NATIONAL GUARD BUREAU

111 SOUTH GEORGE MASON DRIVE

ARLINGTON VA 22204-1373

ARNG-IES-D 16 November 2021

MEMORANDUM FOR RECORD

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

Inspection (SI) for Fort Indiantown Gap, Pennsylvania

1. References:

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

Polyfluoroalkyl Substances (PFAS) Policy), 8 January 2021

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

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

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

Department of Defense Cleanup Program), 15 September 2021

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

e. Final Preliminary Assessment Report Fort Indiantown Gap, Pennsylvania 

Perfluorooctane-Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) Impacted 

Sites ARNG Installations, Nationwide, September 2018

f. Final Site Inspection Report Fort Indiantown Gap, PA Perfluorooctane Sulfonic 

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

Nationwide, April 2021

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

of PFAS under the Comprehensive Environmental Response, Compensation, and 

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

established in References 1.a through 1.d.

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

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

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

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

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

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

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

Inspection (SI) for Fort Indiantown Gap, Pennsylvania

2

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

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

ARNG’s determination related to the PFAS PA/SI at Fort Indiantown Gap, 

Pennsylvania. The need for a RI is based upon the following media-specific risk 

screening levels, as directed by the Assistant Secretary of Defense for (Sustainment) 

(Reference 1.c): Groundwater: PFOS: 40 nanograms per liter (ng/L) (40 parts per trillion 

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

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

4. The PFAS PA at Fort Indiantown Gap, finalized on 27 September 2018, Reference 

1.e, concluded further inspection is warranted at six Areas of Interest (AOI) due to

potential release(s) of PFAS to the environment from the use or storage of PFAScontaining materials, such as Aqueous Film Forming Foam (AFFF).

5. The PFAS SI at Fort Indiantown Gap, finalized on 27 April 2021, Reference 1.f,

sampled six AOIs, and confirmed the presence of PFAS in the environment.

Concentrations of PFAS equal to or exceeding the screening levels established by the 

Office of the Secretary of Defense (OSD) in Reference 1.c were found at one of the six

AOIs. The SI concluded further investigation is warranted via Remedial Investigation 

(RI) at the one AOI where exceedances were found. No Further Action (NFA) was 

determined for the remaining five AOIs.

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

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

facility based on the data collected during the SI.

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

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

by formalizing the following decision(s) for each AOI at Fort Indiantown Gap:

a. AOI 1, Combined Arms Collective Training Facility: No further action.

b. AOI 2, West Ramp Fire Pit Training Areas: RI is required.

c. AOI 2, East Ramp Fire Pit Training Area: RI is required. 

d. AOI 2, Building 019-101 Ramp (Building 019-101): RI is required. 

e. AOI 2, Current Fire Station (Building 5-117): RI is required.
ARNG-IES-D

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

Inspection (SI) for Fort Indiantown Gap, Pennsylvania

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f. AOI 2, Crash Site: No further action.

g. AOI 2, Simulated Emergency Event: No further action.

h. AOI 2, Accidental Tank Spill: No further action.

i. AOI 3, Johnson Trail: No further action.

j. AOI 4, Fire Pit Area #19: No further action.

k. AOI 5, First Street: No further action.

l. AOI 6, Biosolid Area: No further action.

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

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

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

Encl THOMAS K. LAFAVE

Lieutenant Colonel, U.S Army

Chief, Cleanup and Restoration 

G-9, Army National Guard
Encl

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

Fort Indiantown Gap, Pennsylvania

Location Preliminary Assessment (PA) Site Inspection (SI)

AOI 

# Area Description Conclusion Determination Conclusion Determination

1

Combined Arms 

Collective Training 

Facility

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

2

West Ramp Fire Pit 

Training Areas

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into

environmental media 

confirmed above 

screening levels

Proceed with

RI

East Ramp Fire Pit 

Training Area

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into

environmental media 

confirmed above 

screening levels

Proceed with

RI

Building 019-101 

Ramp (Building 

019-101)

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into

environmental media 

confirmed above 

screening levels

Proceed with

RI

Current Fire Station 

(Building 5-117)

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into

environmental media 

confirmed above 

screening levels

Proceed with

RI
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site Inspection (SI) for Fort Indiantown 

Gap, Pennsylvania

2

2 

(cont.)

Crash Site

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

Simulated 

Emergency Event

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

Accidental Tank 

Spill

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

3 Johnson Trail

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

4 Fire Pit Area #19

Sufficient evidence of 

a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action

5 First Street

Sufficient evidence of 

a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media 

not confirmed above

screening levels

No further 

action
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site Inspection (SI) for Fort Indiantown 

Gap, Pennsylvania

3

6 Biosolid Area

Sufficient evidence of 

a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS into 

environmental media not 

confirmed above

screening levels

No further 

action

N/A

Prescribed Burns

Insufficient evidence 

of a potential PFAS 

release warranting 

further investigation

No further 

action Not evaluated during SI No further action

Former Crash Rescue 

Fire Station

Insufficient evidence 

of a potential PFAS 

release warranting 

further investigation

No further 

action Not evaluated during SI No further action

Waste Water 

Treatment Plant

Insufficient evidence 

of a potential PFAS 

release warranting 

further investigation

No further 

action Not evaluated during SI No further action

Building 019-177

Insufficient evidence 

of a potential PFAS 

release warranting 

further investigation

No further 

action Not evaluated during SI No further action

Landfills

Insufficient evidence 

of a potential PFAS 

release warranting 

further investigation

No further 

action Not evaluated during SI No further action