

Table 7-1: AOIs at the State Military Reservation

Area of

Interest Name Used by PotentialRelease Dates

AOI 1 Former AASF NHARNG late 1960s to 2004

AOI 2 Former Camp LaBonte NHARNG late 1960s to pre-1977

Based on actual and potential AFFF releases at these AOIs, there is a 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, and the preliminary CSM for AOI 2 is shown on Figure 6-3. The preliminary CSMs 

present the potential receptors and media impacted. 

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 SMR. 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 at the SMR. 

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

with personnel who had direct knowledge of 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, 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.

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 7-2: Uncertainties

Area of Interest Source of Uncertainty

AOI 1

Former AASF

AOI 1 includes the former AASF hangar fire suppression system

releases, the firetruck parking bay, the washing platform, the aircraft

parking apron, the dry wells, and the Tri-MaxTM training area.

Uncertainties for this AOI include:

· No information was available on the type of AFFF, frequency of

testing, or system maintenance for the former AASF hangar fire

suppression system. The quantities of AFFF released during the

two discharges are unknown.
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

38

Area of Interest Source of Uncertainty

· Although interviewees indicated foam was used on the firetrucks,

the dates of the foam type switch, the frequency of sparing on the

apron, the type of foam used (Class A or Class B), whether the

foam contained AFFF, or the quantities of foam used are

unknown.

· No information was available on the type, quantity, and

concentration of AFFF stored in the Tri-MaxTM extinguishers.

Interviewees could not confirm if routine inspections were

performed on the tanks. Additionally, the frequency and timeframe

of Tri-MaxTM training and the volume of AFFF discharged per

training event are unknown.

AOI 2 Former Camp LaBonte

Interviewees indicated that foam from a firetruck was used for training

on the grass and gravel to the north of the former Camp LaBonte on

the SMR between the late 1960s are pre-1977. However, the no

additional information was available on the dates of foam use,

frequency of training, the type of foam used (Class A or Class B),

whether the foam contained AFFF, or the quantities of foam used.

Potential Future Action

Interviews and records indicate that current or former ARNG activities may have resulted in 

potential PFAS releases at the 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 

surface and subsurface soil at these AOIs. In addition, there is potential for off-site receptors to 

be exposed to PFAS contamination in surface water and sediment or via fish consumption. 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. 

The ARNG evaluates the need for an SI based on the presence of a PFAS release, possible 

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

Table 7-3: PA Findings Summary

Area of

Interest

AOI

Location Rational PotentialFuture Action

AOI 1

Former AASF

43°12'38.1"N;

71°30'44.2"W

Known release in 1999 from the main

hangar fuel suppression system. Known

releases from Tri-MaxTM training. Potential

releases from the firetruck parking bay,

washing platform, and aircraft parking

areas. Surface releases may have

migrated to drywells.

Proceed to an SI,

focus on surface

soil (in areas not

now covered by

asphalt),

subsurface soil,

and groundwater

AOI 2 Former

Camp

LaBonte

43°12'38.9"N;

71°30'40.1"W

Firetruck with foam potentially containing

PFAS was used for training on the grass

and gravel to the north of the former

Camp LaBonte.

Proceed to an SI,

focus on surface

soil, subsurface

soil, and

groundwater
AASF Hangar Releases

Former Tri-Max Training Area

Former FireTruck Parking

Former Aircraft Parking Area

Former Camp LaBonte

Former Washing Platform

Loudon Road 

Fire Training Area

City of Concord

Fire Department, Heights Station

AASF Concord

(PA Report under separate cover)

Concord Municipal Airport

Merrimack River

AOI 2

AOI 1

0 450 900 1,800

Feet

­ Figure 7-1

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Preliminary Assessment for PFAS at the State Military Reservation, NH

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Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

10/30/2019

1:8,281

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Area of Interest

Potential PFAS Release

Facility Boundary

StreamRiver

Wetland

River/Stream

Summary of Findings

12420 Milestone Center Drive

Germantown, MD 20876

Soucook River

Richard M. Flynn

Fire Academy

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2

1

2

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Feet

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PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

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PFAS Preliminary Assessment Report

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Concord, New Hampshire

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8. References

AECOM, 2019. Draft Preliminary Assessment Report, Army Aviation Support Facility Concord,

Concord, New Hampshire, Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic

Acid (PFOA) Impacted Sites, ARNG Installations, Nationwide. May.

City of Concord, 2019a. Concord Municipal Airport, Airport Figures. Accessed May 6 2019 at

https://www.concordnh.gov/344/Concord-Municipal-Airport.

City of Concord, 2019b. Facilities, Concord Municipal Airport. Accessed May 6 2019 at

http://www.concordnh.gov/facilities/facility/details/concordmunicipalairport-31

City of Concord, 2019c. General Services (Public Works), Water, Water Source. Accessed 23

May 2019 at: https://www.concordnh.gov/1396/Water-Source.

City of Concord, 2019d. Heights Station. Accessed May 6 2019 at https://concordnh.gov/1108/

Heights-Station.

Concord Monitor, 2013. Editorial: River must be approached with caution. Accessed 15 October

2019 at https://www.concordmonitor.com/Archive/2013/07/EditRIVER-cmview-070913. 10

July.

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

and Certified Sanborn® Map Report; State Military Reservation, 1 Minuteman Way,

Concord, NH, 03301. May.

GZA GeoEnvironmental, Inc., 2010. Remedial Action Plan, Former Vishay Sprague Facility, 70

Pembroke Road, Concord, New Hampshire. February.

GZA GeoEnvironmental, Inc., 2018. Annual Summary Report – Monitoring Year 2017, Former

Vishay Sprague Facility, 70 Pembroke Road, Concord, New Hampshire.

Jacques Whitford Company, Inc., 2003. Limited Initial Site Characterization, Army Aviation

Support Facility, 4 Pembroke Road, Concord, NH, NHDES Site #199406009. October 10.

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, 1996. Stormwater Pollution Prevention Plan. State Military Reservation, Concord, New

Hampshire. December.

NHDES, 2004. Certificate of No Further Action. CONCORD – Army Aviation Support Facility, 4

Pembroke Road, DES #199406009-OPUF-WLP3. 17 December.

NHDES, 2017. The Upper Merrimack River. Water Division, Rivers Management Protection

Program. Accessed 15 October 2019 at

https://www.des.nh.gov/organization/divisions/water/wmb/rivers/merri_river_upper.htm.

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.

NHDOS, 2019. Division of Fire Standards and Training and Emergency Medical Services. Our

Mission. Accessed May 3, 2019 at https://www.nh.gov/safety/divisions/fstems/.
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

42

Nobis Group, 2018. Focused Site Investigation Work Plan, New Hampshire Department of Safety,

Richard M. Flynn Fire Academy, 98 Smokey Bear Boulevard, Concord, New Hampshire,

NHDES Site No. 201710012. November 9.

Sexton, Adam, 2018. PFAS detected at New Hampshire Fire Academy. New Hampshire News

Channel WMUR9. Accessed May 3 2019 at: https://www.wmur.com/article/baby-sea-lionrescued-from-busy-california-highway-1556904231/27357461. October 31.

Stone & Webster Environmental Technology & Services, 1998. Final Site Investigation, New

Hampshire Army National Guard, State Military Reservation, Concord, New Hampshire.

March.

The Louis Berger Group, Inc., 2006. District Area Survey Form, State Military Reservation,

Concord, New Hampshire. 25 August.

Tighe & Bond, 2018. Building 2 Preconstruction Assessment, New Hampshire Army National

Guard, State Military Reservation Combined Support Team Facility, 4 Pembroke Road,,

New Hampshire. July.

United States Census Bureau, 2018. QuickFacts: Concord city, New Hampshire; United States. 

Accessed May 2 2019 at https://www.usclimatedata.com/climate/concord/newhampshire/united-states/usnh0045.

US Climate Data, 2019. Climate Concord - New Hampshire. Accessed April 9 2019 at

https://www.usclimatedata.com/climate/concord/new-hampshire/united-states/usnh0045.

USAEHA, 1993. Preliminary Assessment, Ground Water Quality Survey No. 38-26-K28T-94,

Selected NHARNG Sites. 12 November.

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

(CERCLA).

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.

VHB, 1993. Spill Prevention, Control and Countermeasures Plan. New Hampshire Army National

Guard/State Military Reservation. Concord, New Hampshire. October.
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Data Resources
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Data resources will be provided separately on CD. Data resources for the State Military 

Reservation include:

Environmental Data Resources Report

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

Certified Sanborn® Map Report; State Military Reservation, 1 Minuteman Way, Concord, 

NH 03301.

Previous Investigations

• GZA GeoEnvironmental, Inc., 2010. Remedial Action Plan, Former Vishay Sprague Facility, 

70 Pembroke Road, Concord, New Hampshire. February.

• Jacques Whitford Company, Inc., 2003. Limited Initial Site Characterization, Army Aviation 

Support Facility, 4 Pembroke Road, Concord, NH, NHDES Site #199406009. October 10.

• NHDES, 2004. Certificate of No Further Action. CONCORD – Army Aviation Support 

Facility, 4 Pembroke Road, DES #199406009-OPUF-WLP3. 17 December. 

• Stone & Webster Environmental Technology & Services, 1998. Final Site Investigation, New 

Hampshire Army National Guard, State Military Reservation, Concord, New Hampshire. 

March.

• The Louis Berger Group, Inc., 2006. District Area Survey Form, State Military Reservation, 

Concord, New Hampshire. 25 August.

• Tighe & Bond, 2018. Building 2 Preconstruction Assessment, New Hampshire Army 

National Guard, State Military Reservation Combined Support Team Facility, 4 Pembroke 

Road, New Hampshire. July.

Real Estate Documentation

• Adjutant General of the State of New Hampshire, 1911. Property transfer from Mary J. Dana 

of Concord, New Hampshire, to the office of Adjutant General. 5 June.

• Foster and Bamford, Inc., 1917. Plan Showing North Line of Land Lease to City of Concord 

by the New Hampshire National Guard, Made from Actual Survey Based on Plan by Lloyd & 

Mann. June.

• State of New Hampshire, 1937. Lease to City of Concord. 4 January.

• City of Concord, 1942. Quitclaim Deed granted to the State of New Hampshire. 28 May.

• City of Concord, 1954. Quitclaim Deed granted to the State of New Hampshire. 22 

December.

• City of Concord, 1959. Quitclaim Deed granted to the State of New Hampshire. 23 

December.

• State of New Hampshire, Superior Court, 1976. Court Decree Eq. 76-1-46. The State of 

New Hampshire v. City of Concord. April Term.

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.

Engineering Drawings

• NHARNG, 1993. Army Aviation Support Facility (AASF) Locus Map.
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

• Adjutant General’s Office. Heating, Plumbing and Electrical Plans. New Hampshire National 

Guard, Liaison Shop Hangar, State Military Reservation, Concord, NH. 

• Dufreene-Henry, 2002. State Military Reservation Site Plan, New Hampshire Army National 

Guard, Concord, New Hampshire. Figure A1-2. January. 

• Dufreene-Henry, 2002. State Military Reservation Stormwater Flow Map, New Hampshire 

Army National Guard, Concord, New Hampshire. Figure A1-2. January. 

• Jacques Whitford Company, Inc, 2003. Site Plan, New Hampshire Army National Guard, 

State Military Reservation, Concord, New Hampshire. Figure 2. 6 October.

• Stone & Webster Environmental Technology & Services, 1998. Site Plan, New Hampshire 

Army National Guard, State Military Reservation, Concord, New Hampshire. Figure 3. 

March.
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Appendix B.1

Interview Records
Chief Warrant Officer 4 (CW4 ) – Phone interview on 5/3/2019

Started with the National Guard at the end of 1982 as a Federal technician (GS)

Became a Chief Warrant Officer 4 (CW4) in 1983. 

Left Hangar (Bldg K) in Fall, 1995 to go to CFMO.

Worked in Construction Facilities Management Office (CFMO) from Oct-Nov 1995 until retirement. 

Retired from the NH Army National Guard in 1997.

relayed the following information: 

Sergeant (of Loudon, NH) was the Fire Chief in the 1990s, and is deceased, as of 5 Feb 

2018. He would have known the most about the history and use of AFFF at the AASF. 

He was a 40 year member of the NH Army National Guard, a 30 year member of the Pembroke, NH Fire 

Department, and a 21 year member of the Loudon, NH Fire Department.

 Maintenance Foreman was , who also went to Law School and became Legal 

Assistant/Warrant Officer.

 did not recall any foam being used/sprayed in the Hangar (Building K). 

He mentioned that the 26th AVN unit out of the Massachusetts Guard was assigned a Fire Truck which 

was located at the Building K hangar. This truck was assigned as the property of the Hangar itself, and it 

went with the unit to Annual Training (AT).

According to , the Fire Truck used water. Every two weeks, the 4-person fire team[(

(deceased), retired), (retired) and (deceased)] from the Hangar 

would take the fire truck down Loudon Road to the Everett Arena parking lot for fire training. 

wasn’t entirely certain what the training consisted of, but was aware that they would donn suits, 

practiced timing to get to the scene. At the hangar, he remembers them only spraying water on the 

grounds of the hangar. The same 4 men on the Fire Team were also mechanics working on aircraft at 

the Hangar (Building K). noted that they conducted fire training 4 hours every two weeks or 4 

hours every month

The Fire Truck was water/fog capable. It had 2 hoses: 1 for Fog, and 1 for Water. The 26th AVN unit was 

absorbed back into MAARNG in 1984. At that time, NHARNG got 6 Huey Helicopters and 1 (one) 

Medical Detachment.

The City of Concord Fire Department also had an interest in the Fire Truck, and they counted it as part of 

their fire suppression equipment, even though they didn’t own it. The NHARNG kept the Fire Truck 

beyond 1984, and the Concord Fire Department would not let the NHARNG turn it in. The Concord Fire 

Department made a deal with the Adjutant General at the time (now 

deceased)) to keep it in the NHARNG’s equipment inventory.

In 1992, the City of Concord Fire Department had all the equipment they needed and no longer 

wanted/needed the Fire Truck for their fire suppression needs (to respond to potential fire at the 

Hangar and the Concord Municipal Airport, so the NHARNG got rid of the Fire Truck at that time (1992).
 also recalled that in the 1960s, a former 1940s vintage LaFrance Fire Truck, with ladders that had 

been formerly used at Manchester Airport in 1957-1958, was moved to Concord for the NHARNG’s use.

 noted that he would reach out and get in touch with , who is now retired and living 

in Webster, NH, and he will find out what he knows and then get back to me. was 

formerly employed as a mechanic at the NHARNG’s Building K on the State Military Reservation in 

Concord.
Phone Interview with (retired) – 5/10/2019

, a retired Command Sergeant Major (who used to work in the Flight Operations Room at 

Building K) noted that there were two (2) incidents that he recalls taking place at Building K, State 

Military Reservation (SMR) in Concord:

1) The first was a fire that was set off by accelerants with a lighter (July 23, 1999) in the Communications 

Room of Building K.

2) The second incident he only remembers the Hangar filling up fast with foam – he only found out 

about it was he was arriving to work.

He will try to reach out to . He noted that his former AASF Commander, is now 

living in Colorado and he cannot reach him. 







PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Appendix B.2

Visual Site Inspection Checklists




PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

State Military Reservation

Concord, New Hampshire

Photograph Log
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

State Military Reservation Concord, New Hampshire

Preliminary Assessment Report

State Military Reservation

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) 

Impacted Sites ARNG Installations, Nationwide

Photograph No. 01

Description:

Front of the former 

Building K AASF Hangar.

Orientation:

West

Date 5/25/1999

Time

Photograph No. 02

Description:

AFFF foam release from 

the former AASF Hangar 

(former Building K).

Orientation:

East

Date 7/23/1999

Time

AECOM Page 1 of 4

Unknown

Unknown
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

State Military Reservation Concord, New Hampshire

Preliminary Assessment Report

State Military Reservation

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) 

Impacted Sites ARNG Installations, Nationwide

Photograph No. 03

Description:

AFFF foam release from 

the former AASF Hangar 

(former Building K). 

Personnel washed foam 

down drain in the main 

hangar which led to the 

municipal sewer system.

Orientation:

NA

Date 7/23/1999

Time

Photograph No. 04

Description:

AFFF foam release from 

the former AASF Hangar 

(former Building K). AFFF 

foam release from the 

former AASF Hangar 

(former Building K). 

Personnel washed foam 

down drain in the main 

hangar which led to the 

municipal sewer system. 

Some foam was washed 

out onto the apron.

Orientation:

South

Date 7/23/1999

Time

AECOM Page 2 of 4

Unknown

Unknown
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

State Military Reservation Concord, New Hampshire

Preliminary Assessment Report

State Military Reservation

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) 

Impacted Sites ARNG Installations, Nationwide

Photograph No. 05

Description:

AFFF foam release from 

the former AASF Hangar 

(former Building K). AFFF 

foam release from the 

former AASF Hangar 

(former Building K). 

Personnel washed foam 

down drain in the main 

hangar which led to the 

municipal sewer system.

Orientation:

East

Date 7/23/1999

Time

Photograph No. 06

Description:

Aerial photograph 

collected by the NHARNG 

of the former AASF.

Orientation:

Northwest

Date 6/25/2003

Time 13:34

AECOM Page 3 of 4

Unknown
Appendix C - Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

State Military Reservation Concord, New Hampshire

Preliminary Assessment Report

State Military Reservation

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) 

Impacted Sites ARNG Installations, Nationwide

Photograph No. 07

Description:

Aerial photograph 

collected by the NHARNG 

of the former AASF.

Orientation:

Southwest

Date 6/25/2003

Time 15:35

Photograph No. 08

Description:

Front of current Building 1, 

which is in the location of 

the former AASF (former 

Building K).

Orientation:

Northeast

Date 4/22/2019

Time 15:46

AECOM Page 4 of 4