FINAL

Preliminary Assessment Report

Fort McClellan Army National

Guard Training Center

Anniston, Alabama

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic

Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

September 2020

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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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...................................................................................5

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

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

1.5.3 Hydrology.......................................................................................................7

1.5.4 Climate...........................................................................................................7

1.5.5 Current and Future Land Use.........................................................................7

2. Fire Training Areas...........................................................................................................11

3. Non-Fire Training Areas ...................................................................................................12

Helicopter Pad ........................................................................................................12

Dining Facilities.......................................................................................................12

Weapons Cleaning Area .........................................................................................12

Fuel Point ...............................................................................................................12

Maintenance Shops ................................................................................................13

Former Decontamination Complex..........................................................................13

4. Emergency Response Areas............................................................................................15

5. Adjacent Sources.............................................................................................................16

Former Fire Training Pit ..........................................................................................16

Former Chemical Laundries (Impregnation Units)...................................................16

6. Preliminary Conceptual Site Model ..................................................................................18

7. Conclusions .....................................................................................................................19

Findings ..................................................................................................................19

Uncertainties...........................................................................................................20

Potential Future Actions ..........................................................................................20

8. References ......................................................................................................................22
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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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

Tables

Table 7-1 No Suspected Release Areas

Table 7-2 Uncertainties

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

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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Acronyms and Abbreviations

°F degrees Fahrenheit

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

ALARNG Alabama Army National Guard

AOI Area of Interest

ARNG Army National Guard

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CSM conceptual site model

CSMS combined maintenance shop

EBS Environmental Baseline Survey

EDRTM Environmental Data Resources, Inc.TM

FTA fire training area

FM-ARNGTC Fort McClellan – Army National Guard Training Center

HA Health Advisory

PA Preliminary Assessment

PFAS per- and poly-fluoroalkyl substances

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

SI Site Inspection

UCMR3 Unregulated Contaminant Monitoring Rule 3

US United States

USACE United States Army Corps of Engineers

USACMLS United States Army Chemical School

USEPA United States Environmental Protection Agency

VSI visual site inspection

WWTP Wastewater Treatment Plant
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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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 Fort McClellan ARNG Training Center (also 

referred to as the “facility”), in Anniston, Alabama, to assess potential PFAS release areas and 

exposure pathways to receptors. Fort McClellan ARNG Training Center is located on 300 acres 

of land that was formerly a portion of the Army Fort McClellan facility, which was closed under 

Base Realignment and Closure. The property is now leased to ALARNG by the United States 

Army Corp of Engineers. 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 11 April 2019 and completed visual site inspections at locations where

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

• Interviewed current Alabama Army National Guard (ALARNG) personnel, including

environmental managers, and operations staff. 

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

McClellan ARNG Training Center, evidence does not support current or former ARNG activities at 

the facility having contributed to PFAS contamination in soil, groundwater, surface water, or 

sediment at the facility or adjacent areas. No areas of interest were identified based on PA data. 

The Fort McClellan Army National Guard Training Center will not move forward in the 

Comprehensive Environmental Response, Compensation, and Liability Act process. Based on 

the USEPA Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, it was indicated that 

PFAS was detected in a public water system above the USEPA lifetime Health Advisory (HA)

within 20 miles of the facility. The HA is 70 parts per trillion for PFOS and PFOA, individually and 

combined. 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. The UCMR3 data is provided in Appendix 

A.
Helicopter

Dining Pad

Facility 1

Dining

Facility 2

Dining

Facility 3

Former

Decontamination

Complex

Fuel

Point

Maintenance

Shop 1

Maintenance

Shop 2

Weapon

Cleaning Area

South Branch

Cane Creek

Remount Creek

Cane Creek

Cave Creek

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Summary of Findings

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Former Fire

Training Pit

Former Chemical Laundries

(Impregnation Units)

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No Suspected Release

Facility Boundary

Water Body

River/Stream

Pipeline

12420 Milestone Center Drive

Germantown, MD 20876

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PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

3

1. Introduction

Authority and Purpose

The Army National Guard (ARNG)-Installations & Environment Division is the lead agency in 

performing Preliminary Assessments (PAs) and Site Inspections (SIs) for Perfluorooctanesulfonic 

acid (PFOS) and Perfluorooctanoic 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 lifetime Drinking Water Health 

Advisories (HAs) for PFOA and PFOS in May 2016, but there are currently no promulgated 

national standards regulating PFAS in drinking water. The HA is 70 parts per trillion for PFOS and 

PFOA, individually or combined. In the absence of federal maximum contaminant levels, some 

states have adopted their own drinking water standards for PFAS. The state of Alabama does not 

currently have drinking water standards for PFAS.

This report presents the findings of a PA for PFAS-containing materials at Fort McClellan Army 

National Guard Training Center (FM-ARNGTC) (referred to as “the facility”), Anniston, Alabama, 

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 locations where PFAS may have been released into the environment at the 

facility. 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 11 April 2019 and 12 April 2019 and completed visual site

inspections (VSIs) at locations where PFAS-containing materials were suspected of being 

stored, used, or disposed; 

• Interviewed current Alabama ARNG (ALARNG) personnel, including environmental

managers, and operations staff. 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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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 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

The Fort McClellan Army National Guard Training Center (FM-ARNGTC) is within the former Fort 

McClellan (approximately 45,679 acres) in Calhoun County, Alabama. The former Fort McClellan

consisted of the Main Post (18,946 acres), Pelham Range (22,245 acres), and the Choccolocco 

Corridor (approximately 4,488 acres which was leased from the State of Alabama) (Environmental 

Science and Engineering, 1998). 

Prior to ALARNG operation of the facility, Fort McClellan was operated by the US Army. The land 

was purchased in 1917 as a troop training ground during World War I. Its primary mission was to 

provide command and support of the US Army Military Police and Chemical School/Training 

Centers, the Training Brigade, and other units by higher authorities (Environmental Science and 

Engineering, 1998). 

In 1995, Base Realignment and Closure (BRAC) Commission identified Fort McClellan for 

closure. In November 1999, the US Army licensed all of Pelham Range and approximately 300 

acres within the cantonment area of the Main Post, known as the Enclave, to the ALARNG. The 

FM-ARNGTC Enclave and Pelham Range make up the FM-ARNGTC. In February 2005 the Army 

transferred real property accountability of the FM-ARNGTC to the ALARNG. The location of 

Pelham Range and the FM-ARNGTC Enclave are depicted in Figure 1-1. The FM-ARNGTC 

Enclave is referred to as the Enclave throughout this PA(Environmental Science and Engineering, 

1998). 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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Facility Environmental Setting

The Enclave lies within the Appalachian Valley and Ridge physiographic province, which is 

characterized by gently rolling parallel valleys separated by steep to well-rounded ridges that rise 

from 100 to 700 feet above the valley floors. Major streams flow down the axes of many of the 

valleys, and tributary streams commonly join the major streams at nearly right angles.

Topography is broadly rolling with elevations ranging from approximately 740 feet near Cave 

Creek to 864 feet on Trench Hill.

1.5.1 Geology

Enclave lies within the Alabama fold-and-thrust belt of the Appalachian Valley and Ridge 

physiographic province of the Appalachian Highlands (USGS, 2004). This province is 

characterized by sharply folded consolidated strata that form northeast trending, subparallel 

valleys and ridges (ANAD, 2005). The Paleozoic rock formations of the area were repeatedly 

folded and thrust-faulted by tectonic stresses, creating fold axes, fault traces, and lithologic 

boundaries. The Enclave is north and east of one such fault complex, the Jacksonville Thrust 

Fault Complex (USGS, 2004). The geology of the area surrounding The Enclave consists of 

Cambrian- to Pennsylvanian-age indurate sedimentary rocks. These rock formations consist of 

folded and faulted sandstones, cherty limestone, dolomites, and conglomerates. High quartz 

content in the rock formations makes these rock types less susceptible to weathering and erosion. 

Valleys are formed by less resistant carbonate limestone, shale, and dolomites, which weather 

easily (Malcolm Pirnie, 2004). The Enclave is on the edge of a widespread karst formation typified 

by the distribution of carbonate rocks within a high rainfall area. The dissolution of carbonate rock 

has been documented as an ongoing process in Calhoun County (USGS, 2004; ANAD, 2005).

Geologic formations beneath the facility from oldest to youngest consist of, quartzose and 

feldspathic sandstone of the Wisner and Wilson Ridge Formations, Shady Dolomite, siltstone and 

sandstone of the Rome Formation; Little Oak and Newala Limestone; Paleozoic Shale; and 

unconsolidated surficial soils (regolith). The Wisner and Wilson Ridge Formations are reportedly 

1,100 feet in thickness, the Shady dolomite is approximately 500 feet thick, and the Little Oak and 

Newala Limestone and Paleozoic Shale are approximately 500 and 175 feet thick, respectively 

(USGS, 2004). The regolith is reported to have an average thickness of 30 to 50 feet but have 

been found as thin as seven feet to greater than 100 feet in some areas. These unconfined soils 

are made up of clay and silty clay with weathered rock fragments (Shaw, 2004). Geologic units 

underlying the facility are depicted on Figure 1-2. 

1.5.2 Hydrogeology

Calhoun County, Alabama, is underlain by carbonate and clastic rocks that are complexly folded 

and faulted; some are slightly metamorphosed. Much of the region is underlain by carbonate rocks 

(limestone and dolomite), which form important aquifers; and silicate rocks (quartzose, sandstone, 

shale, and siltstone), which typically yield less water to wells. Carbonate rocks are soluble by 

acidic water, including rain, which can become even more acidic from decaying vegetation and 

microbial activity when it infiltrates the soil zone. As acidic water infiltrates the subsurface along 

natural openings, such as faults, fractures, and bedding planes, the openings become enlarged 

by dissolution of the rock. This process eventually develops a solution-conduit aquifer oriented 

along the joints, fractures, and bedding planes. The solution-conduit aquifers in Calhoun County 

can supply large volumes of water to wells and springs (Robinson, 2004). 

The complex geology in Calhoun County has created numerous large groundwater storage 

reservoirs formed by thrust fault zones. The water producing aquifers in this area are found in 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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dolomite, limestone, sandstone, and shale (USACE, 2004). The primary aquifers underlying the 

Enclave can be generalized as shallow and deep groundwater systems, consisting of the 

Residuum (shallow aquifer), and the Valley and Ridge aquifer system (deep). Formations 

comprising the Valley and Ridge aquifer system include the Knox Group, Conasauga Formation, 

Shady Dolomite, and Weisner and Wilson Formation aquifers (USGS, 2004). The Conasauga 

Formation is the most important regional aquifer in Calhoun County (SAIC, 1998b).

The depth of the shallow groundwater system within Enclave is as little as four feet in some areas. 

The shallow groundwater system (generally down to 50 feet) is comprised of the residuum, 

weathered bedrock, and epikarst while the deep groundwater (generally below 50 feet) is found 

in the carbonate bedrock within its fractures and dissolution features (ANAD, 2005). The shallow 

and deep groundwater systems are interconnected through fractures, voids, and faults. 

Groundwater flow in the Enclave area is complex as a result of the regional hydrogeology 

including the variable thickness of the surface unconsolidated zone (e.g., residuum and epikarst), 

the porosity of underlying bedrock, and the presence of faults and fractures and other karst 

features. Generally, groundwater flow is controlled by topography and the permeability of the karst 

bedrock. Shallow groundwater flow in the residuum and epikarst follows topography, with 

groundwater movement generally toward Clear Creek and Cane Creek. Groundwater flow 

directions are supported based on reports for groundwater flow provided in installation monitoring 

reports (Weston, 1990). Groundwater beneath the Enclave generally flows northwestward, based 

on average groundwater elevation measurements from spatially clustered wells, as well as widely 

spaced monitoring wells. Variability in the groundwater flow direction is likely to occur in localized 

areas of the facility, depending on local topography, proximity to surface water bodies, and 

subsurface geology and structure. Groundwater features surrounding the facility are shown in 

Figure 1-2. 

An EDRTM report conducted a well search for a 1-mile radius surrounding the facility (Appendix 

A). Using additional online resources, such as state and local GIS databases, wells were 

researched to a 4-mile radius of the facility. Groundwater wells are used for potable and nonpotable water in the surrounding areas. Approximately 90 percent of the water consumed in 

Calhoun County is supplied by groundwater. Groundwater sources for potable water include 

private wells and some of the 147 groundwater springs that have been documented within the 

county. Coldwater Spring located approximately ten miles southwest of former Fort McClellan, at 

the foot of Coldwater Mountain, is the major source of spring water for the area and is a natural 

source of about 24 to 36 million gallons of water per day. This spring serves nearly 60 percent of 

Calhoun County residents, including Anniston, Oxford, Blue Mountain, Hobson City, Anniston 

Army Depot, FM-ARNGTC, and the former Fort McClellan area (AMEC Earth & Environmental, 

2001). The remainder of the residents are served by private wells, groundwater springs, or one 

of four smaller public water supply systems (i.e., Oxford Water System and Sewer Board, Calhoun 

Water System, Jacksonville Treatment Facility, and Weaver City Water Supply). The four smaller 

public water supplies also obtain water from groundwater sources (ATSDR, 1999). A public water 

supply, Anniston Water Works, draws the majority of its water from Coldwater Spring. In addition 

to Coldwater Spring, Anniston Water Works uses the Earl C. Knowlton Treatment Plant for 

standby services. This plant draws its water from Hillabee Lake, which is near the town of Oxford. 

Based on the USEPA Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, it was indicated 

that PFAS was detected in a public water system above the USEPA HA within 20 miles of the 

facility (Appendix A). The HA is 70 parts per trillion for PFOS and PFOA, individually or combined. 

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. 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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1.5.3 Hydrology 

The Enclave is within the Middle Coosa River watershed (approximately 2,571 square miles in 

total area). The Middle Coosa River watershed contains 23 streams and rivers, totaling 

approximately 3,360 river miles. Downgradient of FM-ARNGTC, the Coosa River has been 

impounded to form the Logan Martin Reservoir. Logan Martin Reservoir borders St. Clair and 

Talladega counties and extends 48.5 miles from the Logan Martin dam upstream to Neely Henry 

dam. Cane Creek flows westerly through the Enclave into the Logan Martin Reservoir. Tributaries 

of Cane Creek in this area include Cave, Remount, South Branch, and Ingram creeks (AMEC 

Earth & Environmental, 2001). 

Cane Creek originates at the Choccolocco Mountains on the Enclave and flows westward just 

south of the facility towards Pelham Range. The operational ranges drain to Cave Creek which is 

a tributary of Cane Creek; all of the facility is within the drainage basin of Cane Creek.

Based on information gathered in a 1998 Environmental Baseline Survey (EBS), storm water 

collected by storm drains onsite are directed to the Wastewater Treatment Plant (WWTP), located 

on the west side of Highway 21. The WWTP was built in 1918 and was operated by the US Army

until the WWTP was leased to Water Works and Sewer Board of the city of Anniston in 1974. This 

board operates the facility and holds the WWTP NPDES permit (No. AL0024520). All of the 

Enclave and the surrounding neighborhoods of Pelham Range and Lenlock are supported by the 

WWTP. The treated effluent is discharged to Cane Creek (Environmental Science and 

Engineering, 1998). Surface water features surrounding the facility are shown in Figure 1-3. 

1.5.4 Climate 

The climate in northeastern Alabama is temperate with warm, humid summers and mild, dry 

winters. During the summer months, the climate borders on the subtropical with frequent localized 

thunderstorms. Rainfall is greatest from January through April and lowest from September through 

November. Average annual precipitation is 53.3 inches and the average annual temperature at 

Anniston is 62 degrees Fahrenheit (°F). The mean maximum temperature for January is 48°F, 

while the mean maximum in July is 78°F. Temperature extremes at Pelham Range have ranged 

from -3°F to +105°F. The average daily highs reach 90°F in the summer months. The first frost 

typically occurs in October, and frost conditions may last into mid-April (National Oceanic and 

Atmospheric Administration, 2018). 

1.5.5 Current and Future Land Use

The Enclave is within an area of mixed residential and commercial properties. Mixed residential 

and commercial properties are located adjacent to the facility to the north, west and south. The 

Mountain Longleaf National Wildlife Refuge is located adjacent and to the west of the Enclave. 

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

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12420 Milestone Center Drive

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Facility Location

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A!

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Remount Creek

Alexandria Creek

Bobs Creek

Ingram Creek

Boy d Spring Branch

Sho al

Creek

South Branch Cane Creek

Cave Creek

Little

Tal lasseehatchee Creek

Battle Creek

East erwood Branch

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Facility Boundary

Water Body

Stream/River

Canal/Ditch

Pipeline

Inferred Groundwater

Flow Direction

Geology

Parkwood Formation and

Floyd Shale

Undifferentiated

Paleozoic Shale

Undifferentiated

Athens Shale

Little Oak and Newala

Limestones

Knox Group

Conasagua Formation

Lower Conasagua

Formation

Rome Formation

Shady Dolomite

Chilhowee Group

Weisner and Wilson

Ridge Formations

Undifferentiated

Nichols Formation

Wells

A! USGS Inactive

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Little Tallasseehatchee

Creek Watershed

Rabes

Branch-Tallasseehatchee

Creek Watershed

Upper Cane Creek

Watershed South Branch CaneCreek

Cane Creek

Remount Creek

Ingram

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Cave Creek

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12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

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

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0 1,000 2,000 4,000

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Fort McClellan Army National Guard Training Center

Anniston, Alabama

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2. Fire Training Areas

No FTAs were identified within the facility during the PA through interviews (Appendix B) or 

document review (Appendix A). Based on interviews conducted during this PA, ALARNG 

personnel with knowledge of the property dating back to 1986 confirmed that no fire training 

occurred within the FM-ARNGTC. However, a Former Fire Training Pit used by the US Army prior 

to ALARNG operation, was identified on the former Main Post at the location of Building 350, the 

Consolidated Maintenance Facility. The location of the Former Fire Training Pit is located outside 

the facility boundary and discussed in Section 5. 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

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 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 Appendices A and B. Nine non-FTAs were 

investigated as part of this PA. A description of each non-FTA is presented below and shown on 

Figure 3-1 with photographs appearing in Appendix C. 

Helicopter Pad

The Helicopter Pad is approximately 200 feet southwest of the FM-ALARNGTC Army Air Force 

Exchange Service Building. The geographic coordinates are 33° 43' 58.5" N; 85° 47' 8.8"W. Fire 

protection is provided by mobile ABC class fire extinguishers. According to ALARNG personnel 

with knowledge of the site since 1986, AFFF has not been used or stored in this area. Based on 

interviews and document review, there were no reported rotary aircraft crashes or emergency 

responses at the Helicopter Pad. Therefore, Helicopter Pad is not considered a suspected release 

area.

Dining Facilities

There are seven dining facilities at FM-ALARNGTC. Several dining facilities at the facility were 

visited during the PA site visit. These dining facilities are designated as Dining Facility’s 1 through 

3 on Figure 3-1. The geographic coordinates of Dining Facility 1 through 3 are 33° 43' 56.2" N; 

85° 47' 34.8"W, 33° 44' 6.6" N; 85° 47' 16.4"W, and 33° 43' 54.3" N; 85° 47' 6.7"W, respectively. 

According to ALARNG personnel interviewed, AFFF was not used or stored in the dining facilities. 

Restaurant fire suppression systems are installed within the dining facilities and charged with 

ANSULEX Low pH Liguid Fire Suppressant. Additionally, wall mounted Class K, potassium 

carbonate fire extinguishers are located in each of the dining facilities. Therefore, the dining 

facilities are not considered suspected release areas.

Weapons Cleaning Area

The Weapons Cleaning Area is approximately 400 feet northwest of Dining Facility 1. The 

geographic coordinates are 33° 43' 59.9" N; 85° 47' 36.6"W. The ALARNG uses two wooden 

tables approximately 60 feet long for disassembling, cleaning and reassembling weapons. Gun 

cleaners and lubricant including Break-Free® CLP® are stored in a locked equipment room at the 

east side of the Weapons Cleaning Area. According to ALARNG personnel, approximately one 

gallon of CLP® is used per month. Rags used with CLP® are double bagged and disposed of as 

hazardous waste. According to ALARNG personnel interviewed, AFFF was not used or stored in 

this area. Additionally, minimal amounts of CLP® are stored in the locked equipment room at one

time. Therefore, this weapons cleaning area is not considered a suspected release area. 

Fuel Point

The Fuel Point is approximately 700 feet northwest of Dining Facility 1. The geographic 

coordinates are 33° 43' 58.1" N; 85° 47' 25.5" W. This Fuel Point is used for military vehicle 

refilling. Fire suppression at the fuel point is provided by wall mounted Class ABC fire 

extinguishers. ALARNG personnel interviewed did not have knowledge of fuel spills at this fuel 

point and confirmed that AFFF had not been used or stored in this area. Therefore, the fuel point 

is not considered a suspected release area.
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

13

Maintenance Shops 

Two vehicle maintenance buildings were visited during the PA site visit and designated as 

Maintenance Shop 1 and Maintenance Shop 2. The geographic coordinates for Maintenance 

Shop 1 and Maintenance Shop 2 are 33° 44' 9.1" N; 85° 47' 20.2" W , and 33° 43' 40.7" N; 85° 

47' 6.0" W, respectively. These maintenance areas are used for general maintenance of ALARNG 

vehicles. All fueling activity takes place at the Fuel Point discussed above. Fire protection in the 

maintenance area is provided by a wall mounted ABC class fire extinguisher or Purple K fire 

extinguishers. The maintenance shops were not equipped with an AFFF fire suppression systems, 

and according to ALARNG personnel interviewed, AFFF has not been used or stored in these 

areas. Therefore, the maintenance shops are not considered suspected release areas.

Former Decontamination Complex

The Former Decontamination Complex is at the north end of the FM-ARNGTC. The geographic 

coordinates are 33° 44' 11.9" N; 85° 47' 26.6"W. Prior to ALARNG operation of the facility, the 

Former Decontamination Complex was used by the US Army and housed the 61st Chemical 

Company from 1961 to 1973, a chemical laundry. The 61st Chemical Company reimpregnated 

undergarments with paraffin used in chemical exercises. All the waste from the laundry’s operation 

were discharged to the sanitary sewer. Reimpregnation activities used wax, chlorinated oils and 

reportedly toluene and ethanol alcohol. The Former Decontamination Complex was closed in 

1994 (Environmental Science and Engineering, 1998). Based on aerial imagery provided in the 

EDRTM report (Appendix A), buildings associated with the Former Decontamination Complex 

were demolished after 1998. Currently the area is used as a paved lot for staging of ALARNG 

vehicles. ALARNG personnel with knowledge of the property back to 1986 have confirmed that 

PFAS were not used in the reimpregnation process at the Former Decontamination Complex.

Therefore, the Former Decontamination Complex is not considered a suspected release area. 
Helicopter

Pad

Dining

Facility 1

Dining

Facility 2

Dining

Facility 3

Former

Decontamination

Complex

Fuel

Point

Maintenance

Shop 1

Maintenance

Shop 2

Weapon

Cleaning Area

South Branch

Cane Creek

Remount Creek

Cane Creek

Cave Creek

Legend

No Suspected Release

Facility Boundary

Water Body

River/Stream

Pipeline

CLIENT

REVISED

SCALE

ARNG

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CHK BY

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12420 Milestone Center Drive

Germantown, MD 20876

Non-Fire Training Areas

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:10,800

0 450 900 1,800

Feet

14
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

15

4. Emergency Response Areas

No emergency response areas were identified within the Enclave during the PA through interviews 

or document review. Based on interviewees, informal mutual agreements are in place with the 

local county fire department.
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

16

5. Adjacent Sources

Two potential off-facility sources of PFAS adjacent to FM-ARNGTC, not under the control of 

ALARNG, were identified during the PA. These potential off-facility sources include the Former 

Fire Training Pit and the Former Chemical Laundries (Impregnation Units). These potential 

sources are depicted on Figure 5-1 and described below. 

Former Fire Training Pit

The Former Fire Training Pit is located approximately 0.5 miles southeast of the FM-ARNGTC. 

The geographic coordinates for the Former Fire Training Pit are 33° 43' 19.8" N; 85° 46' 43.2" W. 

The Former Fire Training Pit used by the US Army prior to ALARNG operation, and was identified 

on the former Main Post at the location of Building 350, the Consolidated Maintenance Facility.

Currently, International Automotive Components is constructed on the location of the Former Fire 

Training Pit. 

The dates of the operation of the Former Fire Training Pit are unknown, however, according to an 

Environmental Baseline Survey (EBS) completed in 1998, use of the former fire pit was 

discontinued prior to 1986. The fire pit was reportedly used approximately once a year by the US

Army to train firefighters. Waste oil and other fluids that were stored across the street in a fenced 

compound were spread on the ground at the fire pit, ignited and then extinguished during training. 

According to the EBS the fire pit was concrete lined after 1978 and rainwater runoff was 

discharged to cane Creek. Prior to construction of Building 350 in 1991, the entire pad and soil 

were excavated, and the area was backfilled with clean soil. 

The EBS did not specify methods used to extinguish fires at the Former Fire Training Pit. However, 

based on historical fire training practices and the prevalence of PFAS in AFFF after 1969, it is 

possible AFFF could have been used in these fire training exercises. Therefore, the Former Fire 

Training Pit is considered a potential off-facility source of PFAS, not under control of ALARNG. 

Former Chemical Laundries (Impregnation Units)

The 111th Garment Impregnation Plant and 317th Garment Impregnation Plant were located on 

the hard stand east of 5th Avenue, about 1 mile south of the current FM-ARNGTC. The geographic 

coordinates for the Former Chemical Laundries are 33° 42' 44.0" N; 85° 46' 44.8" W. Based on 

information provided in the 1998 EBS, the dates of operation of this facility are unknown but can 

be estimated as beginning in 1951 when the US Army Chemical School (USACMLS) arrived at 

the former FM-ARNGTC, until approximately the mid-1960s when butyl rubber protective 

garments began to be issued. 

The garment impregnation facilities were reportedly used to treat military garments to render them 

relatively impermeable to chemical warfare material (CWM). The standard operating procedure 

(SOP) for typical impregnation plants was located in the USACMLS library, and describes use of 

only water, wax and “chlorinated oil.” ALARNG personnel with knowledge of the property back to 

1986 have confirmed that PFAS were not used in the impregnation process at the Former 

Chemical Laundries (Impregnation Units). Therefore, the Former Chemical Laundries 

(Impregnation Units) is not considered a potential off-facility source of PFAS. 
Former Chemical Laundries

(Impregnation Units)

Former Fire

Training Pit

South Branch Cane Creek

Cane Creek

Ingram Creek

Remount Creek

Cave Creek

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Pipeline

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

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12420 Milestone Center Drive

Germantown, MD 20876

Adjacent Sources

Base Map: Source: Esri, DigitalGlobe, GeoEye,

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

1:15,600

0 650 1,300 2,600

Feet

17
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

18

6. Preliminary Conceptual Site Model

Based on the PA findings, no release areas were identified as AOIs at FM-ARNGTC. 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. Based on the findings of this PA, there are no PFAS sources that 

originate at the Enclave from activities associated with the facility; therefore, exposure pathways 

are considered incomplete. 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

19

7. Conclusions

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

storage of AFFF and other PFAS-related activities at FM-ARNGTC. The PA findings are based 

on the information presented in Appendix A and Appendix B. 

Findings

No PFAS releases relating to current or historical activities at the Enclave were identified during 

this PA (Figure 7-1. The following areas, which were discussed in Section 3 and Section 5) and 

are presented in Table 7-1 below, were determined to have no suspected releases. 

Table 7-1: No Suspected Release Areas

No Suspected 

Release Area Used by Rationale for No Suspected Release Determination

Helicopter Pad ALARNG

According to interviews and document review, AFFF was 

not used or stored at the Helicopter Pad. There were no 

reported emergency response or rotary aircraft crashes in 

this area. 

Dining Facilities ALARNG

According to interviews, AFFF was not used or stored at 

the dining facilities. Visual inspection confirmed the use of 

ANSULEX Low pH Liquid Fire Suppressant and wall 

mounted Class K, potassium carbonate fire extinguishers. 

Weapons 

Cleaning Area ALARNG

According to interviews, AFFF was not used or stored in 

this area. Minimal amounts of CLP® are stored in the 

locked equipment room at one time. Residual amounts of 

CLP® and rags used in the cleaning process are double 

bagged and disposed of as hazardous waste. 

Fuel Point ALARNG

According to interviews, no fuel spills were reported at the 

Fuel Point and confirmed that AFFF had not been used or 

stored in this area. 

Maintenance 

Shops ALARNG

The maintenance shops were not equipped with an AFFF 

fire suppression systems. According to interviews, AFFF 

has not been used or stored in these areas.

Former 

Decontamination 

Complex

US Army

According to interviews, no PFAS were used in the 

reimpregnation process at the Former Decontamination 

Complex. 

Based on the documented absence of the use or release of PFAS-containing materials at FMARNGTC, evidence does not support current or former ARNG activities at the facility having 

contributed to PFAS contamination in soil, groundwater, surface water, or sediment at the facility 

or adjacent areas. No AOIs related to PFAS release were identified based on PA data. One

potential off-facility PFAS release area, Former Fire Training Pit, exists adjacent to FM-ARNGTC. 

Because this area includes property upgradient of the facility, it is unknown whether or not the offfacility source affects FM-ARNGTC. 
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

20

Uncertainties

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

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

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

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

training, firefighting, or other non-traditional activities, or on its disposition. 

The conclusions of this PA are 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. Sometimes, the provided information 

was vague or conflicted with other sources. Gathered information has a degree of uncertainty due 

to the absence of written documentation, the limited number of personnel with direct knowledge 

due to staffing changes, the time passed since PFAS were first used (1969 to present), and a 

reliance on personal recollection. Inaccuracies may arise in potential PFAS release locations, 

dates of release, volume of releases, and the concentration of AFFF used. There is also a 

possibility the PA has missed a source of PFAS, as the science of how PFAS may enter the 

environment continually evolves.

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

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

for the same potential source area, and potential source areas were visually inspected. Table 7-

3 summarizes the uncertainties associated with the PA:

Table 7-2: Uncertainties

Location Source of Uncertainty

FM-ARNGTC

The US Army operated at the facility from 1917 to 1999. Most ALARNG 

personnel interviewed had limited knowledge of Army operations. One 

interviewee had limited knowledge of the site from 1986. Most of the US

Army operation could only be gleaned from historical document review. 

Potential Future Actions

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

Enclave (1986 to present), no AOIs were identified during the PA. Evidence does not indicate that 

current or former ARNG activities contributed PFAS contamination to soil, groundwater, surface 

water, or sediment at the facility or adjacent areas. Therefore, the Enclave will not move forward 

in the CERCLA process. 
Helicopter

Dining Pad

Facility 1

Dining

Facility 2

Dining

Facility 3

Former

Decontamination

Complex

Fuel

Point

Maintenance

Shop 1

Maintenance

Shop 2

Weapon

Cleaning Area

South Branch

Cane Creek

Remount Creek

Cane Creek

Cave Creek

CLIENT

REVISED

SCALE

ARNG

GIS BY

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Summary of Findings

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

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

1:10,800

0 450 900 1,800

Feet

Former Fire

Training Pit

Former Chemical Laundries

(Impregnation Units)

Legend

Potential PFAS Release

No Suspected Release

Facility Boundary

Water Body

River/Stream

Pipeline

12420 Milestone Center Drive

Germantown, MD 20876

21
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

22

8. References

Agency for Toxic Substances and Disease Registry (ATSDR). 1999. 

http://www.atsdr.cdc.gov/HAC/pha/pha.asp?docid=834&pg=4#table5

AMEC Earth and Environmental, Inc. 2001. Final Integrated Natural Resource Management Plan 

and Environmental Assessment for the Fort McClellan Army National Guard Training Center.

Anniston Army Depot (ANAD). 2005. Installation Action Plan (IAP) FY2006 for Alabama, Anniston 

Army Depot.

Environmental Science & Engineering, Inc. 1998. Final, Environmental Baseline Survey, Fort 

McClellan, Alabama (Volume I and II).

Ewers Water Consultants Inc. 1994. Final Report Groundwater Tracing Studies Anniston Army 

Depot, Anniston, Alabama.

Malcolm Pirnie, Inc. 2004. Final Historical Records Review for Anniston Army Depot.

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

Practice. January.

National Oceanic and Atmospheric Administration. 2018. NOWData – NOAA Online Weather 

Data, Monthly Climate Normals (1981-2010)- Anniston Metropolitan AP, AL. 

https://w2.weather.gov/climate/xmacis.php?wfo=bmx. (Accessed 27 May 2020).

Robinson, J.L. 2004. Age and Source of Water in Springs Associated with the Jacksonville Thrust 

Fault Complex, Calhoun County, Alabama. U.S. Geological Survey Scientific Investigations 

Report 2004–5145.

SAIC. 1998b. Report on the Findings for the Groundwater Tracer Test at the Anniston Army 

Depot Southeast Industrial Area, Anniston, Alabama. 

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

Preliminary Assessments under CERCLA. September.

United States Geological Survey (USGS). 2004. Age and Source of Water in Springs Associated 

with the Jacksonville Thrust Fault Complex, Calhoun County, Alabama.

USACE. 2004. Second Five-Year Review Report for Interim Action Record of Decision Shallow 

Groundwater Operable Unit Groundwater Treatment System, Anniston Army Depot, Calhoun 

County, Alabama.

Weston, Roy F. Inc. (Weston). 1990. Enhanced Preliminary Assessment: Fort McClellan, 

Alabama, Volumes I & II.
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix A 

Data Resources
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center, Anniston, Alabama

Data resources will be provided separately on CD. Data resources for Fort McClellan Army 

National Guard Training Center include:

Deed Documents

• 2001 Quitclaim Deed NO. 3 Form McClellan, Alabama. Deed 3004

• 2003 Quitclaim Deed NO. 9 Form McClellan, Alabama. Deed 3036

2005 Quitclaim Deed Form McClellan, Alabama. Deed 3068

Historical Reports and Documents

• 1990 Weston, Roy F. Inc. (Weston). Enhanced Preliminary Assessment: Fort McClellan,

Alabama, Volumes I & II.

• 1994 Ewers Water Consultants Inc. Final Report Groundwater Tracing Studies Anniston

Army Depot, Anniston, Alabama.

• 1998 Environmental Science & Engineering, Inc. Final, Environmental Baseline Survey,

Fort McClellan, Alabama (Volume I and II).

• 1998 SAIC. Report on the Findings for the Groundwater Tracer Test at the Anniston Army

Depot Southeast Industrial Area, Anniston, Alabama.

• 2001 AMEC Earth and Environmental, Inc. Final Integrated Natural Resource Management

Plan and Environmental Assessment for the Fort McClellan Army National Guard Training

Center

• 2004 Malcolm Pirnie, Inc. Final Historical Records Review for Anniston Army Depot.

• 2004 USACE. Second Five-Year Review Report for Interim Action Record of Decision

Shallow Groundwater Operable Unit Groundwater Treatment System, Anniston Army

Depot, Calhoun County, Alabama.

• 2005 Anniston Army Depot (ANAD). Installation Action Plan (IAP) FY2006 for Alabama,

Anniston Army Depot.

Environmental Data Resources, Inc. Geocheck Report

• 2019 Environmental Data Resources, Inc. Geocheck Report for Fort McClellan, Anniston,

Alabama

Miscellaneous Documents 

• 1989 USEPA Risk Assessment Guidance for Superfund Volume I, Human Health

Evaluation Manual (Part A) Interim Final
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix B 

Preliminary Assessment Documentation
PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix B.1 

Interview Records







PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix B.2 

Visual Site Inspection Checklists

















PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix B.3 

Conceptual Site Model Information



PFAS Preliminary Assessment Report

Fort McClellan Army National Guard Training Center

Anniston, Alabama

Appendix C 

Photographic Log
Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center– Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

Fort McClellan Army National Guard 

Training Center- Anniston AL Anniston, Alabama

Photograph No. 1

Description:

Cleaners and lubricants in the 

Weapons Cleaning Area

Photo date 4/12/19

Photograph No. 2

Description:

Cleaners, lubricants and rags 

in the Weapons Cleaning Area

Photo Date: 4/12/19
Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center– Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

Fort McClellan Army National Guard 

Training Center- Anniston AL Anniston, Alabama

Photograph No. 3

Description:

Looking southeast

General view of Helicopter 

Pad

Photo Date: 4/12/19

Photograph No. 4

Description:

Looking southeast

General view of ABC fire 

extinguisher at Helicopter Pad

Photo Date: 4/12/19
Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center– Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

Fort McClellan Army National Guard 

Training Center- Anniston AL Anniston, Alabama

Photograph No. 5

Description:

General view of hood fire 

suppression system in dining 

facility

Photo Date: 4/12/19

Photograph No. 6

Description:

General view of Class K fire 

extinguisher in dining facility

Photo Date: 4/12/19
Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center– Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

Fort McClellan Army National Guard 

Training Center- Anniston AL Anniston, Alabama

Photograph No. 7

Description:

Looking east

General view of Fuel Point

Photo Date: 4/12/19

Photograph No. 8

Description:

Looking north

General view of ABC fire 

extinguisher at Fuel Point

Photo Date: 4/12/19
Preliminary Assessment Report

Fort McClellan Army National Guard Training 

Center– Anniston, AL

Perfluorooctane-Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

APPENDIX C – Photographic Log

Army National Guard, Preliminary 

Assessment for PFAS

Fort McClellan Army National Guard 

Training Center- Anniston AL Anniston, Alabama

Photograph No. 9

Description:

Looking north

Storm drain at Fuel Point

Photo Date: 4/12/19

Photograph No. 10

Description:

Looking southwest

General view of Purple K fire 

extinguisher at truck 

maintenance area. 

Photo Date: 4/12/19