FINAL

Site Inspection Report

Wendell H. Ford Regional Training Center

Muhlenberg County, Kentucky

Site Inspection for Perfluorooctanoic Acid (PFOA), Perfluorooctanesulfonic Acid (PFOS), 

Perfluorohexanesulfonic Acid (PFHxS), Perfluorononanoic Acid (PFNA), Hexafluoropropylene 

Oxide Dimer Acid (HFPO-DA), and Perfluorobutanesulfonic Acid (PFBS)

ARNG Installations, Nationwide

July 2023

Prepared for:

Army National Guard Headquarters 

111 S. George Mason Drive 

Arlington, VA 22204

UNCLASSIFIED
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TABLE OF CONTENTS

Page

LIST OF APPENDICES ................................................................................................................. ii

LIST OF FIGURES ....................................................................................................................... iv

LIST OF TABLES .......................................................................................................................... v

LIST OF ACRONYMS AND ABBREVIATIONS ...................................................................... vi

EXECUTIVE SUMMARY ...................................................................................................... ES-1

1. INTRODUCTION ............................................................................................... 1-1

1.1 Project Authorization ............................................................................... 1-1

1.2 Site Inspection Purpose ............................................................................ 1-1

2. FACILITY BACKGROUND .............................................................................. 2-1

2.1 Facility Location And Description ........................................................... 2-1

2.2 Facility Environmental Setting ................................................................ 2-1

2.2.1 Geology ..................................................................................... 2-2

2.2.2 Hydrogeology ........................................................................... 2-2

2.2.3 Hydrology ................................................................................. 2-4

2.2.4 Climate ...................................................................................... 2-4

2.2.5 Current and Future Land Use .................................................... 2-5

2.2.6 Sensitive Habitat and Threatened/Endangered Species ............ 2-5

2.3 History of PFAS use ................................................................................ 2-5

3. SUMMARY OF AREA OF INTEREST ............................................................. 3-1

3.1 AOI 1 – Fire Station/Building 325........................................................... 3-1

3.2 Adjacent Sources ..................................................................................... 3-1

3.2.1 Re-Tek Products, Inc. ................................................................ 3-2

4. PROJECT DATA QUALITY OBJECTIVES ..................................................... 4-1

4.1 Problem Statement ................................................................................... 4-1

4.2 Information Inputs ................................................................................... 4-1

4.3 Study Boundaries ..................................................................................... 4-1

4.4 Analytical Approach ................................................................................ 4-1

4.5 Data Usability Assessment ...................................................................... 4-2

5. SITE INSPECTION ACTIVITIES ...................................................................... 5-1
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5.1 Pre-Investigation Activities ..................................................................... 5-2

5.1.1 Technical Project Planning ....................................................... 5-2

5.1.2 Utility Clearance ....................................................................... 5-2

5.1.3 Source Water and PFAS Sampling Equipment Acceptability.. 5-2

5.2 Soil Borings and Soil Sampling............................................................... 5-3

5.3 Temporary Well Installation and Groundwater Grab Sampling.............. 5-4

5.4 Synoptic Water Level Measurements...................................................... 5-5

5.5 Surveying ................................................................................................. 5-5

5.6 Investigation-Derived Waste ................................................................... 5-5

5.7 Laboratory Analytical Methods............................................................... 5-6

5.8 Deviations From SI UFP-QAPP Addemdum .......................................... 5-6

6. SITE INSPECTION RESULTS .......................................................................... 6-1

6.1 Screening Levels...................................................................................... 6-1

6.2 Soil Physicochemical Analyses ............................................................... 6-2

6.3 AOI 1 ....................................................................................................... 6-2

6.3.1 AOI 1 Soil Analytical Results................................................... 6-2

6.3.2 AOI 1 Groundwater Analytical Results.................................... 6-3

6.3.3 Conclusions............................................................................... 6-3

7. EXPOSURE PATHWAYS.................................................................................. 7-1

7.1 Soil Exposure Pathway ............................................................................ 7-1

7.1.1 AOI 1 – Fire Station/Building 325............................................ 7-1

7.2 Groundwater Exposure Pathway.............................................................. 7-2

7.2.1 AOI 1 – Fire Station/Building 325............................................ 7-2

7.3 Surface Water and Sediment Exposure Pathway..................................... 7-3

8. SUMMARY AND OUTCOME .......................................................................... 8-1

8.1 SI Activities ............................................................................................. 8-1

8.2 Outcome................................................................................................... 8-1

9. REFERENCES .................................................................................................... 9-1

LIST OF APPENDICES

Appendix A. Data Usability Assessment and Validation Reports

Appendix B. Field Documentation

B1. Log of Daily Notice of Field Activities
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B2. Sampling Forms 

B3. Survey Data

B4. IDW Placement Locations

Appendix C. Photographic Log

Appendix D. Technical Project Planning Meeting Minutes

Appendix E. Laboratory Reports

Appendix F. Boring Logs and Well Construction Diagrams

Appendix G. Analytical Results
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LIST OF FIGURES

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Groundwater Elevations, November 2021

Figure 2-5 Surface Water Features

Figure 3-1 Area of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOS Detections in Soil

Figure 6-2 PFOA Detections in Soil

Figure 6-3 PFBS Detections in Soil

Figure 6-4 PFHxS Detections in Soil

Figure 6-5 PFNA Detections in Soil

Figure 6-6 PFOS, PFOA, and PFBS Detections in Groundwater

Figure 6-7 PFHxS and PFNA Detections in Groundwater

Figure 7-1 Conceptual Site Model, AOI 1 
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LIST OF TABLES

Table ES-1 Screening Levels (Soil and Groundwater)

Table ES-2 Summary of Site Inspection Findings and Recommendations

Table 5-1 Samples by Medium, Wendell H. Ford Regional Training Center, Kentucky, Site 

Inspection Report

Table 5-2 Soil Boring Depths and Temporary Well Screen Intervals, Wendell H. Ford 

Regional Training Center, Kentucky, Site Inspection Report

Table 5-3 Groundwater Elevation, Wendell H. Ford Regional Training Center, Kentucky, 

Site Inspection Report

Table 6-1 Screening Levels (Soil and Groundwater)

Table 6-2 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil, Site Inspection 

Report, Wendell H. Ford Regional Training Center, Kentucky

Table 6-3 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil, 

Site Inspection Report, Wendell H. Ford Regional Training Center, Kentucky

Table 6-4 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Deep Subsurface Soil, Site 

Inspection Report, Wendell H. Ford Regional Training Center, Kentucky 

Table 6-5 PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater, Site Inspection 

Report, Wendell H. Ford Regional Training Center, Kentucky

Table 8-1 Summary of Site Inspection Findings 
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LIST OF ACRONYMS AND ABBREVIATIONS 

°C degrees celsius

% percent

μg/kg microgram(s) per kilogram

μg/L microgram(s) per liter

AECOM AECOM Technical Services, Inc. 

AFFF aqueous film forming foam

AOI Area of Interest

ARNG Army National Guard

bgs below ground surface

btoc below top of casing

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CSM conceptual site model

DA Department of the Army

DoD Department of Defense

DQI data quality indicator

DQO data quality objective

EA EA Engineering, Science, and Technology, Inc., PBC

EIS Extraction internal standards

ELAP Environmental Laboratory Accreditation Program

ft foot (feet)

HDPE high-density polyethylene

HFPO-DA hexafluoropropylene oxide dimer acid

HQ Hazard Quotient

ICAL initial calibration

IDW investigation-derived waste

ITRC Interstate Technology Regulatory Council

MIL-SPEC military specification

KYARNG Kentucky Army National Guard

LC/MS/MS liquid chromatography tandem mass spectrometry

LCS laboratory control sample 

LCSD laboratory control sample duplicate

LOQ Limit of quantification

MS matrix spike

MSD matrix spike duplicate
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NELAP National Environmental Laboratory Accreditation Program

ng/L nanogram(s) per liter

No. number

OSD Office of the Secretary of Defense

PA preliminary assessment

PFAS per- and polyfluoroalkyl substances

PFBS perfluorobutanesulfonic acid

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PID photoionization detector

PVC polyvinyl chloride

QA quality assurance

QC quality control

QSM Quality Systems Manual

RI remedial investigation

RPD relative percent difference

SI site inspection

SL screening level

TCRA Time Critical Removal Action

TOC total organic carbon

TPP Technical Project Planning

UFP-QAPP Uniform Federal Policy Quality Assurance Project Plan

USACE U.S. Army Corps of Engineers

USEPA U.S. Environmental Protection Agency

WHFRTC Wendell H. Ford Regional Training Center 

Wood Wood Environment & Infrastructure Solutions, Inc.

WSP WSP USA Environment & Infrastructure Inc.
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EXECUTIVE SUMMARY

The Army National Guard (ARNG) G-9 is performing Preliminary Assessments (PAs) and Site 

Inspections (SIs) at ARNG facilities nationwide based on the current or potential historical use of 

per- and polyfluoroalkyl substances (PFAS), with a focus on the six compounds presented in the 

memorandum regarding Investigating Per- and Polyfluoroalkyl Substances within the 

Department of Defense Cleanup Program (Assistant Secretary of Defense, 2022) from the Office 

of the Secretary of Defense (OSD) dated 6 July 2022. The six compounds listed in the OSD 

memorandum are perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), 

perfluorobutanesulfonic acid (PFBS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic 

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1

. These compounds are 

collectively referred to as “relevant compounds” throughout this document, and the applicable 

Screening Levels (SLs) are provided below in Table ES-1. 

The PA identified one Area of Interest (AOI) where PFAS-containing materials may have been 

stored, disposed, or released historically (see Table ES-2 for AOI location). The objective of the 

SI is to identify whether there has been a release to the environment from the AOI identified in 

the PA and determine whether further investigation is warranted, a removal action is required to 

address immediate threats, or no further action is required based on a comparison of SI results to 

SLs for the relevant compounds. This SI was completed at the Wendell H. Ford Regional 

Training Center (WHFRTC) in Muhlenberg County, Kentucky, and determined that further 

investigation is warranted for AOI 1: Fire Station/Building 325. WHFRTC will also be referred 

to as “Facility” throughout this document. 

The Facility is operated by Kentucky ARNG (KYARNG) and encompasses approximately 

11,261 acres in west-central Muhlenberg County, Kentucky. WHFRTC is located

approximately 2,000 feet west of the corporate boundary of Central City and 4 miles north of 

Greenville. KYARNG began operating WHFRTC in 1969. Any structures that existed prior to 

KYARNG’s operation of WHFRTC were demolished by the Peabody Coal Company before 

they began their strip-mining operations. The Facility currently includes about 70 structures

consisting of the headquarters/administration building; a dining hall; five enlisted and four noncommissioned officer barracks; two field grade officers’ quarters; a fire station; various military 

operation training areas; two firing ranges; and various smaller outbuildings, control towers, and

storage sheds (AECOM Technical Services, Inc. [AECOM] 2019). 

The PA identified one AOI for investigation during the SI phase. SI sampling results from the 

AOI were compared to OSD SLs. Table ES-2 summarizes the SI results for the AOI. Based on 

the results of this SI, further evaluation under Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) is warranted in a remedial investigation for AOI 1.

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as 

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS. 
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Table ES-1. Screening Levels for Soil and Groundwater

Analyte1,2

Residential (Soil)

(0–2 feet bgs)

(μg/kg)1

Industrial/Commercial 

Composite Worker (Soil)

(2-15 feet bgs)

(μg/kg)1

Tap Water 

(Groundwater)

(ng/L)1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

1. Assistant Secretary of Defense. 2022. Risk Based Screening Levels in Groundwater and Soil 

using United States Environmental Protection Agency’s Regional Screening Level 

Calculator. Hazard Quotient =0.1. 6 July 2022. 

2. Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA 

(commonly referred to as GenX) was not included as an analyte at the time of this SI. Based 

on the CSM developed during the PA and revised based on SI findings, the presence of 

HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a component 

of MIL-SPEC AFFF and based on its history including distribution limitations that restricted 

use of GenX, it is generally not a component of other products the military used. In addition, 

it is unlikely that GenX would be an individual chemical of concern in the absence of other 

PFAS. 

Abbreviations:

μg/kg = microgram(s) per kilogram

bgs = below ground surface

ng/L = nanogram(s) per liter

Table ES-2. Summary of Site Inspection Findings and Recommendations

AOI Potential Release 

Area

Soil –

Source Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary Future Action

1 Fire Station/Building 

325 Proceed to RI

Legend:

 = detected; exceedance of screening levels.

 = detected; no exceedance of screening levels.

 = not detected.

Abbreviations:

RI = remedial investigation
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1. INTRODUCTION

1.1 PROJECT AUTHORIZATION

The Army National Guard (ARNG) G-9 is the lead agency in performing Preliminary 

Assessments (PAs) and Site Inspections (SIs) at ARNG facilities nationwide based on the current 

or potential historical use of per- and polyfluoroalkyl substances (PFAS) with a focus on the six 

compounds presented in the memorandum regarding Investigating Per- and Polyfluoroalkyl 

Substances within the Department of Defense Cleanup Program (Assistant Secretary of Defense, 

2022) from the Office of the Secretary of Defense (OSD) dated 6 July 2022. The six compounds 

listed in the OSD memorandum are referred to as “relevant compounds” throughout this 

document and include perfluorooctanesulfonic acid (PFOS), perfluorooctanoic acid (PFOA), 

perfluorobutanesulfonic acid (PFBS), perfluorononanoic acid (PFNA), perfluorohexanesulfonic 

acid (PFHxS), and hexafluoropropylene oxide dimer acid (HFPO-DA)1. The ARNG performed 

this SI at the Wendell H. Ford Regional Training Center (WHFRTC) in Muhlenberg County, 

Kentucky. WHFRTC is also referred to as the “Facility” throughout this report. 

The SI project elements were performed in accordance with the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) (U.S. Environmental Protection Agency 

[USEPA] 1980), as amended, the National Oil and Hazardous Substances Pollution Contingency 

Plan (40 Code of Federal Regulations Part 300; USEPA 1994), and in compliance with U.S. 

Department of Army (DA) requirements and guidance for field investigations. 

1.2 SITE INSPECTION PURPOSE

A PA was performed at WHFRTC (AECOM Technical Services, Inc. [AECOM] 2019) that 

identified one Area of Interest (AOI) where PFAS-containing materials may have been used, 

stored, disposed, or released historically. The objective of the SI is to identify whether there has 

been a release to the environment from the AOI identified in the PA and determine whether 

further investigation is warranted, a removal action is required to address immediate threats, or 

no further action is required based on screening levels (SLs) for the relevant compounds.

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as 

GenX) was not included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the facility because 

HFPO-DA is generally not a component of military specification (MIL-SPEC) aqueous film forming foam (AFFF) 

and based on its history including distribution limitations that restricted use of GenX, it is generally not a component 

of other products the military used. In addition, it is unlikely that GenX would be an individual chemical of concern 

in the absence of other PFAS. 
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2. FACILITY BACKGROUND

Information in this section was obtained from the Final Preliminary Assessment Report, Wendell 

H. Ford Regional Training Center, Kentucky (AECOM 2019), and updated with new 

information obtained during the SI as applicable.

2.1 FACILITY LOCATION AND DESCRIPTION

The WHFRTC, formerly referred to as the Western Kentucky Training Site, is located on

11,261 acres of state-owned reclaimed coal strip-mining land in west-central Muhlenberg

County, Kentucky. WHFRTC is located approximately 2,000 feet west of the corporate

boundary of Central City and 4 miles north of Greenville (Figure 2-1). The Facility is accessed

via Exit 53 on the Wendell H. Ford Western Kentucky Parkway at Kentucky Highway 181 

(AECOM 2019).

KYARNG began operating WHFRTC in 1969. Any structures that existed prior to KYARNG’s 

operation of WHFRTC were demolished by the Peabody Coal Company before they began their 

strip-mining operations. The Facility currently includes about 70 structures, consisting of the 

headquarters/administration building; a dining hall; five enlisted and four non-commissioned

officer barracks; two field grade officers’ quarters; a fire station; various military operation

training areas; two firing ranges; and various smaller outbuildings, control towers, and storage

sheds (AECOM 2019).

2.2 FACILITY ENVIRONMENTAL SETTING

WHFRTC lies within the Shawnee Hills section of the Interior Low Plateaus physiographic 

region, also known as the Western Kentucky Coalfield. Within the Shawnee Hills, the

Facility is situated near the middle of the Ohio River Hills and Lowlands subsections (AECOM 

2019).

The area surrounding WHFRTC is characterized by hilly uplands of low to moderate relief, 

dissected by streams, which occupy wide, poorly drained valleys. However, the topography of 

most of WHFRTC has been drastically changed by both surface and deep coal mining

operations. The elevation varies from approximately 395 feet above mean sea level along

Cypress Creek and Little Cypress Creek to just over 645 feet above mean sea level at the crests

of strip mine spoil banks near the southern boundary of the training area (AECOM 2019) 

(Figure 2-2).

Land cover at WHFRTC includes open grassland and shrubs (ideal for maneuver training 

exercises), pine and hardwood forest (ideal for dismounted training, bivouacking, and 

concealment), open water bodies, wetlands, and riparian areas along Little Cypress Creek and 

Cypress Creek, and the developed cantonment area. Numerous active or abandoned oil wells 

can be found in the western portion of the training area (AECOM 2019).

Portions of WHFRTC include reclaimed strip-mined land. The abandoned strip-mined areas

have very rugged topography with 50 feet or more of relief, whereas the reclaimed strip-mined

areas have gently rolling topography with less severe relief (AECOM 2019).
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2.2.1 Geology

WHFRTC is underlain by Recent soils, and by Pennsylvanian-aged bedrock from which coal, 

natural gas, and oil have been extracted. Part of the bedrock is of the Lisman Formation of Upper

Pennsylvanian age and part is of the Carbondale Formation of Middle Pennsylvanian age. These

formations are made up mostly of sandstone, siltstone, and shale. Thin beds of limestone, coal,

and clay also occur. Limestone layers include the Madisonville and Providence Members of the

Lisman Formation (AECOM 2019). 

According to a final environmental assessment contained in an attachment to the PA report 

(AECOM 2019), approximately 23% of WHFRTC soils have recently developed in parent 

materials disturbed during the surface mining for coal. These soils are loamy and contain a 

mixture of fine earth and rock fragments that once were bedrock layers above the coal seams. 

They generally comprise the central portion of the training area and are found on the uplands. 

Approximately 28% of soils occur naturally on the landscape, including silty alluvium on 

floodplains or in small upland depressions, and soils formed in loess and silty or clayey materials 

weathered from sandstone, siltstone, or shale bedrock. Approximately 46% of soils are stripmined areas that have been returned to original contour and covered with topsoil collected from 

original soils stockpiled prior to mining (AECOM 2019). The nature of the remaining 3% of Site 

soils was not detailed in the PA report.

Soil encountered during SI activities was largely consistent with the above expected lithology. 

Lean clay with some silt and sand with occasional iron staining was observed overlying bedrock 

within the borings. A sample for grain size analyses was collected at one location, AOI01-01, 

and analyzed via American Society for Testing and Materials (ASTM) International Method D442. The results indicate that the soil sample was composed primarily of silt (57.65%) and clay 

(18.49%). Grain size results are provided in Appendix G. This result and Facility observations 

are consistent with the reported depositional environment of the region.

Depth to bedrock in the borings ranged from approximately four to 13 feet below ground surface 

(bgs), and borings were completed at depths between 15 and 50 feet bgs. Bedrock underlying the 

soils consisted of sandstone and shale. The bedrock is mostly weak/weathered at the top and 

becomes less weathered and more competent with depth. Boring logs are presented in Appendix 

F.

2.2.2 Hydrogeology

Water-bearing units in the region are the Tradewater and the Caseyville Formations. These 

formations yield significant quantities of water but become saline with depth. Median depths to 

water level in the Tradewater and Caseyville Formations are 18.2 feet and 34.4 feet bgs,

respectively. Regional groundwater flow is toward the broad alluvial area along the Green River,

northeast of WHFRTC. No sole source aquifers have been designated in Kentucky. A freshwater

aquifer—approximately 1,100 feet bgs—lies several miles west of the Facility. The aquifer is

within the New Cypress Pool formation (AECOM 2019). 
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The natural water table and drainage patterns beneath WHFRTC have been altered by mining 

activities. Groundwater features are shown on Figure 2-3. The water table is relatively close to 

the surface throughout most of WHFRTC as a result of surface mining activities. Abandoned 

underground mines found in the Kentucky No. 9 coal seam beneath WHFRTC are known to 

be flooded. Water levels in ten monitoring wells located at WHFRTC ranged from 5 to 64 feet

bgs and averaged 29.74 feet bgs during a groundwater sampling event conducted in June 2004. 

Groundwater flow in the unconfined aquifer at the Facility is generally inferred to be to the 

northeast (AECOM 2019); however, a review of a topographic map for the Site indicates 

groundwater flow near AOI 1 may be to the north-northwest. AOI 1 is situated on a small rise 

and slopes downward to the west, northwest, north, and northeast. A topographic low area to the 

west and northwest of AOI 1 extends northwestward and likely influences the direction of 

groundwater flow from AOI 1. The first groundwater encountered during the SI at AOI 1 was 

observed near the soil/bedrock interface in two borings (WHFRTC-01 and AOI01-05) located at 

lower ground surface elevations than the nearby fire station, where AFFF has been stored 

historically. Groundwater was observed deeper in bedrock in two borings (AOI01-01 and 

AOI01-04) located at higher ground surface elevations closer to the fire station. During the SI, 

depth to groundwater at AOI 1 ranged from approximately 7 to 39 feet bgs, while one well 

(AOI01-02) was dry. Based on groundwater elevations calculated using depth to groundwater 

measurements and survey data collected during the SI (Figure 2-4), first encountered 

groundwater at AOI 1 flows generally to the north-northeast. 

The KYARNG indicated that possible subsurface obstructions from the effects of past Site 

mining activities may exist, and that shallow groundwater may not be continuous across the 

Facility (KYARNG 2021). Therefore, Sonic drilling technology was used to reach groundwater 

at WHFRTC.

Because of the proximity of the Green River, most water supplies are obtained from surfacewater. Public water supplies obtained from the Green River are available to local residents. 

Wells are not used to obtain drinking water (AECOM 2019). 

Peabody Coal Company maintained and monitored several groundwater monitoring points on 

the property, as required by previously held mining permits; however, this monitoring is 

no longer required. The Kentucky Geological Survey installed 10 groundwater wells on 

WHFRTC in the spring of 2001 to monitor groundwater quality and water level fluctuation in 

the soil through wet and dry seasons (spring and fall).

WSP USA Environment & Infrastructure Inc. (WSP), formerly doing business as Wood 

Environment & Infrastructure Solutions, Inc. (Wood) initiated a desktop survey of potential 

private and public water supply wells within a four-mile distance of the WHFRTC boundary to 

identify potential receptor pathways and downstream and/or downgradient receptors. The 

desktop survey included a review of a list of water supply wells provided by the Kentucky 

Geological Survey records (https://kgs.uky.edu/kgsweb/

datasearching/water/waterwellsearch.asp) and Kentucky Division of Water Maps Portal 

(https://watermaps.ky.gov). A total of 343 wells were identified within a four-mile distance of 

the installation (Figure 2-3). The 343 wells comprised two public water supply wells, 83 

domestic wells, 17 agricultural wells, 169 monitoring wells, eight remediation wells, 44 mining 
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wells, and 20 wells of unknown use. Both identified public water supply wells are located almost 

four miles south-southwest of WHFRTC (approximately 4.5 miles south-southwest of AOI 1) at 

an interpreted hydraulically upgradient location from AOI 1. The closest domestic well identified 

as being active and at an interpreted hydraulically downgradient location from AOI 1 is located 

more than five miles from the AOI. Three domestic wells with status identified as unknown are 

located between three and four miles from AOI 1 at an interpreted hydraulically downgradient 

location from AOI 1.

2.2.3 Hydrology

WHFRTC is situated in the Cypress Creek sub-basin of the Pond River Watershed Basin. The 

only major tributary to Cypress Creek is Little Cypress Creek. Cypress Creek originates in westcentral Muhlenberg County and flows 35.5 miles north and then west through McLean County 

before discharging into the Pond River 1.1 miles upstream from its confluence with the Green

River (AECOM 2019).

The immediate watershed receiving discharge from the Facility is Cypress Creek, which is a

low-gradient stream with 97% of its channel having been altered by channelization (AECOM 

2019).

The only other major tributary in the watershed is Little Cypress Creek (a second-order creek), 

which originates 4.16 miles north of Greenville and flows 9.32 miles in a northerly

direction before joining Cypress Creek northwest of Central City. Approximately 35% of

Cypress Creek and 44% of Little Cypress Creek were channelized during the 1920s.

Materials from dredging were placed into two spoil banks on either side of the creek, impeding 

the natural flow of water to adjacent wetlands (AECOM 2019).

WHFRTC is divided into 11 unique hydrologic planning units based on topography, direction of

water flow, and receiving perennial stream. Cypress Creek Watershed is divided into four subwatersheds, and Little Cypress Creek Watershed is divided into three sub-watersheds (AECOM 

2019).

Several small unnamed tributaries and intermittent streams cross the Facility and drain into 

Cypress Creek on the west and north and into Little Cypress Creek on the south and east. In 

addition to surface streams, there are numerous sediment retention basins and ponds and lakes on

the property related to mine reclamation activities. Surface water features are presented on 

Figure 2-5 (AECOM 2019).

2.2.4 Climate

Data from nearby Madisonville, Kentucky, indicate that the average annual temperature between 

1991 and 2021 was 58.8 degrees Fahrenheit (oF) (www.noaa.gov). The warmest months are July

and August, with normal daily mean temperatures of 79.6oF and 78.9oF, respectively.

January is the coldest month, with a mean temperature of 35.8oF. Average annual precipitation

measured from 1991 to 2021 in Madisonville, Kentucky was 48.2 inches. Rainfall is heaviest

during the month of April, averaging 4.64 inches; August is the driest month, averaging 2.99 

inches (https://en.climate-data.org).
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2.2.5 Current and Future Land Use

WHFRTC serves as the primary training area for KYARNG. The majority of training occurs

between June and October; however, training does occur throughout the remainder of the year 

(AECOM 2019).

WHFRTC is used almost entirely by military groups. Military users include units of the

KYARNG and Kentucky Air National Guard, the Army and Marine Reserves, active Army

units from Fort Knox and Fort Campbell, and Army schools. WHFRTC is also used for other

training activities for Reserve Components from Kentucky and surrounding states. Other users

include Youth Challenge, 4-H, Boy Scouts, Junior and Senior Reserve Officers’ Training Corps,

deer and turkey hunters (during scheduled hunts), Kentucky State Police, Department of

Corrections, and local law enforcement agencies (AECOM 2019).

Some expansion of the training facilities is in the planning phase; however, in general, the

future use of the Facility is not anticipated to change significantly (AECOM 2019). The Facility

is fenced and has restricted access. 

2.2.6 Sensitive Habitat and Threatened/Endangered Species

A wildlife survey has not occurred at the Facility. The following species are listed as federally 

endangered, threatened, proposed, and/or candidate species that could potentially be present at 

WHFRTC (USFWS 2021):

Clams:

• Clubshell, Pleurobema clava (endangered)

• Fanshell, Cyprogenia stegaria (endangered)

• Northern Riffleshell, Epioblasma torulosa rangiana (endangered)

• Pink Mucket (pearly mussel), Lampsilis abrupta (endangered)

• Purple Cat’s Paw, Epioblasma obliquata (endangered)

• Rabbitsfoot, Quadrula cylindrica (threatened)

• Ring Pink (mussel), Obovaria retusa (endangered)

• Rough Pigtoe, Pleurobema plenum (endangered)

• Sheepnose Mussel, Plethobasus cyphyus (endangered)

• Spectaclecase (mussel), Cumberlandia monodonta (endangered)

Mammals:

• Northern Long-Eared Bat, Myotis septentrionalis (threatened)

• Gray Bat, Myotis grisescens (threatened)

• Indiana Bat, Myotis sodalis (endangered)

2.3 HISTORY OF PFAS USE 

One potential PFAS release area (non-fire training area) was identified at the Facility during the 

PA (AECOM 2019). Interviews and records obtained during the PA indicate that the WHFRTC

Fire Department stores AFFF on two trucks kept at Fire Station/Building 325. Angus Tridol
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S 3% AFFF is stored in 5-gallon buckets on each truck and in a material storage room at the

fire station. Angus Tridex 3% AFFF is also stored in the fire station storage room, as well as

non-AFFF fire suppressants such as Purple K and ABC fire extinguishers. The fire chief stated

during interviews that AFFF concentrate has not spilled from their storage containers. Only

water and Class A foam have been used by the WHFRTC Fire Department on Facility, 

according to WHFRTC staff. Additionally, no crashes have occurred at WHFRTC that required 

fire department emergency response, and no fire training operations are performed by the fire 

department at WHFRTC. The WHFRTC Fire Department performs prescribed burns at the

Facility but uses only water to mitigate forest and wildfires. No fire department equipment

that uses AFFF is currently tested or washed out at WHFRTC. There is no fire suppression

system at Building 325. According to interviews with WHFRTC Fire Department staff, all

building fire suppression systems at WHFRTC use water or dry chemical suppression agents,

such as Purple K. There are no documented uses of AFFF at Building 325, or anywhere on

WHFRTC by the WHFRTC Fire Department.

The WHFRTC Fire Department used AFFF during a response to an off-Facility fire in Central

City in 2016. The WHFRTC Fire Chief reported that the fire truck used in response to the fire

was most likely washed at the WHFRTC fire station after responding to the fire. It is unclear

whether any AFFF deployed remained on the truck at the time of washing. 

A more detailed description of the AOI is presented in Section 3.
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Figure 2-1

Facility Location

3

0 4

Miles

Facility Boundary

) KY

Data Sources:

ESRI 2020

AECOM 2019

Date:.....................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

Facility Data

Wendell H. Ford RTC
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Figure 2-2

Facility Topography

3

0 2

Miles

Facility Boundary

) KY

Data Sources:

ESRI 2020

AECOM 2019

Date:....................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

Facility Data

Wendell H. Ford RTC
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Data Sources:

ESRI 2020

AECOM 2019

Date:.........................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

) KY

Facility Data

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Muhlenberg County, Kentucky

Figure 2-4

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Fire Station - 

Building 325

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Data Sources: 

ESRI 2020

AECOM 2019

Date:.......................October 2022

Prepared By:..........................WSP

Prepared For:....................USACE

Sample Type

!( Soil Boring/Temporary

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Area of Interest (AOI)

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) KY

Hydrogeology

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Adjacent Source:

Re-Tek Products, Inc

Current View Extent
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Figure 2-5

Surface Water Features

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3

0 2

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Data Sources:

ESRI 2020

AECOM 2019

Date:.........................January 2022

Prepared By:.........................WSP

Prepared For:....................USACE

Facility Data

Facility Boundary

Hydrology

Surface Water Flow Direction

River/Stream

Water Body

Watershed Boundary

) KY
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3. SUMMARY OF AREA OF INTEREST

The PA evaluated areas where PFAS-containing materials may have been used, stored, disposed, 

or released historically. One potential release area was identified at WHFRTC and designated as: 

AOI 1 Fire Station/Building 325. The AOI is shown on Figure 3-1.

3.1 AOI 1 – FIRE STATION/BUILDING 325

Building 325, the Facility fire station, is located in the northern portion of the cantonment area

at WHFRTC, east of the intersection of St-1032 and St-1026. The fire station was considered

a potential PFAS release site based on the storage of AFFF. The geographic coordinates for the

fire station are 37°26'03.60"N and 87°21'00.37"W. According to interviews with the 

Facility fire department staff, construction of Building 325 was completed in 2005 (AECOM 

2019).

WHFRTC Fire Department stores AFFF on two trucks kept at the fire station apparatus bay. 

Angus Tridol S 3% AFFF is stored in 5-gallon buckets on each truck and in a material storage 

room at the fire station. Angus Tridex 3% AFFF is also stored in the fire station storage room, as 

well as non-AFFF fire suppressants such as Purple K and ABC fire extinguishers. The fire

chief stated during interviews that AFFF concentrate has not spilled from their storage

containers. Only water and Class A foam have been used by the WHFRTC Fire Department

on Facility, according to WHFRTC staff. Additionally, no crashes have occurred at WHFRTC

that required fire department emergency response, and no fire training operations are performed

by the fire department at WHFRTC. WHFRTC Fire Department performs prescribed burns at

the Facility, but only uses water to mitigate forest and wildfires. No fire department

equipment that uses AFFF is currently tested or washed out at the Facility. There is no fire

suppression system at Building 325. According to interviews with WHFRTC Fire Department

staff, all building fire suppression systems at WHFRTC use water or dry chemical suppression

agents, such as Purple K. There are no documented uses of AFFF at Building 325, or

anywhere on Facility by the WHFRTC Fire Department (AECOM 2019).

The WHFRTC Fire Department used AFFF during response to an off-Facility fire in Central

City in 2016. The WHFRTC Fire Chief reported that the fire truck used in response to the fire

was most likely washed at the WHFRTC fire station after responding to the fire. It is unclear

whether any AFFF deployed remained on the truck at the time of washing. Floor drains

inside the building direct runoff through sand traps and into the Facility main sanitary sewer

system. The sanitary sewer system connects to the Greenville Wastewater Plant, located

approximately 3 miles southeast of the Facility. Runoff outside the station is channelized to a

stormwater outfall adjacent to Highway 181 east of the fire station (AECOM 2019).

3.2 ADJACENT SOURCES

One potential off-Facility source of PFAS is located adjacent to the Facility and is not under the 

control of the KYARNG. A description of the off-Facility source is presented below and shown 

on Figure 3-1. 
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3.2.1 Re-Tek Products, Inc.

WHFRTC has a mutual agreement to respond to emergencies within Muhlenberg County. 

According to the PA report, the WHFRTC Fire Department used AFFF during response to a

fire at a rubber warehouse owned by Re-Tek Products, Inc. located at 3320 Cleaton Road,

Central City, Kentucky, on 15 October 2016. The location of the fire is approximately 5.8 miles

east of WHFRTC at an interpreted cross-gradient (shallow groundwater flow) direction. During

their response, the WHFRTC Fire Department expelled water and AFFF. Approximately 75

gallons of AFFF was used to suppress the fire by the WHFRTC Fire Department, according to

the KYARNG incident report. Other local fire departments responded to the emergency,

including McLean County Fire Department. The WHFRTC Fire Chief reported that the fire

truck used in response to the fire was most likely washed at the WHFRTC fire station after 

responding to the fire (AECOM 2019).

The Re-Tek Products, Inc. fire location is identified as a potential release area. However, because

it is several miles outside the boundary of WHFRTC at an interpreted cross-gradient location, the

Re-Tek Products, Inc. fire area is not considered an adjacent off-Facility potential source of

PFAS for WHFRTC.
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Figure 3-1

Area of Interest

AOI 1

Ambulance Pick-Up Point

(Building 334) Helipad

Fire Station - Building 325

Dining Facility (DFAC) - Building 301

Little Cypress Creek

3

0 1,000

Feet

Data Sources: 

ESRI 2020

AECOM 2019

Date:........................October 2022

Prepared By:.........................WSP

Prepared For:....................USACE

!(

Current View Extent

Adjacent Source:

Re-Tek Products, Inc

Well Type

$1 Mining Well

A?@ Monitoring Well

Facility Data

Facility Boundary 

Area of Interest (AOI)

Potential PFAS Release Site

No Suspected Release

Hydrology/Hydrogeology

Surface Water Flow Direction

Inferred Shallow Groundwater Flow Direction

River/Stream

Water Body 

) KY
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4. PROJECT DATA QUALITY OBJECTIVES

As identified during the data quality objective (DQO) process and outlined in the SI Uniform 

Federal Policy - Quality Assurance Project Plan (UFP-QAPP) Addendum (EA/Wood 2021a), the 

objective of the SI is to identify whether there has been a release to the environment at the AOI 

identified in the PA. For each AOI, ARNG determines if further investigation is warranted, a 

removal action is required to address immediate threats, or whether no further action is 

warranted. This SI evaluated groundwater and soil for the presence or absence of relevant 

compounds at the sampled AOI.

4.1 PROBLEM STATEMENT

ARNG will recommend AOIs for remedial investigation (RI) if Facility-related soil and 

groundwater samples have concentrations of the relevant compounds above the OSD risk-based 

SLs. The SLs are presented in Section 6.1 of this report.

4.2 INFORMATION INPUTS

Primary information inputs for the SI include the following:

• The PA Report for WHFRTC (AECOM 2019)

• Analytical data from groundwater and soil samples collected as part of this SI in 

accordance with the site-specific UFP-QAPP Addendum (EA/Wood 2021a)

• Field data collected during the SI, including groundwater elevation and water quality 

parameters measured at the time of sampling.

4.3 STUDY BOUNDARIES

The scope of the SI was bounded horizontally by the property limits of the Facility (Figure 2-2). 

The scope of the SI was bounded vertically by the depth of temporary monitoring wells installed 

within groundwater, where encountered (maximum depth of 50 feet bgs). Off-Facility sampling 

was not included in the scope of this SI. If future off-Facility sampling is required, the proper 

stakeholders will be notified, and necessary rights of entry will be obtained by ARNG with 

property owner(s). Temporal boundaries were limited to the earliest available time field 

resources were available to complete the study.

4.4 ANALYTICAL APPROACH

Samples were analyzed by Eurofins, accredited under the DoD Environmental Laboratory 

Accreditation Program (DoD ELAP; Accreditation Number 1.01) and the National 

Environmental Laboratory Accreditation Program (NELAP; Certificate Number 021). PFAS data 

underwent 100 percent (%) Stage 2B validation in accordance with the DoD General Data 

Validation Guidelines (2019a) and DoD Data Validation Guidelines Module 3: Data Validation 

Procedure of Per- and Polyfluoroalkyl Substances Analysis by Quality Systems Manual (QSM) 

Table B-15 (2020). PFAS data were compared to applicable SLs within this document and 

decision rules as defined in the UFP-QAPP Addendum (EA/Wood 2021a).
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4.5 DATA USABILITY ASSESSMENT

The Data Usability Assessment, which is provided in Appendix A, is an evaluation at the 

conclusion of data collection activities that uses the results of both data verification and 

validation in the context of the overall project decisions or objectives. Using both quantitative 

and qualitative methods, the assessment determines whether project execution and the resulting 

data have met installation specific DQOs. Both sampling and analytical activities are considered 

to assess whether the collected data are of the right type, quality, and quantity to support the 

decision-making (DoD 2019a, DoD 2019b, USEPA 2017). 

The environmental data collected during the SI were found to be acceptable and usable for this 

SI evaluation with the qualifications documented in the Data Usability Assessment and its 

associated data validation reports. These data are of sufficient quality to meet the objectives and 

requirements of the UFP-QAPP Addendum (EA/Wood 2021a).
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5. SITE INSPECTION ACTIVITIES 

This section describes the environmental investigation and sampling activities that occurred as 

part of the SI. The SI sampling approach was based on the findings of the PA and was 

implemented in accordance with the following approved documents. 

• Final Preliminary Assessment Report, Wendell H. Ford Regional Training 

Center, Kentucky, dated January 2019 (AECOM 2019)

• Final Programmatic Uniform Federal Policy-Quality Assurance Project Plan,

Site Inspections for Per- and Polyfluoroalkyl Substances Impacted Sites, ARNG 

Installations, Nationwide, dated December 2020 (EA 2020a)

• Final Site Inspection Uniform Federal Policy-Quality Assurance Project Plan 

Addendum, Wendell H. Ford Regional Training Center, Muhlenberg County, 

Kentucky dated August 2021 (EA/Wood 2021a)

• Final Programmatic Accident Prevention Plan, Revision 1, dated November 2020

(EA 2020b)

• Final Accident Prevention Plan/Site Safety and Health Plan Addendum, Wendell 

H. Ford Regional Training Center, Kentucky, dated April 2021 (EA/Wood

2021b). 

The SI field activities were conducted from 15 through 22 November 2021 and consisted 

of utility clearance, Sonic drilling technology boring and soil sample collection, 

temporary monitoring well installation, grab groundwater sample collection, and land 

surveying. Field activities were conducted in accordance with the UFP-QAPP Addendum 

(EA/Wood 2021a), except as noted in Section 5.8.

The following samples were collected during the SI and analyzed for 24 compounds via 

liquid chromatography/tandem mass spectrometry (LC/MS/MS) compliant with QSM 

Version 5.3 Table B-15 to fulfill the project DQOs:

• Eight soil samples from three locations (soil borings);

• Five grab groundwater samples from five of six temporary well locations;

• Eight quality assurance/quality control (QA/QC) samples.

Figure 5-1 provides the sample locations for all media across the Facility. Table 5-1

presents the list of samples collected for each medium. Field documentation is provided 

in Appendix B. A log of Daily Notice of Field Activity was completed throughout the SI 

field activities, which is provided in Appendix B1. Sampling forms are provided in 

Appendix B2, land survey data are provided in Appendix B3, and investigation-derived 

waste (IDW) placement data are provided in Appendix B4. Additionally, a photographic 

log of field activities is provided in Appendix C. 
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5.1 PRE-INVESTIGATION ACTIVITIES

In preparation for the SI field activities, project team members participated in Technical Project 

Planning (TPP) meetings, performed utility clearance, and sampled decontamination source 

water. Details of these activities are presented below. 

5.1.1 Technical Project Planning

The U.S. Army Corps of Engineers (USACE) TPP Process, Engineers Manual 200-1-2 (USACE

2016) defines four phases to project planning: (1) defining the project phase; (2) determining 

data needs; (3) developing data collection strategies; and (4) finalizing the data collection plan. 

The process encourages stakeholder involvement in the SI, beginning with defining overall 

project objectives, including DQOs, and formulating a sampling approach to address the AOI 

identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 30 June 2021, prior to SI field activities. The 

combined TPP Meeting 1 and 2 was conducted in general accordance with Engineer Manual 

200-1-2 (DA 2018). The stakeholders for this SI included ARNG, KYARNG, USACE, 

Kentucky Department for Environmental Protection, and representatives familiar with the 

Facility, the regulations, and the community. Stakeholders were provided the opportunity to 

make comments on the technical sampling approach and methods at the combined TPP Meeting 

1 and 2. The outcome of the combined TPP Meeting 1 and 2 was memorialized in the UFPQAPP Addendum (EA/Wood 2021a). 

A TPP Meeting 3 was held after the field event to discuss the results of the SI. Meeting minutes 

for the TPP 3 are included in Appendix D of this report. Future TPP meetings will provide an 

opportunity to discuss results and findings, and future actions, where warranted. 

5.1.2 Utility Clearance

WSP contacted the Utility Notification Center (Kentucky 811) to notify them of intrusive work 

at the Facility. WSP contracted Blood Hound, a private utility location service, to perform utility 

clearance at the Facility. Utility clearance was performed at each of the proposed boring 

locations on 10 November 2021 with input from the WSP field team. General locating services 

and ground-penetrating radar were used to complete the clearance. Additionally, the first 5 feet 

of each boring were pre-cleared by WSP’s drilling subcontractor, GSE, Inc., using a hand auger 

to verify utility clearance in shallow subsurface where utilities would typically be encountered. 

5.1.3 Source Water and PFAS Sampling Equipment Acceptability

The potable water source used for decontamination of drilling equipment was evaluated to 

determine if it was PFAS-free prior to the start of field activities. A sample from a potable water 

source at the Facility fire station, was collected on 27 July 2021, prior to mobilization, and 

analyzed for PFAS by LC/MS/MS compliant with QSM 5.3 Table B-15. The results of the 

sample of the potable water source used for decontamination of drilling equipment during the SI 

(WHFPOT01) are provided in Appendix E. A discussion of the results is presented in the Data 

Usability Assessment (Appendix A).
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Materials that were used within the sampling zone were confirmed as acceptable for use in the 

PFAS sampling environment. The checklist of acceptable materials for use in the PFAS sampling 

environment was provided in the Standard Operating Procedures appendix to the Programmatic 

UFP-QAPP (EA/Wood 2021a). 

5.2 SOIL BORINGS AND SOIL SAMPLING

Soil samples were collected via Sonic drilling methods in accordance with Standard Operating 

Procedure 019, Monitoring Well Installation (EA 2014). A TSi 150CC track-mounted Sonic drill 

rig sampling system was used to collect continuous soil cores to the target depth. A hand auger 

was used to collect soil from the top 5 feet of the boring in compliance with utility clearance 

procedures. The soil boring locations are shown on Figure 5-1, and boring sample depths are 

provided in Table 5-1. Certain boring locations were adjusted slightly (less than 50-foot offset)

for reasons including drill rig access, utility avoidance and bias toward sampling within observed 

drainage features.

Three discrete soil samples were planned to be collected for chemical analysis from each of the 

three soil borings: one sample at the surface (0 to 2 feet bgs) and two subsurface soil samples. 

One subsurface soil sample was to be collected approximately 1 foot above the groundwater 

table, and one subsurface sample was to be collected at the mid-point between the surface and 

the groundwater table (not to exceed 15 feet bgs). However, the UFP-QAPP Addendum 

(EA/Wood 2021a) specified only two samples be collected if refusal was encountered at 6 feet 

bgs or shallower. Because shallow bedrock was encountered less than 6 feet bgs at one soil 

boring location (AOI01-03), only two soil samples were collected at this location. Three soil 

samples were collected at the other two soil boring locations.

During drilling, the uppermost saturated zone was observed at depths ranging from 

approximately 10 to 30 feet bgs in three borings (AOI01-04, AOI01-05, and WHFRTC-01) and 

was not observed in three other borings (AOI01-01 through AOI01-03). Following installation of 

temporary monitoring wells, the static groundwater depths in five of the wells ranged from 

approximately 7 to 39 feet bgs, while one well (AOI01-02) was dry. 

The soil cores were continuously logged for lithological descriptions by a field geologist using 

the Unified Soil Classification System. A photoionization detector (PID) was used to screen the 

breathing zone during boring activities as a part of personal safety requirements. Observations 

and measurements were recorded on sampling forms (Appendix B2) and in a non-treated field 

logbook. Depth interval, recovery thickness, PID concentrations, moisture, relative density, 

Munsell color, and Unified Soil Classification System texture were recorded. The boring logs are 

provided in Appendix F. Bedrock encountered underlying the soils consisted of weathered and 

unweathered shale and sandstone.

Each sample was collected into a laboratory-supplied PFAS-free high-density polyethylene 

(HDPE) bottle and labeled using a PFAS-free marker or pen. Samples were packaged on ice and 

transported via Federal Express under standard chain-of-custody procedures to the laboratory 

and analyzed for PFAS (LC/MS/MS compliant with QSM Version 5.3 Table B-15), total organic 

carbon (TOC) (EPA Method 9060A), pH (USEPA Method 9045D), and grain size (ASTM 
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International Method D-422 and USEPA Method 9045D), in accordance with the UFP-QAPP 

Addendum (EA/Wood 2021a). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. Matrix spike/matrix spike duplicate (MS/MSD) samples were 

collected at a rate of 5% and analyzed for the same parameters as the accompanying samples. In 

instances when non-dedicated sampling equipment was used, such as a hand auger for the 

shallow soil samples, one equipment blank was collected per day and analyzed for the same 

parameters as the soil samples. A temperature blank was placed in each cooler for use in 

confirming that samples were preserved at or below 6 degrees Celsius (°C) during shipment. 

Sonic borings were converted to temporary wells, which were subsequently abandoned after 

sampling and surveying in accordance with the UFP-QAPP Addendum (EA/Wood 2021a). After 

removal of the casings, boreholes were abandoned using bentonite chips. Borings were installed 

in grass areas to avoid disturbing concrete or asphalt surfaces. 

5.3 TEMPORARY WELL INSTALLATION AND GROUNDWATER GRAB 

SAMPLING

Temporary wells were installed using a TSi 150CC track-mounted Sonic-drill rig sampling 

system. Once the borehole was advanced to the desired depth, a temporary well was constructed 

of a 10-foot section of 1-inch Schedule 40 polyvinyl chloride (PVC) screen with sufficient casing 

to reach the ground surface. New PVC pipe and screen were used at each location to avoid cross 

contamination between locations. The screen intervals for the temporary wells are provided in 

Table 5-2.

Groundwater samples were collected using a PFAS-free 0.85-inch Geotech Bladder pump with 

PFAS-free HDPE tubing. Samples were collected after a period of time following well 

installation to allow groundwater to infiltrate and recharge the temporary well intervals. The 

temporary wells were purged at a rate determined in the field to reduce turbidity and draw down 

prior to sampling. Water quality parameters (e.g., temperature, specific conductance, pH, 

dissolved oxygen, and oxidation-reduction potential) were measured using a water quality meter 

and recorded on the field sampling form (Appendix B2) before each grab sample was collected 

in a separate container. Additionally, a subsample of each groundwater sample was collected in a 

separate container, and a shaker test was completed to identify if there was any foaming. No 

foaming was noted in any of the groundwater samples.

Each sample was collected in laboratory-supplied PFAS-free HDPE bottles and labeled using a 

PFAS-free marker or pen. Samples were packaged on ice and transported via Federal Express 

under standard chain-of-custody procedures to the laboratory and analyzed for PFAS by 

LC/MS/MS compliant with QSM Version 5.3 Table B-15 in accordance with the UFP-QAPP 

Addendum (EA/Wood 2021a). 

Field duplicate samples were collected at a rate of 10% and analyzed for the same parameters as 

the accompanying samples. MS/MSDs were collected at a rate of 5% and analyzed for the same 

parameters as the accompanying samples. Two field blanks were collected in accordance with 

the UFP-QAPP Addendum (EA/Wood 2021a). In instances when non-dedicated sampling 
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equipment was used, such as a bladder pump, one equipment blank per day was collected and 

analyzed for the same parameters as the groundwater samples. A temperature blank was placed 

in each cooler for use in confirming that samples were preserved at or below 6°C during 

shipment. 

Following well surveying (described below in Section 5.5), temporary wells were abandoned in 

accordance with the SI UFP-QAPP Addendum (EA/Wood 2021a) by removing the PVC and 

backfilling the hole with bentonite chips. 

5.4 SYNOPTIC WATER LEVEL MEASUREMENTS

A synoptic groundwater gauging event was performed on 22 November 2021. Groundwater 

elevation measurements were collected from the new temporary monitoring wells. Water level 

measurements were taken from the survey mark on the northern side of the well casing. 

Groundwater elevation data are provided in Table 5-3. A groundwater flow contour map is 

provided as Figure 2-4. 

5.5 SURVEYING

The northern side of each new temporary well casing was surveyed using a Carlson BRx7 GNSS 

Receiver and the Kentucky Transportation Cabinet VRS System. Positions were collected in the 

applicable Universal Transverse Mercator zone projection with World Geodetic System 1984 

datum (horizontal) and North American Vertical Datum 1988 (vertical). Surveying data were 

collected on 22 November 2021 and are provided in Appendix B3. 

5.6 INVESTIGATION-DERIVED WASTE 

As of the date of this report, the disposal of PFAS IDW is not regulated federally. IDW 

generated during the SI is considered non-hazardous waste and was managed in accordance with 

the UFP-QAPP Addendum (EA/Wood 2021a) and with the DA Guidance for Addressing 

Releases of PFAS, Q18 (DA, 2018). 

Soil IDW (i.e., soil and rock cuttings) generated during the SI activities were distributed on the 

downgradient side of the borehole, while liquid IDW (i.e., purge water and decontamination 

fluids) was discharged directly to the ground surface slightly downgradient of the source of 

generation. The IDW was not sampled and assumes the characteristics of the associated soil or 

groundwater samples collected from that source location. Geographic coordinates were collected 

using a Global positioning system (GPS) around each location where IDW was placed. A map 

depicting the locations of the IDW placement with coordinates is provided in Appendix B4. 

Other solids such as spent personal protective equipment, plastic sheeting, tubing, rope, unused 

monitoring well construction materials, and other environmental media generated during the 

field activities were disposed of at a licensed solid waste landfill. 
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5.7 LABORATORY ANALYTICAL METHODS

Samples were analyzed by LC/MS/MS, compliant with QSM Version 5.3 Table B-15 (DoD, 

2020), at Eurofins in Lancaster, Pennsylvania, a DoD ELAP and NELAP-certified laboratory. 

Soil samples were also analyzed for TOC using EPA Method 9060A, pH by EPA Method 

9045D, and grain size by ASTM D422.

5.8 DEVIATIONS FROM SI UFP-QAPP ADDEMDUM

Deviations from the UFP-QAPP Addendum occurred based on conditions encountered during 

field activities. These deviations were discussed between EA, Wood, the ARNG, and/or USACE, 

as applicable. Deviations from the UFP-QAPP Addendum (EA/Wood 2021a) are noted below: 

• For temporary monitoring wells, a 10-foot screen was used rather than a 5-foot screen, 

based on observations during drilling to attempt to screen the wells across the 

groundwater zone. In spite of the longer screen the water table in temporary monitoring 

well AOI01-03 was above the top of the screen.

• At location AOI01-02 the boring was advanced to 40 feet bgs. Apparent groundwater was 

not observed during drilling; however, considering the depth, the advancement of the 

boring 31 feet into bedrock, and the depths to water in the other wells installed (7.74 to 

36.76 feet bgs), a temporary monitoring well was installed. The well remained dry for the 

duration of the SI field efforts. Therefore, a groundwater sample was not collected from 

this location. 
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Table 5-1. Site Inspection Samples by Medium

Sample Identification Sample Collection Date Sample Depth (feet bgs) PFAS1 TOC2 pH3 Grain Size4 Comments

Soil Samples

AOI01-01-SB-(0-2) 18 Nov 2021 0-2 X X X X

AOI01-01-SB-(3-5) 18 Nov 2021 3-5 X

AOI01-01-SB-(6-7) 18 Nov 2021 6-7 X

AOI01-02-SB-(0-2) 17 Nov 2021 0-2 X MS/MSD

AOI01-02-SB-(4-6) 17 Nov 2021 4-6 X

AOI01-02-SB-(8-9) 17 Nov 2021 8-9 X

AOI01-03-SB-(0-2) 18 Nov 2021 0-2 X

AOI01-03-SB-(2.5-3) 18 Nov 2021 2.5-3 X

WHFRTC-DUP-01 18 Nov 2021 0-2 X AOI01-01-SB-(0-2)

Groundwater Samples

WHFRTC-01-GW 20 Nov 2021 X

AOI01-01-GW 22 Nov 2021 X

AOI01-03-GW 22 Nov 2021 X

AOI01-04-GW 20 Nov 2021 X MS/MSD

AOI01-05-GW 20 Nov 2021 X

WHFRTC-DUP-02 20 Nov 2021 X WHFRTC-01-GW

Blank Samples

WHFRTC-EB-01 17 Nov 2021 X

WHFRTC-EB-02 18 Nov 2021 X

WHFRTC-EB-03 20 Nov 2021 X

WHFRTC-EB-04 22 Nov 2021 X

WHFRTC-FB-01 20 Nov 2021 X

WHFRTC-FB-02 22 Nov 2021 X

Notes: Abbreviations:

1. PFAS were analyzed by LC/MS/MS compliant with QSM 5.3 Table B-15. bgs = below ground surface

2. TOC was analyzed using USEPA Method 9060A. DUP = field duplicate

3. pH was analyzed using USEPA Method 9045D. EB = equipment rinsate blank

4. Grain size was analyzed using ASTM International Method D-422. FB = field reagent blank

MS/MSD = matrix spike/ matrix spike duplicate

PFAS = per- and polyfluoroalkyl substances

TOC = total organic carbon

USEPA = United States Environmental Protection Agency
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Table 5-2. Soil Boring Depths and Temporary Well Screen Intervals

Area of Interest Boring Location

Soil Boring Depth

(feet bgs)

Temporary Well Screen Interval

(feet bgs)

1 

AOI01-01 38 28–38

AOI01-02 40 24.6–34.6

AOI01-03 50 39–49

AOI01-04 35 25–35

AOI01-05 15 5–15

Upgradient WHFRTC-01 16 5.4–15.4

Abbreviations:

bgs = below ground surface
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Table 5-3. Groundwater Elevation 

Monitoring Well ID

Top of Casing Elevation

(feet NAVD88)

Depth to Water

(feet btoc)

Groundwater Elevation

(feet NAVD 88)

AOI01-01 508.39 38.98 469.41

AOI01-02 504.89 DRY DRY

AOI01-03 508.64 18.56 490.08

AOI01-04 506.12 31.42 474.70

AOI01-05 494.61 13.38 481.23

WHFRTC-01 514.05 6.82 507.23

Abbreviations: 

btoc = below top of casing

NAVD88 = North American Vertical Datum of 1988
Army National Guard Site Inspections

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Figure 5-1

Site Inspection Sample Locations

!(

!( !(

!(

!(

WHFRTC-01 !(

AOI01-01

AOI01-02

AOI01-03

AOI01-04

Fire Station -

Building 325

AOI 1

AOI01-05

3

0 500

Feet

Data Sources:

ESRI 2020

AECOM 2019

Date:........................January 2022

Prepared By:........................WSP

Prepared For:....................USACE

Sample Type

!( Soil Boring/Temporary

Monitoring Well

!( Temporary Monitoring Well

Facility Data

Area of Interest (AOI)

Potential PFAS Release Site

Hydrogeology

Inferred Groundwater Flow

Direction

) KY
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6. SITE INSPECTION RESULTS

This section presents the analytical results of the SI. The SLs for relevant compounds, for both 

soil and groundwater, are presented in Table 6-1 in Section 6.1. A discussion of the results for 

the AOI is provided in Section 6.3. Table 6-2 through Table 6-5 present results in soil or 

groundwater for the relevant compounds. Tables that contain all results are provided in 

Appendix G, and the laboratory reports are provided in Appendix E. 

6.1 SCREENING LEVELS

The DoD has adopted a policy to retain facilities in the CERCLA process based on risk-based 

SLs for soil and groundwater, as described in an OSD memorandum (Assistant Secretary of 

Defense 2022). The ARNG program under which this SI was performed follows this DoD 

policy. Should the maximum concentration for sampled media exceed the SLs established in the 

OSD memorandum, the AOI will proceed to the next phase under CERCLA. The SLs 

established in the OSD memorandum apply to the five compounds presented on Table 6-1. 

Table 6-1. Screening Levels for Soil and Groundwater

Analyte1,2

Residential Soil

(0–2 feet bgs)

(μg/kg)1

Industrial/Commercial 

Composite Worker Soil

(2–15 feet bgs)

(μg/kg)1

Tap Water 

(Groundwater)

(ng/L)1

PFOA 19 250 6

PFOS 13 160 4

PFBS 1,900 25,000 601

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

1. Assistant Secretary of Defense. 2022. Risk Based Screening Levels in Groundwater and Soil using 

United States Environmental Protection Agency’s Regional Screening Level Calculator. Hazard Quotient 

=0.1. 6 July 2022.

2. Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly 

referred to as GenX) was not included as an analyte at the time of this SI. Based on the CSM developed 

during the PA and revised based on SI findings, the presence of HFPO-DA is not anticipated at the 

facility because HFPO-DA is generally not a component of MIL-SPEC AFFF and based on its history 

including distribution limitations that restricted use of GenX, it is generally not a component of other 

products the military used. In addition, it is unlikely that GenX would be an individual chemical of 

concern in the absence of other PFAS. 

Abbreviations:

μg/kg = microgram(s) per kilogram

CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act

HFPO-DA hexafluoropropylene oxide dimer acid

ng/L = nanogram(s) per liter

PFBS = perfluorobutanesulfonic acid

PFHxS = perfluorohexanesulfonic acid

PFNA = perfluorononanoic acid

PFOA = perfluorooctanoic acid

PFOS = perfluorooctanesulfonic acid
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The data in the subsequent sections are compared against the SLs presented in Table 6-1. The 

SLs for groundwater are based on direct ingestion. The SLs for soil are based on incidental 

ingestion and are applied to the depth intervals reasonably anticipated to be encountered by the 

receptors identified at the Facility: the residential scenario is applied to surface soil results (0 to 2 

feet bgs) and the industrial/commercial worker scenario is applied to shallow subsurface soil 

results (2 to 15 feet bgs). The SLs are not applied to deep subsurface soil results (>15 feet bgs) 

because 15 feet is the anticipated limit of construction activities. 

6.2 SOIL PHYSICOCHEMICAL ANALYSES

To provide basic soil parameter information, soil samples were analyzed for TOC, pH, and grain 

size, which are important for evaluating transport through the soil medium. Appendix E contains 

the results of the TOC, pH, and grain size sampling. TOC in the samples collected at AOI 1 was 

3,900 milligrams per kilogram. The grain size results correlate with the clays, silts, and sands 

observed during drilling activities. Soil pH in the sample collected at AOI 1 was 6.1 Standard 

Units.

The data collected in this investigation will be used in subsequent investigations, where 

appropriate, to assess fate and transport. According to the Interstate Technology Regulatory 

Council, important PFAS partitioning mechanisms include hydrophobic and lipophobic effects, 

electrostatic interactions, and interfacial behaviors. At relevant environmental pH values, certain 

PFAS are present as organic anions, and are therefore relatively mobile in groundwater (Xiao et 

al. 2015) but tend to associate with the organic carbon fraction that may be present in soil or 

sediment (Higgins and Luthy 2006, Guelfo and Higgins 2013). When sufficient organic carbon is 

present, organic carbon normalized distribution coefficients (Koc values) can help in evaluating 

transport potential, although other geochemical factors (for example, pH and presence of 

polyvalent cations) may also affect PFAS sorption to solid phases (ITRC 2018). 

6.3 AOI 1 

This section presents the analytical results for soil and groundwater in comparison to SLs for 

AOI 1: Fire Station/Building 325. The soil and groundwater results are summarized in Table 6-2

through Table 6-5. Soil and groundwater results are presented on Figure 6-1 through Figure 6-

7.

6.3.1 AOI 1 Soil Analytical Results

Soil samples were collected from three boring locations associated with AOI 1 during the SI. 

Figure 6-1 through Figure 6-5 present the ranges of detections in soil. Tables 6-2 through Table 

6-4 summarize the soil results.

Surface soil (0 to 2 feet bgs) was sampled from boring locations AOI01-01 through AOI01-03. 

Soil was also sampled from shallow subsurface soil (2.5 to 6 feet bgs) in the three borings and 

from deep subsurface soil intervals (6 to 9 feet bgs) from boring locations AOI01-01 and AOI01-

02. PFOA, PFOS, PFHxS, and PFNA were detected in surface soil at concentrations below their 

respective SLs. PFOS was detected in one of three surface soil samples at a concentration of 2.3 

J+ micrograms per kilogram (μg/kg); PFOA was detected in one of three surface soil samples at 
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a concentration of 0.8 J+ μg/kg; PFHxS was detected in one of three surface soil samples at a 

concentration of 0.65 J μg/kg; and PFNA was detected in one of three surface soil samples at a 

concentration of 0.56 J μg/kg. PFBS was not detected in the surface soil samples.

PFHxS was detected in shallow subsurface soil at a concentration below the SL. PFHxS was 

detected in one of three shallow subsurface soil samples at a concentration of 0.75 J μg/kg. 

PFOA, PFOS, PFNA, and PFBS were not detected in the shallow subsurface samples.

No PFOA, PFOS, PFBS, PFHxS, or PFNA were detected in deep subsurface soil.

6.3.2 AOI 1 Groundwater Analytical Results 

Groundwater samples were collected from five of six temporary monitoring wells at AOI 1

(AOI01-01, AOI01-03, AOI01-04, AOI04-05, and WHFRTC-01). Monitoring well AOI01-02, 

which was installed adjacent to the fire station driveway, was dry following installation. 

Considering sample location WHFRTC-01 (upgradient of AOI 1) was not at the WHFRTC 

installation boundary and the potential for off-Facility groundwater flow variations, there is some 

uncertainty as to whether location WHFRTC-01 identified any off-Facility PFAS releases. 

Figure 6-6 and Figure 6-7 present the ranges of detections in groundwater. Table 6-5 

summarizes the groundwater results.

PFOS and PFOA were detected at concentrations exceeding their respective SLs. PFOS was 

detected in three of five groundwater samples collected at AOI 1 at concentrations ranging from 

2.4 J+ ng/L to 9 ng/L, and it exceeded the SL at one location (AOI01-03). PFOA was detected in 

three of five groundwater samples at concentrations ranging from 2.5 ng/L to 32 ng/L, and it 

exceeded the SL at two locations (AOI01-03 and AOI01-05). PFBS, PFHxS, and PFNA were 

detected at concentrations below their respective SLs. PFBS was detected in three of five

groundwater samples at concentrations ranging from 1.5 J ng/L to 5.9 ng/L; PFHxS was detected 

in two of four groundwater samples at concentrations of 14 ng/L; and PFNA was detected in 

three of five groundwater samples at concentrations ranging from 1 ng/L to 3.9 ng/L.

6.3.3 Conclusions

The results of the SI showed that four PFAS constituents (PFOS, PFOA, PFHxS, and PFNA) 

were detected in soil, none of which exceeded their screening levels (See Tables 6-2 to 6-4). 

PFOS and PFOA were detected in groundwater at AOI 1 above their respective SLs, while 

PFBS, PFHxS, and PFNA were detected in groundwater at concentrations below their respective 

SLs. Based on the exceedances of the SLs in groundwater, further evaluation at AOI 1 is 

warranted.
Table 6-2

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Surface Soil

Site Inspection Report, Wendell H. Ford Regional Training Center, Kentucky

Analyte OSD Screening Level1,2 Result Qual Result Qual Result Q

Soil, PFAS3 (μg/kg)

PFBS 1900 ND ND ND 

PFOA 19 ND ND ND PFNA 19 ND ND ND PFHxS 130 ND ND ND PFOS 13 ND ND ND Notes Chemical Abbrev

Gray Fill Detected concentration exceeded OSD Screening Level PFBS Perfl

PFHxS Perfl

References PFNA Perfl

PFOS PerflPFOA Perfl

2. The Screening Levels for soil are based on a residential scenario for direct ingestion of contaminated soil. Acronyms and A

3. PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15

AOI Area 

Interpreted Qualifiers ft Feet

J = Estimated concentration LC/MS/MSliqui

J+ = Estimated quantity but may bias high ND analy

OSD OfficPFAS per- QSM QualQual interpμg/kg micr

Sample Name

Sample Date 11/17/2021

Depth 0-2 ft

Parent Sample ID

0-2 ft

11/18/2021

AOI01-01-SB-(0-2)

0-2 ft

11/18/2021

AOI 1

AOI01-01

AOI01-01-SB-(0-2)

AOI01-01

WHFRTC-DUP-01

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection Agency’s Regional Screening Level Calculator. Hazard Quotient (HQ)=0.1 . May 2022. 

Area of Interest 

Location ID AOI01-02

AOI01-02-SB-
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Table 6-3

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Shallow Subsurface Soil

Site Inspection Report, Wendell H. Ford Regional Training Center, Kentucky

Analyte OSD Screening Level1, 2 Result Qual Result Qual Result Qual

Soil, PFAS3 (μg/kg)

PFBS 25000 ND ND ND

PFOA 250 ND ND ND

PFNA 250 ND ND ND

PFHxS 1600 ND ND 0.75 J

PFOS 160 ND ND ND

Notes Chemical Abbreviations

Gray Fill Detected concentration exceeded OSD Screening Level PFBS Perfluorobutanesulfonic acid 

PFHxS Perfluorohexanesulfonic acid 

References PFNA Perfluorononanoic acid 

PFOS Perfluorooctanesulfonic acid PFOA Perfluorooctanoic acid 

2. The SL for soil is based on incidental ingestion of soil industrial/commercial worker >2 ft. Acronyms and Abbreviations

3. PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15

AOI Area of Interest

Interpreted Qualifiers ft Feet

J = Estimated concentration LC/MS/MS liquid chromatography tandem mass spectrometry

ND analyte not detected above the LOD (LOD values are presenteOSD Office of the Secretary of DefensePFAS per- and polyfluoralkyl substancesQSM Quality Systems ManualQual interpreted qualifierμg/kg micrograms/kilogram

11/18/2021

Area of Interest 

Sample Date

Depth

Parent Sample ID

Sample Name

Location ID

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection Agency’s Regional Screening Level Calculator. Hazard Quotient (HQ)=0.1 . May 2022. 

AOI-01

4-6 ft

11/17/2021

AOI01-02-SB-(4-6)

AOI01-02 AOI01-03

AOI01-03-SB-(2.5-3)

2.5-3 ft

11/18/2021

AOI01-01

AOI01-01-SB-(3-5)

3-5 ft
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Table 6-4

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Deep Subsurfa

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Analyte OSD Screening Level1, 2 Result Qual Result Qual

Soil, PFAS3 (μg/kg)

PFBS 25000 ND NDPFOA 250 ND NDPFNA 250 ND NDPFHxS 1600 ND NDPFOS 160 ND NDNotes

Gray Fill Detected concentration exceeded OSD Screening LevelReferences2. The SL for soil is based on incidental ingestion of soil industrial/commercial worker >2 ft. 3. PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15Chemical AbbreviationsPFBS Perfluorobutanesulfonic acid PFHxS Perfluorohexanesulfonic acid PFNA Perfluorononanoic acid PFOS Perfluorooctanesulfonic acid PFOA Perfluorooctanoic acid Acronyms and AbbreviationsAOI Area of Interestft FeetLC/MS/MS liquid chromatography tandem mass spectrometryND analyte not detected above the LOD (LOD values are presented in Appendix E)OSD Office of the Secretary of DefensePFAS per- and polyfluoralkyl substancesQSM Quality Systems ManualQual interpreted qualifierμg/kg micrograms/kilogram

Parent Sample ID

Sample Name AOI01-01-SB-(6-7) AOI01-02-SB-(8-9)

Area of Interest AOI 1

Location ID AOI01-01 AOI01-02

11/17/2021

Depth 6-7 ft 8-9 ft

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection Agency’s Regional Screening Level Calculator. Hazard Quotient (HQ)=0.1. May 2022. 

Sample Date 11/18/2021
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Table 6-5

PFOA, PFOS, PFBS, PFNA, and PFHxS Results in Groundwater

Site Inspection Report, Wendell H. Ford Regional Training Center, Kentucky

Analyte OSD Screening Level1 Result Qual Result Qual Result Qual Result Qual Result Qual Result Qu

Groundwater, PFAS2 (ng/L)

PFOA 6 2.5 2.8 ND 15 ND 32

PFNA 6 1 J 1.2 J ND 3.9 ND 2.4PFBS 601 2.7 2.9 ND 1.5 J ND 5.9

PFHxS 39 ND ND ND 14 ND 14

PFOS 4 2.4 J+ 2.7 J+ ND 9 ND 3.4 J

Notes Chemical Abbreviations

Grey Fill Detected concentration exceeded OSD Screening Levels PFBS Perfluorobutanesulfonic acid 

PFHxS Perfluorohexanesulfonic acid 

References PFNA Perfluorononanoic acid 

PFOS Perfluorooctanesulfonic acid PFOA Perfluorooctanoic acid 

2. PFAS by LC/MS/MS compliant with QSM Version 5.3 Table B-15 

Acronyms and Abbreviations

Interpreted QualifiersJ = Estimated concentration AOI Area of InterestJ+ = Estimated quantity but may bias high HQ Hazard Quotient

ID identification

 LC/MS/MS liquid chromatography tandem mass spectrome

ND analyte not detected above the LOD (LOD valuOSD Office of the Secretary of DefensePFAS per- and polyfluoralkyl substancesQSM Quality Systems ManualQual interpreted qualifierng/l nanograms/liter

1. Assistant Secretary of Defense. July 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection Agency’s Regional Screening Level Calculator. Hazard Quotient (HQ)=0.1 . May 2022. 

Location ID

Sample Name

Parent Sample ID

Sample Date

WHFRTC-01

WHFRTC-01-GW

11/20/2021

WHFRTC-01

WHFRTC-DUP-02

WHFRTC-01-GW

11/20/2021

AOI01-01

AOI01-01-GW

11/22/2021

AOI01-05

AOI01-05-G

11/20/2021

AOI01-03

AOI01-03-GW

11/22/2021

AOI01-04

AOI01-04-GW

11/20/2021
Site Inspection Report

Wendell H. Ford Regional Training Center, Kentucky Version: FINAL

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DataS ource s:

ES RI 2020

AECOM 2020

Date :........................Octobe r2022

Pre pare d By:........................WS P

Pre pare d For:....................US ACE

Facility Data

Are aofInte re st(AOI)

Pote ntial PFAS Re le ase S ite

Army National Guard Site Inspections

Site Inspection Report

Wendell H. Ford Regional Training Center

Muhlenberg County, Kentucky

Figure 6-1

PFOS Detections in Soil (AOI 1)

) KY

3

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

AOI01-01

AOI01-02

0 200

Fe e t

0 200

Fe e t

0 200

Fe e t

S h allow Inte rm e d iate De e p

3

Hydrogeology

Infe rre d Ground wate r

FlowDire ction

NOTES:

PFAS =Pe r-and Polyfluoroalk yl S ubstance s

PFOS =pe rfluorooctane sulfonicacid

ND=Non-De te ct

(μg/Kg)=Microgram (s)pe rKilogram

Ex ce e d ance sofTh e Office ofth e S e cre taryofDe fe nse (OS D)

S cre e ningLe ve l (S L)are d e picte d with aye llowh alo.

PFOS Results (μg/kg)

!( ND(Non-De te ct)

!( >ND-13

!!( >13-160

!!( >160-1,600

!!( >1,600
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DataSourc es:

ESR I 2020

AECOM 2020

Date:........................Oc tober2022

Prepared By:........................WSP

Prepared For:....................USACE

Army National Guard Site Inspections

Site Inspection Report

Wendell H. Ford Regional Training Center

Muhlenberg County, Kentucky

Figure 6-2

PFOA Detections in Soil (AOI 1)

) KY

3

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

AOI01-01

AOI01-02

0 200

Feet

0 200

Feet

0 200

Feet

Sh allow Interm ed iate Deep

3

Facility Data

AreaofInterest(AOI)

PotentialPFASR eleaseSite

Hydrogeology

Inferred Ground w aterFlow Direction

NOTES:

PFAS=Per-and Polyfluoroalk ylSubstanc es

PFOA=perfluorooc tanoic ac id

ND=Non-Detec t

(μg /Kg )=Mic rog ram (s)perKilog ram

Exceed anc esofTh eOffic eofth eSec retary ofDefense

(OSD)Sc reening Level(SL)ared epic ted w ith ayellow h alo.

PFOA Results (μg/kg)

!( ND(Non-Detec t)

!( >ND-19

!!( >19-250

!!( >250-2,500

!!( >2,500
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DataSourc es:

ESR I 2020

AECOM 2020

Date:.......................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

Fac ilityData

AreaofInterest(AOI)

PotentialPFASR eleaseSite

Arm yNation alGu ardSiteIn s pec tion s

SiteIn s pec tion Report

Wen dellH.FordRegion alTrain in gCen ter

Mu hlen bergCou n ty,Ken tu c ky

Figu re6-3

PFBSDetec tion s in Soil(AOI1)

) KY

3

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

AOI01-01

AOI01-02

0 200

Feet

0 200

Feet

0 200

Feet

Sh allow Interm ed iate Deep

3

Hydrogeology

Inferred

Ground w aterFlow

Direction

NOTES:

PFAS=Per-and Polyfluoroalk ylSubstanc es

PFBS=perfluorobutanesulfonic ac id

ND=Non-Detec t

(μg /Kg )=Mic rog ram (s)perKilog ram

Exceed anc es ofTh e Offic e ofth e Sec retary ofDefense (OSD)

Sc reening Level(SL)ared epic ted w ith ayellow h alo.

PFBSRes u lts (μg/kg)

!( ND(Non-Detec t)

!( >ND-10

!( >10-1,900

!!( >1,900-25,000

!!( >25,000
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DataSourc es:

ESR I 2020

AECOM 2020

Date:........................October2022

Prepared By:........................WSP

Prepared For:....................USACE

FacilityData

AreaofInterest(AOI)

PotentialPFASR eleaseSite

ArmyNatio n alGu ard SiteIn s pectio n s

SiteIn s pectio n Repo rt

Wen d ellH.Fo rd Regio n alTrain in gCen ter

Mu hlen bergCo u n ty,Ken tu cky

Figu re6-4

PFHx SDetectio n s in So il(AOI1)

) KY

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

AOI01-01

AOI01-02

0 200

Feet

0 200

Feet

0 200

Feet

Sh allow Interm ed iate Deep

3

Hyd ro geo lo gy

Inferred

Ground w aterFlow

Direc tion

NOTES:

PFAS-Per-and Polyfluoroalk ylSubstances

PFHxS=perfluoroh exanesulfonic ac id

ND=Non-Detect

(μg /Kg )=Microg ram (s)perKilog ram

Exc eed ances ofTh eOfficeofth eSecretary ofDefense(OSD)

Screening Level(SL)ared epicted w ith ayellow h alo.

PFHx SRes u lts (μg/kg)

!( ND(Non-Detec t)

!( >ND-13

!!( >1,600 !( >13-130

!!( >130-1,600
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ESR I 2020

AECOM 2020

Date:........................Oc tober2022

Prepared By:........................WSP

Prepared For:....................USACE

Facility Data

AreaofInterest(AOI)

PotentialPFASR eleaseSite

Army Natio n alGu ard SiteIn s pectio n s

SiteIn s pectio n Repo rt

Wen d ellH.Fo rd Regio n alTrain in gCen ter

Mu hlen bergCo u n ty ,Ken tu cky

Figu re6-5

PFNADetectio n s in So il(AOI1)

) KY

3

!(

!(

!(

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

!(

AOI01-01

AOI01-02 AOI01-03

!(

!(

AOI01-01

AOI01-02

0 200

Feet

0 200

Feet

0 200

Feet

Sh allow Interm ed iate Deep

3

Hy d ro geo lo gy

Inferred

Ground w aterFlow

Direction

NOTES:

PFAS=Per-and Polyfluoroalk ylSubstanc es

PFNA=perfluorononanoic ac id

ND=Non-Detec t

(μg /Kg )=Mic rog ram (s)perKilog ram

Exc eed anc esofTh eOffic e ofth eSec retary ofDefense (OSD)

Sc reening Level(SL)ared epic ted w ith ayellow h alo.

PFNARes u lts (μg/kg)

!( ND(Non-Detec t)

!( >ND-19

!!( >19-250

!!( >250-2,500

!!( >2,500
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Data Sources:

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

Army National Guard Site Inspections

Site Inspection Report

Wendell H. Ford Regional Training Center

Muhlenberg County, Kentucky

Figure 6-6

PFOA, PFOS and PFBS Detections in Groundwater

) KY

3

!(

!!(

!(

!!(

!(

AOI01-01

AOI01-03

AOI01-04

AOI01-05

WHFRTC-01

!(

!!(

!(

!(

!(

AOI01-01

AOI01-03

AOI01-04

AOI01-05

WHFRTC-01

!(

!(

!(

!(

!(

AOI01-01

AOI01-03

AOI01-04

AOI01-05

WHFRTC-01

0 200

Feet

0 200

Feet

0 200

Feet

3 PFOA PFOS PFBS

Facility Data Hydrogeology

Area of Interest (AOI) Inferred Groundwater Flow Direction

Potential PFAS Release Site

PFOA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 40

!!( >40 - 70

!!( >70

PFOS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 4

!!( >4 - 40

!!( >40 - 70

!!( >70

NOTES:

PFAS = Per- and Polyfluoroalkyl Substances

PFOS = perfluorooctanesulfonic acid

PFOA = perfluorooctanoic acid

PFBS = perfluorobutanesulfonic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD) Screening Level (SL) are depicted with a yellow halo.

PFBS (ng/L)

!( ND (Non-Detect)

!( >ND - 100

!!( >601 - 1,000

!!( >1,000

!( >100 - 601
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Data Sources:

ESRI 2020

AECOM 2020

Date:........................October 2022

Prepared By:........................WSP

Prepared For:....................USACE

Army National Guard Site Inspections

Site Inspection Report

Wendell H. Ford Regional Training Center

Muhlenberg County, Kentucky

Figure 6-7

PFHxS and PFNA Detections in Groundwater

) KY

3

!(

!(

!(

!(

!(

AOI01-01

AOI01-03

AOI01-04

AOI01-05

WHFRTC-01

!(

!(

!(

!(

!(

AOI01-01

AOI01-03

AOI01-04

AOI01-05

WHFRTC-01

0 200

Feet

0 200

Feet

3 PFHxS PFNA

Facility Data Hydrogeology

Area of Interest (AOI) Inferred Groundwater Flow Direction

Potential PFAS Release Site

NOTES:

PFAS - Per-and Polyfluoroalkyl Substances

PFHxS = Perfluorohexanesulfonic acid

PFNA = Perfluorononanoic acid

ND = Non-Detect

ng/L = nanogram(s) per liter

Exceedances of The Office of the Secretary of Defense (OSD)

Screening Level (SL) are depicted with a yellow halo.

PFHxS Results (ng/L)

!( ND (Non-Detect)

!( >ND - 39

!!( >39 - 100

!!( >100 - 1000

!!( >1,000

PFNA Results (ng/L)

!( ND (Non-Detect)

!( >ND - 6

!!( >6 - 100

!!( >100 - 1000

!!( >1000
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7. EXPOSURE PATHWAYS

The CSM for AOI 1, revised based on the SI findings, is presented on Figure 7-1. Please note 

that while the CSM discussion assists in determining if a receptor may be affected, the decision 

to move from SI to RI or interim action is determined based upon exceedances of the SLs for the 

relevant compounds and whether the release is more than likely attributable to the DoD. A CSM 

presents the current understanding of the Site conditions with respect to known and suspected 

sources, potential transport mechanisms and migration pathways, and potentially exposed human 

receptors. A human exposure pathway is considered potentially complete when the following 

conditions are present:

1. Contaminant source;

2. Environmental fate and transport;

3. Exposure point;

4. Exposure route; and

5. Potentially exposed populations. 

If any of these elements are missing, the pathway is incomplete. The CSM figure uses an empty 

circle symbol to represent an incomplete exposure pathway. Areas with an incomplete pathway 

generally warrant no further action. However, the pathway is considered potentially complete if the 

relevant compounds are detected, in which case the CSM figure uses a half-filled circle symbol to 

represent a potentially complete exposure pathway. Additionally, a completely filled circle symbol 

is used to indicate when a potentially complete exposure pathway has detections of relevant 

compounds above the SLs. Areas with an identified potentially complete pathway that have 

detections of the relevant compounds above the SLs may warrant further investigation. Although 

the CSM indicates whether potentially complete exposure pathways may exist, the 

recommendation for future study in a RI or no action at this time is based on the comparison of 

the SI analytical results for the relevant compounds to the SLs.

In general, the potential routes of exposure to the relevant compounds are ingestion and 

inhalation. Human exposure via the dermal contact pathway may occur, and current risk practice 

suggests it is an insignificant pathway compared to ingestion; however, exposure data for dermal 

pathways are sparse and continue to be the subject of toxicological study. The receptors 

evaluated are consistent with those listed in USEPA guidance for risk screening (USEPA 2001). 

Receptors at the Facility include site workers (e.g., Facility staff and visiting soldiers), 

construction workers, recreational users, trespassers, and off-facility residents. 

7.1 SOIL EXPOSURE PATHWAY 

The SI results in soil were used to determine whether a potentially complete pathway exists 

between the source and potential receptors at each AOI based on the aforementioned criteria. 

7.1.1 AOI 1 – Fire Station/Building 325

WHFRTC Fire Department stores AFFF on two trucks kept at Fire Station/Building 325. 

Angus Tridol S 3% AFFF is stored in 5-gallon buckets on each truck and in a material storage 
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room at the fire station. Angus Tridex 3% AFFF is also stored in the fire station storage room, 

as well as non-AFFF fire suppressants such as Purple K and ABC fire extinguishers. The fire 

chief stated during interviews that AFFF concentrate has not spilled from their storage 

containers. Only water and Class A foam have been used by the WHFRTC Fire Department on 

Facility, according to WHFRTC staff. There are no documented uses of AFFF at Building 325, 

or anywhere on WHFRTC by the WHFRTC Fire Department. 

The WHFRTC Fire Department used AFFF during response to an off-Facility fire in Central

City in 2016. The WHFRTC Fire Chief reported that the fire truck used in response to the fire

was most likely washed at the WHFRTC fire station after responding to the fire. It is unclear

whether any AFFF deployed remained on the truck at the time of washing.

PFOA, PFOS, PFHxS, and PFNA were detected below their SLs in surface soil at AOI 1. 

Facility workers, construction workers, and visitors/recreational users could contact constituents 

in surface soil via incidental ingestion and inhalation of dust. Therefore, the surface soil exposure 

pathway for Facility workers, construction workers, or visitor/ recreational user are potentially 

complete. PFHxS was detected in subsurface soil at AOI 1. Construction workers could contact 

constituents in subsurface soil via incidental ingestion and inhalation of dust; therefore, the 

subsurface soil exposure pathway for construction workers is potentially complete. The CSM for 

AOI 1 is presented on Figure 7-1.

7.2 GROUNDWATER EXPOSURE PATHWAY

The SI results for groundwater were used to determine whether a potentially complete pathway 

exists between the source and potential receptors at each AOI based on the aforementioned 

criteria. 

7.2.1 AOI 1 – Fire Station/Building 325

PFOA and PFOS were detected above their respective SLs in groundwater samples collected at 

AOI 1 (Table 6-5). Depths to water measured at AOI 1 in November 2021 during the SI ranged 

from approximately 7 to 39 feet bgs; therefore, the exposure pathway for ingestion of 

groundwater is potentially complete for construction workers involved in ground disturbing 

activities that extend to the water table. No potable wells are located within the Facility

boundary. The Facility receives potable water from a municipal source; therefore the exposure 

pathway for groundwater to Facility workers and Facility visitors/recreational users is 

incomplete. Two public water system wells are located approximately 4.5 miles south-southwest 

and hydraulically upgradient of AOI 1, and several domestic water supply wells are located 

within a 4-mile radius of the Facility, the closest identified as being active and at an interpreted 

hydraulically downgradient location from AOI 1 being located more than five miles from the 

AOI. The concentration at the potential point of exposure for off-site residents is not known, 

therefore, the exposure pathway for ingestion of groundwater is potentially complete for off-site 

residential receptors. The CSM for AOI 1 is presented on Figure 7-1. 
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7.3 SURFACE WATER AND SEDIMENT EXPOSURE PATHWAY

Because there are no natural surface water bodies at AOI 1, surface water and sediment were not 

sampled as part of the SI. Therefore, the exposure pathways for surface water and sediment are 

incomplete. 
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SOURCE

Source Release 

Mechanism Media

RECEPTOR

Fire Truck 

Washing/AFFF 

Storage

Human 

Activities

Leaching/

Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Shallow 

Groundwater

Subsurface 

Soil

PATHWAY

Transport 

and Migration Media Exposure Routes

Inhalation of 

Dust

Human Receptors: 

Current/ Future

Site 

Worker

Construction 

Worker

Off-facility 

Resident

Site 

Worker

Construction 

Worker

Off-facility 

Resident

/ /

/ / /

/ /

Figure 7-1

Conceptual Site Model, AOI 1

Wendell H. Ford Regional Training Center

Potential 

Off-Facility 

Sources Not

under 

Control of 

ARNG

/

/ /

/ /

/

/

/ /

/

/

PFAS in 

Surface Soil

AOI 1 – Fire 

Station/ 

Building

325

Precipitation/

Run-off

/ / / /

/

Ingestion

/

Visitor/

Recreational User

Visitor/

Recreational User

Ingestion

Ingestion

Ingestion

/
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8. SUMMARY AND OUTCOME

This section summarizes the SI activities and findings. The most significant findings are 

summarized in this section and are reproduced directly or abstracted from information contained 

in this report. The outcome provides general and comparative interpretations of the findings 

relative to the SLs. 

8.1 SI ACTIVITIES 

The SI field activities at the Facility were conducted from 15 through 22 November 2021. The SI 

field activities included soil and groundwater sampling. Field activities were conducted in 

accordance with the UFP-QAPP Addendum (EA/Wood 2021a), except as previously noted in 

Section 5.8. 

To fulfill the project DQOs set forth in the approved UFP-QAPP Addendum (EA/Wood 2021a), 

samples were collected and analyzed for a subset of PFAS by LC/MS/MS compliant with QSM 

5.3 Table B-15 (DoD 2020) as follows.

• Eight (8) soil samples from three locations (soil borings locations)

• Five (5) grab groundwater samples from five of six temporary well locations

• Eight (8) QA/QC samples.

An SI is conducted when the PA determines an AOI exists based on probable use, storage, and/or 

disposal of PFAS-containing materials. The SI includes multi-media sampling at the AOI to 

determine whether or not a release has occurred. The SI may conclude further investigation is 

warranted, a removal action is required to address immediate threats, or no further action is 

required. Additionally, the CSM was refined to assess whether a potentially complete pathway 

exists between the source and potential receptors for potential exposure at the AOI, as described 

in Section 7. 

8.2 OUTCOME

Based on the results of this SI, further evaluation in the form of an RI is warranted for AOI 1. 

Based on the CSM developed and revised based on the SI findings, there is potential for 

exposure to receptors from AOI 1 from sources on the Facility resulting from historical DoD 

activities. 

Sample analytical concentrations collected during the SI were compared against the project SLs 

in soil and groundwater, as described in Table 6-1. The SI results relative to the SLs are 

summarized below. 

At AOI 1:

• PFOA, PFOS, PFHxS, and PFNA were detected in soil at AOI 1 at concentrations below 

the SLs.
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• PFOA, PFOS, PFBA, PFHxS, and PFNA were detected in groundwater at AOI 1. PFOA 

and PFOS exceeded their respective SLs, while PFBS, PFHxS, and PFNA did not exceed 

the SLs.

Based on the results of the SI, further evaluation of AOI 1 is warranted in the RI. 

Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA 

(commonly referred to as GenX) was not included as an analyte at the time of this SI. Based on 

the CSM developed during the PA and revised based on SI findings, the presence of HFPO-DA 

is not anticipated at the facility because HFPO-DA is generally not a component of MIL-SPEC 

AFFF and based on its history including distribution limitations that restricted use of GenX, it is 

generally not a component of other products the military used. In addition, it is unlikely that 

GenX would be an individual chemical of concern in the absence of other PFAS.

Table 8-1 summarizes the SI results for soil and groundwater used to determine if an AOI should 

be considered for further investigation under CERCLA and undergo an RI. 

Table 8-1. Summary of Site Inspection Findings and Recommendations

AOI Potential Release 

Area

Soil –

Source Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary Future Action

1 Fire Station/Building 

325 Proceed to RI

Legend:

 = detected; exceedance of screening levels.

 = detected; no exceedance of screening levels.

 = not detected.
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9. REFERENCES

AECOM Technical Services, Inc. (AECOM). 2019. Final Preliminary Assessment Report, 

Wendell H. Ford Regional Training Center, Kentucky. January.

Assistant Secretary of Defense. 2022. Investigating Per- and Polyfluoroalkyl Substances within 

the Department of Defense Cleanup Program. United States Department of Defense. 

July.

Department of the Army (DA). 2018. Army Guidance for Addressing Releases of Per- and 

Polyfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) Contamination. 

Department of Defense and Department of Energy (DoD/DOE 2019a). Department of Defense 

(DoD) Department of Energy (DOE) Consolidated Quality Systems Manual (QSM) for 

Environmental Laboratories. Version 5.3. May.

DoD. 2019b. General Data Validation Guidelines. November.

DoD. 2020. Data Validation Guidelines Module 3: Data Validation Procedure for Per- and 

Polyfluoroalkyl Substances Analysis by QSM Table B-15. May.

EA, Engineering, Science, and Technology, PBC (EA). 2014. Monitoring Well Installation. 

Standard Operating Procedure 019. 

EA. 2020a. Final Programmatic Uniform Federal Policy Quality Assurance Project Plan, Site 

Inspections for Per- and Polyfluoroalkyl Substances Impacted Sites, ARNG Installations, 

Nationwide. December.

EA. 2020b. Final Programmatic Accident Prevention Plan, Revision 1. November. 

EA Engineering, Science, and Technology, PBC and Wood Environment & Infrastructure 

Solutions, Inc. (EA/Wood). 2021a. Final Site Inspection Uniform Federal Policy Quality 

Assurance Project Plan (UFP-QAPP) Addendum, Wendell H. Ford Regional Training 

Center, Muhlenberg County, Kentucky, Per- and Polyfluoroalkyl Substances Impacted 

Sites ARNG Installations, Nationwide. August. 

EA/Wood. 2021b. Final Accident Prevention Plan/Site Safety and Health Plan Addendum, Site 

Inspections for Per- and Polyfluoroalkyl Substances Impacted Sites, ARNG Installations, 

Nationwide, Wendell H. Ford Regional Training Center, Kentucky. April. 

Guelfo, J.L. and C.P. Higgins. 2013. Subsurface transport potential of perfluoroalkyl acids and 

aqueous film-forming foam (AFFF)-impacted sites. Environmental Science and 

Technology 47(9):4164-71. 

Higgins, C.P. and R.G. Luthy. 2006. Sorption of perfluorinated surfactants on sediments. 

Environmental Science and Technology 40 (23): 7251-7256. 
Site Inspection Report

Wendell H. Ford Regional Training Center, Kentucky Version: FINAL

EA Engineering, Science, and Technology, Inc., PBC 9-2

Interstate Technology Regulatory Council (ITRC). 2018. Environmental Fate and Transport for 

Per- and Polyfluoroalkyl Substances. March. 

USACE. 2016. Technical Project Planning Process, EM-200-1-2. 26 February. 

U.S. Environmental Protection Agency (USEPA). 1980. Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA). December.

U.S. Environmental Protection Agency (USEPA). 1994. National Oil and Hazardous Substances 

Pollution Contingency Plan (Final Rule). 40 Code of Federal Regulations Part 300; 59 

Federal Register 47384. September. 

U.S. Environmental Protection Agency (USEPA). 2001. Risk Assessment Guidance for 

Superfund, Volume I: Human Health Evaluation

Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk 

Assessments). December.

U.S. Environmental Protection Agency (USEPA). 2005. Federal Facilities Remedial Site 

Inspection Summary Guide. July.

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