FINAL

Preliminary Assessment Report

Camp Ethan Allen Training Site

Jericho, Vermont

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

April 2019 

Prepared for:

Army National Guard Headquarters 

111 S. George Mason Drive

Arlington, VA 22204

U.S. Army Corps of Engineers, Baltimore District

2 Hopkins Plaza

Baltimore, MD 21201

Prepared by:

AECOM

12420 Milestone Center Drive, Suite 150

Germantown, MD 20876

aecom.com

Contract Number: W912DR-12-D-0014

Delivery Order: W912DR17F0192
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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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

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

1.5.2 Hydrogeology................................................................................................. 8

1.5.3 Hydrology.....................................................................................................10

1.5.4 Climate.........................................................................................................11

1.5.5 Current and Future Land Use.......................................................................11

2. Fire Training Areas...........................................................................................................16

3. Non-Fire Training Areas ...................................................................................................17

3.1 Waxing Areas..........................................................................................................17

3.2 Snowmaking Pond..................................................................................................17

3.3 Biathlon Course ......................................................................................................18

3.3.1 Off-Site Snow...............................................................................................18

4. Emergency Response Areas............................................................................................20

4.1 Skidder Tire Fire .....................................................................................................20

5. Adjacent Sources.............................................................................................................22

5.1 Underhill Jericho Fire Department...........................................................................22

5.2 Underhill Jericho Fire Department FTA ...................................................................22

5.3 Car Accident ...........................................................................................................22

6. Conceptual Site Model.....................................................................................................24

6.1 AOI 1: Biathlon Facility............................................................................................24

7. Conclusions .....................................................................................................................27

7.1 Findings..................................................................................................................27

7.2 Uncertainty .............................................................................................................27

7.3 Potential Future Actions ..........................................................................................28

8. References ......................................................................................................................31
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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Tables

Table 1-1 Potable Wells Sampled in March 2017

Table 1-2 Well # 40293 (Walker Building Well) Quarterly Sampling Results

Table 7-1 AOIs at Ethan Allen TS

Table 7-2 Uncertainties

Table 7-3 PA Findings Summary

Figures

Figure ES- 1 Summary of Findings

Figure ES- 2 Conceptual Site Model, Ethan Allen Training Site, VT

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 4-1 Emergency Response Areas

Figure 5-1 Adjacent Sources

Figure 6-1 Areas of Interest

Figure 6-2 Conceptual Site Model, AOI 1 – Biathlon Facility

Figure 7-1 Summary of Findings30

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 Ethan Allen Training Site, Vermont

iii

Acronyms and Abbreviations

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

amsl above mean sea level

AOI area of interest

ARNG Army National Guard

bgs below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

Act

CFR Code of Federal Regulations

CSM conceptual site model

FTA fire training area

HA Health Advisories

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

ppt parts per trillion

SI Site Inspection

TFT Task Force Tips®

TS Training Site

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

VSI visual site inspection

VTARNG Vermont Army National Guard
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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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Executive Summary

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

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

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

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

Impacted Sites at ARNG Facilities Nationwide. The ARNG is assessing potential effects on 

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

(PFAS) (a suite of related chemicals), primarily in the form of aqueous film forming foam (AFFF)

released during firefighting activities or training, although other PFAS sources are possible. 

AECOM completed a PA for PFAS at the Vermont Army National Guard (VTARNG) Camp Ethan 

Allen Training Site (Ethan Allen TS) in Jericho, Vermont, to assess potential PFAS release areas 

and exposure pathways to receptors. The Ethan Allen TS is an 11,000 acre facility operated by 

the VTARNG since 1976 that hosts a variety of training activities and facilities. The Army 

Mountain Warfare School and Armory is located within the facility and training activities include 

helicopter training. General Dynamics Armament Systems, Inc. occupies 766 acres within the 

11,000 acre Ethan Allen TS for weapons systems development and testing. In addition, the 

facility hosts a 5-kilometer biathlon course, and associated facilities, and is considered one of 

the premier cross-country ski and biathlon facilities in North America. 

The performance of this PA included the following tasks: 

• Reviewed data resources to obtain information relevant to suspected PFAS releases

• Conducted a 1-day PA site visit on 17 May 2018

• Interviewed current Ethan Allen TS and VTARNG personnel during the PA site visit 

including biathlon staff and environmental manager

• Interviewed current Jericho Fire Department Duty Captain and staff

• Completed visual site inspections at known or suspected PFAS release locations and 

documented with photographs 

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

summarize potential PFAS Source-Pathway-Receptor linkages for each AOI

One AOI related to potential PFAS releases was identified at Ethan Allen TS during the PA. High 

grade commercial ski and snowboard waxes have been found to contain high concentrations of 

PFAS (Kotthoff et al., 2015). Surface water and snowmelt have been shown to have 

measureable PFAS impacts downgradient of ski areas (Kwok et. al., 2013). Interviewees noted 

that high grade waxes are almost exclusively used for competition and that lower grade waxes 

(reportedly not PFAS containing) are used the majority of the time at Ethan Allen TS. The AOI 

identified during the PA is associated with the biathlon course at Ethan Allen TS. The AOI is

shown on Figure ES-1 and described in the table below. The CSM for the entirety of the Ethan 

Allen TS is presented in Figure ES-2. 

Area of Interest Name Used by Potential Release Dates

AOI 1 Biathlon Facility VTARNG and 

public

Approximately 1972 to 

present

The Underhill Jericho Fire Department occasionally uses AFFF to respond to fires within the 

area. Interviewees recalled approximately 1-gallon of AFFF being used on a car fire located off-
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

2 

facility at the intersection of Lee River Road and State Route 15, hydraulically downgradient of 

the Ethan Allen TS.

Based on the PA findings, there is potential for exposure to PFAS contamination in surface soil, 

to site workers, construction workers, recreational users, and trespassers via ingestion and 

inhalation; groundwater, surface water and sediment to site workers, construction workers,

recreational users, trespassers, and off-facility residents via ingestion; and subsurface soil to 

site and construction workers via ingestion. 
Walker Building

Snowmaking Pond

Waxing Sheds

Biathlon Course

Skidder Tire Fire

Car Accident

Underhill Jericho 

Fire Department

Underhill Jericho 

Fire Department FTA

Lee River

AOI 1

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Summary of Findings

Figure ES-1

CLIENT

REVISED

SCALE

11/26/2018 MS

AZ

11/26/2018

11/26/2018

ARNG

GIS BY

CHK BY

TITLE

PROJECT Preliminary Assessment for PFAS at Ethan Allen Training Site, VT

Q:\Projects\ENV\GEARS\GEO\MAES 2012 Unrestricted\Fort Meade\E. Data Management\GIS\MXDs\Chisholm_6th\March2017\ Fig_ES-1_TS-Ethan_Allen_Summary.mxd

Base Map: National Agricultural Imagery Program, 2016 PM RG 11/26/2018

1:38,401 ­ 12420 Milestone Center Drive

Germantown, MD 20876

0 1,600 3,200 6,400

Feet

3
Media

SOURCE PATHWAY REC

AOI 1

AOI 1: PFAS 

containing ski wax 

and groundwater 

filled snowmaking 

pond

PFAS in 

Surface Soil

PFAS in 

Subsurface 

Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

at AOI

Surface 

Water/ 

sediment

Subsurface 

Soil

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Huma

Curr

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

Site 

Worker

Construct

Worker 

Site 

Worker

Construct

Worke

/ / / / 

LEGEND

/ // / 

Figure ES-2

Conceptual Site 

Ethan Allen Trainin

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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 Site 

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

Impacted Sites at ARNG Facilities Nationwide under Contract Number W912DR-12-D-0014, 

Task Order W912DR17F0192, issued 11 August 2017. The ARNG is assessing potential effects 

on human health related to processes at 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 varies. The regulatory framework at both federal and state levels 

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

Health Advisories (HAs) 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, such as Vermont, have adopted their own drinking 

water advisory levels for PFAS. On 10 July 2018 the Vermont Department of Health issued a 

Drinking Water HA level of 20 parts per trillion (ppt) combined for five PFAS chemicals

(Appendix A). 

This report presents findings of a PA for PFAS at Vermont Army National Guard (VTARNG) 

Camp Ethan Allen Training Site (Ethan Allen TS) in Jericho, Vermont 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 locations where PFAS may have been released to the environment at Ethan 

Allen TS. The term PFAS will be used throughout this report to encompass all PFAS chemicals 

being evaluated, including PFOS and PFOA, which are key components of AFFF.

1.2 Preliminary Assessment Methods

The performance of this PA included the following tasks: 

• Reviewed data resources to obtain information relevant to suspected PFAS releases

• Conducted a 1-day PA site visit on 17 May 2018

• Interviewed current Ethan Allen TS and VTARNG personnel during the PA site visit 

including biathlon staff and environmental manager

• Interviewed current Jericho Fire Department Duty Captain and staff

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

and documented with photographs 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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

summarize potential PFAS Source-Pathway-Receptor linkages 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 fire training areas (FTAs) at the facility 

identified during the site visit

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

at the facility identified during the site visit 

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

the facility, specifically in response to emergency situations 

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

the facility that are not under the control of ARNG 

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

and receptors at the facility 

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

uncertainties of the PA 

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

• Appendix A – Data Resources

• Appendix B – Preliminary Assessment Documentation

• Appendix C – Photographic Log

1.4 Facility Location and Description

The Ethan Allen TS occupies approximately 11,000 acres in eastern Chittenden County, 

Vermont, on the western side of the Green Mountains. The Town of Jericho, Vermont is 

approximately 1.5 miles to the northeast. The southern boundary of the facility runs adjacent to 

Mill Brook, a tributary of the Winooski River. The eastern boundary abuts the drainage divide 

formed by the main ridgeline of the Green Mountains. Mt. Mansfield State Forest is located 

directly east of the facility on the eastern side of the Green Mountains. Land to the north, south, 

and west of the facility consists of privately owned farmland, residences, and undeveloped 

forests (Figure 1-1). 

The majority of the facility’s footprint is undeveloped and forested. Indoor facilities are located 

along the western portion of the Ethan Allen TS, by the main entrance. Approximately 600 acres 

of fields with trails, firing ranges, and other indoor and outdoor facilities occupy central, southcentral, and eastern portions of the Ethan Allen TS. A network of trails and paved and unpaved 

roads is distributed throughout the Ethan Allen TS. Current and former use of the Ethan Allen TS 

(including separately operated portions within the facility boundary) is discussed below.

The Ethan Allen TS is operated by the VTARNG and hosts the Army Mountain Warfare School 

and Infantry Armory, as well as the 86th Infantry Brigade Combat Team. The facility contains the 

Jericho Readiness Center, along with a few offices, barracks, and equipment maintenance 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

7 

buildings, primarily located along Ethan Allen Road in the Lee River valley. The barracks are 

occasionally used to house a few thousand individuals during training exercises throughout the 

year. 

Prior to being established, the area was used for farming and pasture. In 1926, the War 

department established Ethan Allen TS as an artillery range; the area has since been used 

during the 1930s for Reserve Officer Training corps and two Civilian Conservation Corp camps. 

The Ethan Allen TS was expanded in 1941 and used as a bombing range by the Army Air 

Corps. Beginning in 1952, developmental and proof testing of newly manufactured weapons 

systems has been conducted by the General Dynamics Armament Systems, Inc. (formerly the 

Armament Systems Department of General Electric) on 766 acres within the Ethan Allen TS. 

Between 1969 and 1982, depleted uranium ammunition was tested in this area. Affected soils 

and materials were subsequently removed and shipped off-site to licensed disposal facilities 

(Clark, Chalmers, Mack, & Denner, 2005). The Department of the Army granted license to the 

State of Vermont for ARNG use beginning 17 December 1976. Since that time several 

supplemental agreements have been issued to add additional acreage and extend the license 

until 16 December 2027. Leasing agreements are included in Appendix A. Activities at Ethan 

Allen TS include helicopter training. 

In addition, the Ethan Allen TS hosts one of the premier cross-country ski and biathlon courses 

and support structures in North America and features one of three internationally licensed 

biathlon courses in the US (globalsecurity.org, 2011). Vermont became the pinnacle of the US

Military Biathlon Program in 1972; the National Guard Bureau's first biathlon championships

were held at Ethan Allen TS in 1975. Since then, the Ethan Allen TS has been used for both 

military and civilian biathlon training and held national and international competitions. Civilian 

use includes the Ethan Allen Biathlon Club, Mansfield Nordic Club, and local high schools. The 

5 kilometer course is operated year round; during winter months the course is supplemented 

with artificially made snow.

1.5 Facility Environmental Setting

Ethan Allen TS is in the Green Mountains of Vermont within the New England Physiographic 

Province. Surface topography of the TS is rugged, hilly, and mountainous, with a maximum 

elevation of approximately 3,573 feet above mean sea level (amsl) and a minimum elevation of 

approximately 604 feet amsl. The easternmost edge of the property trends north-south along 

the main ridge of the Green Mountains. The westward-flowing Lee River originates at the 

eastern boundary, flows westward through the center of the facility, and exits at the western 

boundary. This main drainage and drainages to the north and south are fed by several 

tributaries located within the facility boundary, some of which form small ponds at low-lying 

interior locations. The area surrounding the facility is rural and supports a variety of wildlife.

1.5.1 Geology

The Ethan Allen TS is on the western side of the Green Mountains, within a region 

characterized by generally north-south-trending hills, ranges, and intervening valleys, all of 

which are cut by east-west-trending drainages. The eastern boundary of the facility corresponds 

to the drainage divide formed by the linear, north-south-trending main ridge of the Green 

Mountains.

The Ethan Allen TS is underlain by the western limb of the north-south-trending Green Mountain 

Anticlinorium, an antiformal duplex that is approximately 10 miles wide and consists of 

Ordovician, Cambrian, and Neoproterozoic rock units separated by depositional contacts and 

thrust faults. The area is underlain by lithologically diverse, predominantly metasedimentary 

rocks of the West Bridgewater Formation, Fairfield Pond Formation, Underhill Formation, 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

8 

Hazens Notch Formation, Fayston Formation, and Pinnacle Formation. These rocks include 

schist, phyllite, marble, amphibolite, gneiss, quartzite, and greenstone. Depositional contacts, 

bedding, and thrust faults generally dip to the west and strike to the south (Ratcliffe et al., 2011). 

The bedrock geology beneath the area is presented in Figure 1-2. 

Surface materials at the Ethan Allen TS consist predominantly of glacial till mantling bedrock 

and reflect the topography of the underlying bedrock surface, bedrock, and pluvial deposits

consisting of swamp, peat, and/or muck. Modern, unconsolidated fluvial and glacial outwash 

deposits are also present in areas adjacent to the Lee River in the western half of the facility 

(Stewart and MacClintock, 1970).

Northwestern Vermont is an area of greater earthquake hazard potential relative to elsewhere in 

Vermont and the northeast US based on probabilistic seismic hazard analysis performed by the 

United States Geological Survey. The probable intensity of ground shaking in northwestern 

Vermont is less than that in more recognized seismic hazard risk areas of the US but it has the 

fifth highest probable intensity in the continental US. The earthquake shaking hazard in 

northwestern Vermont derives from its proximity to areas of significant seismic activity in the 

northern portion of New York State and the St. Lawrence River valley in Canada (Lens et al., 

2013).

1.5.2 Hydrogeology

As a result of glacial retreat, stratified drift sediments form a confined aquifer in places overlain 

by an unconfined aquifer that make up the stratified-drift aquifers in the Mill Brook and Lee River 

Valleys at the facility. The Pinnacle and Underhill Formations are the major bedrock formations 

at the Ethan Allen TS. These formations contain varied textural and compositional differences; 

the differences are enough to define mapable rock units shown on Figure 1-2, but are not great 

enough to create regional variations in groundwater flow in the bedrock aquifer. 

The overall direction of groundwater flow in the Lee River and Mill Brook Valleys is from east to 

west, while localized flow is from the valley walls to the Lee River or Mill Brook. The regional 

bedrock hydraulic conductivity at the facility is approximated to be 1 feet per day or less. 

Groundwater flow velocity in the center of the Lee River Valley is estimated to be 0.7 to 2 feet 

per day due to the steep gradient of the Valley and relatively coarse stratified drift. The Mill 

Brook Valley has a relatively shallow gradient and fine-grained streambed sediments resulting in 

an estimated velocity of 0.7 feet per day or less (Clark et al., 2005)

Static depth to groundwater in the bedrock aquifer is commonly 10 to 20 feet below ground 

surface (bgs). Depths to groundwater greater than 20 feet bgs usually occur at higher altitudes 

and ridges, whereas shallow groundwater is typically found in topographic low points or near 

surface water bodies. The water table generally follows the land surface. Streams in the center 

of valleys containing stratified-drift deposits typically drain the aquifer whereas streams that 

cross from upland till into stratified-drift deposits generally lose water to the aquifer.

The primary drinking water source for the facility has been the Champlain Water District system 

since 1999 (Clark et al., 2005). Prior to this, Ethan Allen TS was served by three onsite bedrock 

wells. Two bedrock wells, approximately 300 feet bgs, formerly supplied water to the Mountain 

Warfare School and a bedrock well, 140 feet bgs, formerly provided water to the Cantonment. 

The Cantonment occasionally uses its well to fill portable drinking water supply tanks (Clark et 

al., 2005). Additional drinking water sources at the facility include a potable well (#40293, 

located south of the Walker Building) used to supply the biathlon facilities located within the 

Ethan Allen TS. Within the Walker Building, drinking water is treated using a clean water 

filtration, Point-of-Entry Treatment system manufactured by Kinetico Water Systems. In addition 

to potable well #40293, the March 2017 sampling and analysis report indicated that there are 

eight other wells at the Ethan Allen TS which supply potable water sources (Tetra Tech 2017). 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

9 

These potable water sources are located within classroom and bathroom sinks located within 

training buildings used intermittently by the Mountain Warfare School. Table 1-1 summarizes 

the potable well locations sampled in the March 2017 sampling and analysis report. Well 

locations are shown on Figure 1-2. 

Table 1-1 Potable Wells Sampled in March 2017

Well Number Location PFAS Detected (ppt)

40293 Walker Building Yes (PFOA: 19.5; PFHpA: 12.2)

40030 Range Yes (PFBA:1.4J; PFTeA: 0.645J)

WAT21 Firing Point Classroom No

40163 Range Yes (PFTeA: 0.456J)

WAT19 Range No

40167 Range Classroom Yes (PFOA: 0.724J; PFTriA: 0.572J)

40107 Range No

40081 Range Yes (PFOA: 1.24J; PFBA: 1.59J; PFHxA: 

0.96J; PFPeA: 1.13J)

40054 Pump House #2 Yes (PFOA: 8.19, PFOS: 1.54J)

Notes: ppt = parts per trillion; J = estimated concentration 

Of the nine potable wells sampled in the March 2017 sampling event, PFAS were detected at 

six wells. Of those detections, well #40293 (Walker Building well) was the only well to exceed 

the Vermont HA of a combined 20 ppt for five PFAS chemicals. Low level detections of some 

PFAS chemicals were detected at five other wells; however, no concentrations exceeded either 

the Vermont or USEPA HA levels. VTARNG has sampled well #40293 on a quarterly basis since 

the initial sampling event. Table 1-2 summarizes the results for the PFAS analytes included in 

the Vermont HA for each quarter. The full report and results can be found in Appendix A. 

Table 1-2 Well # 40293 (Walker Building Well) Quarterly Sampling Results

Vermont HA 

Analytes (ppt)

March

2017

August

2017

November

2017

February

2018

Perfluorooctanoic acid (PFOA) 19.5 29 31 34

Perfluorooctanesulfonic acid (PFOS) -- 1.48J 0.721J --

Perfluorohexanesulfonic acid (PFHxS) -- -- -- --

Perfluoroheptanoic acid (PFHpA) 12.2 19.5 18 21.5

Perfluorononanoic acid (PFNA) -- 1.96J 1.93J 1.76J

Notes: ppt = parts per trillion; -- = not detected; J = estimated concentration 

General Dynamics Armament Systems, Inc. is still supplied by onsite water from a bedrock well. 

One of the firing ranges is also supplied by a bedrock well, 226 feet bgs, which is infrequently

used. An artificial pond, used by Ethan Allen TS to supply snowmaking machines, is fed by 2 

wells; one deep well, drilled to a depth of 625 feet bgs, and one shallow well, approximately 4 

feet bgs, that is fed by a spring. The West Bolton Public Water Source Protection area includes

land areas within the facility boundaries; however, the water system is upgradient of the Ethan 

Allen TS watershed and not likely to be affected by activities within the facility boundary. 

Domestic wells are commonly drilled into bedrock in the communities surrounding the Ethan 

Allen TS. Numerous domestic wells are located immediately outside of the northern, western, 

and southern boundaries of the facility. Median well depths are approximately 300 feet bgs; 

hydraulic properties and aquifer characteristics vary widely across relatively short distances

(Clark et al., 2005). 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

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1.5.3 Hydrology 

The Ethan Allen TS is located within three separate sub-watersheds. The majority of the facility 

lies within the Browns River Watershed, which runs through the center of the facility from east to 

west and encompasses approximately 6,548 acres of the Ethan Allen TS. The second largest 

drainage area, covering around 3,830 acres, is the Snipe Island Brook-Winooski River 

Watershed. This watershed drains the southern area of the facility to Mill Brook. Lastly, 

approximately 840 acres of the far northeastern portion of the facility lies within Headwaters 

Browns River Watershed. Watersheds within the facility boundary lie within hilly, mountainous 

terrain and include drainage areas that are mostly forested and undeveloped. Watersheds, 

surface water features, and their associated drainages at Ethan Allen TS are presented in 

Figure 1-3. 

Numerous unnamed tributaries, natural and artificial ponds, springs, and wetlands are located 

within the Ethan Allen TS. These freshwater features predominantly drain into two major 

waterbodies: the Lee River, which subsequently discharges to the Browns River to the 

northwest, and Mill Brook, which drains to the Winooski River to the southwest. The drainage 

divide between the watersheds runs east-west across the southcentral half of the facility. Both 

systems drain into Lake Champlain, a large freshwater lake that forms the western border 

between New York and Vermont and comprises the main freshwater supply for adjacent 

regions.

The major hydrologic feature of the Ethan Allen TS is the Lee River which runs through the 

central portion of the facility, flowing generally east to west. Several small, unnamed tributaries

flow into the Lee River along its length. Data from 2003 showed that the average streamflow 

that year was 25.4 cubic feet per second (Clark et al., 2005). A comparative analysis of the Lee 

River to other similar rivers in Vermont indicated that groundwater likely contributes largely to

streamflow during periods of low rainfall. The watershed contains a large area of relatively 

permeable stratified-drift deposits that may act as a storage reservoir for groundwater (Clark et 

al., 2005). 

The southern third of the facility is drained by several southward- and/or southwestward-flowing 

tributaries that feed into Mill Brook. Mill Brook runs along the southern boundary of the facility 

and flows westward towards its confluence with the Winooski River, approximately 4 miles west 

of the Ethan Allen TS. 

At low-lying locations within the north-central, central, and south-central portions of the Ethan 

Allen TS, surface water flows into several freshwater surface ponds, forested/shrub wetlands, 

and emergent wetlands (Figure 1-3). In total, ponds cover approximately 60 acres, 

forested/shrub wetland cover approximately 330 acres, and emergent wetlands cover 

approximately 15 acres (USFWS, 2018).

One of the larger ponds on the property is a man-made pond, located adjacent to the Wax 

Sheds, which is used by the biathlon facility to supply snow making machines and snowmaking 

huts with water. Shallow and deep groundwater wells are used to supply the pond with water for 

snowmaking. The pond is upgradient to the Wax Sheds and Walker Building. Surface water in 

the pond may infiltrate to shallow groundwater. Localized groundwater flow direction is assumed 

to be travel to the northeast from the pond, towards the Wax Sheds and past the deep well 

impacted by PFAS at the Walker Building. From there, groundwater would continue to travel 

northeast to a creek that connects to the Lee River. The snowmaking pond may be a secondary 

source of PFAS, because the pond is partly fed by a deep well and PFAS have been detected in 

groundwater at the nearby deep well. The following diagram depicts a generalized cross-section 

for the area.
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

11

1.5.4 Climate 

The Ethan Allen TS is in the western half of the Green Mountains physiographic region of 

Vermont. Local rainfall and temperature ranges in this region are strongly affected by factors 

such as slope, elevation, aspect, and urbanization, and can vary considerably over short 

distances. Temperatures are moderated year round by the proximity of Lake Champlain to the 

west. Cool breezes blow inland off the lake in the summer and in the winter the Lake acts as a 

heat reservoir that moderates local land temperature. Air temperature highs in July and lows in 

January average 80 degrees Fahrenheit (°F) and 18°F, respectively (NOAA, 2018). Rainfall data 

indicates that the Ethan Allen TS is located in an area that averages approximately 38 inches of 

precipitation per year. Precipitation is well distributed throughout the year but typically heavier in 

the summer than in the winter. Strong thunderstorms in the summer produce the heaviest local 

rainfall intensities (NOAA, 2018). Precipitation remains largely locked in snowpack during winter 

months prior to melt.

1.5.5 Current and Future Land Use

Ethan Allen TS is used by the VTARNG for weapons-testing and training. The camp is home to 

the US Army Mountain Warfare School and Infantry Armory, along with the 86th Infantry Brigade 

Combat Team. The majority of the facility’s footprint is undeveloped and forested. The few 

offices, barracks, and equipment maintenance buildings are primarily located along Ethan Allen 

Road in the Lee River Valley. The facility is sparsely populated; however, the barracks 

occasionally host a few thousand individuals during Army Mountain Warfare School training 

exercises throughout the year. 

The facility is used for both military and civilian biathlon training and holds national and 

international competitions. Civilian use includes the Ethan Allen Biathlon Club, Mansfield Nordic 

Club, and local high schools. Biathlon training and competitions occur throughout the year; 

traditional snow skis are used for training and competitions during winter months while roller

skis are used during the warmer months of the year. During the VSI, facility staff mentioned that 

people have used the Snowmaking Pond for recreational swimming. 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

12

Land to the north, south, and west of the facility is primarily rural, consisting of privately owned 

farmland, residences, and undeveloped forests. The eastern border of the facility abuts the 

western slope of the Green Mountains and Mount Mansfield State Forest. 

Reasonably anticipated future land use is not expected to change from the current land use

described above. 
Winooski River

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12420 Milestone Center Drive

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^_

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Society, i-cubed

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Figure 1-2

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14
Mill Brook

Lee River

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Browns River

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Surface Water Features

Figure 1-3

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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

16

2. Fire Training Areas 

No FTAs were identified at Ethan Allen TS during the PA. Interviewees confirmed that the facility 

is supported by the Underhill Jericho Fire Department and that firefighting training has never 

occurred on Ethan Allen TS property (Appendix B). 
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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

17

3. Non-Fire Training Areas

Three non-FTAs were identified during the PA at Ethan Allen TS. A description of each non-FTA 

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

appear in Appendix C. 

VTARNG began quarterly sampling of drinking water at well #40293, located approximately 50 

feet south of the Walker Building within the biathlon facilities at Ethan Allen TS, in March 2017. 

Four rounds of samples have been collected from the kitchen sink of the Walker Building, at the 

time of reporting. Since the initial sampling event, PFAS have consistently been detected in well 

#40293 above the July 2018 updated Vermont Department of Health Drinking Water HA level of 

20 ppt but below the USEPA Drinking Water HA of 70 ppt (Tetra Tech 2018). Eight other wells at 

Ethan Allen TS were sampled during the initial sampling event in March 2017. Low level 

detections of some PFAS chemicals were detected; however, no concentrations exceeded 

either the Vermont or USEPA HA levels (Tetra Tech 2018). 

High grade commercial ski and snowboard waxes have been found to contain high 

concentrations of PFAS (Kotthoff et al., 2015). Surface water and snowmelt have been shown to 

have measureable PFAS impacts downgradient of ski areas (Kwok et. al., 2013). Interviewees 

noted that high grade waxes are almost exclusively used for competition and that lower grade 

waxes (reportedly not PFAS containing) are used the majority of the time at the facility. The nonFTAs identified during the PA are associated with the biathlon course at Ethan Allen TS.

3.1 Waxing Areas

As part of the biathlon facility, 20 Wax Sheds (2 rows of 10 huts) used by biathletes during 

training and competitions for ski maintenance and ski waxing, are located on the western side of 

the Walker Building at geographic coordinates 44°28'3.07"N and 72°56'12.84"W. Each shed

stands above grade, is approximately 15 feet long by 10 feet wide, and is constructed with a 

wooden (plywood) floor and work benches, an exhaust fan, and a window. 

During the VSI, hardened wax was observed on the floor and work benches of the sheds. 

Discarded wax shavings were also observed in plastic waste bins within the sheds. Interviewees 

were not sure where the bins were emptied, but speculated they were likely emptied in facility 

trash bins for municipal waste disposal. An empty waste bin with wax remnants was observed 

during the VSI lying on its side in the strip of grass between the two rows of sheds. Interviewees 

also noted that wax shavings from the floors of the warming huts have typically been swept out 

of the sheds onto the grassy area between the 2 rows of sheds. 

Additionally, inside the Walker Building are rooms for applying ski wax and a wax storage room. 

A French drain surrounds the Walker Building and is connected to the facility’s storm water 

drainage network. Wax may have been swept from inside the building and entered the drainage 

system. 

Remnants of ski wax left in and swept from the Waxing Sheds and Walker Building by patrons 

of the biathlon facility are potential PFAS sources. 

3.2 Snowmaking Pond

Located approximately 130 feet to the west and upgradient of the Wax Sheds is an artificial 

pond used to supply snowmaking machines and snowmaking huts with water. The approximate 

geographic coordinates are 44°28'1.80"N and 72°56'15.93"W. Historical aerials provided in the 

Environmental Data Resources report (Appendix A) show that the pond was built between 

1986 and 1999. Portions of the biathlon track are supplemented with artificial snow during the 

winter, as needed. The pond is fed by 2 wells; one deep well (Figure 1-2), drilled to a depth of 

625 feet bgs, and one shallow well, approximately 4 feet bgs, that is spring fed. Based on 
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

18

interviews with facility staff during the VSI, approximately 3.3 kilometers of the 5 kilometer track

can be covered by the artificial snow. Snowmaking Pond may be a secondary source of PFAS, 

because the pond is partly fed by a deep well and PFAS have been detected in groundwater 

from a nearby deep well.

3.3 Biathlon Course

The biathlon course is a 5 kilometer asphalt paved track averaging about 20 feet in width that 

starts at a newly constructed building, located immediately to the south of the Walker Building. 

The course is situated to both the north/northwest and south of the Walker Building. Biathlon 

training and competitions occur throughout the year at the course; traditional snow skis are used 

for training and competitions during winter months while roller skis are used during the warmer 

months of the year. At select locations along the course, snow is supplemented with water from 

the Snowmaking Pond (a potential secondary source of PFAS). Normal use of the biathlon 

course during winter months results in wax from skis incidentally transferring from the ski to 

snow. This residual wax left on the snow surface may be a potential source of PFAS in 

snowmelt along the 5 kilometer track.

3.3.1 Off-Site Snow

During the 2017 ski course season, a combination of low snow and snowmaking machine failure 

required off-site snow to be transported to facility for use at the biathlon course. Interviews with 

facility staff have indicated that about 120-160 tons of snow was trucked in from the Army 

Aviation Support Facility at the South Burlington Airport, down-gradient Ethan Allen TS, 

declination station, and Hyde Park (approximately 30-40 tons from each location). The PFAS 

concentrations (if any) in the off-site snow is unknown and may have contributed to the detected 

levels of PFAS in groundwater from infiltration due to snow melt.
Snowmaking Pond

Waxing Sheds

Biathlon Course

Walker Building

Mill Bro ok

Legend

Potential PFAS Release

Facility Boundary

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Camp Ethan Allen Training Site, Vermont

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4. Emergency Response Areas 

One emergency response area was identified at Ethan Allen TS during the PA. A description of 

the emergency response area is presented below and shown on Figure 4-1. Interview records 

are included in Appendix B and a copy of the incident report in Appendix A. 

Emergency response at Ethan Allen TS is supported by the Underhill Jericho Fire Department. 

The fire department has a foam-capable tanker (9 Tanker 2), 3 portable “foam packs,” a Gator 

equipped with a Task Force Tips® (TFT) Foam-Pro system, and stores approximately 3 5-gallon 

buckets (15 gallons) of AFFF at the Jericho Fire Station as well as Class A foams. 

4.1 Skidder Tire Fire

During interviews, the Captain of the Underhill Jericho Fire Department recalled one incident 

where foam was used at Ethan Allen TS, a copy of the incident report was provided. On 9 

January 2015, the Underhill Jericho Fire Department responded with foam to a tire fire on a 

skidder located on a road within the facility boundary. An interviewee with a firsthand knowledge 

of the incident reported that the location was approximately 44°29'2.25"N and 72°55'1.96"W. 

The incident report indicates that the response to the fire was use of a water supply engine (9 

Engine 4) and foam was applied to the fire. VTARNG contacted the Underhill Jericho Fire 

Department to determine the type of foam that was used. This correspondence confirmed that 

the type of foam used was not AFFF and that it did not contain PFAS (Appendix B). Because of 

this, the location of the skidder tire fire is not considered a potential source area. 
Skidder Tire Fire

Legend

No Suspected Release

Facility Boundary

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Emergency Response Areas

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0 250 500 1,000

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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

22

5. Adjacent Sources

Two potential off-site PFAS sources adjacent to the Ethan Allen TS facility were identified during 

the PA through interviews (Appendix B). Review of the Third Unregulated Contaminant 

Monitoring Rule database did not return any results for a PFAS release within the vicinity of 

Ethan Allen TS. Data Resources used are provided in Appendix A. Figure 5-1 presents the 

location of potential adjacent source areas. 

5.1 Underhill Jericho Fire Department

Emergency response at Ethan Allen TS is supported by the Underhill Jericho Fire Department. 

The Jericho Fire Station is located approximately 1 mile from the main gate of the Ethan Allen 

TS. Approximate geographic coordinates are 44°28'33.11"N and 72°58'7.91"W. According to 

interviewees, the fire department has a foam-capable tanker (9 Tanker 2), 3 portable “foam 

packs,” a Gator equipped with a TFT Foam-Pro system, and stores approximately 3 5-gallon 

buckets (15 gallons) of AFFF at the Jericho Fire Station. Both Chemguard 3% AFFF and Ansul 

T-Storm AR-AFFF 3% are stored at the fire station. Expired foam is reportedly disposed of at 

the Chittenden Solid Waste Facility. Instances of AFFF spills were not noted during interviews.

5.2 Underhill Jericho Fire Department FTA

Interviewees reported that the fire department conducts informal fire training at a gravel pit 

located on an adjacent portion of their property that is situated just before the main gate for 

Ethan Allen TS along Lee River Road. Approximate geographic coordinates are 44°28'44.68"N

and 72°57'40.22"W. The fire department has used the gravel pit as a FTA for over 25 years.

Training includes utilization of a mobile home and wooden pallets as training props. Water is 

typically used during training; however, a few instances of Class A foam use were noted during 

interviews. AFFF was reportedly not used during any training activities. 

5.3 Car Accident

AFFF was reportedly applied to a car fire that occurred at the western end of Lee River Road 

where it intersects with State Route 15. Approximate geographic coordinates are 44°30'14.44"N 

and 72°59'53.16"W. Details regarding the incident were not available; however, interviewees 

recalled that approximately 1-gallon of AFFF was applied to the fire at the end of suppression 

activities. Because AFFF was applied to the car fire, the location may be a potential source of 

PFAS adjacent to Ethan Allen TS.
Underhill Jericho Fire Department

Underhill Jericho Fire Department FTA

Car Accident

Lee River

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Adjacent Sources

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PFAS Preliminary Assessment Report

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24

6. Conceptual Site Model

Based on the PA findings, one AOI was identified at Ethan Allen TS: AOI 1 Biathlon Facility. The 

AOI location is shown on Figure 6-1. The following sections describe the CSM components and 

the specific CSMs developed for AOI 1. 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 (NGWA, 2018). Receptors at the current Ethan Allen TS

include site workers, construction workers, recreational users, trespassers, and off-facility 

residents. The CSM for the facility indicates which specific receptors could potentially be 

exposed to PFAS.

6.1 AOI 1: Biathlon Facility

AOI 1 includes 3 non-FTAs associated with the biathlon course at Ethan Allen TS; the Waxing 

Areas, Biathlon Course, and the Snowmaking Pond. A potential source of PFAS comes from the 

use of PFAS containing ski wax, as wax shavings are left in and swept from the Wax Sheds and 

Walker Building by the patrons of the biathlon facility. Remnants of the residual wax are left on 

the snow surface along the 5 kilometer Biathlon Course and thus can travel with melting snow. 

PFAS have consistently been detected in groundwater from a potable well located at the Walker 

Building (well #40293) above the Vermont Department of Health Drinking Water HA level of 20 

ppt but below the USEPA Drinking Water HA of 70 ppt (Tetra Tech 2018). Shallow and deep 

groundwater wells are used to supply water to the Snowmaking Pond. Because PFAS has 

consistently been detected in deep groundwater from the nearby Walker Building, the 

Snowmaking Pond, and areas where man-made snow was used to supplement the biathlon 

course, may be secondary sources of PFAS. 

AOI 1 is divided by the Browns River watershed, draining the Lee River, and the Snipe Island 

Brook-Winooski River watershed, draining Mill Brook. The overall direction of groundwater flow 

in the Lee River and Mill Brook Valleys is east to west, while localized flow is from the valley 

walls to the Lee River or Mill Brook. The primary drinking-water source for the Ethan Allen TS

has been the Champlain Water District system since 1999; however, bedrock wells are still 

occasionally used at the General Dynamics Armament Systems, Inc. facility along with several 

individual buildings and firing ranges within Ethan Allen TS. Additionally, numerous domestic

wells are located off-facility in both Lee River and Mill Brook Valleys. Because well #40293 has 

combined PFAS concentrations above the Vermont HA of 20 ppt, the drinking water pathway via 

ingestion is complete for site workers, construction workers, recreational users, and 

trespassers; the ingestion pathway is potentially complete for off-facility residents.

Ground-disturbing activities to surface soil at AOI 1 could result in site worker, construction 

worker, recreational users, and trespassers exposure to potential PFAS contamination. Grounddisturbing activities to subsurface soil could result in site worker and construction worker

exposure to potential PFAS contamination. Therefore, the exposure pathways for inhalation of 

soil particles and ingestion of soil are potentially complete for these receptors. Site workers, 

construction workers, recreational users, trespassers, and off-facility residents may wade in the 

Snowmaking Pond, Lee River, or Mill Brook; these receptors may be exposed to potential PFAS 

contamination in surface water and sediment. Therefore, the exposure pathway via ingestion is 

potentially complete for these receptors. 

The CSM for the Biathlon Facility is shown on Figure 6-2. 
Walker Building

Snowmaking

Pond

Waxing Sheds

Biathlon Course

Skidder Tire Fire

Car Accident

Underhill Jericho 

Fire Department

Underhill Jericho 

Fire Department FTA

M illBrook

Lee R iver

Snipe Island

Brook-Winooski

River Watershed

Winooski

River Watershed

Headwaters

Browns River

Watershed

Browns

River

Watershed

AOI 1

Areas of Interest

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0 0.5 1 2

Miles

Legend

Area of Interest

Potential PFAS

Release

No Suspected

Release

Facility Boundary

Water Body

Wetland

River/Stream

Surface Water Flow

Direction

Inferred Groundwater

Flow Direction

!C( Public Water System

!P Potable Well

!5 Agricultural Well

!5 Industrial Well

A! Other Well

!5 Nonpotable Well

25
Media

SOURCE PATHWAY REC

AOI 1

AOI 1: PFAS 

containing ski wax 

and groundwater 

filled snowmaking 

pond

PFAS in 

Surface Soil

PFAS in 

Subsurface 

Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

at AOI

Surface 

Water/ 

sediment

Subsurface 

Soil

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Huma

Curr

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

Site 

Worker

Construct

Worker 

Site 

Worker

Construct

Worke

/ / / / 

LEGEND

/ // / 

Figure 6-2

Conceptual Site 

AOI 1 – Biathlon 

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ 
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7. Conclusions

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

AFFF and other PFAS-related activities at Ethan Allen TS. The PA findings are based on the 

information presented in Appendix A and Appendix B. 

7.1 Findings

One AOI related to potential PFAS releases (Table 7-1) was identified at the Ethan Allen TS 

during the PA. Figure 7-1 presents a summary of PA findings.

Table 7-1 AOIs at Ethan Allen TS

Area of Interest Name Used by Potential Release Dates

AOI 1 Biathlon Facility VTARNG and 

public

Approximately 1972 to 

present

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

contamination in surface soil via inhalation and ingestion by site workers, construction workers, 

and recreational users/trespassers; in subsurface soil via ingestion by site workers and 

construction workers; in groundwater, surface water and sediment via ingestion by site workers, 

construction workers, off-facility residents, and recreational users/trespasser. 

The Underhill Jericho Fire Department occasionally uses AFFF to respond to fires within the 

area. Interviewees recalled approximately 1-gallon of AFFF specifically being used on a car fire 

located off-facility at the intersection of Lee River Road and State Route 15, downgradient of the 

Ethan Allen TS.

7.2 Uncertainty

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

PFAS-containing materials to have been present, used, or released at the 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 containing materials in training, firefighting, or other non-traditional activities (such as high 

grade ski wax), 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 the use of PFAS containing materials 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 historically 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, current personnel were interviewed, multiple persons were 

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

inspected where possible. Table 7-2 summarizes the uncertainties associated with the PA.
PFAS Preliminary Assessment Report

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Table 7-2 Uncertainties

Location Source of Uncertainty

AOI 1 Biathlon 

Facility – Ski Wax

The frequency of ARNG versus private entity use is unknown as well 

as whether the waxes used contain PFAS or not. Additionally, the 

initial date that PFAS containing wax was used at the facility is not 

known.

AOI 1 Biathlon 

Facility – 

Snowmaking Pond

The exact locations where artificial snow, created from water taken 

from the pond, was applied along the 5 kilometer biathlon track are 

unknown. However, based on interviews during the VSI, approximately 

3.3 kilometers of track can be covered with artificial snow.

AOI 1 Biathlon 

Facility – 

Snowmaking Pond

It is not known if water within the snowmaking pond contains PFAS.

PFAS were confirmed in deep groundwater at a nearby well; however, 

the well that supplies water to the snowmaking pond has not been 

tested for PFAS to date. 

AOI 1 Biathlon 

Facility – Off-Site 

Snow

During the 2017 ski season, approximately 120-160 tons of snow was

transported to the facility for use at the biathlon course. Transported 

snow may have contained PFAS prior to entering the facility and 

introduces a source of uncertainty.

AOI 1 Biathlon 

Facility – Waxing 

Areas

The disposal of remnant ski wax shavings from waste bins located in 

the Waxing Sheds and Walker Building is unknown. Interviewees 

suggested that contents were emptied in facility trash bins for 

municipal waste disposal but were not certain if this was the standard 

operating procedure.

AOI 1 Biathlon 

Facility – Walker 

Building Area

In general, the area of ski wax deposition was predominantly around 

the Walker Building where biathlon participants start and finish. The

degree of impact from the deposition of ski wax is unknown.

General Locations where the Underhill Jericho Fire Department responded to 

local emergencies off-facility with AFFF are not known. One location 

was identified during interviews; however, additional locations may be 

present within the surrounding communities of Jericho and Underhill.

7.3 Potential Future Actions

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

Skidder Tire Fire, evidence does not indicate that current or former VTARNG activities in these 

areas contributed PFAS contamination to soil, groundwater, surface water, or sediment at Ethan 

Allen TS. The Ethan Allen TS Skidder Tire Fire will not move forward in the CERCLA process.

Interviews and records (covering 1970s to present) indicate that current or former ARNG 

activities related to the biathlon course may have resulted in potential PFAS releases at AOI 1 

identified during the PA. Based on the CSM developed for the AOI, there is potential for 

receptors to be exposed to PFAS contamination in soil, groundwater, surface water, and 

sediment at the AOI. Table 7-3 summarizes the rationale used to determine if the AOI should be 

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

ARNG is evaluating an SI at Ethan Allen TS based on the presence of a PFAS release, possible 

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

Camp Ethan Allen Training Site, Vermont

29

Table 7-3 PA Findings Summary

Area of Interest AOI Location Rational Potential Future 

Action

AOI 1 Biathlon 

Facility

44°28'3.07"N 

and 

72°56'12.84"W

PFAS containing ski wax may have 

been released to site media. 

Proceed to an SI;

focus on soil, 

groundwater, 

surface water, 

and sediment
Walker Building

Snowmaking Pond

Waxing Sheds

Biathlon Course

Skidder Tire Fire

Car Accident

Underhill Jericho 

Fire Department

Underhill Jericho 

Fire Department FTA

Lee River

AOI 1

Legend

Area of Interest

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

Wetland

River/Stream

Summary of Findings

Figure 7-1

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8. References 

Clark, S.F., Jr., Chalmers, Ann, Mack, T.J., and Denner, J.C., 2005, Hydrogeologic framework 

and water quality of the Vermont Army National Guard Ethan Allen Firing Range, northern 

Vermont, October 2002 through December 2003: U.S. Geological Survey Scientific 

Investigations Report 2005-5159, 48 p.

globalsecurity.org, 2011. Camp Ethan Allen Training Site. 

https://www.globalsecurity.org/military/facility/camp-ethan-allen.htm. (Accessed August 2018)

Koffhoff, M., Müller, J., Jürling, H., Schlummer, M., Fiedler, D., 2015. Perfluoroalkyl and 

polyfluoroalkyl substances in consumer products. Environ Sci Pollut Res (2015) 22:14546–

14559.

Kwok, K. Y., E. Yamazaki, N. Yamashita, S. Taniuasu, M. Murphy, Y. Horii, G. Petrick, R. 

Kallerborn, K. Kannan, K. Murano, and P. K. S. Lam. 2013. Transport of perfluoroalkyl 

substances (PFAS) from an arctic glacier to downstream locations: Implications for sources. 

Science of the Total Environment 447: 46-55.

Lens, J. E., Dewoolkar, M. M., Springton, G. E., and Becker, L. R., 2013. Seismic Hazard for the 

Burlington and Colchester, Vermont USGS 7-1/2 Minute Quadrangles

National Oceanic and Atmospheric Administration (NOAA). 2018. Climate of Vermont. 

https://www.ncdc.noaa.gov/climatenormals/clim60/states/Clim_VT_01.pdf. (Accessed July 

2018)

Ratcliffe, N.M., Stanley, R.S., Gale, M.H., Thompson, P.J., and Walsh, G.J., 2011, Bedrock 

geologic map of Vermont: U.S. Geological Survey Scientific Investigations Map 3184, 3 sheets, 

scale 1:100,000.

Stewart, D. P., and MacClintock, P., 1970. Surficial Geologic Map of Vermont

Tetra Tech, 2017. PFOS and PFOA Sampling and Analysis Report, Training Site (TS) Ethan 

Allen Range, Vermont. USACE Contract No. W912DR-15-D-0021, DO #001. March 2017.

Tetra Tech, 2018. PFOS and PFOA Sampling and Analysis Report, Training Site (TS) Ethan 

Allen Range, Vermont. USACE Contract No. W912DR-15-D-0021, DO #001. February 2018.

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

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

U.S. Fish and Wildlife Service (USFWS) 2018. U.S. Fish and Wildlife Service National Wetlands 

Inventory. https://www.fws.gov/wetlands/data/Mapper.html. (Accessed August 2018)
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Appendix A

Data Resources
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PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

Data resources will be provided separately on CD. Data resources for Ethan Allen Training Site 

include:

Environmental Data Resources Report

 2018 The EDR Radius Map Report with GeoCheck; Aerial Photo Decade Package; & 

Certified Sanborn Map Report; Target Property Ethan Allen Training Site, 113 Ethan Allen 

Rd, Jericho, VT 05465.

Previous Investigations Completed

 Clark, S.F., Jr., Chalmers, Ann, Mack, T.J., and Denner, J.C., 2005, Hydrogeologic 

Framework and Water Quality of the Vermont Army National Guard Ethan Allen Firing 

Range, northern Vermont, October 2002 through December 2003: U.S. Geological Survey 

Scientific Investigations Report 2005-5159, 48 p.

 Quarterly PFOS and PFOA Sampling and Analysis Reports, Training Site Ethan Allen 

Range, Vermont. March 2017 through February 2018.

 Well completion report Walker Building Well

 Well completion report for Snowmaking Pond water supply well

Leasing Information

 Supplemental Agreement No. 1 to License No. DACA51-3-78-571

 Supplemental Agreement No. 2 to License No. DACA51-3-78-571

 Supplemental Agreement No. 3 to License No. DACA51-3-78-571

 Supplemental Agreement No. 4 to License No. DACA51-3-78-571

 Supplemental Agreement No. 5 to License No. DACA51-3-78-571

Regulatory Advisory

 Vermont Department of Health Memorandum on Drinking Water Health Advisory for Five 

PFAS

Miscellaneous Data Resources

 Underhill Jericho Fire Department AFFF Inventory

 Underhill Jericho Fire Department incident report for Skidder Tire Fire

 Koffhoff, M., Müller, J., Jürling, H., Schlummer, M., Fiedler, D., 2015. Perfluoroalkyl and 

polyfluoroalkyl substances in consumer products. Environ Sci Pollut Res (2015) 22:14546–

14559.
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Appendix B

Preliminary Assessment Documentation
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PFAS Preliminary Assessment Report

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Appendix B.1

Interview Records
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Ryan Ochs Vermont Military Department August 2017 This map has been produced on the Vermont Military Department’sGeographic Information System. Data provided herein is derived from sources with varying levels of accuracy. The Vermont Military Department disclaims all responsibility for the accuracy or completeness of information contained herein. 

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Miles

EAFR Wetlands


PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

Appendix B.2

Visual Site Inspection Checklists
THIS PAGE IS INTENTIONALLY BLANK




PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

Appendix B.3

Conceptual Site Model Information
THIS PAGE IS INTENTIONALLY BLANK
Preliminary Assessment – Conceptual Site Model Information

Site Name: Camp Ethan Allen Training Site

Why has this location been identified as a site? PFAS was detected in potable water wells at and within 

the vicinity of a biathlon facility that is used by the VTARNG and public.

Are there any other activities nearby that could also impact this location? No other nearby activities 

were noted.

Training Events

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

If so, how often? Not Applicable (N/A).

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

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

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

pathways to larger water bodies?

Surface Water:

Surface water flow direction? Surface water flows to the north and the south – the Green Mountains 

ridgeline defines a drainage divide 

Average rainfall? Approximately 40 inches per year

Any flooding during rainy season? Flooding during the rainy season is possible

Direct or indirect pathway to ditches? Both direct and indirect pathways exist

Direct or indirect pathway to larger bodies of water? Both direct and indirect pathways exist to the Lee 

River and Mill Brook

Does surface water pond any place on site? Yes, in ditches, springs and low-lying wetland areas

Any impoundment areas or retention ponds? Two larger 1 to 11⁄2-acre ponds and wetland areas

Any NPDES location points near the site? Unknown

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

Groundwater:

Groundwater flow direction? Groundwater flow is from east to west; highly variable localized flow likely

Depth to groundwater? 10 to 20 ft bgs

Uses (agricultural, drinking water, irrigation)? Potentially potable wells; Champlain Water District 

provides drinking water to the facility

Any groundwater treatment systems? A POET/filtration system exists within the Walker Building

Any groundwater monitoring well locations near the site? Yes

Is groundwater used for drinking water? Wells are potentially potable

Are there drinking water supply wells on installation? Yes

Do they serve off-post populations? No

Are there off-post drinking water wells downgradient? Yes, numerous drinking water wells are off-post 

and associated mostly with residential dwellings

Waste Water Treatment Plant:

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

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

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

Is surface water from potential contaminated sites treated? No

Equipment Rinse Water

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

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? N/A

3. Other?
Preliminary Assessment – Conceptual Site Model Information

Identify Potential Receptors: 

Site Worker X

Construction Worker X

Recreational User X

Residential 

Child 

Ecological X

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

Documentation 

Ask for Engineering drawings (if applicable).

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

drainage system was upgraded approximately 10 years ago, replacing a shallower system in the same 

location. No other drainage infrastructure noted.
THIS PAGE IS INTENTIONALLY BLANK
PFAS Preliminary Assessment Report

Camp Ethan Allen Training Site, Vermont

Appendix C

Photographic Log
THIS PAGE IS INTENTIONALLY BLANK
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 1

Description:

View to the south of Waxing

Sheds. The artificial pond is

situated behind the crest of the

grass covered hill; right side

of the photograph.

Photograph No. 2

Description:

View to the south of grassy

area in between two rows of

Waxing Sheds.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 3

Description:

View to the south of Waxing

Sheds and surrounding area.

Photograph No. 4

Description:

View to the southwest of

waxing sheds, roadway and

grassy areas.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 5

Description:

View to the south of Walker

Building. Note wellhead in

center of photograph.

Photograph No. 6

Description:

View to the west of the course

starting area, new structure

and Walker Building. The

approximate 20 feet wide

asphalt covered ski track is

visible in the left side and

bottom right corner of the

photograph.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 7

Description:

View to the north of steel

cover covering access-way to

the stormwater drainage pipe.

Photograph No. 8

Description:

View to the north of low-lying

areas adjacent to ski track.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 9

Description:

View to the north of spring

adjacent to ski track.

Photograph No. 10

Description:

View to the north of wooden

shed covering corrugated

pipe/valve pit used for

artificial snowmaking

purposes.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 11

Description:

View of snowmaking water

valve/nozzle situated adjacent

to snowmaking shed.

Photograph No. 12

Description:

View of corrugated pipe/valve

pit inside snowmaking shed.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 13

Description:

View to the south of

snowmaking shed and Walker

Building.

Photograph No. 14

Description:

View to the south of asphalt

paved ski track, starting

area/structure, new structure

and Walker Building.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 15

Description:

View of Kinetico Water

Systems water filtration

system inside Walker

Building.

Photograph No. 16

Description:

View of a component of the

water filtration system inside

the Walker Building.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 17

Description:

View of the south side of the

Walker Building. The Waxing

Huts are in the background of

the photograph.

Photograph No. 18

Description:

View to the south of the west

facing side of the Walker

Building and new structure

under construction. Artificial

fill placed during construction

is visible in the center of the

photograph. The water well

head is situated in the center

left portion of the photograph.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 19

Description:

View of water well #40293

well head; re-constructed as

stick-up (casing). The south

side of the Walker Building is

visible in the right side of the

photograph. The Waxing Huts

are in the background.

Photograph No. 20

Description

View to the south of steel

plate covering the stormwater

drainage infrastructure.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 21

Description:

View to the south of a steel

grate/drop inlet associated

with the stormwater drainage

infrastructure.

Photograph No. 22

Description:

View to the east of pump

house associated with the

artificial pond used for storing

water, for snowmaking

purposes.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 23

Description:

View to the north of well/well

house associated with the

artificial pond used for storing

water, for snowmaking

purposes.

Photograph No. 24

Description:

View to the southeast of the

artificial pond used to store

water for snowmaking

purposes.
Preliminary Assessment Report

Camp Ethan Allen Training Site

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 Ethan Allen Training Site Vermont

Photograph No. 25

Description:

Photograph provided by

VTARNG, Skidder Tire Fire

response. Underhill Jericho

Fire Department applied nonAFFF foam to Skidder Tire

Fire.