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NATIONAL GUARD BUREAU

111 SOUTH GEORGE MASON DRIVE

ARLINGTON VA 22204-1373

ARNG-IES-D 6 December 2021

MEMORANDUM FOR RECORD

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site 

Inspection (SI) for Camp Minden, Louisiana

1. References:

a. HQDA, ASA-IE&E, SAIE-ZA, memorandum (Army Environmental Per- and 

Polyfluoroalkyl Substances (PFAS) Policy), 8 January 2021

b. DoDM 4715.20 (Defense Environmental Restoration Program (DERP) 

Management), 9 March 2012, incorporating Change 1, 31 August 2018

c. OSD, memorandum (Investigating Per- and Polyfluoroalkyl Substances within the 

Department of Defense Cleanup Program), 15 September 2021

d. AR 200-1 (Environmental Protection and Enhancement)

e. Final Preliminary Assessment Report Camp Minden, Louisiana PerfluorooctaneSulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) Impacted Sites ARNG 

Installations, Nationwide, February 2019

f. Final Site Inspection Report Camp Minden, LA Perfluorooctane Sulfonic Acid 

(PFOS) and Perfluorooctanoic Acid (PFOA) Impacted Sites ARNG Installations, 

Nationwide, September 2020

2. The requirement for an environmental response to potential and/or known releases 

of PFAS under the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA) and the Department of Defense Manual (DoDM) for the DERP is 

established in References 1.a through 1.d.

3. This memorandum documents the determinations reached at the conclusion of the 

PA/SI phases in accordance with the Department of Defense (DoD) DERP 

Management manual (DERP Management; Reference 1.b). When concluding the PA/SI 

phase of the CERCLA process, the Army National Guard (ARNG) must formally 

document a determination for each site in accordance with paragraph 4.b.(2)(b) of 

Enclosure 3 of DoDM 4715.20. The potential options are as follows: 1) No need for 
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site 

Inspection (SI) for Camp Minden, Louisiana

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action; 2) Need for a removal action, but not a remedial action; or, 3) Need for Remedial 

Investigation (RI)/Feasibility Study (FS). This Technical Memorandum documents the 

ARNG’s determination related to the PFAS PA/SI at Camp Minden, Louisiana. The 

need for a RI is based upon the following media-specific risk screening levels, as 

directed by the Assistant Secretary of Defense for Sustainment (Reference 1.c): 

Groundwater: PFOS: 40 nanograms per liter (ng/L) (40 parts per trillion (ppt)), PFOA: 40 

ng/L (40 ppt), PFBS: 600 ng/L (600 ppt); Soil: PFOS: 130 micrograms per kilogram 

(μg/kg), PFOA: 130 μg/kg, PFBS: 1,900 μg/kg.

4. The PFAS Preliminary Assessment at Camp Minden, LA, finalized in February 2019, 

Reference 1.e, concluded further inspection is warranted at one Area of Interest (AOI)

due to potential release(s) of PFAS to the environment from the use or storage of 

PFAS-containing materials, such as Aqueous Film Forming Foam (AFFF).

5. The PFAS Site Inspection at Camp Minden, LA, finalized on 30 September 2020, 

Reference 1.f, concluded that further inspection under CERCLA is not warranted at the 

one area of interest (AOI) due to no detections of PFOA, PFOS or PFBS in 

groundwater; PFOA detected in soil at concentrations several orders of magnitude 

below the screening level. Concentrations of PFAS equal to or exceeding the screening 

levels established by the Office of the Secretary of Defense (OSD) in Reference 1.c 

were not found at the one AOI. Additionally, the one area of interest, the Louisiana State 

University Fire and Emergency Training Institute, is not under the control of the ARNG. 

Based on the state of Louisiana owner/operator status, the state may consider any 

future follow-up actions.

6. The determination for NFA, progressing to RI, or implementing a Time-Critical 

Removal Action (TCRA) is made independently for each of the AOIs at the subject 

facility based on the data collected during the SI.

7. Army National Guard Installations and Environment Division, Environmental Cleanup 

and Restoration Branch (ARNG G-9) hereby confirms the recommendations from the SI 

by formalizing the following decision(s) for each AOI at Camp Minden, LA:

a. AOI 1, Fire and Emergency Training Area: No further action.

8. Appropriate coordination regarding this determination has occurred between ARNGOffice of General Counsel (OGC) and ARNG G-9.
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site 

Inspection (SI) for Camp Minden, Louisiana

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9. The point of contact for this action is Mr. David Connolly, PFAS Program Manager, 

david.m.connolly8.civ@mail.mil, or 703-607-7589. 

Encl THOMAS K. LAFAVE

Lieutenant Colonel, U.S Army

Chief, Cleanup and Restoration 

G-9, Army National Guard
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site Inspection (SI) for Camp Minden, 

Louisiana

Encl

Per- And Polyfluoroalkyl Substances (PFAS) PA/SI Determination Summary

Camp Minden, LA

Location Preliminary Assessment (PA) Site Inspection (SI)

AOI # Area Description Conclusion Determination Conclusion Determination

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Louisiana 

State 

University Fire 

and 

Emergency 

Training 

Instititute

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS 

into environmental 

media not 

confirmed above

screening levels; 

area is not under 

the control of the 

ARNG

No further 

action