Final

Preliminary Assessment Report 

Pelham Range, 

Anniston, Alabama 

Perfluorooctanesulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites 

ARNG Installations, Nationwide 

September 2020 

Prepared for: 

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

i

Table of Contents

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

1. Introduction........................................................................................................................3

Authority and Purpose ..............................................................................................3

Preliminary Assessment Methods .............................................................................3

Report Organization..................................................................................................4

Facility Location and Description...............................................................................4

Facility Environmental Setting...................................................................................5

1.5.1 Geology .........................................................................................................5

1.5.2 Hydrogeology................................................................................................. 5

1.5.3 Hydrology.......................................................................................................6

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

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

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

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

Fire Station .............................................................................................................12

Former Airstrip ........................................................................................................12

Forestry Compound Maintenance Shed..................................................................12

4. Emergency Response Areas............................................................................................15

5. Adjacent Sources.............................................................................................................16

Anniston Army Depot ..............................................................................................16

Calhoun County Landfill..........................................................................................16

6. Conceptual Site Model.....................................................................................................18

7. Conclusions .....................................................................................................................19

Findings ..................................................................................................................19

Uncertainties...........................................................................................................19

Potential Future Actions ..........................................................................................20

8. References ......................................................................................................................22
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

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Figures

Figure ES-1 Summary of Findings

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 7-1 Summary of Findings

Tables

Table 7-1 No Suspected Releases Areas

Table 7-2 Summary of Uncertainties

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

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Acronyms and Abbreviations

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

ALARNG Alabama Army National Guard

AOI Area of Interest

ARNG Army National Guard

ATSDR Agency for Toxic Substances and Disease Registry

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

Act

CFR Code of Federal Regulations

CSM conceptual site model

EDRTM Environmental Data Resources, Inc.TM 

FM-ARNGTC Fort McClellan Army National Guard Training Center

FTA fire training area

HA Health Advisory

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

UCMR3 Unregulated Contaminant Monitoring Rule 3

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

VSI visual site inspection
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

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Executive Summary

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

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

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

(PFAS)-containing materials was completed for Pelham Range (also referred to as the “facility”) 

in Anniston, Alabama, to assess potential PFAS release areas and exposure pathways to 

receptors. Pelham Range is a portion of Fort McClellan Army National Guard Training Center 

(FM-ARNGTC), located within the former Fort McClellan in Calhoun County, Alabama. Following 

the closure of Fort McClellan, the Army licensed Pelham Range to the Alabama Army National 

Guard (ALARNG) in 1999, and property accountability was transferred in 2005. The performance 

of this PA included the following tasks: 

• Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility;

• Conducted a site visit on 11 April 2019 and completed visual site inspections at locations

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

• Interviewed current ALARNG Environmental Managers, Fire Station Chief, and Maintenance

Inspector during the site visit. 

Two potential off-facility PFAS release areas, Anniston Army Depot and Calhoun County Landfill, 

exist adjacent to Pelham Range. Because these areas include property upgradient of the facility, 

it is unknown whether or not the off-facility sources affect Pelham Range. Based on the United 

States Environmental Protection Agency (USEPA) Unregulated Contaminant Monitoring Rule 3 

(UCMR3) data, it was indicated that PFAS were detected in the Southside Water Works public 

water system above the USEPA’s lifetime Health Advisories (HAs). The HA is 70 parts per trillion 

for PFOS and PFOA, individually or combined. The surface water intakes for Southside Water

Works are located within 10 miles to the north of the facility. PFAS analyses performed in 2016 

had method detection limits that were higher than currently achievable. Thus, it is possible that 

low concentrations of PFAS were not detected during the UCMR3 but might be detected if 

analyzed today. 

Based on the documented absence of the use or release of PFAS-containing materials at Pelham 

Range, evidence does not support current or former ARNG activities at the facility having 

contributed to PFAS contamination in soil, groundwater, surface water, or sediment at the facility 

or adjacent areas. No Areas of Interest related to PFAS release were identified at Pelham Range 

based on PA data (Figure ES-1). 
Fire Station

Current Airstrip

Hangar

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Airstrip

Forestry Compound

Maintenance Shed

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Calhoun County

Landfill

Anniston

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Summary of Findings

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Germantown, MD 20876

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PFAS Preliminary Assessment Report

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Anniston, Alabama

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1. Introduction

Authority and Purpose

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

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

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

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

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

Order W912DR17F0192, issued 11 August 2017.

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

used per- and poly-fluoroalkyl substances (PFAS) (a suite of related chemicals), 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 lifetime Drinking Water Health 

Advisories (HAs) for PFOA and PFOS in May 2016, but there are currently no promulgated 

national standards regulating PFAS in drinking water. The HA is 70 parts per trillion for PFOS and 

PFOA, individually or combined. In the absence of federal maximum contaminant levels, some 

states have adopted their own drinking water standards for PFAS. The State of Alabama has 

adopted the USEPA HAs for PFAS.

This report presents the findings of a PA for PFAS-containing materials at Pelham Range in 

Anniston, Alabama, in accordance with the Comprehensive Environmental Response, 

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

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

Army requirements and guidance.

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

the Pelham Range. 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: 

• Reviewed available administrative record documents and Environmental Data Resources,

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

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

environmental compliance actions in the area surrounding the facility; 

• Conducted a site visit on 11 April 2019 and completed visual site inspections (VSIs) at

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

disposed;

• Interviewed current Alabama Army National Guard (ALARNG) Environmental Managers, Fire

Station Chief, and Maintenance Inspector during the site visit. 
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Report Organization

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

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

of each are as follows: 

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

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

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

identified during the site visit

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

at the facility identified during the site visit

• Section 4 – Emergency Response Areas: describes areas of potential PFAS release at the

facility, specifically in response to emergency situations 

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

facility that are not under the control of ARNG

• Section 6 – Conceptual Site Model: describes the pathways of PFAS transport and

receptors for the Areas of Interest (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

Pelham Range is located within the historical footprint of former Fort McClellan (approximately 

45,679 acres) in Calhoun County, Alabama. The former Fort McClellan consisted of the Main Post 

(18,946 acres), Pelham Range (22,245 acres), and the Choccolocco Corridor (approximately 

4,488 acres which was leased from the State of Alabama) (Environmental Science and 

Engineering, 1998). The current Fort McClellan Army National Guard Training Center (FMARNGTC) is comprised of the entire Pelham Range and approximately 300 acres within the 

cantonment area of the Main Post, known as the Enclave. Pelham Range is approximately 5 miles 

west of the Enclave and lies contiguously north of the Anniston Army Depot. The historical 

boundary of Fort McClellan and current locations of Pelham Range and the Enclave are depicted 

in Figure 1-1. 

Pelham Range, formerly known as the Morrisville Maneuver Area, was purchased by the US Army 

in 1941 in order to expand the training capacity at Fort McClellan. The operational range areas at 

Pelham Range have been in use by multiple organizational elements; such as the US Army 

Chemical School, US Army Reserves, Marine Corps Administrative Detachment, Women’s Army 

Corps, and US Air Force Disaster Preparedness School; since the land was first acquired. In 

1995, the Base Realignment and Closure Commission identified Fort McClellan for closure. In 

November 1999, after the closure of Fort McClellan, the Army licensed all of Pelham Range and 

the Enclave to the ALARNG, and in February 2005, the Army transferred real property 
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accountability of the FM-ARNGTC to the ALARNG. Pelham Range continues to be actively used 

by ALARNG (Shaw Environmental, Inc., 2004b). 

Facility Environmental Setting

Pelham Range lies within the Appalachian Valley and Ridge physiographic province, which is 

characterized by gently rolling parallel valleys separated by steep to well-rounded ridges that rise 

from 100 to 700 feet above the valley floors. Major streams flow down the axes of many of the 

valleys, and tributary streams commonly join the major streams at nearly right angles. 

Topographic relief at Pelham Range is approximately 445 feet. Elevations range from 500 feet, in 

the area where Cane Creek exits the Pelham Range to the west, to approximately 945 feet, near 

the southeastern range boundary. The northern portion of Pelham Range contains broad rolling 

topography with northeast to southwest oriented ridges and isolated round knobs rising 75 to 90 

feet above the surrounding terrain (URS Group, Inc. and Arcadis U.S. Inc., 2014). 

1.5.1 Geology

The primary geologic formations underlying Pelham Range from youngest to oldest consist of the 

Pennsylvanian to Mississippian shale, siltstone, sandstone, limestone, and chert; Devonian 

sandstone and shale; Ordovician shale, limestone, chert, mudstone, and dolomite; and Cambrian 

dolomite, shale, and mudstone. The Ordovician-Cambrian dolomite and limestone compose the 

majority of the facility’s geology is part of the Knox Group and is underlain by the Cambrian 

Conasauga Formation, which is approximately 2,500 feet thick (Figure 1-2). The unconsolidated 

surficial soils at Pelham Range area are reported to have an average thickness of 30 to 50 feet 

but have been found as thin as seven feet to greater than 100 feet in some areas. These soils are 

made up of clay and silty clay with weathered rock fragments (Shaw Environmental, Inc., 2004a). 

Numerous sinkholes and underwater sink holes have been identified throughout Pelham Range, 

in areas where the regolith is thin or absent. Sinkholes, other subsurface voids, and underwater

holes common to karst geology can accelerate the transport of surface water to groundwater.

1.5.2 Hydrogeology

The complex geology in Calhoun County has created numerous large groundwater storage 

reservoirs formed by thrust fault zones. The water producing aquifers in this area are found in 

dolomite, limestone, sandstone, and shale (USACE, 2004). The groundwater flow system at 

Pelham Range is complex and can be divided into two general regions. The eastern two-thirds of 

Pelham Range is underlain by Knox Group carbonates and dolomites comprising the Valley and 

Ridge aquifer system, which is a karst aquifer at Pelham Range. Karst aquifers are formed of 

bedrock that exhibits enhanced permeability due to dissolution processes. The west-northwest 

portion of Pelham Range sits atop a system of faulted and folded rocks that form part of the Coosa 

Deformed Belt consisting of the Fort Payne-Tuscumbia aquifer, and clastic aquicludes of 

Mississippian age. All of the bedrock units beneath Pelham Range are overlain by a relatively 

thick mantle (30 to 100 feet) of unconsolidated material. The unconsolidated material overlying 

the Knox Group of the Valley and Ridge aquifer system consists mainly of residuum, the insoluble 

remnants of the carbonate bedrock that has weathered in place. 

The shallow groundwater system (generally down to 50 feet) is comprised of the residuum, 

weathered bedrock, and epikarst while the deep groundwater (generally below 50 feet) is found 

in the carbonate bedrock within its fractures and dissolution features (Anniston Army Depot, 

2005). The water table at Pelham Range occurs in the residuum; therefore, the underlying epikarst 

and bedrock units are perennially saturated. The shallow and deep groundwater systems are 

interconnected through fractures, voids, and faults. 
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Previous dye trace and localized studies of groundwater movement have been completed at 

Anniston Army Depot and Pelham Range (Ewers Water Consultants Inc., 1994; SAIC, 1998, 

1999, and 2000; and URS Group Inc., 2002). The results of the studies indicate the following: 1) 

multi-directional flow in the bedrock from higher elevations to lower elevations, generally following 

topography; 2) groundwater migration within the epikarst is directed by the regional gradient to 

the west-northwest with a mixture of low-velocity, conduit-directed flow and diffuse flow; and 3) 

groundwater flow in the residuum generally following local topography with a portion of the 

groundwater discharging as base flow to seeps, creeks, and streams. 

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

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

databases, wells were researched to a 4-mile radius of the facility. Four wells are located on 

Pelham Range and used for non-potable water only (Shaw Environmental, Inc., 2003; U.S. Army, 

2004). Groundwater wells in the surrounding areas are used for potable and non-potable water 

(agriculture and recreation) but are currently classified as “inactive” by U.S. Geological Survey

(USGS) (USGS, 2019). Approximately 90 percent of the water consumed in Calhoun County is 

supplied by groundwater. Groundwater sources for potable water include private wells and some 

of the 147 groundwater springs that have been documented within the county. Coldwater Spring 

is the major source of spring water for the area and is a natural source of an enormous quantity 

of very high-quality water (about 24 to 36 million gallons per day) located approximately four miles 

southeast of Pelham Range at the foot of Coldwater Mountain. This spring serves nearly 60

percent of Calhoun County residents, including Anniston, Oxford, Blue Mountain, Hobson City, 

Anniston Army Depot, FM-ARNGTC, and the former Fort McClellan area (AMEC Earth & 

Environmental, 2001). The remainder of the residents are served by private wells, groundwater 

springs, or one of four smaller public water supply systems (i.e., Oxford Water System and Sewer 

Board, Calhoun Water System, Jacksonville Treatment Facility, and Weaver City Water Supply). 

The four smaller public water supplies also obtain water from groundwater sources (Agency for 

Toxic Substances and Disease Registry [ATSDR], 1999). A public water supply, Anniston Water 

Works, draws the majority of its water from Coldwater Spring. In addition to Coldwater Spring, 

Anniston Water Works uses the Earl C. Knowlton Treatment Plant for standby services. This plant 

draws its water from Hillabee Lake, which is near the town of Oxford. 

Based on the USEPA Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, it was indicated 

that PFAS were detected above the USEPA’s HA in the Southside Water Works public water 

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

water intakes for the Southside Water Works are located at the Coosa River within 10 miles of 

the facility, and the UCMR3 data are included in Appendix A. PFAS analyses performed in 2016 

had method detection limits that were higher than currently achievable. Thus, it is possible that 

low concentrations of PFAS were not detected during the UCMR3 but might be detected if 

analyzed today. Groundwater features are presented in Figure 1-2. 

1.5.3 Hydrology 

Approximately 93 miles of streams and creeks and 34 acres of open water occur on Pelham 

Range (AMEC Earth & Environmental, 2001) which drains portions of the three drainage basins 

within the Middle Coosa River Watershed: the Cane Creek drainage basin, the Tallasseehatchee 

Creek drainage basin, and the Middle Choccolocco Creek drainage basin. The Cane Creek 

drainage basin receives a majority of the drainage from Pelham Range. Cane Creek flows in a 

westward direction from the Enclave and enters Pelham Range approximately 4.5 miles to the 

west. Several relatively large unnamed tributaries contribute to Cane Creek on Pelham Range. 

The Tallasseehatchee Creek drainage basin includes portions of the northern Pelham Range. 

Intermittent streams in the northwestern portion of Pelham Range contribute to Tallasseehatchee 

Creek. Cane Creek flows in a westward direction roughly bisecting Pelham Range. The runoff 
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from the operational ranges drains toward the center of the Pelham Range through perennial and 

intermittent tributaries flowing into Cane Creek which then flows westward off-range. Both Cane 

Creek and Tallasseehatchee Creek flow to the Logan Martin Reservoir. A small portion of 

southeastern Pelham Range is within the Middle Choccolocco Creek drainage basin and is 

drained by Coldwater Spring Branch which also flows to the Logan Martin Reservoir.

Pelham Range contains numerous seeps and springs due to the topography and underlying 

geology of the area. Ridges generally have rapid runoff, and lower slopes often support wetweather seeps. Several relatively large springs are located on Pelham Range, including Willett 

Springs and Cabin Club Springs. Water quality surveys in the area indicate relatively good quality 

at most locations; the state has classified streams in this area as suitable for fish and wildlife use 

(AMEC Earth & Environmental, 2001). Surface water features are presented in Figure 1-3. 

1.5.4 Climate 

The climate in northeastern Alabama is temperate with warm, humid summers and mild, dry 

winters. During the summer months, the climate borders on the subtropical with frequent localized 

thunderstorms. Rainfall is greatest from January through April and lowest from September through 

November. Average annual precipitation is 53.3 inches and the average annual temperature at 

Anniston is 62 degrees Fahrenheit (°F). The mean maximum temperature for January is 48°F, 

while the mean maximum in July is 78°F. Temperature extremes at Pelham Range have ranged 

from -3°F to +105°F. The average daily highs reach 90°F in the summer months. The first frost 

typically occurs in October, and frost conditions may last into mid-April (National Oceanic and 

Atmospheric Administration, 2018). 

1.5.5 Current and Future Land Use

Pelham Range covers approximately 34 square miles and training activities include the use of 

weapons firing points and impact areas, a demolition range, small arms firing ranges, and training 

and maneuver areas. The firing ranges and training areas on Pelham Range are actively used by 

ALARNG and other military entities such as the US Air Force and Anniston Army Depot. 

Reasonably anticipated land use is not expected to change from the current land use.
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Logan Martin

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Neely Henry

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reek

Havers

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Snows Branch

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Joseph Creek

Willis Branch

Corn House Branch

Wolfskull Creek

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Ottery Creek

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Bridge Creek

Cane Creek

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Ja ck son Creek

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Geology

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siltstone (Upper)

Pottsville Formation (Lower)

Lay Dam Formation

Parkwood Formation and

Floyd Shale Undifferentiated

Heflin Phyllite

Paleozoic Shale

Undifferentiated

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Hartselle Sandstone

Pride Mountain Formation

Tuscumbia Limestone and

Fort Payne Chert

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Red Mountain Formation

Sequatchie Formation

Colvin Mountain Sandstone

Greensport Formation

Athens Shale

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Limestones Undifferentiated

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Longview Limestone

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Conasagua Formation

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Rome Formation

Shady Dolomite

Chilhowee Group

Weisner and Wilson Ridge

Formations Undifferentiated

Nichols Formation

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12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:126,720

0 1 2 4

Miles

10
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2. Fire Training Areas 

No FTAs were identified within the facility during the PA through interviews (Appendix B) 

document review (Appendix A). 
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 3. Non-Fire Training Areas

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

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

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

features obtained during the PA are included in Appendices A and B. Three 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 shown on Figure 3-1. 

Fire Station

The Fire Station is located on the northeast portion of the facility at geographic coordinates 

33°44’13.0” N and 85°54’34.7” W. Historical imagery from EDRTM Reports (Appendix A) show 

that the building was built between 2004 and 2006. Foam capable firetrucks with 150-gallon foam 

reservoirs are currently stored at the Fire Station. However, based on the interviewees only water 

has been used to extinguish fires and no AFFF has been used or stored at the Fire Station. One 

ALARNG personnel stated that the Hi Combat ATM Class A Foam stored in the Forestry Compound 

Maintenance Shed (Section 3.3) was rarely used as a foam additive on the firetrucks. The Class 

A Foam (non-AFFF) concentrate is not suspected to contain PFAS. The safety data sheet for the 

Hi Combat ATM Class A Foam is included in Appendix A. 

Former Airstrip

The former airstrip is located on the northern portion of the facility at geographic coordinates 

33°45'7.1" N and 85°56'47.9" W. The site was used as an airstrip by US Army prior to ALARNG 

property licensing in 1999; however, the details regarding US Army’s historical activities at the site 

are unknown. Historical imagery from EDRTM Reports (Appendix A) show the former airstrip

existing as far back as 1972. 

The former airstrip is currently a staging area for historical aircrafts. During the VSI, the airstrip

was observed to be an unpaved, grassy area not improved with concrete or asphalt. The ALARNG 

interviewees (whose collective knowledge extends back to 1986) also reported that neither fire 

training activities nor crashes requiring emergency response have occurred at the former airstrip. 

Forestry Compound Maintenance Shed

The Forestry Compound Maintenance Shed is on Gate 5 Road in the northeast portion of the 

facility. Geographic coordinates for the maintenance shed are 33°44'42.8" N and 85°55'59.8" W. 

Based on historical imagery from EDRTM Reports (Appendix A), the maintenance shed was 

constructed sometime between 1987 and 1992. The maintenance shed is a wooden structure 

that was previously used to store and mix herbicides, fungicides, and pesticides with no floor 

drains. A Site Investigation performed in 2002 at the Forestry Compound identified metals, volatile 

organic compounds, and chlorinated pesticides in site media; however, it was determined that the 

detected metals and chemical compounds posed no unacceptable risk to human health and the 

environment (IT Corporation, 2002). 

The Forestry Compound is currently used for storage of road-building materials. Two 5-gallon 

buckets of Hi-Combat ATM Class A Foam were observed in the maintenance shed. One ALARNG 

personnel stated that the Class A Foam was rarely used as a foam additive on firetrucks. The 

Class A Foam (non-AFFF) concentrate is not suspected to contain PFAS. The safety data sheet 

for the Hi Combat ATM Class A Foam is included in Appendix A. 
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Pelham Range, 

Anniston, Alabama

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Current Airstrip and Hangar

The current airstrip is located on the northern portion of the facility at geographic coordinates 

33°43'24.9" N and 85°54'26.7" W. Adjacent to the current airstrip is what appears to be a small 

hangar. Based on Google Earth aerial imagery, the airstrip and hangar were constructed 

sometime between 2010 and 2011. According to ALARNG interviewees, there are no staff and 

fire extinguishers located at the airstrip, and the airstrip is used for drones. Neither fire training 

activities nor crashes requiring emergency response have occurred at the current airstrip, and 

there are no fire dispensing systems located at the hangar. The current airstrip and hangar are

not considered a suspected PFAS release area. 
Fire Station

Current Airstrip

Hangar

Former

Airstrip

Forestry Compound

Maintenance Shed

0 300 600 1,200

Feet

1

2

1 2

Legend

No Suspected Release

Facility Boundary

Stream/River ­ Figure 3-1

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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 EDRTM Reports. The Fire Station at the Pelham Range (described in Section 3.1) is the first 

responder for facility emergencies. Based on interviewees, informal mutual agreements are in 

place with the local county fire department; however, the local county fire department does not 

respond to brush fires within the facility. 
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5. Adjacent Sources

Two potential off-facility sources of PFAS adjacent to the facility, not under the control of the 

ALARNG, were identified during the PA. A description of each adjacent source is presented below 

and shown on Figure 5-1. 

Anniston Army Depot

Anniston Army Depot is an active US Army installation lying contiguously south of Pelham Range. 

The installation was established in 1941 and occupies approximately 25 square miles, containing 

a maintenance center and munitions storage site (Anniston Army Depot, 2019). Anniston Army 

Depot was identified as an installation where the Department of Defense is “performing an 

assessment of PFAS use or potential release” (Defense.gov, 2019); therefore, Anniston Army 

Depot was identified as a potential adjacent source of PFAS. 

Calhoun County Landfill

Calhoun County Landfill is adjacent to the southern boundary of Pelham Range and eastern 

boundary of Anniston Army Depot. The landfill is owned by Calhoun County and has a recycling 

and transfer station. The landfill was identified as a potential adjacent source of PFAS, because 

PFAS may be present in a variety of solid waste materials landfilled and have historically been 

discovered in landfills, leachates, and landfill gas (USEPA, 2018). 
Calhoun

County

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Anniston

Army Depot

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12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:126,720

0 1 2 4

Miles

Legend

Potential PFAS Release

Facility Boundary

Water Body

Stream/River

Pipeline

17
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6. Conceptual Site Model

Based on the PA findings, no release areas were identified as AOIs at the Pelham Range; 

therefore, a conceptual site model (CSM) is not required for the facility. A CSM identifies three 

components necessary for potentially complete exposure pathways: (1) source, (2) pathway, and 

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

on the findings of this PA, there are no PFAS sources that originate at Pelham Range or from 

activities associated with the facility; therefore, exposure pathways are considered incomplete. 
PFAS Preliminary Assessment Report

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Anniston, Alabama

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7. Conclusions

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

storage of AFFF and other PFAS-related activities at the Pelham Range. The PA findings are 

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

Findings

The following areas discussed in Section 3 were determined to have no suspected PFAS 

releases (Table 7-1): 

Table 7-1: No Suspected Releases

No Suspected 

Release Area

Used by Rationale for No Suspected Release 

Determination

Fire Station ALARNG No storage or use of AFFF. The firetrucks at 

the fire station are foam capable but have only 

carried a Class A, non-AFFF foam. 

Former Airstrip ALARNG / US 

Army

Interviewees (whose collective knowledge 

extends back to 1986) reported that neither fire 

training activities nor crashes requiring 

emergency response have occurred at the 

former airstrip. 

Forestry Compound 

Maintenance Shed

ALARNG There is no storage or use of AFFF. Two 

buckets of Class A, non-AFFF foam are stored 

within the shed. 

Current Airstrip and 

Hangar

ALARNG Interviewees (whose collective knowledge 

extends back to 1986) reported that neither fire 

training activities nor crashes requiring 

emergency response have occurred at the 

current airstrip. There are no fire dispensing 

systems located at the hangar. 

Based on the documented absence of the use or release of PFAS-containing materials at Pelham 

Range, evidence does not support current or former ARNG activities at the facility having 

contributed to PFAS contamination in soil, groundwater, surface water, or sediment at the facility 

or adjacent areas. No AOIs related to PFAS release were identified at Pelham Range based on 

PA data.

Two potential off-facility PFAS release areas, Anniston Army Depot and Calhoun County Landfill, 

exist adjacent to Pelham Range. Because these areas include property upgradient of the facility, 

it is unknown whether or not the off-facility sources affect Pelham Range.

Uncertainties

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 facility. Historically, 

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

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

training, firefighting, or other non-traditional activities, or on its disposition. 
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20

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

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

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

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

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

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

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

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

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

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

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

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

interviewed for the same potential source area, and potential source areas were visually 

inspected. Table 7-2 summarizes the uncertainties associated with the PA. 

Table 7-2. Summary of Uncertainties

Location Source of Uncertainty

Former Airstrip Details regarding U.S. Army’s historical activities at the site 

are unknown.

Current Airstrip and Hangar No VSI was conducted for the current airstrip and adjacent 

hangar. 

General Pelham Range was formerly licensed to ALARNG in 1999. 

However, interviewee knowledge of ALARNG activities 

extends to 1986. It is unknown when ALARNG activities 

may have begun at Pelham Range or what might have 

occurred prior to 1986.

Potential Future Actions

Based on the documented absence of the use or release of PFAS-containing materials at Pelham 

Range since the beginning of the ALARNG property license (1999 to present), no AOIs were 

identified during the PA. Evidence does not indicate that current or former ARNG activities 

contributed PFAS contamination to soil, groundwater, surface water, or sediment at the facility or 

adjacent areas. Pelham Range will not move forward in the CERCLA process. 
Fire Station

Current Airstrip

Hangar

Former

Airstrip

Forestry Compound

Maintenance Shed

0 300 600 1,200

Feet

Calhoun County

Landfill

Anniston

Army Depot

1

2

1 2

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Stream/River ­ Figure 7-1

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Summary of Findings

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Germantown, MD 20876

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8. References

Agency for Toxic Substances and Disease Registry (ATSDR). 1999. 

http://www.atsdr.cdc.gov/HAC/pha/pha.asp?docid=834&pg=4#table5

AMEC Earth and Environmental, Inc. 2001. Final Integrated Natural Resource Management Plan 

and Environmental Assessment for the Fort McClellan Army National Guard Training Center.

Anniston Army Depot. 2005. Installation Action Plan (IAP) FY2006 for Alabama, Anniston Army 

Depot.

Anniston Army Depot. 2019. The Official Site of Anniston Army Depot, Pit Crew of the American 

Warfighter. https://www.anad.army.mil/. (Accessed 27 March 2020). 

Defense.gov. 2019. Installations Where DoD is Performing an Assessment of PFAS Use or 

Potential Release. https://media.defense.gov/2020/Mar/17/2002265607/-1/-

1/1/SPREADSHEET_OF_INSTALLATIONS_WHERE_DOD_PERFORMING_ASSESSMENT_O

F_PFAS_USE_OR_POTENTIAL_RELEASE.PDF. (Accessed 27 March 2020). 

Environmental Science & Engineering, Inc. 1998. Final, Environmental Baseline Survey, Fort 

McClellan, Alabama (Volume I and II).

Ewers Water Consultants Inc. 1994. Final Report Groundwater Tracing Studies Anniston Army 

Depot, Anniston, Alabama.

IT Corporation. 2002. Final Site Investigation Report, Forestry Compound – Pelham Range, 

Parcel 84(7), Fort McClellan, Calhoun County, Alabama. March. 

National Oceanic and Atmospheric Administration. 2018. NOWData – NOAA Online Weather 

Data, Monthly Climate Normals (1981-2010)- Anniston Metropolitan AP, AL. 

https://w2.weather.gov/climate/xmacis.php?wfo=bmx. (Accessed 27 May 2020). 

SAIC. 1998. Report on the Findings for the Groundwater Tracer Test at the Anniston Army Depot 

Southeast Industrial Area, Anniston, Alabama. 

SAIC. 1999. Work Plan for Phase One of the Offpost Remedial Investigation— Hydrogeologic 

Characterization of the Jacksonville Thrust Fault at Anniston Army Depot, Anniston, Alabama. 

SAIC. 2000. Results of Extended Monitoring Period Groundwater Tracer Test Anniston Army 

Depot, Anniston, Alabama.

Shaw Environmental, Inc. 2003. Water Supply Well Report for Pelham Range.

Shaw Environmental, Inc. 2004a. Remedial Investigation Report Range K, Former Training Area 

Parcel 203(7), Fort McClellan, Calhoun County, Alabama.

Shaw Environmental, Inc. 2004b. Remedial Investigation Report Range J – Pelham Range, 

Parcel 202(7), Fort McClellan, Calhoun County, Alabama.

URS Group, Inc. 2002. Closure Report for Open Burn and Open Detonation Unit, Fort McClellan, 

Alabama.

URS Group Inc., and Arcadis U.S., Inc. 2014. Final Operational Range Phase II Assessment, Fort 

McClellan, Calhoun County, Alabama. January. 

United States (U.S.) Army. 2004. Final Decision Document Water Supply Wells at Pelham Range.
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

23

USACE. 2004. Second Five-Year Review Report for Interim Action Record of Decision Shallow 

Groundwater Operable Unit Groundwater Treatment System, Anniston Army Depot, Calhoun 

County, Alabama.

United States Geological Survey (USGS). 2019. National Water Information System: Mapper. 

https://maps.waterdata.usgs.gov/mapper (Accessed 1 June 2020). 

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

Preliminary Assessments under CERCLA. September.

USEPA, 2018. Practical Methods to Analyze and Treat Emerging Contaminants (PFAS) in Solid 

Waste, Landfills, Wastewater/Leachates, Soils, and Groundwater to Protect Human Health and 

the Environment.

United States Geological Survey (USGS). 2004. Age and Source of Water in Springs Associated 

with the Jacksonville Thrust Fault Complex, Calhoun County, Alabama.
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix A 

Data Resources
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Data resources will be provided separately on CD. Data resources for Pelham Range include:

Environmental Data Resources, Inc. Geocheck Report

• 2019 Environmental Data Resources, Inc. Geocheck Report for Pelham Range, AL

Material Safety Data Sheets

• Material Safety Data Sheet #AMSE225 – Hi Combat ATM Fire fighting foam

Miscellaneous 

• Email from Karen Pinson (ALARNG) to Brett McKee (AECOM) Re: ARNG PFAS: Alabama 

Fort McClellan and Pelham Range

Previous ALARNG Pelham Range Investigations 

• 1998 Final Environmental Baseline Survey, Fort McClellan, Alabama, Volumes I and II

• 2001 Ordnance and Explosives Chemical Warfare Materials, Pelham Range, Anniston, 

Alabama

• 2002 Final Site Investigation Report, Forestry Compound – Pelham Range, Parcel 84(7)

• 2002 Final Site Investigation Report for Pelham Range Sites for Recovered Chemical 

Warfare Material (RCWM)

• 2003 Final Water Supply Well Report for Pelham Range, Fort McClellan, Calhoun County, 

Alabama

• 2004 Final Remedial Investigation, Range J – Pelham Range, Parcel 202(7)

• 2004 Final Decision Document, Water Supply Wells at Pelham Range, Fort McClellan, 

Calhoun County, Alabama

• 2014 Operational Range Assessment, Phase II Assessment Report, Fort McClellan Army 

National Guard Training Center, Alabama

Unregulated Contaminants Monitoring Rule 3 (UCMR3)

• UCMR3 Dataset for Pelham Range, AL
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix B 

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix B.1 

Interview Records


( 

PA Interview Questionnaire - Environmental Manager Facility:� 

Interviewer:

Dateffime: 

------L/JII /11 13'5 I 

11. When a release of AFFF occurs during a fire training exercise, now and in the past, how is the

AFFF cleaned and disposed of? Were retention ponds built to store discharged AFFF? Was the

AFFF trickled to the sanitary sewer or left in the pond to infiltrate?

12. Can you recall specifi9 times when city, county, and/or state personnel came on-po�

t for training? If so,

please state which statt/county agency or military entity? Do you have any records, !including

photographs to share with us?

13. Did military routinely or occasionally fire train off-post? List the units that you can recall used/trained

at various areas.

14. Did individual units come with their own safety personnel, did they also bring their own AFFF? Was

training with AFFF part of these exercises? How were emergencies handled under these circumstances?

15. Are there specific emergency response incident reports (i.e., aircraft or vehicle

crash sites and fires)? If so, may we please copy these reports? Who (entity) was

the responder?

(/VO Cr--41-VJ, "TNrt "Ir{ .{_c,(,/O A.Jr <:.J,(?'�. -rJ.e (r.,,,c,,-,/. c;...,r 5./,.p 

+� fV'-••'-"' b ... ,1.1,"'.), Or- �,�,_ e,,,..j( Vt\,11- �I' �fllN1. 

or Cn1N'S 

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PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix B.2 

Visual Site Inspection Checklists










PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix B.3 

Conceptual Site Model Information
Preliminary Assessment – Conceptual Site Model Information

Site Name: Pelham Range

Why has this location been identified as a site?

Facility includes a fire station and former airstrip

Are there any other activities nearby that could also impact this location?

Anniston Army Depot is adjacent to the facility

Training Events

Have any training events with AFFF occurred at this site? No

If so, how often? N/A

How much material was used? Is it documented? N/A

Identify Potential Pathways: Do we have enough information to fully understand over land surface

water flow, groundwater flow, and geological formations on and around the facility? Any direct

pathways to larger water bodies?

Surface Water:

Surface water flow direction? To local streams and tributaries primarily in Lower and Upper Cane Creek

Watershed

Average rainfall? 53.3 inches

Any flooding during rainy season? None known

Direct or indirect pathway to ditches? Indirect

Direct or indirect pathway to larger bodies of water? Indirect

Does surface water pond any place on site? Yes

Any impoundment areas or retention ponds? Yes

Any NPDES location points near the site? None known

How does surface water drain on and around the flight line? No flight line
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction? Inferred northeast

Depth to groundwater? Shallow aquifer generally down to 50 feet

Uses (agricultural, drinking water, irrigation)? Non-potable use within facility only

Any groundwater treatment systems? No

Any groundwater monitoring well locations near the site? No

Is groundwater used for drinking water? No

Are there drinking water supply wells on installation? Only four non-potable wells

Do they serve off-post populations? No

Are there off-post drinking water wells downgradient? Yes, but considered inactive by USGS

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present? No

If so, do we understand the process and which water is/was treated at the plant? N/A

Do we understand the fate of sludge waste? N/A

Is surface water from potential contaminated sites treated? N/A

Equipment Rinse Water

1. Is firefighting equipment washed? Where does the rinse water go?

Not known, but only water or Class A foam has ever been used with firefighting equipment

2. Are nozzles tested? How often are nozzles tested? Where are nozzles tested? Are nozzles cleaned after

use? Where does the rinse water flow after cleaning nozzles?

See answer above

3. Other?
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker - Yes

Construction Worker - Yes

Recreational User - Potentially

Residential - No

Child - No

Ecological - Yes

Note what is located near by the site (e.g. daycare, schools, hospitals, churches, agricultural, livestock)?

Agriculture, sparsely populated residential areas

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur?

No
PFAS Preliminary Assessment Report

Pelham Range, 

Anniston, Alabama

Appendix C

Photographic Log
Preliminary Assessment Report

Pelham Range – Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Pelham Range Anniston, Alabama

Photograph No. 1

Description:

Looking southwest

General view of the former air

strip at Pelham Range

Photo date 4/11/19

Photograph No. 2

Description:

Looking Northeast

General view of Forestry

Compound

Photo Date: 4/11/19
Preliminary Assessment Report

Pelham Range – Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Pelham Range Anniston, Alabama

Photograph No. 3

Description:

Looking Northeast

Two 5-gallon containers of

Hi-Combat A foam located in

the Forestry Compound

Photo Date: 4/11/19

Photograph No. 4

Description:

Looking South

General view of the back side

of the fire station at Pelham

Range

Photo Date: 4/11/19
Preliminary Assessment Report

Pelham Range – Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Pelham Range Anniston, Alabama

Photograph No. 5

Description:

Unknown direction

Floor drain located inside the

fire station truck bay

Photo Date: 4/11/19