FINAL

Preliminary Assessment Report

River Road Training Site,

New Castle, Delaware

Perfluorooctanesulfonic Acid (PFOS) and Perfluorooctanoic 

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

July 2020 

Prepared for:

Army National Guard Headquarters

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

i

Table of Contents

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

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

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

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

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

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

Facility Environmental Setting ...................................................................................4

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

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

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

1.5.4 Climate ...........................................................................................................6

1.5.5 Current and Future Land Use .........................................................................6

2. Fire Training Areas ...........................................................................................................10

3. Non-Fire Training Areas ...................................................................................................11

HAZMAT Storage ....................................................................................................11

4. Emergency Response Areas ............................................................................................13

5. Adjacent Sources .............................................................................................................14

Delaware City Refinery ...........................................................................................14

Tybouts Corner Landfill Trust ..................................................................................14

Mid-Atlantic Steel LLC ............................................................................................14

Summit Steel, Inc ....................................................................................................14

Atlas Welding & Fabrication, Inc .............................................................................14

Delaware Sand and Gravel Landfill .........................................................................15

Army Creek Landfill.................................................................................................15

6. Preliminary Conceptual Site Model ..................................................................................17

7. Conclusions .....................................................................................................................18

Findings ..................................................................................................................18

Uncertainties ...........................................................................................................18

Potential Future Actions ..........................................................................................19

8. References ......................................................................................................................21
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

ii

Tables

Table 7-2 No Suspected Release Areas

Figures

Figure ES-1 Summary of Findings

Figure 1-1 Facility Location

Figure 1-2 Groundwater Features

Figure 1-3 Surface Water Features

Figure 3-1 Non-Fire Training Areas

Figure 5-1 Adjacent Sources

Figure 7-1 Summary of Findings

Appendices

Appendix A Data Resources

Appendix B Preliminary Assessment Documentation

B.1 Interview Records

B.2 Visual Site Inspection Checklists

B.3 Conceptual Site Model Information

Appendix C Photographic Log
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Acronyms and Abbreviations

°F Degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

AFW Amec Foster Wheeler

AOI Area of Interest

amsl above mean sea level

ANG Air National Guard

ARNG Army National Guard

bgs below ground surface

bmsl below mean sea level

C&D Chesapeake and Delaware

CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act

CFR Code of Federal Regulations

CSM conceptual site model

DEARNG Delaware Army National Guard

DGS Delaware Geological Survey

DO Delaware Online

DoD Department of Defense

DNREC Delaware Department of Natural Resources and Environmental Control

DRBC Delaware River Basin Commission

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

HA USEPA’s lifetime Health Advisory

HAZMAT hazardous materials

IED Installations & Environment Division

NCCDE New Castle County Delaware Government

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

RRTS River Road Training Site

SI Site Inspection

SWAT Special Weapons and Tactics

US United States

USACE United States Army Corps of Engineers

USEPA United States Environmental Protection Agency

USGS United States Geological Survey

iii
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

1

Executive Summary

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

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

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

(PFAS)-containing materials was completed for River Road Training Site (RRTS; also referred to

as the “facility”) in New Castle, Delaware, to assess potential PFAS release areas and exposure

pathways to receptors. RRTS is constructed on a parcel of land purchased by the US from private

landowners in 1908.The performance of this PA included the following tasks:

· Reviewed available administrative and record documents and Environmental Data

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

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

and environmental compliance actions in the area surrounding the facility.

· Conducted a site visit on 5 August 2019 and completed visual site inspections at locations

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

· Interviewed current RRTS personnel, including environmental managers during the site visit.

No potential PFAS releases were identified at RRTS during the PA investigation. As a result, the

exposure pathways to potential receptors are incomplete, and there are no Areas of Interest at

the facility (Figure ES-1).

Delaware City Refinery, Tybouts Corner Landfill Trust, Mid-Atlantic Steel LLC, Summit Steel, Inc,

and Atlas Welding & Fabrication, Inc are potential sources of PFAS adjacent to the facility. The

fires at Delaware City Refinery in 2019 both required emergency response either from local fire

departments or on-site fire response. Tybouts Corner Landfill Trust may have PFAS-containing

materials which could have leeched to the surrounding environment in the area of RRTS. The

remaining three potential adjacent sources are metals industries that could use PFAS-containing

materials.

Based on the US Environmental Protection Agency (USEPA) Unregulated Contaminant

Monitoring Rule 3 data, it was indicated that PFAS were detected in a public water system above

the USEPA’s lifetime Health Advisory level within 20 miles of the facility. PFAS analyses performed

in 2016 had method detection limits that were higher than currently achievable. Thus, it is possible

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

analyzed today.
Mid-Atlantic

Steel LLC

Atlas Welding

& Fabrication

HAZMAT

Storage

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

LS

2/3/2020

2/3/2020

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:12,000

2/3/2020 ­ Figure ES-1

PM RG 2/3/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_7-1_RRTS_Summary.mxd

Legend

No Suspected Release

Potential PFAS Release

Facility Boundary

Water Body

Wetland

0 500 1,000 2,000

Feet

2
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

3

1. Introduction

Authority and Purpose

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

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

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

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

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

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

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

(PFAS), primarily in the form of aqueous film forming foam (AFFF) released as part of firefighting 

activities, although other PFAS sources are possible. In addition, the ARNG is assessing 

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

potentially be responsible for a PFAS release. 

PFAS are classified as emerging environmental contaminants that are garnering increasing 

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

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

in the environment varies. The regulatory framework at both federal and state levels continues to 

evolve. The US Environmental Protection Agency (USEPA) issued a lifetime Drinking Water 

Health Advisory (HA) for PFOA and PFOS in May 2016, but there are currently no promulgated 

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

contaminant levels, some states have adopted their own drinking water standards for PFAS; the 

state of Delaware does not currently have promulgated standards for PFAS in any environmental 

media. 

This report presents the findings of a PA for PFAS-containing materials at River Road Training 

Site (RRTS; also referred to as the “facility”) in New Castle, Delaware, in accordance with the 

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

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

Federal Regulations [CFR] Part 300), and Army requirements and guidance. 

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

at RRTS. The term PFAS will be used throughout this report to encompass all PFAS chemicals 

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

Preliminary Assessment Methods

The performance of this PA included the following tasks: 

· Reviewed available administrative record documents and Environmental Data Resources, 

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

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

environmental compliance actions in the area surrounding the facility;

· Conducted a site visit on 5 August 2019 and completed visual site inspections (VSIs) at 

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

disposed;

· Interviewed current RRTS personnel including environmental managers during the site visit. 
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

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Report Organization

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

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

each are as follows:

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

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

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

identified during the site visit 

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

at the facility identified during the site visit 

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

facility, specifically in response to emergency situations 

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

facility that are not under the control of ARNG 

· Section 6 – Preliminary Conceptual Site Model: describes the pathways of PFAS transport 

and receptors for the Areas of Interest (AOIs) and the facility 

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

uncertainties of the PA 

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

· Appendix A – Data Resources

· Appendix B – Preliminary Assessment Documentation

· Appendix C – Photographic Log

Facility Location and Description

RRTS occupies 190.7 acres in New Castle, Delaware (Figure 1-1). The facility’s eastern side is 

bounded by the Delaware River and the facility is located 3 miles southeast of the New Castle 

Airport. The nearest metropolitan area to RRTS is Wilmington, Delaware, 8.1 miles northeast of 

the facility. Properties surrounding RRTS are primarily zoned for single-family homes and 

suburban neighborhoods (New Castle County Delaware Government [NCCDE], 2018).

RRTS is located on a portion of land that, according to the deed provided by RRTS personnel, 

the Federal Government purchased from private landowners on 16 November 1908. Early 

activities for the site are unknown due to lack of documentation and the loss of Delaware ARNG 

(DEARNG) records (URS, 2015). RRTS has historically been used for training encampments, 

field exercises, and most prominently, live-fire exercises. The facility provides administrative, 

training and logistical support to the DEARNG, the New Castle City and County police, Special 

Weapons and Tactics (SWAT) teams, and military and paramilitary organizations (URS, 2015). 

Directly outside of the facility boundary are a park, a hunter safety training center, and residential 

neighborhoods. Access to the facility is via a guarded gate.

Facility Environmental Setting

The facility is located in northern New Castle County, Delaware, along the Delaware River, which 

flows south to the Delaware Bay. The facility is primarily green space consisting of wetlands and 

wooded areas. RRTS sits below sea level, and the eastern edge of the property is mostly wetlands 

that are subject to flooding from the river, while buildings and paved areas sit on the western side 
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

5

of the property. RRTS is in a transition zone between the Delaware Bay, which has saline waters,

and the freshwater Delaware River (URS, 2015). The facility is part of the Army Creek-Frontal

Delaware River Watershed, where Army Creek, located to the facility’s north, is the main drainage

pathway to the Delaware river. On-site drainage pathways are to the wetlands and smaller creeks

on-site that discharge into the Delaware River.

In the area of RRTS, the soil is classified as primarily loam. Shallower soils are mostly silt loam

from 0-34 inches below ground surface (bgs), while the deeper soil is described as sandy loam

from 34-60 inches bgs (EDRTM, 2019).

1.5.1 Geology

A geologic map of New Castle County, Delaware provides specific surficial geology of the RRTS

area. The portion of land on which RRTS is located includes marsh deposits, the Scotts Corners

Formation, and the Lynch Heights Formation (Delaware Geological Survey [DGS], 2005). As

shown in Figure 1-2, data from the US Geological Survey (USGS) shows the primary rock types

of the area are silt and sand. Marsh deposits, located on the eastern edge of the property

bordering the Delaware River, mainly consist of organic-rich silty clay to clayey silt. The Scotts

Corners Formation in the center of the property consists of coarse to fine sand that is often capped

by 1-2 feet of sandy silt. Lastly, the Lynch Heights Formation is located on the western side of the

property and consists of fine sand with discontinuous beds of coarse sand, gravel, silt, fine to very

fine sand, and organic rich clayey silt to silty sand (DGS, 2005).

1.5.2 Hydrogeology

New Castle County, Delaware has two aquifers: the Columbia and Potomac. The Columbia

aquifer is the primary surficial aquifer in New Castle County, Delaware but is in partial contact with

the Potomac aquifer, allowing them to act as a hydrogeologic unit (Amec Foster Wheeler [AFW],

2019). An environmental investigation was conducted by the Air National Guard (ANG)

approximately 3.5 miles from RRTS. Due to the proximity of this study, it is inferred that the

hydrogeologic information provided would be similar to that at RRTS. The study indicated that the

Columbia formation in this area is predominantly dry, with perched water tables present (AFW,

2019). The Potomac aquifer consists of two independent water bearing zones (Upper and Middle)

in the laterally continuous sand bodies of the Potomac formation.

The Upper Potomac Aquifer lies in both the shallow and intermediate groundwater-bearing zones.

The shallow zone extends from 0 to 30 feet above mean sea level (amsl), and there is no clear

distinction between the surficial Columbia aquifer and the Upper Potomac aquifer. Separated from

the shallow zone by a semi-confining layer of clay, the intermediate groundwater-bearing zone

ranges from 1 to 20 feet thick, extends approximately 50 feet below mean sea level (bmsl), and

is considered to be part of the Upper Potomac aquifer. Results of groundwater elevation data from

a nearby investigation suggest that the shallow and intermediate zones are interconnected, as

they show similar trends. Groundwater flow in both zones of the Upper Potomac Aquifer as well

as the Columbia Aquifer is generally to the southeast (AFW, 2019) (Figure 1-2).

In New Castle County, south of the Chesapeake and Delaware (C&D) Canal and approximately

7 miles south of the facility, nearly all drinking water is from groundwater provided by public and

private wells. However, north of the canal in northern New Castle County, where RRTS is located,

groundwater supplies only 30 percent of drinking water (DGS, 2019).

The Delaware Department of Natural Resources and Environmental Control (DNREC) reported

that Artesian Water Company, a primary drinking water provider in the area, and the City of New

Castle Municipal Services Commission detected PFAS in public water supply wells in the area of

RRTS. The area of contamination is approximately 7 square miles and is bounded to the north by

Interstate 295, the Delaware River to the east, Route 273 to the south, and Route 13 and New
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

6

Castle Airport to the west. This area of PFAS contamination is approximately 2.5 miles north of

RRTS.

Four of Artesian Water Company’s public water supply wells are between 0.2 and 0.7 miles north

of the facility and south of the Army Creek Landfill and the Delaware Sand and Gravel Landfill

(Figure 1-2 and 5-1). (USEPA, September 2019). Monitoring wells south of the adjacent Landfills

tested positive for PFAS (USEPA, September 2019). The public water supply is treated for PFAS

contamination by Artesian before distribution (DNREC, 2019); however, there are also 5 private

domestic groundwater supply wells within 1 mile of the facility. Well locations shown on Figure 1-

2 are based on the EDRTM report’s Physical Setting Source Map and are approximate (Appendix

A). According to interviewees, drinking water at RRTS is public and provided by Artesian Water

Company.

Based on the USEPA Unregulated Contaminant Monitoring Rule 3 data, it was indicated that

PFAS were detected in a public water system above the HA level within 20 miles of the facility

(Appendix A). PFAS analyses performed in 2016 had method detection limits that were higher

than currently achievable. Thus, it is possible that low concentrations of PFAS were not detected

during the UCMR3 but might be detected if analyzed today.

1.5.3 Hydrology

Approximately 2 miles west of RRTS is the Christina River Basin, which extends from

Pennsylvania through New Castle County, Delaware. The facility is located within the Army CreekFrontal Delaware River Watershed, between Army Creek to the north and Red Lion Creek to the

south (Figure 1-3). Both the Christina River Basin and the Army Creek Watershed are portions of

the Delaware River Basin, which is characterized by dendritic interconnected rivers, streams, and

wetlands, with outflow to the Delaware River (Figure 1-3). Surface water in the area of the basin

where RRTS is located flows generally to the southeast. Due to the facility’s eastern bound on

the Delaware River, tidal wetlands occur in and adjacent to the facility grounds. Interviewee

recollection also includes instances of flooding on-site, close to the river. On facility grounds,

runoff flows southeast towards the wetlands and river (Figure 1-3).

A presentation from the Delaware River Basin Commission provides 2009 PFAS concentration

data for media tested along the Delaware river. Results from samples closest to the facility, at

river miles 50 and 68, found that PFAS have been detected in source water as well as ambient

water (Delaware River Basin Commission [DRBC], 2013).

1.5.4 Climate

The climate at RRTS is humid continental. The Delaware Bay and Atlantic Ocean to the east and

south and Chesapeake Bay to the west moderate temperature extremes in the winter and summer

months. Although the extremes are lessened, the climate at RRTS is still continental, with hot

summers, cold winters, and precipitation throughout the year (AFW, 2019). Mean annual

temperature in nearby Wilmington is 54.95 degrees Fahrenheit (°F). The average annual high

temperature for nearby Wilmington, Delaware is 64.1°F, and the average annual low temperature

is 45.8°F. Annual precipitation for Wilmington is approximately 43 inches of rain and 19 inches of

snowfall (US Climate Data, 2019).

1.5.5 Current and Future Land Use

RRTS resides on a portion of land purchased by the US Government in 1908 from private owners

and used as a military training facility. The facility is currently used for administrative, training, and

logistical support activities. Future land use is not anticipated to change.
RIVER ROAD

TRAINING SITE

CLIENT

REVISED

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ARNG

GIS BY

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12/3/2019

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:126,720

12/3/2019 ­ Figure 1-1

PM RG 12/3/2019

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

Intermap, INCREMENT P, NRCan, Esri Japan, METI,

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_1-1_RRTS_Facility_Location.mxd

Legend

Facility Boundary

^_

0 1 2 4

Miles

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CLIENT

REVISED

SCALE

ARNG

GIS BY

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GC

LS

2/4/2020

2/4/2020

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:48,000

2/4/2020 ­ Figure 1-2

PM RG 2/4/2020

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_1-2_RRTS_Groundwater.mxd

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Inferred Groundwater Flow Direction

Geology

Silt

Sand

Wells

!5 Agricultural

!P Domestic

A! Unknown

A! Monitoring

!C( Public Water Supply

0 2,000 4,000 8,000

Feet

8
Pigeon Run

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Delaware Watershed

River-Delaware

Bay Watershed

Middle Christina

River Watershed

Broad Dyke

Canal-Frontal Delaware

River Watershed

Army Creek-Frontal

Delaware River

Watershed

Red Lion Creek-Frontal

Delaware River

Watershed

Dragon Creek-Frontal

Delaware River

Watershed

Army Creek

Red Lion Creek

Doll Run

Tom Creek

Delaware River

Dragon Creek

Christina River

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

LS

12/3/2019

12/3/2019

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:48,000

12/3/2019 ­ Figure 1-3

PM RG 12/3/2019

12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_1-3_RRTS_SurfaceWater.mxd

Legend

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Surface Water Flow Direction

0 2,000 4,000 8,000

Feet

9
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

10

2. Fire Training Areas

No FTAs were identified within RRTS during the PA through interviews. All fire training for

individuals at RRTS is held at the Delaware State Fire School in New Castle, Delaware. It is

unknown if training at the Fire School includes AFFF training. Firsthand knowledge of interviewees

reaches back to approximately 1991, and there is no primary source information between 1969,

the year the Department of Defense (DoD) started using AFFF, and 1991 (Appendix A).
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

11

3. Non-Fire Training Areas

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

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

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

features obtained during the PA are included in Appedices A and B. One non-FTA where fire 

extinguishers and hazardous chemicals are stored was identified during the PA. A description of 

the non-FTA is presented below, and the non-FTA is shown on Figure 3-1. 

HAZMAT Storage

The hazardous materials (HAZMAT) storage unit for RRTS is located on the western side of the 

property. Geographic coordinates for the unit are 39°38'5.946"N; 75°36'35.989"W (Figure 3-1). 

According to interviewee knowledge, there is no AFFF fire suppression system for the HAZMAT 

storage unit. Photographic logs show a large dry chemical fire extinguisher attached to the side 

of the storage unit (Appendix C). This tank is installed with pipes supplying a deluge system for 

the unit. Additionally, interviewees do not recall AFFF extinguishers having been used or stored 

on RRTS property during their time at the facility. Upon visual inspection, extinguishers at the 

HAZMAT storage unit and around the property are all dry chemical units (Appendix C). These 

extinguishers are visually inspected annually by Hoopes Fire Prevention Inc. Due to the current 

and historic absence of AFFF extinguishers at this location, there is no suspected AFFF release 

at the storage unit.
HAZMAT

Storage

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

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2/3/2020

2/3/2020

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:2,400

2/3/2020 ­ Figure 3-1

PM RG 2/3/2020

12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

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

Intermap, INCREMENT P, NRCan, Esri Japan, METI,

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_3-1_RRTS_Non-FTAs.mxd

Legend

No Suspected Release

Facility Boundary

0 100 200 400

Feet

12
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

13

4. Emergency Response Areas

No emergency response areas were identified at RRTS during the PA through interviews.

Interviewees do not recall emergency response at the facility, and there is no documentation of

an emergency response event (Appendix A).
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

14

5. Adjacent Sources

Five potential off-facility sources of PFAS located adjacent to RRTS, not under the control of 

ARNG, were identified during the PA through interviews and news reports. A description of each 

adjacent source is presented below, and the adjacent sources are shown on Figure 5-1. 

Delaware City Refinery

Delaware City Refinery is located approximately 3.5 miles southwest of the facility (Figure 5-1). 

In both February and April of 2019, there were fires at the refinery. During the fire in February, 

flames were contained to the refinery with the help of local emergency response units (Delaware 

Online [DO], 2019). News reports did not mention the use of AFFF, and interviewees are unsure 

of what was used to control the fire. The fire in April was smaller and did not require outside 

emergency response from local fire departments. Though there is no definite information provided 

as to the use of AFFF in either of these emergency responses, AFFF is commonly used at 

refineries in the event of fuel related fires. As such, there is a possibility that AFFF was released 

during one or both of these occurrences, making the Delaware City Refinery a possible adjacent 

source of PFAS. Emergency Response personnel were not interviewed during the PA because 

the focus of the assessment was to evaluate potential PFAS related activities and sources at 

DEARNG properties. 

Tybouts Corner Landfill Trust

Tybouts Corner Landfill Trust is located 2.6 miles west-southwest of the facility (Figure 5-1). 

Initially, this location housed a sand and gravel quarry until 1968 and was subsequently converted 

to a landfill (USEPA, 2019). The landfill was operational until 1971 and accepted municipal and 

household waste. In 1983, after it was determined that the landfill was the source of contamination 

in drinking water wells, it was added to CERCLA’s national Priorities List. The landfill has since 

been capped and is monitored semi-annually, with reports ensuring the remedial efforts are, 

“protective of human health and the environment” (USEPA, 2019). Though there are remedial 

efforts in place at this site, PFAS-containing materials may have been disposed of in the landfill 

and may not have been properly contained during the process of remediation. PFAS were not 

known to be harmful at the time of the remedial action plan and were not taken into account during 

planning. It is possible that the landfill could be a potential adjacent source of PFAS. 

Mid-Atlantic Steel LLC

Mid-Atlantic Steel LLC sits 0.3 miles northeast of RRTS. While there is no confirmation of the use 

of PFAS-containing materials at this steel fabrication plant, PFAS are commonly used in the 

metals and metals plating industries. As such, Mid-Atlantic Steel LLC is a possible adjacent 

source of PFAS. Figure 5-1 shows the location of Mid-Atlantic Steel LLC.

Summit Steel, Inc

Summit Steel, Inc is located 1.4 miles northeast of RRTS (Figure 5-1). There is no confirmation 

of the use of PFAS-containing materials at this steel erecting company in New Castle, Delaware; 

however, materials containing PFAS are commonly used in metals industries. As a result, Summit 

Steel, Inc is a possible adjacent source of PFAS.

Atlas Welding & Fabrication, Inc

Atlas Welding & Fabrication, Inc is located 1.2 miles from RRTS (Figure 5-1). There is no 

confirmation of the use of PFAS-containing materials at this location; however, PFAS are often 
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

15

used in metalworking industries. Therefore, Atlas Welding & Fabrication, Inc is considered a 

possible adjacent source of PFAS. 

Delaware Sand and Gravel Landfill

The Delaware Sand and Gravel landfill is a 27-acre superfund site located 0.8 miles north of 

RRTS and is shown in Figure 5-1 (USEPA, 2017). Formerly a sand and gravel quarry, the site 

was converted to a landfill and was operational from 1968 to 1976. The landfill consisted of four 

disposal areas, three of which held waste materials including hazardous substances in unlined 

gravel pits. The fourth area was used for temporary chemical waste storage where spillage of 

hazardous substances occurred (USEPA, 2017). The landfill housed 550,000 cubic yards of both 

municipal and industrial wastes, including 15,000 drums of chemical production, petroleum, and 

manufacturing liquids (USEPA, 2017). Contaminants leaking from this site were found in public 

groundwater supplies in 1971. Since that time, a slurry wall system was installed to prevent 

contaminants leaking to groundwater, the landfill was capped, and extraction wells were installed 

to capture and remove contaminants for transfer to the nearby wastewater treatment plant. PFOA 

and PFOS were detected in groundwater samples from the landfill’s monitoring wells in 2013. 

Monitoring for PFAS began at the landfill in fall 2016 (USEPA, 2017). Because groundwater 

testing has shown PFAS contamination from the landfill, this location is considered an adjacent 

source of PFAS.

Army Creek Landfill

The Army Creek Landfill is a also a superfund site and former sand and gravel quarry and is 

located adjacent to the Delaware Sand and Gravel Landfill, which is immediately across Army 

Creek to the south of this site (Figure 5-1). It operated as an unlined landfill from 1960 to 1968. 

The Army Creek Landfill accumulated 1.9 million cubic yards of municipal and industrial waste 

during its time of operation (USEPA, September 2019). In 1971, contaminants were discovered 

in residential groundwater supply. In response, groundwater monitoring started at the Army Creek 

Landfill, a groundwater recovery system was installed to remove contaminated groundwater and 

prevent contamination in an Artesian Water company well field. In 1992, the landfill was capped, 

and a groundwater treatment plan was put in place between 1992 and 1993 (USEPA, September 

2019). The plan consisted of the installation of a water treatment plant to remove contaminants 

from groundwater before discharging the water to Army Creek. Groundwater monitoring samples 

between 2013 and 2017 showed the presence of PFAS in groundwater downgradient from Army 

Creek Landfill (USEPA, September 2019). Artesian water company implemented a treatment 

system at their adjacent public water supply well field for PFOA and PFOS. The EPA requested 

that potentially responsible parties conduct groundwater investigations to determine if the Army 

Creek Landfill is a source of PFAS in the area’s groundwater. The investigation is ongoing and is 

expected to be completed and summarized in a report in March, 2020 (USEPA, September 2019). 

The exact contents of the landfill are unknown and there is a potential for PFAS-containing 

substances to be in the landfill, therefore the Army Creek Landfill is a potential adjacent source of 

PFAS.
Army Creek

Landfill

Delaware City

Refinery

Tybouts Corner

Landfill Trust

Mid-Atlantic

Steel LLC

Summit

Steel, Inc

Atlas Welding

& Fabrication

Delaware Sand

and Gravel Landfill

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

LS

2/4/2020

2/4/2020

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:60,000

2/4/2020 ­ Figure 5-1

PM RG 2/4/2020

12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_5-1_RRTS_AdjacentSources.mxd

Legend

Potential PFAS Release

Facility Boundary

0 2,500 5,000 10,000

Feet

16
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

17

6. Preliminary Conceptual Site Model

Based on the PA findings, no PFAS release areas were identified at RRTS. A conceptual site

model (CSM) identifies the three components necessary for a potentially complete exposure

pathway: (1) source, (2) pathway, (3) receptor. If any of these elements are missing, the pathway

is considered incomplete. In general, the potential PFAS exposure pathways are ingestion and

inhalation. 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 PFAS toxicological study. No known

releases of PFAS have been identified at RRTS, therefore the exposure pathways to potential

receptors are incomplete, and there are no AOIs at the facility.
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

18

7. Conclusions

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

AFFF at RRTTS. The PA findings are based on the information presented in Appendix A, 

Appendix B, and Appendix C.

Findings

No AOIs related to potential PFAS release were identified at RRTS based on information gathered 

as part of this PA (Figure 7-1). Based on the absence of PFAS releases, evidence does not 

support current or former ARNG activities at the facility contributing to PFAS contamination in soil, 

groundwater, surface water, or sediment at RRTS or adjacent areas.

The following area, which is shown in Table 7-1 and was discussed in Section 3, is determined 

to have no suspected release.

Table 7-1 No Suspected Release Areas

No Suspected Release Area Used by Rationale for No Suspected Release 

Determination

HAZMAT Storage Unit RRTS

The storage unit has never contained AFFF or 

had an AFFF fire suppression system. The facility 

has only had dry-chemical extinguishers around 

the facility.

Several potential adjacent sources of PFAS exist near RRTS. These sources include Delaware 

City Refinery, Tybouts Corner Landfill Trust, Mid-Atlantic Steel LLC, Summit Steel, Inc, and Atlas 

Welding & Fabrication, Inc. The fires at Delaware City Refinery in 2019 both required emergency 

response either from local fire departments or on-site fire response. Though it is unknown if AFFF 

were used to extinguish these fires, it is commonly used at refineries for fire-fighting purposes. 

Tybouts Corner Landfill Trust may have PFAS-containing materials that could have leeched to the 

surrounding environment near RRTS. The remaining three potential adjacent sources are in the 

metals industry and could use PFAS-containing materials

The summary of findings is presented in Figure 7-1.

Uncertainties

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

PFAS-containing materials to have been present, used, or released at the facility. Historically, 

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

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

training, firefighting, other non-traditional activities, or on its disposition. There is no historically 

documented use of PFAS-containing materials at RRTS.

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

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

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

a facility’s historical and current PFAS-containing materials. Direct personnel knowledge of the 

facility spans from 1991 to present. Sometimes, the provided information was vague. Gathered 

information has a degree of uncertainty due to the absence of written documentation, the limited 

number of personnel with direct knowledge due to staffing changes, the time passed since PFAS 

were first used (1969 to present), and a reliance on personal recollection. Inaccuracies may arise 
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

19

in potential PFAS release locations, dates of release, volume of releases, and the concentration 

of AFFF used. There is also a possibility the PA has missed a source of PFAS, as the science of 

how PFAS may enter the environment continually evolves.

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

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

for the same potential source area, and potential source areas were visually inspected.

Potential Future Actions

Interviews with RRTS personnel indicate that current and historic DEARNG activities have not 

resulted in PFAS releases at RRTS. Based on the absence of AFFF and PFAS-containing 

materials at RRTS, there were no AOIs identified at the facility during the PA.

The DEARNG RRTS will not move forward in the CERCLA process.
Mid-Atlantic

Steel LLC

Atlas Welding

& Fabrication

HAZMAT

Storage

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

GC

LS

2/3/2020

2/3/2020

NOTES Preliminary Assessment for PFAS at River Road Training Site, DE

1:12,000

2/3/2020 ­ Figure 7-1

PM RG 2/3/2020

12420 Milestone Center Drive

Germantown, MD 20876

Summary of Findings

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

Q:\Projects\ENV\GEARS\GEO\ARNG PFAS\900-CAD-GIS\920-GIS or Graphics\MXD\DE\River_Road_Training_Site\Fig_7-1_RRTS_Summary.mxd

Legend

No Suspected Release

Potential PFAS Release

Facility Boundary

Water Body

Wetland

0 500 1,000 2,000

Feet

20
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

21

8. References

Amec Foster Wheeler (AFW). 2019. Final Report FY16 Phase 1 Regional Site Inspections for Per

and Poly Fluoralkyl Substances Volume I of XII: Delaware 166th Airlift Wing, Delaware Air

National Guard, New Castle Air National Guard Base, New Castle, Delaware.

Delaware Department of Natural Resources and Environmental Control (DNREC). New castle

County Airport Area Community Fact Sheet. (Accessed September 2019).

http://www.dnrec.delaware.gov/dwhs/SIRB/Documents

Delaware Geological Survey (DGS). 2019. Hydrologic Information for Delaware. (Accessed

September 2019). https://www.dgs.udel.edu/water-resources

Delaware Geological Survey (DGS). 2005. Geologic Map of New Castle County, Delaware.

(Accessed October 8, 2019). https://www.dgs.udel.edu/datasets/dgs-geologic-map-no-13-

new-castle-county-dataset

Delaware Online (DO). 2019. Delaware City Refinery Fire: Residents Report Hearing Loud

Rumbling, Horns. (Accessed December 12, 2019).

https://www.delawareonline.com/story/news/local/2019/02/03/fire-delaware-cityrefinery/2762056002/

Delaware River Basin Commission (DRBC). 2013. Contaminants of Emerging Concern in the

Tidal Delaware River. (Accessed November 1, 2019).

https://www.nj.gov/drbc/library/documents/contaminants-of-emergingconcernAug2013rev.pdf

Environmental Data Resources (EDR)TM. 2019. The EDRTM Radius Map Report with GeoCheck.

New Castle County Delaware Government (NCCDE). 2018. Zoning Map Index: Zone 59.

(Accessed September 2019). http://zoningmaps.nccde.org/

URS Group, Inc (URS). 2015. Remedial Investigation Report: River Road Training Site Delaware

Army national Guard New Castle, Delaware.

U.S. Climate Data. 2019. Climate Wilmington – Delaware. (Accessed August 2019).

https://www.usclimatedata.com/climate/wilmington/delaware/united-states/usde0055

U.S. Environmental Protection Agency (USEPA), 1991. Guidance for Performing Preliminary

Assessments under CERCLA. EPA/540/G91/013.

U.S. Environmental Protection Agency (USEPA), 2017. Amendment No. 2 to the 1988 Record of

Decision for the Delaware Sand & Gravel Landfill Superfund Site New Castle, Delaware.

(Accessed February 2019). https://semspub.epa.gov/work/03/2247185.pdf

U.S. Environmental Protection Agency (USEPA), September 2019. Fifth Five-Year Review Report

for Army Creek Landfill Superfund Site New Castle County, Delaware. (Accessed February

2019). https://semspub.epa.gov/work/03/2282857.pdf

U.S. Environmental Protection Agency (USEPA). 2019. Tybouts Corner Landfill New Castle, DE.

(Accessed December 3, 2019).

https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.Cleanup&id=0

300035#bkground
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix A

Data Resources
Data Resources will be provided separately on CD. Data Resources for River Road Training

Site includes:

RRTS Previous Site Investigations

· 2012, Contaminants of Emerging Concern in the Tidal Delaware River: Pilot Monitoring

Survey 2007-2009

· 2014, RRTS Military Munitions Response Program: Remedial Investigation Work

Plan/Uniform Federal Policy-Quality Assurance Project Plan, March 2014

· 2015, RRTS Military Munitions Response Program: Remedial Investigation Report, April

2015

· 2019, FY16 Phase 1 Regional Site Inspections For Perfluorinated Compounds:

Delaware Air National Guard – 166th Airlift Wing, New Castle Air National Guard Base,

New Castle, Delaware, March 2019

· Delaware Department of Natural Resources and Environmental Control’s New Castle

County Airport Area Fact Sheet, PFOS/PFOA Detected in Ground Water from New

Castle Public Wells

RRTS Site Background Documents

· 1998, New Castle County, Delaware Government Zoning Map Index: Zone 59

· 2005, USGS Geologic Map of New Castle County, Delaware, Kelvin W. Ramsey, 2005

· 2017, USEPA Amendment No. 2 to the 1988 Record of Decision for the Delaware Sand

& Gravel landfill Superfund Site, New Castle, Delaware, 2017

· 2019, USEPA Fifth Five-Year Review Report for Army Creek Landfill Superfund Site

New Castle County, Delaware, September 2019

· UCMR3 Summary Table 

RRTS Site Property Documents

· 1908, RRTS Deed, November 16, 1908

Environmental Data Resources, Inc.TM Reports

· 2019, Aerial Photo Decade Package, Environmental Data Resources, Inc., August 27,

2019

· 2019, Historic Aerials Photo Package, Environmental Data Resources, Inc, August 27,

2019

· 2019, Certified Sanborn Map Report, Environmental Data Resources, Inc., August 26,

2019

· 2019, Radius Map Report with Geocheck, Environmental Data Resources, Inc., August

26, 2019
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix B

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix B.1

Interview Records






PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix B.2

Visual Site Inspection Checklists



PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix B.3

Conceptual Site Model Information



PFAS Preliminary Assessment Report

River Road Training Site, New Castle, Delaware

Appendix C

Photographic Log
Preliminary Assessment Report

River Road Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS River Road Training Site New Castle, Delaware

Photograph No. 1

Description:

Fire Extinguisher and tag 

inside administrative building. 

Extinguishers in building are 

all ABC, non-PFAS fire 

suppressants. 

Photo Date: 8/5/2019 

Photograph No. 2

Description:

Wash rack drain that leads to 

oil/water separator.

Photo Date: 8/5/2019 
Preliminary Assessment Report

River Road Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS River Road Training Site New Castle, Delaware

Photograph No. 3

Description:

Oil/water separator is 

underground, approximately 

where the white shed in this 

photograph is located.

Photo Date: 8/5/2019

Photograph No. 4

Description:

HAZMAT Materials Storage 

Shed with a dry chem fire 

extinguisher attached to the 

side.

Photo Date: 8/5/2019
Preliminary Assessment Report

River Road Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS River Road Training Site New Castle, Delaware

Photograph No. 5

Description:

Dry chem Fire Extinguisher

kept on side of the HAZMAT 

storage shed.

Photo Date: 8/5/2019

Photograph No. 6

Description:

Label from extinguisher in the 

previous photograph. It is a 

Pyro Chem PCL 75 ABC dry 

chem extinguisher.

Photo Date: 8/5/2019
Preliminary Assessment Report

River Road Training Site

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS River Road Training Site New Castle, Delaware

Photograph No. 7

Description:

Handheld CO2 fire 

extinguisher stored outdoors at 

RRTS.

Photo Date: 8/5/2019