FINAL

Preliminary Assessment Report

Camp Roberts, California

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

US 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

Camp Roberts, California
PFAS Preliminary Assessment Report

Camp Roberts, California

i

Table of Contents

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

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

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

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

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

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

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

Geology .........................................................................................................7

Hydrogeology .................................................................................................7

Hydrology .......................................................................................................9

Climate ...........................................................................................................9

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

2. Fire Training Areas ...........................................................................................................15

2.1 East Garrison Old Fire Training Area ......................................................................15

Description and Operational History .............................................................15

Previous Investigations ................................................................................16

Surface Water and Groundwater ..................................................................16

2.2 Main Garrison Fire Training Area 2 .........................................................................16

Description and Operational History .............................................................16

Previous Investigations ................................................................................16

Surface Water and Groundwater ..................................................................17

2.3 Prescribed Range Burns and Various Building Burns at East and Main 

Garrisons ................................................................................................................17

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

3.1 McMillan Airfield ......................................................................................................19

NPS Airfield Shed AFFF Storage ..................................................................19

TUAS Hangar Building 1702 AFFF Storage .................................................19

McMillan Airfield Wildfires .............................................................................20

3.2 East Garrison Camp Roberts Army Airfield .............................................................20

3.3 East Garrison Old Fire Station ................................................................................20

3.4 Camp Roberts Parade Field Fueling Point Area ......................................................21

3.5 Camp Roberts Fire Departments ............................................................................21

Fire Station Building 7020 ............................................................................21

Camp Roberts Fire Department Fire Station and Shipping Container ...........21

Camp Roberts Fire Department Building 3000 .............................................22

3.6 Landfills, Trench Areas, Disposal Pits and Quarry ...................................................22

North and South Waste Management Unit Landfills .....................................23

Trench Areas ................................................................................................23

South Landfill ...............................................................................................23

Nacimiento Tributary Landfill ........................................................................24

Quarry Dump Site ........................................................................................24

Other Camp Roberts Dumping Grounds.......................................................24

Prescribed Burns ..........................................................................................25

3.7 Wastewater Treatment Plant ...................................................................................25

4. Emergency Response Areas ............................................................................................29
PFAS Preliminary Assessment Report

Camp Roberts, California

ii

4.1 TUAS Aircraft Crash Sites ....................................................................................... 29

5. Adjacent Sources ............................................................................................................. 31

5.1 Vehicle Incidents on US Route 101 ......................................................................... 31

6. Conceptual Site Model ..................................................................................................... 33

6.1 AOI 1: East Garrison Old Fire Station and AOI 2 East Garrison Old Fire

Training Area .......................................................................................................... 33

6.2 AOI 3 Main Garrison Fire Training Area 2 and Building 7020 .................................. 34

6.3 AOI 4 Camp Roberts Fire Department Fire Station and Shipping Container ........... 34

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

7.1 Findings .................................................................................................................. 37

7.2 Uncertainties ........................................................................................................... 39

7.3 Potential Future Actions .......................................................................................... 39

References ............................................................................................................................... 43

Tables

Table 7-1: AOIs at Camp Roberts

Table 7-2: No Suspected Release Areas at Camp Roberts

Table 7-3: Uncertainties

Table 7-4: PA Findings Summary

Figures

Figure ES-1 Summary of Findings

Figure ES-2 Conceptual Site Model, Camp Roberts

Figure 1-1 Camp Roberts 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 4-1 Emergency Response Area

Figure 6-1 Areas of Interest

Figure 6-2 Conceptual Site Model, Camp Roberts

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 Photographic Log
PFAS Preliminary Assessment Report

Camp Roberts, California

iii

Acronyms and Abbreviations

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AOI area of interest

ARNG Air National Guard

bgs below ground surface

CA ARNG California Army National Guard

CCRWQCB Central Coast Regional Water Quality Control Board

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CIRPAS Center for Interdisciplinary Remotely-Piloted Aircraft Studies

CR FD Camp Roberts Fire Department

CSM conceptual site model

°F degrees Fahrenheit

FTA fire training area

IED Installations and Environment Division

MATE Mobilization and Training Equipment Site

msl mean sea level

ng/L nanograms per liter

NPS Naval Postgraduate School

NTL Nacimiento Tributary Landfill

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PFTeA

ppt

SI

Perfluorotetradecanoic acid

parts per trillion

Site Inspection

TUAS Tactical Unmanned Aerial Systems

TFFT tactical firefighting truck

US United States

USACE United States Army Corps of Engineers
PFAS Preliminary Assessment Report

Camp Roberts, California

iv

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

VSI visual site inspection

WWTP Waste Water Treatment Plant
PFAS Preliminary Assessment Report

Camp Roberts, California

1

Executive Summary

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

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

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

site inspections) for Perfluorooctanesulfonic acid (PFOS) and Perfluorooctanoic acid (PFOA)

Impacted Sites at ARNG Facilities Nationwide. The ARNG is assessing the potential exposure to

humans and the effect on the environment 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 released during firefighting activities or training, although other PFAS sources

are possible.

AECOM completed a PA for PFAS at the California Army National Guard (CA ARNG) Camp

Roberts in Monterey and San Luis Obispo Counties, California, to assess potential PFAS release

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

tasks:

· Reviewed available administrative record documents and Environmental Data Resources,

Inc. report packages to obtain information relevant to potential PFAS releases

· Conducted a 2-day site visit on 23 and 24 May 2018

· Interviewed current Camp Roberts personnel during the site visit including the CA ARNG

Senior Environmental Scientist and other facility operations staff; and, Camp Roberts Fire 

Department Chief and Captain

· Completed VSIs at known or suspected PFAS release locations and documented with

photographs

· Identified areas of interest (AOI) and developed a conceptual site model (CSM) to

summarize potential Source-Pathway-Receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI

Four AOIs related to potential PFAS releases were identified at Camp Roberts during the PA. The

AOIs are shown on Figure ES-1 and described below:

Area of Interest Name Used by Release Dates

AOI 1 East Garrison Old

Fire Station

CA ARNG Camp Roberts

Fire Department

Potentially as

early as 1976

AOI 2 East Garrison Old

Fire Training Area

CA ARNG Camp Roberts

Fire Department

Potentially as

early as 1976

AOI 3

Main Garrison Fire

Training Area 2 and

Building 7020

CA ARNG Camp Roberts

Fire Department Prior to 2001

AOI 4

Camp Roberts Fire

Department Fire

Station and

Shipping Container

CA ARNG Camp Roberts

Fire Department Unknown

Based on information obtained during the PA at these AOIs, there is potential for exposure to

PFAS contamination in surface soil and intermittent surface water and sediments to site workers,

construction workers, residents, recreational users, and trespassers via ingestion and inhalation;
PFAS Preliminary Assessment Report

Camp Roberts, California

2

subsurface soil to site and construction workers via inhalation; and groundwater to all receptors

via ingestion. The CSM for Camp Roberts is shown on Figure ES-2.
Main Garrison

Fire Training Area 2 

& Building 7020

Camp Roberts Fire Departmemt

Fire Station & Shipping Container

East Garrison Old Fire Station

East Garrison Old Fire Training Area

Quarry Dump Site

Nacimiento Tributary Landfill

Camp Roberts 

Fire Department 

Building 3000

Camp Roberts 

Parade Field 

Fueling Point Area

East Garrison 

Camp Roberts 

Army Airfield

South Landfill

North and South Waste Management Unit Landfills

Trench Areas

Wastewater

Treatment

Plant

TUAS Aircraft Crash Site

NPS Airfield Shed AFFF Storage

TUAS Hangar Building 1702 AFFF Storage

Wastewater

Treatment

Plant

AOI 4

AOI 3

AOI 1

AOI 2

D ipC ree k

SanAntonio R ive r

Nacimiento R iver

San Marcos Cr eek

Hames Cree k

B gi S a ndy Creek

SnakeCreek

Salin as River

Estrella Ri ver

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

GR

2/22/2019

2/22/2019

NOTES Preliminary Assessment for PFAS at Camp Roberts, CA

1:108,000

2/22/2019 ­ Figure ES-1 PM RG 2/22/2019

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\CA\Camp_Roberts\Fig_ES-1_Camp_Roberts_Summary.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

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

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

0 4,500 9,000 18,000

Feet

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Pipeline

3
Media

SOURCE PATHWAY RECEPTOR

AOI 1

AOI 2

AOI 3

AOI 4

Fire Training

Activities,

Incidental Spills

PFAS in

Surface Soil

and

Concrete

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

LEGEND

/ / /

/ / /

Figure ES-2

Conceptual Site Model

Camp Roberts

Potential

Off-Facility

Source Not

under

Control of

ARNG

/ /

/ / /

/ /

/ / / /

/

/

/

4
PFAS Preliminary Assessment Report

Camp Roberts, California

5

1. Introduction

1.1 Authority and Purpose

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

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

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

site inspections (VSIs) 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. The ARNG is assessing potential

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

substances (PFAS) (a suite of related chemicals), primarily releases of aqueous film forming foam

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

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

potentially be responsible for a PFAS release.

PFAS are classified as emerging environmental contaminants that are garnering increasing

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

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

compounds in the environment will vary. The regulatory framework at both federal and state levels

continues to evolve. The US Environmental Protection Agency (USEPA) issued Drinking Water

Health Advisories for PFOA and PFOS in May 2016, but there are currently no promulgated

national standards regulating PFAS in drinking water . In the absence of federal maximum

contaminant levels, some states have adopted their own drinking water standards for PFAS. On

13 July 2018, under the authority of the Deputy Director of the Division of Drinking Water,

California issued drinking water notification levels of 14 parts per trillion (ppt) for PFOA and 13

ppt for PFOS. Notification levels are nonregulatory health-based advisory levels established for

contaminants in drinking water for which maximum contaminant levels have not been established.

This report presents findings of a PA for PFAS at California Army National Guard (CA ARNG) at

Camp Roberts in Monterey and San Luis Obispo Counties, California, in accordance with the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as

amended, the National Oil and Hazardous Substances Pollution Contingency Plan (40 Code of

Federal Regulations Part 300), and USACE requirements and guidance.

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

PFAS may have been released to the environment at Camp Roberts. The term PFAS will be used

throughout this report to encompass all PFAS chemicals being evaluated, including PFOS and

PFOA, which are key components AFFF.

1.2 Preliminary Assessment Methods

· Reviewed available administrative record documents and Environmental Data Resources,

Inc. report packages to obtain information relevant to potential PFAS releases

· Conducted a 2-day site visit on 23 and 24 May 2018

· Interviewed current Camp Roberts personnel during the site visit including the CA ARNG

Senior Environmental Scientist and other facility operations staff; and, Camp Roberts Fire

Department Chief and Captain

· Completed VSIs at known or suspected PFAS release locations and documented with

photographs
PFAS Preliminary Assessment Report

Camp Roberts, California

6

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

summarize potential Source-Pathway-Receptor linkages of potential PFAS in soil,

groundwater, surface water, and sediment for each AOI

1.3 Report Organization

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

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

of each are:

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

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

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

visit.

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

at the facility identified during the site visit.

· Section 4 – Emergency Response Areas: describes areas of potential 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 at each AOI.

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

PA.

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

1.4 Facility Location and Description

Camp Roberts is in southern Monterey and northern San Luis Obispo Counties in central

California. It is situated along the eastern foothills of the Santa Lucia Mountains in the valley of

the Salinas River, which flows towards the northwest through the property. The facility is about 12

miles north of Paso Robles and 25 miles east of the Pacific Ocean (Figure 1-1). The latitude,

longitude and surface elevation at the main gate of the facility are 35 47’53”; 120 44’40” and, 620

feet above mean sea level (msl), respectively.

Camp Roberts occupies 42,784 acres of land and is bordered on the west by the unincorporated

community of Heritage Ranch and on the east by the unincorporated community of San Miguel.

Camp Roberts includes three main types of use areas including cantonment areas, training areas,

and airfield operational areas. Facilities at Camp Roberts are concentrated in two cantonment

areas. The Main Garrison and East Garrison are located in the northeastern portion of Camp

Roberts near the facility’s main gate and are separated by the Salinas River and US Route 101.

Training areas include weapons ranges and impact areas, open areas for heavy and light

maneuver training, and land navigation areas. These areas are in the southern, central, and

northern portion of the property. Firing ranges occupy areas in the western and central portions

of Camp Roberts. The three airfield operational areas include McMillan Airfield, located at the
PFAS Preliminary Assessment Report

Camp Roberts, California

7

southernmost end of Camp Roberts, the East Garrison Airfield, located towards the northern end 

of the facility, north of U.S Route 101, and the Parade Field, which is also used as a landing field 

for rotary wing aircraft.

Camp Roberts was originally developed as an Army replacement training center in 1941 

(Environmental Resources Management Inc. [ERM], 1995). The facility was inactivated and then 

reverted to caretaker status from 1946 to 1950. After 1950, Camp Roberts was reactivated during 

the Korean Conflict. Camp Roberts was again inactivated and reverted to caretaker status from 

1954 until it was officially closed by the Army in 1970. Although the facility was active during the 

Vietnam War, it was never officially brought out of inactive status. On 2 April 1971, the CA ARNG 

received control of the site under a license from the Army to establish a Reserve Component 

Training Center.

1.5 Facility Environmental Setting

Camp Roberts is in a region of rolling hills and steep mountainous valleys between the Pacific 

Ocean and the Santa Lucia Mountains. Much of the facility is grasslands and oak woodlands. The 

area surrounding the facility is a mix of agriculture, rural residential, recreation, and open spaces. 

Surface elevations at Camp Roberts range from 600 feet msl in the area where higher plains meet 

the Nacimiento River Basin area to 1,800 feet msl, in steep slope areas of the southwestern 

portion of the training area. The Nacimiento River traverses through the Main Garrison and meets 

the Salinas River near US Route 101, within the boundaries of Camp Roberts. Ephemeral 

tributary streams of the Nacimiento River are located in the northern portion of the facility.

Geology

Camp Roberts is situated in the southern portion of the California Coast Ranges section of the 

Pacific Border physiographic province, which stretches over 400 miles from the Klamath 

Mountains in Humbolt County to the Traverse Ranges in Santa Barbara County (FPM, 2008). The 

topography of Camp Roberts is characteristic of the Coast Ranges, with terrain varying from low 

plains and river valleys to steep hills. A series of folds and faults follow a northwest trend as a 

result of mountain forming episodes that occurred from the late Pliocene into the mid Pleistocene.

The most prevalent geologic units at Camp Roberts are composed of Quaternary or Late Tertiary 

semi- to unconsolidated layers of sand, gravel, sandstone, and conglomerate deposits that are 

consistent with stream deposition environments. The low and high plains are composed of 

Quaternary (Recent and Late Pleistocene) alluvium and the Paso Robles Formation, respectively. 

The Paso Robles Formation accumulated extensively after withdrawal of the Tertiary Sea and is 

mainly a mixture of semi- to unconsolidated alternating layers of conglomerate and sandstone, 

with smaller amounts of mudstone (US Geological Survey [USGS], 1974). Other units residing 

beneath the lower hills in the northern portion of Camp Roberts include alternating layers of 

massive- to thinly-bedded Tertiary mudstones, shales, and sandstones of the Pancho Rico, Santa 

Margarita and Tierra Redonda Formations, and an unnamed Cretaceous marine unit (Chemistry 

Systems Laboratory [CSL], 1983). 

The southern Salinas Valley lies mainly on the Salinian block, a structural basement comprised 

of granitic and high-grade metamorphic rocks (USGS, 1974). The Salinian block is bounded by 

the San Andreas and Rinconada fault zones, which are approximately 17.5 and 8 miles northeast 

and west of Camp Roberts, respectively. Both faults are active, right-lateral slip faults capable of 

generating significant earthquakes.

Hydrogeology

Camp Roberts lies within the Salinas Valley Groundwater Basin, which is subdivided into the Paso 

Robles Area Subbasin and the Upper Valley Aquifer Subbasin. Camp Roberts is situated within 
PFAS Preliminary Assessment Report

Camp Roberts, California

8

the Paso Robles Area Subbasin, which is bordered on the north by the Upper Valley Aquifer

Subbasin, on the east by the Temblor Range, on the south by the La Panza Range, and on the

west by the Santa Lucia Range (California Department of Water Resources [DWR], 2004). The

limited amounts of groundwater used from the basin are from mostly unconfined Holocene age

alluvium deposits found as deep as 130 feet below ground surface (bgs), but generally less than

30 feet bgs. Although permeability is considered high, limited amounts of groundwater are

extracted for use. The most important source of groundwater in the basin is found in Pleistocene

age Paso Robles Formation, which reaches a thickness of 2,000 feet (DWR, 2004). Groundwater

recharging the basin is provided by infiltration, seepage from streams, and return flow from

irrigation. The estimated annual recharge rate for the Paso Robles Area Sub-basin is 47,000 acrefeet, and specific yield values in the Paso Robles Area Subbasin range from 7-11 percent, with

an average yield of 9 percent. The estimated usable storage capacity of the Paso Robles Area

Subbasin is estimated to be 1.7 million acre-feet (DWR, 2004).

Groundwater from the Paso Robles Area Subbasin is the main source of water for the facility.

Groundwater supply wells located throughout the Salinas Valley region have typical intake depths

of over 200 feet (DWR, 2004). Groundwater features are presented on Figure 1-2.

Camp Robert’s potable water is sourced from groundwater wells situated within the boundaries

of the facility. The primary source of drinking water for the facility is provided from wells located

in the Main Garrison. These wells include Well Numbers C-3-A, C-4A, and C-5A, which are active

wells situated adjacent to the Nacimiento River. Well depths range from 350 to 450 feet bgs.

Information about Camp Robert’s water wells is tabulated and included in Appendix A.

From a 2012 Site Investigation, the water table at the northwest end of the Main Garrison and at

the East Garrison ranged from approximately 82 to 85 feet bgs. At the southwest end of the Main

Garrison, the water table was encountered at 29 to 36 feet bgs (American Integrated Services,

Inc., 2012). Several logs for wells installed near McMillian Airfield recorded static water levels

ranging from 60 to 78 feet bgs.

In the southeast area of Camp Roberts, there are three wells, two public supply wells, and one

potable well at the Satellite Communication. The Satellite Communication is a US Army enclave

that is surrounded by Camp Roberts but administratively distinct.

In March 2017, groundwater from the majority of Camp Roberts’ well network was analyzed for

PFAS. PFAS is a large group of related chemicals including PFOA, PFOS, and

Perfluorotetradecanoic acid (PFTeA). The samples were collected at spigots from various facilities

at Camp Roberts. The spigots are associated with the wells identified below, however, no

information regarding the precise locations of spigots sampled was available. The results of the

analyses are presented below, and a tabulated data set is provided in Appendix A.

· Water from a spigot associated with Well C-5A had PFTeA at a concentration of 2.25

nanograms per liter (ng/L)

· Water from a spigot associated with Well C-4A had PFTeA at a concentration of 1.84 ng/L

· Water from a spigot associated with Well C-3A had PFTeA at a concentration of 1.47 ng/L

· Water from a spigot associated with McMillan Airfield had PFTeA at a concentration of 2.41

ng/L

· Water from a spigot associated with the Tactical Unmanned Aerial Systems (TUAS) facility

had PFTeA at a concentration of 1.9 ng/L

The specific chemicals PFOA and PFAS were not detected in any sample.
PFAS Preliminary Assessment Report

Camp Roberts, California

9

The lead regulatory agency for Camp Roberts is the Central Coast Regional Water Quality Control 

Board (CCRWQCB). 

Hydrology

Waters flowing through or collecting on land surfaces within the boundaries of Camp Roberts 

drain through four watersheds including the Kemp Canyon-San Antonio, Portuguese CanyonSalinas River, San Marcos Creek, and the Nacimiento River Watersheds. The Nacimiento River 

watershed occupies the largest portion of surface areas within Camp Robert’s property boundary. 

Surface water features are presented on Figure 1-3.

The major water courses that pass through the cantonment areas of Camp Roberts are the 

Salinas and the Nacimiento Rivers. All surface water draining from Camp Roberts flows to the 

Salinas River or one of its tributaries which include the San Antonio and Nacimiento Rivers and 

San Marcos Creek. Waters in the Salinas River flow through Monterey County to the Monterey 

Bay National Marine Sanctuary in the Pacific Ocean. 

The Nacimiento River drains approximately 70 percent of the land surfaces covering Camp 

Roberts (CSL, 1983). The river flows in a northeastern direction along the north side of the Main 

Garrison’s developed area and joins the Salinas River approximately 2 miles north of the facility’s 

main gate. Surface waters from the Main Garrison, the southern portion of Camp Roberts, and 

McMillan Airfield drains into the Nacimeinto River and its smaller tributaries. The River is 

ephemeral and periodically dries up in the summer months. 

Surface waters originating in the East Garrison drain to the Salinas River and its smaller 

tributaries. The Salinas River is more than 175 miles long and flows from the southeast to the 

northwest in the vicinity of Camp Roberts. The Salinas River is designated by the National Marine 

Fisheries Service as a critical habitat for steelhead.

Several seasonal wetlands that include clay flats and vernal pools supporting a fairy shrimp 

population are situated within Camp Roberts boundaries. There are approximately 64 acres of 

ponds and reservoirs, of which about 35, 24 and 10 acres are classified as wetlands, seasonal 

wetlands and clay flats, respectively (Science Applications International Corporation [SAIC], 

2011). Furthermore, the majority of stream bank areas situated along the Salinas River are 

classified as wetlands.

Climate

Camp Roberts is in a Mediterranean climate zone characterized by warm, dry weather from June 

through September, and mild, rainy weather from November through March. The average annual 

rainfall is approximately 14 inches, with the majority of the rainfall occurring between late fall and 

early spring (ERM, 1995). Summer temperatures average 87 degrees Fahrenheit (°F) to 94oF, 

and the daily high temperature can frequently exceed 110oF. Winter temperatures range from 

57oF during the day to 30o F at night. Snowfall is rare, but frost occurs occasionally.

Current and Future Land Use

Camp Roberts serves as a year-round training site for the CA ARNG. The cantonment area of the 

facility is developed with numerous buildings and related infrastructure including paved and 

unpaved roadways and parking areas. The cantonment area occupies a small percentage of the 

total area controlled by the CA ARNG. The other, much larger lands are occupied by and used as 

training ranges. The ranges are generally in vegetated sloping areas, mostly to the west of the 

cantonment areas. Access to lands under Camp Robert’s purview is restricted and inaccessible 

to the general public in most areas. 
PFAS Preliminary Assessment Report

Camp Roberts, California

10

The mission of Camp Roberts is to provide training, administrative, and logistical site support to

US forces including units from the National Guard and reserve components of the US 60th Army

area (CA ARNG, 2004). Camp Roberts also provides emergency support services for the State

of California in the event of an emergency or disaster. Reasonably anticipated future land use is

not expected to change from the current land use described above.
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

ZN

11/5/2018

11/5/2018

NOTES Preliminary Assessment for PFAS at Camp Roberts, CA

1:253,440

11/5/2018 ­ Figure 1-1 PM RG 11/5/2018

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\CA\Camp_Roberts\Fig_1-1_Camp_Roberts_Site_Location.mxd

12420 Milestone Center Drive

Germantown, MD 20876

Camp Roberts Facility Location

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

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

0 1.5 3 6

Miles

^_

Legend

Facility Boundary

Camp Roberts

11
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Inferred Groundwater

Flow Direction

Geology

Q - Quaternary alluvium

deposits

Qoa - Quaternary older

alluvium deposits

QPc - Pliocenepleistocene sandstone,

shale, and gravel

deposits

P - Pliocene marine

sandstone, siltsone,

shale, and conglomerate

M - Miocene marine

sandstone, shale,

siltsone, and breccia

Ku-Ep - Paleocenecretaceous

unidfferentiated Marine

Sedimentary and

Metasedimentary rocks

grMz - Mesozoic granite,

quartz monzonite,

granodiorite, and quartz

diorite.

Wells

!C( Public Water System

&<

Potable

&<

Non-Potable

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Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

024 1

Miles

12
H

Nacimiento

Reservoir-Nacimiento

River Watershed

Nacimiento River

Watershed

Kemp Canyon-San

Antonio River

Watershed

Portuguese 

Canyon-Salinas 

River Watershed

Hames Creek Watershed

San Marcos Creek Watershed

Bridge

Canyon-Salinas

River Watershed

Lower Big

Sandy Creek

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HuerhueroC r e ek

Nacimiento River

Big

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San Marcos Cr eek

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024 1

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Facility Boundary

Water Body

Wetland

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Surface Water Flow

Direction

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13
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2. Fire Training Areas

Two former FTAs were identified through record reviews during the PA. A description and the 

location of the FTAs are shown on Figure 2-1. PA interview and VSI documents and photographs 

are included in Appendix B and Appendix C, respectively. Per interview with a Staff Sergeant at 

range control, the Range Facility Management Support System database contained no 

information on fire training activities at any of the range areas. The fire department chief and 

captain had knowledge spanning back 4 and 22 years, respectively.

2.1 East Garrison Old Fire Training Area 

The Old FTA is located in the East Garrison cantonment area of Camp Roberts to the east of US 

Route 101, the Salinas River, and the airfield (Figure 2-1). Per a 2003 Site Inspection Report, the 

Old FTA is across the road from the southeast corner of the airfield parking apron (Forsgren 

Associates/Brown and Caldwell, 2003). The approximate geographic coordinates and elevation 

of the general area are 35°48'57.085”N; 120°44'28.714"W, and 636 feet msl, respectively. A 

photograph of the general area of the Old FTA is included in Appendix C. 

Description and Operational History

Various sets of aerial photographic images from 1949 through to 2017 were reviewed for this PA. 

The earliest available photographs show the Old FTA to be occupied by about one dozen 

structures. Sometime between 1971 and 1976, the majority of the structures were removed, with 

only a few concrete building pads visible in a 1976 photograph. In 1994, one rectangular shape 

concrete pad was visible adjacent to O Street, and in 2015, two structures were visible that 

occupied the pad. Subsequent photographs reviewed through to 2017 indicate that land use 

remained generally consistent from 2015 to 2017. 

The Camp Roberts Fire Department (CR FD) reportedly used an area in the East Garrison for fire 

training exercises (CA ARNG, 2004). Based on historical drawings of Camp Roberts, the Old FTA 

was located directly south of Building 27211, at the former foundation of Building 27210 (SAIC, 

2011). The area used was reported to consist of a concrete pad associated with a former mess 

hall that had a small wash rack, where drums of combustibles were ignited (CSL, 1983). Diesel 

fuel and gasoline were reportedly used during the training (ERM, 1995). Additionally, there was a 

Fire and Rescue Station associated with the Old FTA (CA ARNG, 2004) and is discussed in 

Section 3. The demolished Fire Station (Building 27110) was located about 700-800 feet north of 

the Old FTA, as shown in the 2003 Site Inspection Report. The former Fire Station did not have 

floor drains leading to the waste water treatment plant (WWTP).

According to the CR FD and airfield operations staff interviewed for this PA, no interviewees during 

their tenure at Camp Roberts recalled the use of the Old FTA nor did they have knowledge of 

AFFF use in the area. 

During subsequent review of the historic aerial photographs, another area (500 to 600 feet south 

of the Old FTA) in the East Garrison was identified to have features that may be indicative of an 

FTA. In a 1976 photograph, a circular berm feature is seen occupying the area, and in a 1981 

photograph, ground disturbance is visible near the center of the feature. In the same photo, small 

portions of land directly to the north of the area appear black, possibly burned due to fire. In a 

1989 photograph, the circular feature is no longer visible. However, two square shaped berm 

features are visible directly south of Avenue 54. These two features are approximately 50-by-50 

feet in dimension. The features do not appear to be related to two structures that were previously 

removed, as their historic locations do not orient with the locations of the former structures. 

Subsequent photographs reviewed through to 2017 indicate that land use remained generally 
PFAS Preliminary Assessment Report

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consistent from 1989 to 2017. Since 1949, the area has been kept as open space, and no 

structures were visible in the historical aerial photographs.

Previous Investigations

In the late 1990s, the California Department of Toxic Substances Control requested that surface 

soil be sampled at the Old FTA to locate any hot spots of soil contaminated with fuels and solvents 

that may have been used as the combustion source (US Army Center for Health Promotion and 

Preventative Medicine [US CHPPM], 1996). In May 2000, four soil samples were collected from 

two locations near the wash rack associated with the mess hall and analyzed for volatile organics, 

petroleum hydrocarbons, and metals (CA ARNG, 2011). No significant detections in the shallow 

soil sampled were noted.

Surface Water and Groundwater

Surface water and groundwater flow to the west, towards the Salinas River in the East Garrison 

and within the vicinity of the airfield. The river is situated approximately 0.3 miles to the west of O 

Street. The nearest groundwater well is Well Number (No.) B-3, located hydraulically 

downgradient and approximately 1 mile north of the Old FTA, north of the Mobilization and 

Training Equipment Site (MATE) facility and WWTP. Information about the wells at Camp Roberts 

is tabulated and included in Appendix A.

2.2 Main Garrison Fire Training Area 2

The Main Garrison FTA 2 is located in the northwestern portion of the Main Garrison cantonment 

area, on the east side of Utah Avenue and north of the former CR FD Fire Station Building 7020 

(Figure 2-1). The approximate geographic coordinates and elevation of the area is 

35°48'06.16"N; 120°45'07.15"W and 640 feet msl. Photographs of the area are included in 

Appendix C.

Description and Operational History

Aerial photographs from 1949 to 2017 were reviewed for this PA. The earliest available 

photograph shows the FTA 2 occupied by numerous square features that appear to be bivouacs. 

By 1956, the bivouacs were removed, and the area appeared as open grassy fields. A few dirt 

trails converging near the center of the FTA 2 are visible in a 1971 photograph. By 1978, an 

increase in surface disturbance was noted near the center of the area. The area remained 

generally unchanged through 1989, with exception of a building that had been constructed to the 

east of FTA 2. Subsequent photographs reviewed through 2017 indicate that land use remained 

generally consistent from 1989 to 2017. 

Contaminated waste fuels were reported to have been used in fire training operations, and 

reportedly, waste fuels were either directly disposed on the ground surface or burned in 55-gallon 

drums (CA ARNG, 2002). Burns occurred directly on the ground in a bermed area, with a disturbed 

area northwest of Building 7020 approximately 150 by 250 feet in dimension (SAIC, 2011). 

According to CR FD, CA ARNG, and Camp Roberts museum staff interviewed for this PA, no 

interviewees during their tenure at Camp Roberts recalled the use of FTA 2 and had no knowledge 

of AFFF use in the area. No documents reviewed indicate if AFFF was used during fire training 

exercises. The duration of use for fire training purposes is also not known.

Previous Investigations

In September 2002, sixteen boreholes were advanced randomly within a 200-foot grid in FTA 2. 

Shallow soil samples were collected from depths less than 7 feet and analyzed for solvents, 
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petroleum hydrocarbons and metals. Low and non-detect concentrations of constituents analyzed

in soil were reported, with no reported concentrations above action levels used (SAIC, 2011).

Surface Water and Groundwater

Surface water and groundwater flow to the east towards a small drainage ditch which captures 

and carries water towards the northeast and eventually to the Salinas River within the vicinity of 

FTA 2. The river is located approximately 0.5 miles to the east of area. The nearest groundwater 

well to FTA 2 is Well No. C-1. The well is located hydraulically cross-gradient and to the east of 

the area. The well is listed as inactive. Information about the wells at Camp Roberts is tabulated 

and included in Appendix A.

2.3 Prescribed Range Burns and Various Building Burns at East and 

Main Garrisons

Based on interviewee recollection, up to four buildings were burned in the Main Garrison, during 

which structure fire training took place. The buildings reported to have been burned included a 

building at the south end of the parade ground, a couple of barracks buildings, and a building for 

the service club. Water was reportedly used during the structure fire training sessions. The precise 

locations of the various buildings burned are not known.

Various buildings were also historically burned in the East Garrison. The state Division of Forestry, 

in connection with the demolition of the buildings in the East Garrison, obtained permits from the 

state for limited burning (CSL, 1983). The permit was effective from October to December 1980. 

Based on aerial photographs reviewed for this PA, the majority of structures to the west of the 

airfield in the East Garrison were removed between the early 1970s to about 1977. It is not known 

if fire training was involved during demolition of the buildings, and it is not known if AFFF was 

used in the East Garrison areas.
Salinas River

Main Garrison Fire Training Area 2

East Garrison Old Fire Training Area

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12420 Milestone Center Drive

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Fire Training Areas

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

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

0 450 900 1,800

Feet

Legend

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

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3. Non-Fire Training Areas

The following sections describe non-FTA areas where AFFF was stored and potentially released, 

and where other features of interest that may be sources of PFAS were identified during the PA. 

The locations of the non-FTAs are shown on Figure 3-1.

3.1 McMillan Airfield 

McMillan Airfield is located in a high plains area in the southern portion of Camp Roberts, between 

East Perimeter Road and Generals Road. The geographic coordinates and elevation of the 

approximate center of the airfield runway are 35°43'05.86"N and 120°46'06.32"W, and 908 feet 

msl, respectively (Figure 3-1). The airfield and related facilities are accessible only to facility 

operations staff and personnel.

McMillan Airfield was constructed in 1986 by the Air National Guard to serve as a landing strip for 

C-130s. In 1998, the facility was leased by CA ARNG to the US Navy’s Center for Interdisciplinary

Remotely-Piloted Aircraft Studies (CIRPAS), a division of the Naval Postgraduate School (NPS).

The CIRPAS facility is used as a field laboratory for NPS students participating in research and

design opportunities. The facility is also used by TUAS, a division of the CA ARNG. In early 2014,

the TUAS facility opened and is a 10,000-square foot complex where CA ARNG staff can perform

launch, recovery, maintenance, and flight operations of TUAS aircraft. McMillan Airfield is used

as a takeoff and landing strip for the TUAS aircraft.

Surface water and groundwater flow to the south/southwest into tributaries of San Marcos Creek, 

which eventually empties to the Salinas River within the vicinity of McMillan Airfield. No 

stormwater drainage infrastructure was observed in the areas visited during the PA at McMillan 

Airfield.

NPS Airfield Shed AFFF Storage

During the PA site visit, AFFF was observed to be stored in a metal shed located on the east end 

of the runway. The geographic coordinates of the shed are 35°42'55.38"N and 120°45'47.61"W 

(Figure 3-1). The shed is used and maintained by the NPS. One 5-gallon bucket of Cold Fire 302 

manufactured by FIREFREEZE Worldwide, Inc. was observed. The product is a Class A:B:D:K 

fire suppressing agent. A material safety data sheet of the product is included in Appendix A. The 

plastic bucket was observed to be stored on the shed’s concrete building slab. According to NPS 

staff interviewed, the bucket was given to the NPS by the manufacturer and has been stored in 

the shed for a long period of time and has never been used.

TUAS Hangar Building 1702 AFFF Storage

The CA ARNG TUAS division operates a hangar, designated as Building 1702, where they 

perform TUAS aircraft maintenance. The geographic coordinates of the hangar are 35°42'56.93"N 

and 120°45'54.64"W (Figure 3-1). During the PA site visit, two Tri-Max 30 crash fire rescue carts 

were observed to be stored in the hangar. Photographs of the carts are included in Appendix C. 

Labels on the carts indicated that they contained either 2 quarts of Class A, 1 gallon of Class B 

3% or 2 gallons of Class B 6% foam. The TUAS staff indicated that the crash carts have never 

been used and further stated that no AFFF has been used at McMillan Airfield based on their 

recollection. Attempts were made via post-site visit follow-up requests to ascertain more 

information about the Tri-Max units, such as: whether the solution was changed out periodically, 

who would use these units in the case of an emergency, and who is responsible for maintaining 

the Tri-Max. No additional information was made available.
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The NPS and TUAS facility is supported by a domestic well and septic sewer system. 

Photographs of the TUAS well head are included in Appendix C. The well was installed in 2012 

to a depth of 400 feet bgs. The well is listed as active and serves individual facilities only, including 

toilets and sinks. The well is not connected to the drinking water system. Water from the well was 

reported to have not been analyzed for PFAS. 

McMillan Airfield Wildfires

Three wildfires have burned at or within the vicinity of McMillan Airfield since it was constructed. 

According to NPS and CR FD staff interviewed during the PA, all fires were extinguished with 

water or Class A extinguishing agents, which do not contain PFAS.

3.2 East Garrison Camp Roberts Army Airfield

The Camp Roberts Army Airfield is located in the East Garrison, which is east of the Salinas River 

and US Route 101 and includes a 2,760-foot paved runway. The approximate geographic 

coordinates and elevation of the center of the airfield runway are 35°48'51.44"N; 120°44'36.44"W, 

and 630 feet msl, respectively. The location of the Airfield is shown on Figure 3-1, and 

photographs of the area are presented in Appendix C.

At the time of the PA site visit, operational facilities observed included an airfield operations 

Building (Building 27109) located to the east of the Airfield. The Airfield was constructed sometime 

between 1956 and 1967 based on historical aerial photographs reviewed. Currently, the Airfield 

is only used as a landing field for rotary wing aircraft.

During the PA site visit, four Tri-Max 30 crash fire rescue carts were observed to be stored at the 

Airfield in an area historically used for parking aircraft. Photographs of the carts are included in 

Appendix C. Labels on the carts indicated that they contained either 2 quarts of Class A, 1 gallon 

of Class B 3% or 2 gallons of Class B 6% foam. Two of the carts were observed to be without 

compressed air tanks and cannot be used to dispense AFFF. The Airfield operations control staff 

that were interviewed indicated that the crash carts were charged but never used, and no AFFF 

has been used at or within the vicinity of the Airfield. If service was needed, it was provided by an 

off-site vendor.

On the west side of the Airfield, little is known regarding Buildings 27011, 27013, and 27015 

except that they were wash racks and fuel storage. They are demolished, with only concrete slabs 

remaining. None of the buildings had drains connected to the WWTP.

Surface water and groundwater flow to the west, towards the Salinas River in the East Garrison. 

No stormwater drainage infrastructure was observed in the areas visited during the PA within the 

vicinity of the Airfield.

3.3 East Garrison Old Fire Station

A Fire and Rescue Station was associated with the Old FTA (CA ARNG, 2004). The demolished 

Fire Station (Building 27110) was located about 700-800 feet north of the Old FTA, as shown in 

the 2003 Site Inspection Report. This Fire Station did not have floor drains leading to the WWTP. 

According to the CR FD and Airfield operations staff interviewed for this PA, no interviewees 

during their tenure at Camp Roberts recalled any details regarding the use of the Old Fire Station 

located in the East Garrison; therefore, it is not known if AFFF was used or stored at this location 

(35°49'3.959"N; 120°44'31.157"W).
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3.4 Camp Roberts Parade Field Fueling Point Area

The Camp Roberts Parade Field, which is also used as a landing field for rotary wing aircraft, is 

situated in the central portion of the Main Garrison cantonment area. The approximate geographic 

coordinates and elevation of the center of the field are 35°47'28.68"N; 120°44'27.18"W, and 634 

feet msl, respectively. The location of the airfield is shown on Figure 3-1, and photographs of the 

area are presented in Appendix C. 

During the PA site visit, one Tri-Max 30 crash fire rescue cart was observed in the southern end 

of the field within a fuel point area. Photographs of the cart are included in Appendix C. Labels 

on the carts indicated that they contained either 2 quarts of Class A, 1 gallon of Class B 3% or 2 

gallons of Class B 6% foam. Based on interviewee recollection, the cart has not been used, tested, 

or maintained. Any service needed would have been provided by an off-site vendor. 

Surface water and groundwater flow to the east/northeast, towards the Salinas River in the area 

of the fueling port. No stormwater drainage infrastructure was observed in the area where the 

crash cart is stored during the PA .

3.5 Camp Roberts Fire Departments

The CR FD has historically operated out of several buildings at Camp Roberts since the early 

1940s. 

Fire Station Building 7020

In the Main Garrison, the former CR FD Fire Station was Building 7020 (35°48'3.979"N; 

120°45'4.894"W), adjacent to FTA 2 (Figure 3-1). Little information was available to indicate 

whether AFFF was used or stored here. Building 7020 was boarded up and not entered during 

the PA site visit. This building does not have floor drains leading to the WWTP.

Camp Roberts Fire Department Fire Station and Shipping Container

Currently, the CR FD uses Building 4050 as their Fire Station and Building 3000 as a warehouse 

structure used mostly for storage purposes. The location of the two buildings is shown on Figure 

3-1, and photographs of the two areas are presented in Appendix C.

The Fire Station building is located mid-way along the southwest facing boundary of the Parade 

Field on Arizona Boulevard between Avenue 11 and Avenue 12. The approximate geographic 

coordinates are 35°48'51.44"N; 120°44'36.44"W. The Building 3000 Warehouse is located in the 

southeast corner of the Parade Field, near the intersection of Montana Boulevard and Wyoming 

Avenue. The approximate geographic coordinates of the warehouse are 35°47'20.45"N; 

120°44'05.39"W.

The CR FD is a federal facility that is state managed. The CR FD moved into Building 4050 in 

2001, however, the building itself was constructed sometime around 1980. The CR FD responds 

to most fire and medical incidents occurring at Camp Roberts. The San Miguel Fire Department 

serves as first alarm for structure-related fires on Camp Roberts. According to the CR FD staff 

interviewed, the majority of responses involve wildland fire suppression, with occasional response 

to vehicle accidents on US Route 101. 

Two fire engines, two Humvee Brush Fire trucks, and one tactical firefighting truck (TFFT) were 

observed at the CR FD station building during the PA site visit. According to CR FD staff, the fire 

engines and brush trucks carry only Class A fire extinguishing agents. The TFFT is equipped to 

carry up to 2,500 gallons of a mixture of water and foam, of which 65 gallons constitute Class B 

AFFF.
PFAS Preliminary Assessment Report

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A steel storage container located adjacent to Building 4050 is used for storing and servicing TriMax 30 crash fire rescue carts and for storing AFFF. The geographic coordinates of the storage 

container are 35°47'28.97"N, 120°44'36.19"W (Figure 3-1).

During the PA site visit a total of 20 Tri-Max 30 crash fire rescue carts were observed to be stored 

in or just outside of the container. According to CR FD staff interviewed, none of the carts are 

used, as they are designated as out-of-service due to various issues. Additionally, numerous 5-

gallon plastic containers of various brands of AFFF were observed to be stored in the container. 

The inventory of AFFF stored included: 12 containers of Phos-Chek WD881 Class-A Foam 

Concentrate, one container of FireAde 2000 3% AFFF Liquid Foam Concentrate, five containers 

of Eco-Foam 3% AFFF, and one container of US First Strike 3% AFFF Liquid Foam Concentrate. 

Material safety data sheets of the various AFFF products are included in Appendix A. 

According to CR FD staff interviewed (whose tenure covers the last 22 years), the crash carts 

were historically filled with AFFF in an area outside the door of the container. Staff that were 

interviewed indicated that incidental leaks and spills may have occurred, however, details specific 

to the filling of carts were not recalled. 

The area was observed to be gravel covered and relatively flat, with no discernable surface water 

flow direction. Groundwater beneath the area flows towards the east/northeast. No stormwater 

drainage infrastructure was observed in the immediate vicinity of the shipping container.

Camp Roberts Fire Department Building 3000

Building 3000 is used by the CR FD mostly for storing training equipment and supplies. During 

the PA site visit, 19 5-gallon plastic containers of various brands of AFFF were observed to be 

stored on shelves in the eastern corner of the building. The inventory of AFFF stored included 15 

containers of Ansulite 6% AFFF and 4 containers of Chemguard 6% AFFF. Material safety data 

sheets of the AFFF products stored in the building are included in Appendix A. The approximate 

geographic coordinates of the approximate center of the area are 35°46'13.06"N; 120°44'02.49"W 

(Figure 3-1).

According to CR FD staff interviewed, the AFFF stored is purchased through Services Supply and 

has not been used since the early 2000s. Staff that were interviewed could not recall if there were 

any incidental spills or leaks of AFFF in the building. 

Much of the area around Building 3000 is not paved, and a drainage ditch originates near the 

building’s north corner. This ditch flows north and would ultimately discharge into the Salinas 

River.

The floor of the warehouse is concrete. No interior drainage infrastructure was observed in the 

concrete floor of the warehouse. Groundwater flows to the east/northeast, towards the Salinas 

River.

3.6 Landfills, Trench Areas, Disposal Pits and Quarry

Several landfills, trench areas, a quarry dump site, and disposal pits were used for the landfilling 

and disposal of industrial, sanitary, and solid wastes at Camp Roberts since the 1940s. Each of 

the disposal areas operated at various times within the facility’s boundaries. Camp Roberts 

currently operates one active landfill. The other disposal areas are listed as closed. The lead 

regulatory agency for landfills at Camp Roberts is the CCRWQCB.

Landfills are not usually a primary source of PFAS, however, materials disposed of in landfills 

containing PFAS may leach the compounds to the environment over time. Such materials may 
PFAS Preliminary Assessment Report

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include residual sludge wastes from WWTP operations, used AFFF storage containers, or 

products associated with waterproofing such as uniforms or boots. 

None of the landfilled areas discussed below were observed during the PA site visit. No 

information obtained during the PA efforts indicates PFAS-containing materials were disposed of 

in the several landfilling areas that operated at the facility; however, the dates during which some 

of the landfilling-related activities were conducted coincide with the years during which AFFF was 

in use at the facility. 

A discussion of the areas used for landfilling purposes is presented in the below sections

North and South Waste Management Unit Landfills

The permitted North and South Waste Management Units at Camp Roberts are located to the 

east of East Perimeter Road, south of the Main Garrison cantonment areas. The approximate 

geographic coordinates of the approximate center of the area are 35°46'13.06"N; 120°44'02.49"W 

(Figure 3-1). The units are comprised of a 14.3-acre permitted solid waste disposal site, 4.4 acres 

of which were a canyon fill area. Sanitary waste generated, which included general domestic 

waste such as foodstuffs, paper, plastic, wood, and cardboard was disposed of in the permitted 

active canyon fill area from 1972 to 2004 (SAIC, 2011).

Trench Areas

A series of closed waste disposal areas are located to the southeast of the Main Garrison 

cantonment area, to the east of the East Perimeter Road off Sanitary Fill Road. The approximate 

geographic coordinates of the approximate center of the area, at a distance of about 1,000 feet 

east of Sanitary Fill Road, are 35°46'13.06"N; 120°44'02.49"W (Figure 3-1).

The canyon fill area was a 9.9-acre permitted inactive area where domestic trash and construction 

debris waste materials were reportedly disposed of in trench fills during a period between 1977 

to 1984 (SAIC, 2011). The disposal areas are not lined and without leachate collection systems. 

Additionally, six inactive trench fills operated to the south of the permitted area during the 1940s 

to 1966 (SAIC, 2011). The volume and nature of the wastes disposed of are unknown. The 

thickness and the permeability of the cover material for the trenches are unknown. 

South Landfill

The South Landfill covers 4 acres and is located in the southern portion of the Main Garrison, in 

between San Miguel Avenue and US Route 101. The approximate geographic coordinates and 

elevation of the landfill are 35°46'38.56"N; 120°43'16.63"W, and 626 feet msl, respectively 

(Figure 3-1). Waste disposal into the landfill is believed to have started in 1941 and ended 

sometime in the 1970s, at which time an intermediate cover was constructed (Star Resources 

Corp [Star], 2017). No additional information is available regarding the wastes disposed of at the 

landfill. The landfill is currently capped and has drainage control, and gas and groundwater 

continue to be monitored on an annual basis.

Surface water and groundwater flow to the northeast, through subdued swales and towards the 

Salinas River within the vicinity of the aforementioned landfill sites. The river is situated 

approximately 1.3 miles from the intersection of East Perimeter Road and Sanitary Fill Road and 

0.3 miles to the northeast of the South Landfill. There are no potable wells hydraulically 

downgradient of the landfill areas, however, numerous monitoring wells associated with the landfill 

sites are in the area. Information about Camp Robert’s water wells is tabulated and included in 

Appendix A.
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Nacimiento Tributary Landfill

The Nacimiento Tributary Landfill (NTL) is located within a north facing stream bank of an

unnamed tributary of the Nacimiento River. The approximate geographic coordinates and 

elevation of the NTL are 35°48'06.85"N; 120°46'07.66"W, and 552 feet msl, respectively (Figure 

3-1).

The NTL was discovered by facility personnel in October 1999, during which buried, burned

material was observed to be exposed in the streambed. The material was reported to contain

burned medical debris, glassware, flatware, and ash. Subsequent to discovery, surface soil

samples were collected at the site and chemically analyzed for petroleum aromatic hydrocarbons

and metals. Lead concentrations were noted in particular to be elevated. In 2002 and 2003,

approximately 1,000 cubic yards of ash and soil were excavated, treated, and disposed of offfacility (SAIC, 2011). Confirmation samples collected subsequent to the excavation of the landfill

indicated that constituents analyzed were below screening values used. The dates of operation 

of the landfill are not known.

The NTL is situated directly adjacent to a tributary of the Nacimiento River. Surface and 

groundwater flow to the north. No active potable wells are located downgradient of the NTL.

Quarry Dump Site

A former quarry east of the Main Garrison and south of Perimeter Road was later used for various

storage and landfilling purposes. The approximate geographic coordinates and elevation of the 

quarry are 35°47'43.15"N; 120°45'59.34"W, and 577 feet msl, respectively (Figure 3-1).

After the quarry was used in the 1940s, the area was repurposed in the mid-1970s for storage

and disposal of building rubble generated during the demolition of a Camp Roberts hospital (SAIC, 

2011). Sanitary wastes were reported to have been disposed of in the quarry. This practice was

stopped, and the waste was reportedly removed from the quarry and relocated to the Camp

Roberts sanitary landfill. Stored materials were reported to have been occasionally burned.

Burned materials included wood debris, household municipal garbage and other building

materials, and tires.

Soil samples were collected in 1990 and analyzed for petroleum hydrocarbons, volatile

compounds, and metals. Concentrations of constituents analyzed were below screening levels

used.

The former quarry site is situated near a tributary of the Nacimiento River. Surface and 

groundwater flow to the north. Base Well No. C3-A is located to the west and hydraulically crossgradient of the area. The well is listed as active and used as a potable water source for Camp 

Roberts. Base Well No. C-01 is situated to the northeast and hydraulically cross-gradient of the 

quarry. The well is active, however, and more recently, water is contaminated at times with 

coliform, and its use becomes limited. Information about Camp Roberts’ water wells is tabulated 

and included in Appendix A.

Other Camp Roberts Dumping Grounds

In addition to the known landfill areas, several areas at Camp Roberts were used to dump solid

waste. These areas are located throughout training areas on the Main Garrison and south of

MATES at the former Army Airfield on the East Garrison.

Observed debris at these locations includes appliances, scrap wood, and metal debris. A larger

solid waste dumpsite is located approximately 1,800 feet south of Nacimiento Road and 4,000

feet east-northeast of Range Control (SAIC, 2011). The dumpsite is located behind a former range
PFAS Preliminary Assessment Report

Camp Roberts, California

25

berm and covers approximately 1 and 2 acres. Materials dumped at this location include wooden

utility poles, scrap metal, and miscellaneous paper and wood debris. The current disposition of

these areas is not known, and they were not observed during the PA site visit.

Prescribed Burns

Camp Roberts has a history of prescribed burns for wildfire containment purposes and for building 

removal. Local fire departments including San Miguel, Bradley, and Paso Robles perform annual 

controlled burns, mostly in the range areas of Camp Roberts. According to CR FD staff 

interviewed and during their tenure, AFFF was not used for wildland fire or prescribed burn 

operations.

3.7 Wastewater Treatment Plant

Camp Roberts operates a WWTP consisting of two components which are located adjacent to 

the Salinas River and on the east side of US Route 101. The geographic coordinates of settling 

ponds located in the northern portion of the East Garrison cantonment area are 35°47'48.93"N, 

120°44'4.17"W. The coordinates of clarifiers located southeast of the main entrance to Camp 

Roberts are 35°47'49.22"N, 120°44'03.95"W (Figure 3-1). 

Constructed in 1941, the WWTP provides secondary treatment for industrial and sanitary

wastewaters generated by Camp Roberts’ operations. The WWTP’s discharge is to groundwater

through percolation ponds, the activity of which is permitted through the CCRWQCB.

Buildings located outside the Cantonment Area use septic systems and leaching fields for 

wastewater disposal. Septic systems are currently located throughout various areas at Camp 

Roberts including the shooting ranges, the TUAS and CIRPAS facilities, and along Nacimiento 

and East Perimeter Roads.

No storm drains on the site are plumbed to the WWTP, as all storm drains flow to the Salinas 

River. 
PFAS Preliminary Assessment Report

Camp Roberts, California

26

THIS PAGE IS INTENTIONALLY BLANK
NPS Airfield Shed

AFFF Storage

TUAS Hangar Building

1702 AFFF Storage

Camp Roberts Fire Dept Fire

Station & Shipping Container

East Garrison

Old Fire Station

Fire Station-Building 7020

Quarry Dump Site

Nacimiento

Tributary Landfill

Camp Roberts Fire

Department Building 3000

Camp Roberts Parade

Field Fueling Point Area

East Garrison Camp

Roberts Army Airfield

South

Landfill

North and South Waste

Management Unit Landfills

Trench Areas

Wastewater

Treatment Plant

Wastewater Treatment Plant

Salinas River

Nacimien t oRiver

Big Sandy Creek

North

South

0 150 300 600

Feet

0 1,500 3,000 6,000

Feet

North South

­ Figure 3-1

CLIENT

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PROJECT

ARNG

Preliminary Assessment for PFAS at Camp Roberts, CA

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2/21/2019

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MS

GR

RG

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, DeLorme, USGS, Intermap, increment P Corp.,

NRCAN, Esri Japan, METI, Esri China (Hong Kong), Esri (Thailand), MapmyIndia, ©

2/21/2019

1:3,600

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Non Fire Training Areas

12420 Milestone Center Drive

Germantown, MD 20876

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

27
PFAS Preliminary Assessment Report

Camp Roberts, California

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PFAS Preliminary Assessment Report

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29

4. Emergency Response Areas

TUAS aircraft were reported to have crashed on two occasions at or within the vicinity of McMillan

Airfield. The location of one of the crash sites is shown on Figure 4-1. The approximate

geographic coordinates of the one crash site are 40°26'53.9"N, 76°32'42.2"W. The location of the

second crash is not known.

4.1 TUAS Aircraft Crash Sites

In the late 1990s or early 2000s, a TUAS aircraft crashed near the end of the McMillan Airfield

runway. TUAS aircraft at McMillan airfield are operated by the TUAS division of the CA ARNG.

During the crash, the lithium ion battery was damaged and caused a fire that spread to about

three acres in size. According to the NPS and CR FD staff interviewed, the fire was extinguished

with water by the CR FD.

A second crash incident occurred that also involved a TUAS aircraft. The aircraft was reported to

have crashed in a high ridge area near Camp Roberts. Other information related to the crash was

not recalled by those interviewed.
TUAS Aircraft Crash Site

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12420 Milestone Center Drive

Germantown, MD 20876

Emergency Response Area

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

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

0 150 300 600

Feet

Legend

No Suspected Release

Facility Boundary

Wetland

River/Stream

30
PFAS Preliminary Assessment Report

Camp Roberts, California

31

5. Adjacent Sources

The USEPA collects occurrence data for potential contaminants that may be present in drinking

water, but do not have enforceable drinking water standards under its Unregulated Contaminant

Monitoring program. For this PA, the Third Unregulated Contaminant Monitoring Rule 3 (UCMR3)

data for water purveyors within a 10-mile radius of Camp Roberts was searched for PFAS-specific

data. Appendix A includes the UCMR3 2013 tabulated data set.

According to the UCMR3 2013-2015 occurrence data database search (USEPA, 2017), the

Atascadero Mutual Water Company detected PFOA at one of their treatment buildings on 30

October 2013. The detection of PFOA was above the laboratory’s 0.02 nanogram per liter (ng/L)

method reporting limit at a concentration of 0.028 ng/L. The exact location of where the water was

sampled is not known. The southern-most developed portion of the City of Atascadero is located

southeast of Camp Roberts and hydraulically upgradient of Camp Roberts. The City of Atascadero

is situated adjacent to the Salinas River, upstream of Camp Roberts.

5.1 Vehicle Incidents on US Route 101

According to the CR FD staff interviewed, less than six responses to vehicle incidents on US

Route 101 were reported during their tenures. The incidents were reported to have occurred

several miles away from Camp Roberts. Fewer than 5 gallons of AFFF were used during the

incidents to extinguish vehicle/tractor trailer fires. The precise quantity, exact locations, and final

disposition of AFFF used were not recalled by CR FD staff interviewed.

No other off-site PFAS sources adjacent to Camp Roberts were identified during the PA.
PFAS Preliminary Assessment Report

Camp Roberts, California

32
PFAS Preliminary Assessment Report

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33

6. Conceptual Site Model

Based on the PA findings, there were three areas where fire training occurred and four areas

where AFFF may have been incidentally spilled or leaked to the ground surface. As such, these

AOIs may be potential PFAS source areas. The AOIs and CSM for the AOIs are shown on Figure

6-1 and Figure 6-2, respectively, and summarized below.

Although the use of AFFF could not be confirmed, the following AOIs were identified that could be

PFAS source areas include:

· AOI 1 - East Garrison Old Fire Station

· AOI 2 - East Garrison Old Fire Training Area

· AOI 3 - Main Garrison Fire Training Area 2 and Building 7020

· AOI 4 - Camp Roberts Fire Department Fire Station and Shipping Container,

Vehicle incidents on US Route 101 were reported to have been responded to by the CR FD.

Fewer than 5 gallons of AFFF were expelled during each incident. The various response locations

are not known.

The following sections describe the CSM components and the specific CSMs developed for each

AOI. The CSM identifies 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.

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

is not considered to be a potential exposure pathway, as studies have shown very limited

absorption of PFAS through the skin (National Ground Water Association, 2018). Receptors for

Camp Roberts include site workers, construction workers residents, recreational users, and

trespassers. Groundwater is too deep in the region for direct exposure however it is used as water

supply. The CSMs for each AOI indicate which specific receptors could potentially be exposed to

PFAS.

6.1 AOI 1: East Garrison Old Fire Station and AOI 2 East Garrison

Old Fire Training Area

AOI 1 is the East Garrison Old Fire Station near Camp Roberts Army Airfield, and to its south is

AOI 2, the East Garrison Old Fire Training Area. Although the use of AFFF could not be confirmed,

more substantial fire training activities occurred as early as 1976, and the AOIs could be a

potential PFAS source. The timeframe during which the training activities occurred is

commensurate with the use of AFFF for fire training purposes.

AOI 1 and AOI 2 lie within the Salinas River watershed, and all surface water is drained by

tributaries to the Salinas River. PFAS are water soluble and can migrate readily from soil to

groundwater or surface water via leaching and run-off. If PFAS releases to surface and subsurface

soil occurred, it is possible that PFAS migrated from surface soil at AOI 1 and AOI 2 to

groundwater and waters in the Salinas River. Drinking water is supplied by potable wells in the

Main Garrison, and two active potable water wells are located downgradient of the East Garrison.

In addition, precipitation infiltrating into the gravelly covered areas at the AOIs may cause the

migration of PFAS from surface and subsurface soil to groundwater and surface water.

Ground-disturbing activities to soil at AOI 1 or AOI 2 could result in site and construction worker

exposure to potential PFAS contamination via inhalation of dust or ingestion of surface soil.

Ground-disturbing activities to subsurface soil could result in site and construction worker
PFAS Preliminary Assessment Report

Camp Roberts, California

34

exposure via ingestion of subsurface soil. Therefore, the inhalation and ingestion pathways for

these receptors are considered potentially complete. Based on an assumed northwestern

groundwater flow direction, the AOIs are upgradient of potable wells. Because the drinking water

supply wells may be impacted by potential PFAS releases at the AOIs, the exposure pathway for

groundwater to all receptors is potentially complete. Site workers, construction workers, and

trespassers at the facility may be exposed to PFAS via ingestion of surface water and sediment

in the Salinas River and its tributaries. Similarly, farmers, residents, and recreational users may

be exposed to PFAS in surface water and sediment off-facility. The CSM for AOI 1 and AOI 2 is

shown on Figure 6-2.

6.2 AOI 3 Main Garrison Fire Training Area 2 and Building 7020

AOI 3 is the Main Garrison FTA 2 area, including the former CR FD Fire Station Building 7020.

Although the use of AFFF could not be confirmed, more substantial fire training activities occurred

prior to 2001 and as such, the area could be a potential PFAS source.

Surface water at AOI 3 flows to the southeast, towards a small drainage ditch which captures and

carries water towards the Salinas River. The river is located approximately 0.5 miles to the east

of AOI 3. If PFAS were released to surface soil at AOI 3, they had potential to migrate from surface

soil to surface water via run-off and to groundwater via leaching. The nearest groundwater wells

to AOI 3 are to the west of the AOI. With groundwater flow to the northwest, the supply wells are

potentially downgradient of the AOI. The pathways and receptors for AOI 3 are the same as

described in Section 6.1. The CSM for AOI 3 is shown on Figure 6-2.

6.3 AOI 4 Camp Roberts Fire Department Fire Station and Shipping

Container

A steel storage container located adjacent to the CR FD Building 4050 is used for storing and

servicing Tri-Max 30 crash fire rescue carts and for storing AFFF. According to CR FD staff

interviewed, the crash carts were historically filled with AFFF in an area outside the door of the

container. Staff that were interviewed indicated that incidental leaks and spills may have occurred,

however, details specific to the filling of carts were not recalled. The area was observed to be

gravel covered.

Incidental spills of AFFF could migrate through gravel covered areas into surface soil and

subsurface soil to groundwater via leaching. Nearby tributaries may have been impacted by

surface water run-off from AOI 4. Surface and groundwater flow is to the north/northeast, towards

the Salinas River. The pathways and receptors for AOI 4 are the same as described in Section

6.1. The CSM for AOI 4 is shown on Figure 6-2.
Media

SOURCE PATHWAY RECEPTOR

AOI 1

AOI 2

AOI 3

AOI 4

Fire Training

Activities,

Incidental Spills

PFAS in

Surface Soil

and

Concrete

Human

Activities

Precipitation/

Run-Off

Leaching/

Infiltration

Airborne Soil

Particulate

Surface Soil

at AOI

Surface

Water/

Sediment

Subsurface

Soil

Shallow

Groundwater

Source Release

Mechanism Media Transportand Migration Media ExposureRoutes

Inhalation of

Dust

Ingestion

Ingestion

Ingestion

Ingestion

Human Receptors:

Current/ Future

Flow-Chart Continues

Partial / Possible Flow

Flow-Chart Stops

Incomplete Pathway

Potentially Complete Pathway

Complete Pathway

Site

Worker

Construction

Worker Resident Trespasser/Recreational User

Site

Worker

Construction

Worker Resident Trespasser/

Recreational User

LEGEND

/ / /

/ / /

Figure 6-2

Conceptual Site Model

Camp Roberts AOIs

Potential

Off-Facility

Source Not

under

Control of

ARNG

/ /

/ / /

/ /

/ / / /

/

/

/

35
&<

&<

&<

&<

!C( &<

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

!C(

Main Garrison 

Fire Training Area 2 

& Building 7020

Camp Roberts Fire Department 

Fire Station & Shipping Container

East Garrison Old Fire Station

East Garrison Old Fire Training Area

San Antonio River

Nacimie n to River

Salinas River

AOI 4

AOI 3

AOI 1

AOI 2

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1:48,000

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12420 Milestone Center Drive

Germantown, MD 20876

Areas of Interest

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

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

0 2,000 4,000 8,000

Feet

Legend

Area of Interest

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

Wells

!C( Public Water System

&<

Potable

&<

Non-Potable

36
PFAS Preliminary Assessment Report

Camp Roberts, California

37

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 Camp Roberts. The PA findings are based

on the information presented in Appendix A and Appendix B.

7.1 Findings

Four AOIs related to potential PFAS release were identified (Table 7-1) at Camp Roberts during

the PA (Figure 7-1).

Table 7-1: AOIs at Camp Roberts

Area of Interest Name Used by Release Dates

AOI 1 East Garrison Old

Fire Station

Division of Forestry and CA

ARNG Camp Roberts Fire

Department

Potentially as

early as 1976

AOI 2 East Garrison Old

Fire Training Area

Division of Forestry and CA

ARNG Camp Roberts Fire

Department

Potentially as

early as 1976

AOI 3

Main Garrison Fire

Training Area 2 and

Building 7020

CA ARNG Camp Roberts

Fire Department Prior to 2001

AOI 4

Camp Roberts Fire

Department Fire

Station and

Shipping Container

CA ARNG Camp Roberts

Fire Department Unknown

Based on information obtained during the PA at these AOIs, there is potential for exposure to

PFAS contamination in surface soil and intermittent surface water and sediments to site workers,

construction workers, residents, recreational users, and trespassers via ingestion and inhalation;

subsurface soil to site and construction workers via inhalation; and groundwater to all receptors

via ingestion.

Water analyzed for PFAS from spigots that are associated with potable wells at various locations

had PFTeA detections. These included:

· Water from a spigot associated with Well C-5A had PFTeA at a concentration of 2.25 ng/L

· Water from a spigot associated with Well C-4A had PFTeA at a concentration of 1.84 ng/L

· Water from a spigot associated with Well C-3A had PFTeA at a concentration of 1.47 ng/L

· Water from a spigot associated with McMillan Airfield had PFTeA at a concentration of 2.41

ng/L

· Water from a spigot associated with the TUAS facility had PFTeA at a concentration of 1.9

ng/L.
PFAS Preliminary Assessment Report

Camp Roberts, California

38

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

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

Table 7-2: No Suspected Release Areas at Camp Roberts

No Suspected

Release Area Used by

Rationale for No Suspected Release

Determination

Prescribed Range

Burns and Various

Building Burns at East

and Main Garrisons

Division of Forestry

and Camp Roberts

Fire Department

Fire training activities were reported to have

occurred within the East and Main Garrisons. It was

reported that only water was used during more

recent structural fire training activities. Various other

fires and burns occurred at the facility although

detailed information was not available.

NPS Airfield Shed AFFF

Storage CIRPAS/NPS

One 5-gallon bucket of Cold Fire 302 was stored in

the airfield shed. The bucket was full and reported to

have not been used.

TUAS Hangar Building

1702 AFFF Storage CA ARNG

Two Tri-Max 30 crash fire rescue carts containing

AFFF were observed in the hangar. Interviewees

reported that the carts were never used.

McMillan Airfield

Wildfires CA ARNG

Wildfires have burned at or within the vicinity of the

airfield. According to those interviewed, fires were

fought with water or Class A extinguishing agents,

which do not contain PFAS.

East Garrison Camp

Roberts Army Airfield CA ARNG

Four Tri-Max 30 crash fire rescue carts containing

AFFF were observed at the airfield. Interviewees

reported that the carts were never used.

Camp Roberts Parade

Field CA ARNG

One Tri-Max 30 crash fire rescue cart containing

AFFF was observed at the south end of the parade

field, at the fueling port. Interviewees reported that

the cart was never used.

Camp Roberts Fire

Department Building

3000 Warehouse

CA ARNG

Numerous 5-gallon buckets of AFFF were stored in

the warehouse. Interviewees could not recollect

whether the buckets have been used or whether

there had been spills or leaks from the buckets.

Landfills, Trench Areas,

Disposal Pits and

Quarry

CA ARNG

None of the landfills, trench areas, disposal pits,

quarry, and/or dumping grounds had reported

materials disposed containing PFAS. Most operated

during a time inconsistent with AFFF use.

Wastewater Treatment

Plant CA ARNG

No known storm drains were identified in the areas

of the facility visited during the PA. As such, PFAS

was likely not introduced to the WWTP

Tactical Unmanned

Aerial Systems Aircraft

Crash Sites

CA ARNG

Two crashes involving TUAS aircraft occurred.

According to those interviewed, fires were fought

with water or Class A extinguishing agents, which do

not contain PFAS
PFAS Preliminary Assessment Report

Camp Roberts, California

39

7.2 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.

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 or conflicted with other sources. 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.

The following Table 7-3 summarizes the uncertainties associated with the PA.

Table 7-3: Uncertainties

Area of Interest Source of Uncertainty

East Garrison Old Fire

Training Area

It is not known if AFFF was used for fire training purposes.

East Garrison It is not known if fire training was involved during building

demolition and if so, whether AFFF was used.

Main Garrison Fire Training

Area 2 in Vicinity of Building

7020

It is not known if AFFF was used for fire training purposes.

Camp Roberts Fire

Department Fire Station

Shipping Container

The area outside of the steel container was reportedly used

for the filling and servicing of firefighting equipment (TriMax

units). The amount and type of AFFF released during

servicing, if any, is not known.

General Some facility operations are not well defined given the

limitation of interviewee knowledge. FD operations were

better understood as the recently retired Fire Captain had

been at Camp Roberts for 22 years and the current Chief

has been at the facility for 4 years.

7.3 Potential Future Actions

Based on the documented absence (1997-present) of the use or release of PFAS-containing

materials at the areas listed in Table 7-2, evidence does not indicate that current or former ARNG
PFAS Preliminary Assessment Report

Camp Roberts, California

40

activities contributed PFAS contamination to soil, groundwater, surface water, or sediment in

these locations, and they will not move forward in the CERCLA process.

Interviews and records (covering 1997 to present) indicate that current or former ARNG activities

may have resulted in potential PFAS releases at the four AOIs identified during the PA. Based on

the CSMs developed for the AOIs, there is potential for receptors to be exposed to PFAS

contamination in soil, groundwater, surface water, and sediment at these AOIs. 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 Site Inspection (SI).

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

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

Camp Roberts, California

41

Table 7-4 PA Findings Summary

Area of Interest AOI Location Rationale Potential

Future Action

AOI 1 East

Garrison Old Fire

Station

35°49'3.959"N; 

120°44'31.157"W

Presumptive storage of AFFF; no 

interviewee had direct knowledge

of this area

Proceed to an

SI, focus on

soil,

groundwater,

surface water,

sediment

AOI 2 East

Garrison Old Fire

Training Area

35°48'57.085”N; 

120°44'28.714"W

Presumptive use of AFFF; no 

interviewee had direct knowledge

of this area

Proceed to an

SI, focus on

soil,

groundwater,

surface water,

sediment

AOI 3 Main

Garrison Fire

Training Area 2

and Building 7020

35°48'06.16"N;

120°45'07.15"W Known AFFF use

Proceed to an

SI, focus on

soil,

groundwater,

surface water,

sediment

AOI 4 Camp

Roberts Fire

Department Fire

Station and

Shipping Container

35°47'28.97"N,

120°44'36.19"W Known storage of AFFF

Proceed to an

SI, focus on

soil,

groundwater,

surface water,

sediment
Main Garrison

Fire Training Area 2 

& Building 7020

Camp Roberts Fire Departmemt

Fire Station & Shipping Container

East Garrison Old Fire Station

East Garrison Old Fire Training Area

Quarry Dump Site

Nacimiento Tributary Landfill

Camp Roberts 

Fire Department 

Building 3000

Camp Roberts 

Parade Field 

Fueling Point Area

East Garrison 

Camp Roberts 

Army Airfield

South Landfill

North and South Waste Management Unit Landfills

Trench Areas

Wastewater

Treatment

Plant

TUAS Aircraft Crash Site

NPS Airfield Shed AFFF Storage

TUAS Hangar Building 1702 AFFF Storage

Wastewater

Treatment

Plant

D ipC ree k

SanAntonio R ive r

Nacimiento R iver

San Marcos Cr eek

Hames Cree k

B gi S a ndy Creek

SnakeCreek

Salin as River

Estrella Ri ver

AOI 4

AOI 3

AOI 1

AOI 2

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12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

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

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

0 4,500 9,000 18,000

Feet

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Pipeline

42
PFAS Preliminary Assessment Report

Camp Roberts, California

43

References

American Integrated Services, Inc. 2012. Site Investigation Report for the Former Vehicle Wash

Pads, Former Fire Training Area, and the Former Warehouse Bladder Area Farm, October 31,

2012.

California Department of Water Resources (DWR). 2004. Salinas Valley Groundwater Basin,

Paso Robles Area Subbasin. Central Coast Hydrologic Region, Salinas Valley Groundwater Basin

– California’s Groundwater Bulletin 118.

California Army National Guard (CA ARNG). 2004. FY 2004 Camp Roberts Installation Action

Plan.

CA ARNG. 2002. Installation Plan for Camp Roberts, California. 14 March 2002.

Chemical Systems Laboratory (CSL). 1983. Installation Assessment of Camp Roberts, Calif.,

Report No. 196A.

Environmental Resources Management, Inc. (ERM). 1995. Preliminary Assessment Report for

Camp Roberts, California.

Forsgren Associates/Brown and Caldwell. 2003. Site Inspection Report, Basewide Site Inspection

Camp Roberts, second draft, May 2013.

FPM Group, Ltd. (FPM). 2008. Historical Records Review/Site Inspection Report, Camp Roberts

– Camp Roberts, California.

National Ground Water Association. 2018. Groundwater and PFAS: State of Knowledge and

Practice. January 2018.

Science Applications International Corporation (SAIC). 2011. Environmental Condition of

Property/Environmental Site Assessment – Camp Roberts Training Site, San Miguel, California.

Star Resources Corp (Star). 2017. 2017 Annual Groundwater Monitoring Report – South and

Closed Landfills (CPRO-31 and CPRO-29), California Army National Guard Cap Roberts, SAan

Luis Obispo County, California.

US Army Center for Health Promotion and Preventative Medicine [US CHPPM]. 1996. Site

Inspection No. 38EH-4242-97, Camp Roberts, California.

USEPA. 2017. Website accessed 15 2018 10: https://www.epa.gov/dwucmr/occurrence-dataunregulated-contaminant-monitoring-rule#3

United States Geological Survey (USGS). 1974. Geology of the Southern Salinas Valley Area,

California. Geological Survey Professional Paper 819.

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

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

Camp Roberts, California

44
PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix A

Data Resources

Draft PFAS Preliminary Assessment Report

Camp Roberts, CA

Appendix A - Data Resources provided separately on CD. Data Resources for Camp

Roberts includes:

Camp Roberts Well Information

· Water System Summary for Camp Roberts

· Well Completion Report 0962099

· Well Permit Applications and Well Completion Report e012542

· Well Construction and Testing Report for Well C-5A, Army National Guard, Camp Roberts

California

Previous Investigations Completed at Camp Roberts

· 1983 - Installation Assessment of Camp Roberts, Calif., Report No. 196A.

· 1995. Preliminary Assessment Report for Camp Roberts, California.

· 2004 - FY 2004 Camp Roberts Installation Action Plan.

· 2008 - Historical Records Review/Site Inspection Report, Camp Roberts – Camp Roberts,

California.

· 2017 - 2017 Annual Groundwater Monitoring Report – South and Closed Landfills (CPRO31 and CPRO-29)

· Camp Roberts Stored AFFF Documentation

· 2006 Material Safety Data Sheet Ansul Ansulite 6% AFFF (AFC-3)

· 2006 Material Safety Data Sheet Chemguard 3% AFFF C-303

· 2006 Material Safety Data Sheet Chemguard 6% AFFF C-601MS

· 2008 Material Safety Data Sheet FireAde 2000 - Fire Fighting Agent

· 2015 Material Safety Data Sheet PHOS-CHEK® WD881 Class A Foam Concentrate

· First StrikeTM 3%-6% ATC/AFFF Concentrate (US-FCAR36) Technical Data Sheet

Camp Roberts EDR Report

· 2018 Camp Roberts EDR Reports 5326783, 5326788, 5329246 and 5329261

Laboratory Analytical Data

· 2017 Lab Report: Subcontract Analysis for FGL Lab No. CC 1684318

· Camp Roberts Tabulated PFAS Analytical Data

Real Estate Transactions

· Acquisition of Camp Roberts

· Summary of Outgrants

PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix B

Preliminary Assessment Documentation

PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix B.1

Interview Records









PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix B.2

Visual Site Inspection Checklists

















PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix B.3

Conceptual Site Model Information

Preliminary Assessment – Conceptual Site Model Information

Site Name: Camp Roberts, California

Why has this location been identified as a site?

Previous reports have indicated that fire training areas were used during the period that AFFF was in

use (late 60’s to early 2000’s). The facility has three flightlines.

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

No PFAS sources were identified in the area surrounding Camp Roberts however, vehicle incidents on

US Route 101 were responded to with use of AFFF.

Training Events

Have any training events with AFFF occurred at this site? Possibly as FTA’s were used during the time

period AFFF was available for use

If so, how often? Unknown/not recalled by interviewees (before their tenure)

How much material was used? Is it documented? Unknown. Less than 5-gals used for vehicle crash fire

suppression

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? Yes – topographic and geology maps avail. Groundwater inferred.

Surface Water:

Surface water flow direction? Surface waters drain to the Salinas and Nacimiento Rivers

Average rainfall? 14inches annually on average

Any flooding during rainy season? Yes

Direct or indirect pathway to ditches? Yes

Direct or indirect pathway to larger bodies of water? Yes (two Rivers that drain eventually to Pacific)

Does surface water pond any place on site? Yes

Any impoundment areas or retention ponds? Yes

Any NPDES location points near the site? Treated sewage discharged to groundwater

How does surface water drain on and around the flight line? Various. McMillan Airfield surface water

drains to southeast. East Garrison Airfield surface water drains to west. Parade Field surface water

drains generally to the east.
Preliminary Assessment – Conceptual Site Model Information

Groundwater:

Groundwater flow direction? Regional is to west. Localized is various – in direction of closest

stream/river

Depth to groundwater? Unknown

Uses (agricultural, drinking water, irrigation)? Potable water, latrines

Any groundwater treatment systems? One WWTP – two components (settling/aeration ponds and

clarifiers- pipeline in between)

Any groundwater monitoring well locations near the site? Yes

Is groundwater used for drinking water? Yes (mostly 4 wells used for potable – C-01, C3-A, C-4A, C-5A)

Are there drinking water supply wells on installation? Yes, located in the Main Garrison Area

Do they serve off-post populations? No

Are there off-post drinking water wells downgradient “Municipal”

Waste Water Treatment Plant:

Has the installation ever had a WWTP, past or present? Yes

If so, do we understand the process and which water is/was treated at the plant? Yes – settling/aeration

ponds to clarifiers

Do we understand the fate of sludge waste? Final disposition of sludge waste not known. Treated sewage

water discharged to groundwater

Is surface water from potential contaminated sites treated? Unknown

Equipment Rinse Water

1. Is firefighting equipment washed? Where does the rinse water go? Little to no storm water

infrastructure observed. Oil water separators used at MATES

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? None of above recalled

3. Other?
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors:

Site Worker

Construction Worker

Recreational User

Residential

Child

Ecological

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

Open fields to north, east and west. Commercial buildings/activities to south.

Documentation

Ask for Engineering drawings (if applicable).

Has there been a reconstruction or changes to the drainage system? When did that occur? None recalled
PFAS Preliminary Assessment Report

Camp Roberts, California

Appendix C

Photographic Log

Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 1

Description:

View of East Garrison Old

Fire Training Area in

vicinity of Camp Roberts

Army Airfield. View to the

west.

Photograph No. 2

Description:

View of old Fire Station

Building 7020 adjacent to

Main Garrison Fire

Training Area 2. View to

the northeast.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 3

Description:

View of Main Garrison

Fire Training Area 2 in

vicinity of Building 7020.

View to the northwest

Photograph No. 4

Description:

View of TUAS Hangar

Building 1702 of Tri-Max

30 crash fire rescue carts.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 5

Description:

View of Tri-Max 30 crash

fire rescue cart label. Cart

is stored in TUAS Hangar

Building 1702.

Photograph No. 6

Description:

View of East Garrison

Camp Roberts Army

Airfield Tri-Max 30 crash

fire rescue carts stored

adjacent to rotary wing

landing field. View to the

east.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 7

Description:

View of Tri-Max 30 crash

fire rescue cart stored at a

fueling depot situated at the

south end of the Camp

Roberts Parade Field. View

to the southwest.

Photograph No. 8

Description:

View of Camp Roberts Fire

Department shipping

container used at the fire

station. View to the north.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 9

Description:

View of various AFFF

brands stored in a shipping

container situated to the

west of the Camp Roberts

Fire Department station.

Photograph No. 10

Description:

View of AFFF stored in a

shipping container situated

to the west of the Camp

Roberts Fire Department

station.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 11

Description:

View of Tri-Max 30 crash

fire rescue carts stored in a

shipping container situated

to the west of the Camp

Roberts Fire Department

station.

Photograph No. 12

Description:

View to the west of the

shipping container used by

the Camp Roberts Fire

Department for storage

purposes.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 13

Description:

View of the interior of the

Building 3000 warehouse

used for equipment storage

by the Camp Roberts Fire

Department. AFFF was

observed during the PA to

be stored on the bottom of

the shelf situated in the

right-center portion of

photograph.

Photograph No. 14

Description:

View of various brands of

AFFF stored in the

Building 3000 warehouse

used by the Camp Roberts

Fire Department.
Preliminary Assessment Report

Camp Roberts

Perfluorooctane-Sulfonic Acid (PFOS) and

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

AECOM

APPENDIX C – Photographic Log

Army National Guard, Preliminary

Assessment for PFAS Camp Roberts California

Photograph No. 15

Description:

View of the Waste Water

Treatment Plant

settling/aeration ponds

located in the East

Garrison. View to the east.