FINAL

Site Inspection Report 

Camp Ethan Allen Training Site, 

Vermont

Perfluorooctanesulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites

ARNG Installations, Nationwide

August 2021

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
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Table of Contents

Executive Summary ................................................................................................................ES-1

1. Introduction ....................................................................................................................1-1

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

1.2 SI Purpose ..............................................................................................................1-1

2. Facility Background........................................................................................................2-1

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

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

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

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

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

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

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

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

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

2.4 Other PFAS Investigations......................................................................................2-6

3. Summary of Areas of Interest.........................................................................................3-1

3.1 AOI 1 – Biathlon Course .........................................................................................3-1

3.1.1 Waxing Areas (Walker Building and Waxing Sheds) ....................................3-1

3.1.2 Snowmaking Pond........................................................................................3-1

3.1.3 Biathlon Course............................................................................................3-1

4. Project Data Quality Objectives .....................................................................................4-1

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

4.2 Goals of the Study ..................................................................................................4-1

4.3 Information Inputs: ..................................................................................................4-2

4.4 Study Boundaries ...................................................................................................4-2

4.5 Analytical Approach ................................................................................................4-2

4.6 Data Usability Assessment .....................................................................................4-3

4.6.1 Precision.......................................................................................................4-3

4.6.2 Precision.......................................................................................................4-3

4.6.3 Accuracy.......................................................................................................4-4

4.6.4 Representativeness......................................................................................4-4

4.6.5 Comparability................................................................................................4-5

4.6.6 Completeness...............................................................................................4-5

4.6.7 Sensitivity .....................................................................................................4-6

5. Site Inspection Activities.................................................................................................5-1

5.1 Pre-Investigation Activities......................................................................................5-1

5.1.1 Technical Project Planning ...........................................................................5-1

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

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

5.2 Soil Borings and Soil Sampling...............................................................................5-2

5.3 Temporary Well Installation and Groundwater Grab Sampling ...............................5-3

5.4 Surface Water and Sediment Sampling..................................................................5-4

5.5 Investigation-Derived Waste ...................................................................................5-5

5.6 Laboratory Analytical Methods................................................................................5-5

5.7 Deviations from SI QAPP Addendum .....................................................................5-6
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6. Site Inspection Results...................................................................................................6-1

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

6.2 Soil Physicochemical Analyses...............................................................................6-1

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

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

6.3.2 AOI 1 Groundwater Analytical Results .........................................................6-2

6.3.3 AOI 1 Surface Water Analytical Results .......................................................6-3

6.3.4 AOI 1 Sediment Analytical Results ...............................................................6-3

6.3.5 AOI 1 Conclusions........................................................................................6-3

7. Exposure Pathways .......................................................................................................7-1

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

7.1.1 AOI 1 ............................................................................................................7-1

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

7.2.1 AOI 1 ............................................................................................................7-2

7.3 Surface Water and Sediment Exposure Pathway...................................................7-2

7.3.1 AOI 1 ............................................................................................................7-2

8. Summary and Outcome .................................................................................................8-1

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

8.2 SI Goals Evaluation ................................................................................................8-1

8.3 Outcome .................................................................................................................8-2

9. References.....................................................................................................................9-1

Appendices

Appendix A Data Validation Reports

Appendix B Field Documentation

B1. Log of Daily Notice of Field Activities

B2. Sampling Forms

B3. Nonconformance and Corrective Action Reports 

B4. Investigation-Derived Waste Polygons

Appendix C Photographic Log

Appendix D TPP Meeting Minutes

Appendix E Boring Logs 

Appendix F Analytical Results

Appendix G Laboratory Reports
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Figures

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Surface Water Features

Figure 3-1 Area of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOS Detections in Soil

Figure 6-2 PFOA Detections in Soil

Figure 6-3 PFOA and PFOS Detections in Groundwater

Figure 6-4 PFOA and PFOS Detections in Surface Water

Figure 6-5 PFOA and PFOS Detections in Sediment

Figure 7-1 Conceptual Site Model, AOI 1

Tables

Table ES-1 Screening Levels (Soil and Groundwater)

Table ES-2 Summary of Site Inspection Findings

Table ES-3 Site Inspection Recommendations

Table 2-1 PFAS Detections in Potable Wells at CEATS (March 2017)

Table 2-2 Well #40293 (Walker Building Well) Sampling Results

Table 5-1 Site Inspection Samples by Medium

Table 5-2 Soil Boring Depths and Temporary Well Screen Intervals

Table 6-1 Screening Levels (Soil and Groundwater)

Table 6-2 PFAS Detections in Surface Soil

Table 6-3 PFAS Detections in Shallow Subsurface Soil

Table 6-4 PFAS Detections in Groundwater

Table 6-5 PFAS Detections in Surface Water

Table 6-6 PFAS Detections in Sediment

Table 8-1 Summary of Site Inspection Findings

Table 8-2 Site Inspection Recommendations
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Acronyms and Abbreviations

6:2 FTS 6:2 Fluorotelomer sulfonate

8:2 FTS 8:2 Fluorotelomer sulfonate

μg/kg micrograms per kilogram

°C degrees Celsius

°F degrees Fahrenheit

% percent

AECOM AECOM Technical Services, Inc.

AFFF aqueous film forming foam

amsl above mean sea level

AOI Area of Interest

ARNG Army National Guard

bgs below ground surface 

CEATS Camp Ethan Allen Training Site

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CoC chain of custody

CSM conceptual site model

DA Department of the Army

DoD Department of Defense

DO dissolved oxygen

DPT direct-push technology

DQI data quality indicator

DQO data quality objective

DUA data usability assessment

DVR data validation report 

EDRTM Environmental Data Resources, Inc.

EIS extraction internal standards

ELAP Environmental Laboratory Accreditation Program

EM Engineering Manual

FedEx Federal Express

ERB equipment rinsate blank

FRB Field Reagent Blank

foot/day foot per day

GPR ground-penetrating radar

GPS global positioning system

HDPE high-density polyethylene 

HA Health Advisory

IDW investigation-derived waste

ITRC Interstate Technology Regulatory Council

LC/MS/MS liquid chromatography with tandem mass spectrometry

LCS laboratory control spike

LCSD laboratory control spike duplicate

LOD limit of detection

LOQ limit of quantitation
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MCL maximum contaminant level

MDL method detection limit

MS matrix spike

MSD matrix spike duplicate

NELAP National Environmental Laboratory Accreditation Program

NEtFOSAA N-ethyl perfluorooctanesulfonamidoacetic acid

ng/L nanograms per liter

NMeFOSAA N-methyl perfluorooctanesulfonamidoacetic acid

NOAA National Oceanic and Atmospheric Administration

ORP oxidation-reduction potential

OSD Office of the Secretary of Defense

PA Preliminary Assessment

PFAS per- and polyfluoroalkyl substances

PFBA perfluorobutyrate

PFBS perfluorobutanesulfonic acid

PFDA perfluorodecanoic acid

PFDoA perfluorododecanoic acid

PFHpA perfluoroheptanoic acid

PFHxA perfluorohexanoic acid

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PFPeA perfluoropentanoic acid

PFTeDA perfluorotetradecanoic acid

PFTrDA perfluorotridecanoic acid

PFUdA perfluoroundecanoic acid

PID photoionization detector

PQAPP Programmatic UFP-QAPP

PVC poly-vinyl chloride

QAPP Quality Assurance Project Plan

QC quality control

QSM Quality Systems Manual

RI Remedial Investigation

RPD relative percent differences

SDWA Safe Drinking Water Act

SI Site Inspection

SL screening level

SOP standard operating procedure

TOC total organic carbon

TPP Technical Project Planning

UFP Uniform Federal Policy

US United States

USACE United States Army Corps of Engineers

USCS Unified Soil Classification System
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USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VHWMR Vermont Hazardous Waste Management Regulations

VSI visual site inspection

VTARNG Vermont Army National Guard

VTDEC Vermont Department of Environmental Conservation

VTUL Vermont Underground Locators
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Executive Summary

The Army National Guard (ARNG) G9 is performing Preliminary Assessments (PAs) and Site 

Inspections (SIs) at per- and polyfluoroalkyl substances (PFAS)-impacted sites at ARNG facilities 

nationwide. The objective of the SI at each facility is to identify whether there has been a release 

to the environment from the Areas of Interest (AOIs) identified in the PA and determine the 

presence or absence of perfluorooctanoic acid (PFOA), perfluorooctanesulfonic acid (PFOS), and 

perfluorobutanesulfonic acid (PFBS) at or above screening levels (SLs). An SI was completed at 

Camp Ethan Allen Training Site (CEATS) in Jericho, Vermont. CEATS will be referred to as the 

“facility” throughout this document. 

CEATS occupies approximately 11,000 acres in eastern Chittenden County, Vermont, on the 

western side of the Green Mountains and is operated by the Vermont ARNG (VTARNG). The 

majority of the facility’s footprint is undeveloped and forested. Indoor facilities are located along 

the western portion of CEATS, including a few offices, barracks, and equipment maintenance 

buildings. The remaining portions of the facility are occupied by fields with trails, firing ranges, 

and other indoor and outdoor facilities. A network of trails and paved and unpaved roads is 

distributed throughout the facility. Additionally, CEATS hosts one of the premier cross-country ski 

and biathlon courses in North America. During the PA for PFAS, four potential PFAS release areas 

associated with the biathlon facility were identified: the Waxing Areas, Biathlon Course, Walker 

Building, and Snowmaking Pond (AECOM, 2019a). Remnants of ski wax potentially containing 

PFAS may have been released in these areas. The release areas were grouped into one Area of 

Interest (AOI), AOI 1, which was investigated during the SI. The SI field activities were conducted 

from 2 to 8 August 2019 and included the collection of soil, groundwater, surface water, and 

sediment samples.

To fulfill the project Data Quality Objectives set forth in the approved SI Quality Assurance Project 

Plan (QAPP) Addendum (AECOM, 2019b), samples were collected and analyzed for a subset of 

18 PFAS by liquid chromatography with tandem mass spectrometry (LC/MS/MS) compliant with 

Quality Systems Manual (QSM) 5.1 Table B-15. The 18 PFAS analyzed as part of the ARNG SI 

program are specified in Section 5.6 of this Report.

The Department of Defense (DoD) has adopted a policy to retain facilities in the Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA) process based on riskbased SLs for soil and groundwater, as described in a memorandum from the Office of the 

Secretary of Defense (OSD) dated 15 October 2019 (Assistant Secretary of Defense, 2019). The 

ARNG PFAS SIs follow this DoD policy and, should the maximum site concentration for sampled 

media exceed the SLs, the AOI will proceed to a Remedial Investigation (RI), the next phase 

under CERCLA. The SLs apply to three compounds, PFOA, PFOS, and PFBS, for both soil and 

groundwater, as presented in Table ES-1. All other results presented in this report are considered 

informational in nature and serve as an indication as to whether soil, groundwater, sediment, and 

surface water contain or do not contain the 18 PFAS analyzed within the boundaries of the facility. 

Sample chemical analytical concentrations were compared against the project SLs as described 

in Table ES-1. A summary of the results of the SI data relative to the SLs is as follows: 

• While detected concentrations indicate a release of PFAS materials, the detected 

concentrations of PFOA, PFOS, and PFBS in soil samples from AOI 1 were orders of 

magnitude below the SLs. 
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• PFOS was not detected in groundwater. PFOA and PFBS were detected in groundwater at 

AOI 1 at maximum concentrations of 10.9 nanograms per liter (ng/L) and 2.33 J1 ng/L, 

respectively, below the SLs of 40 ng/L and 40,000 ng/L, respectively.

Drinking water sources at the facility include a potable well (#40293, located south of the Walker 

Building) used to supply the biathlon facilities located within CEATS. As a state action in accordance 

with the Safe Drinking Water Act (SDWA), the Vermont ARNG (VTARNG) has sampled well #40293 

nine times between March 2017 and December 2020. The well #40293 sampling was completed 

separately from the SI described in this report. Since the initial sampling event, PFAS have 

consistently been detected in well #40293 above the Vermont Drinking Water Maximum 

Contaminant Level (MCL), with a maximum detection of PFOS at 40.8 ng/L in December 2020. The 

Vermont MCL is 20 nanograms per liter (ng/L) for PFOA, PFOS, perfluoroheptanoic acid (PFHpA), 

perfluorohexanesulfonic acid (PFHxS), and perfluorononanoic acid (PFNA), individually or 

combined ( Vermont Department of Environmental Conservation [VTDEC], 2020). Due to the 

detections of PFAS in well #40293 above the Vermont MCL, units are currently responsible for 

providing their own water when using the facility. 

Table ES-2 summarizes the SI results for soil and groundwater. Table ES-3 summarizes the 

rationale used to determine if an AOI should be considered for further investigation under CERCLA 

and undergo an RI. Based on the results of this SI, no further evaluation under CERCLA is 

warranted at this time. However, in light of the detections of PFAS in drinking water samples from 

well #40293 above the Vermont MCL of 20 ng/L, which were collected under a separate action in 

accordance with the SDWA, there is a potentially complete pathway to drinking water receptors, 

which include DoD and civilian users of the biathlon facility. Samples of soil and groundwater 

collected as part of the CERCLA SI show detections of PFOA, PFOS, and PFBS, but they were

detected at levels below the OSD SLs. Therefore, additional action will be taken under the SDWA.

Table ES-1 Screening Levels (Soil and Groundwater)

Analyte

Residential

(Soil)

(μg/kg)a

0-2 feet bgs

Industrial/ 

Commercial 

Composite Worker

(Soil)

(μg/kg)a

2-15 feet bgs

Tap Water

(Groundwater)

(ng/L)a

PFOA 130 1,600 40

PFOS 130 1,600 40

PFBS 130,000 1,600,000 40,000

Notes:

a.) Assistant Secretary of Defense, 2019. Risk Based Screening Levels Calculated for PFOS, PFOA, PFBS in 

Groundwater and Soil using United States Environmental Protection Agency’s (USEPA’s) Regional Screening 

Level Calculator. Hazard quotient (HQ) = 0.1. 15 October 2019.

1 Positive field sample results associated with percent recoveries less than the lower quality control limits are qualified “J.”
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Table ES-2 Summary of Site Inspection Findings

AOI Potential PFAS 

Release Area

Soil –

Source Area

Groundwater –

Source Area

Groundwater –

Facility Boundary

1

Walker Building NA

Waxing Sheds NA

Snowmaking Pond NA NA NA

Biathlon Course

Legend:

NA = not applicable

= detected; exceedance of SLs

 = detected; no exceedance of SLs

 = not detected

Table ES-3 Site Inspection Recommendations

AOI Description Rationale Future Action

1

Walker Building

Detections in soil and groundwater were 

below SLs. 

No further action under 

CERCLA

Waxing Sheds

Snowmaking Pond

Biathlon Course
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1. Introduction

1.1 Project Authorization

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

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

acid (PFOA) at Impacted Sites, ARNG Installations, 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 performed this SI at Camp Ethan 

Allen Training Site (CEATS) in Jericho, Vermont. CEATS will be referred to as the “facility” 

throughout this document.

The SI project elements were performed in compliance with Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA; US Environmental Protection Agency 

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

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

Department of the Army (DA) requirements and guidance for field investigations including specific 

requirements for sampling for PFOA, PFOS, and perfluorobutanesulfonic acid (PFBS), and the 

group of related compounds known in the industry as per- and polyfluoroalkyl substances (PFAS).

The term PFAS is used throughout this report to encompass all PFAS chemicals being evaluated, 

including PFOA, PFOS, and PFBS, which are the key components of the suspected releases 

being evaluated, and the other 15 related compounds listed in the task order.

1.2 SI Purpose

A PA was performed at CEATS (AECOM, 2019a) that identified four potential PFAS release areas,

which were grouped into one Areas of Interest (AOI). The objective of the SI is to identify whether 

there has been a release to the environment from the AOI and determine the presence or absence 

of PFOA, PFOS, and PFBS at or above screening levels (SLs). 

As stated in the Federal Facilities Remedial Site Inspection Summary Guide (USEPA, 2005), an 

SI has five goals: 

1. Develop information to potentially eliminate a release from further consideration because 

it is determined that it poses no significant threat to human health or the environment;

2. Determine the potential need for a removal action;

3. Collect or develop data to evaluate potential release;

4. Collect data to better characterize the release for more effective and rapid initiation of a 

Remedial Investigation (RI), if determined necessary; and

5. Collect data to determine whether the release is more than likely the result of activities 

associated with the Department of Defense (DoD).

In addition to the USEPA-identified goals of an SI, the ARNG SI also identifies whether there are 

potential off-facility PFAS sources. 
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2. Facility Background

2.1 Facility Location and Description

CEATS occupies approximately 11,000 acres in eastern Chittenden County, Vermont, on the 

western side of the Green Mountains. The town of Jericho, Vermont is approximately 1.5 miles to 

the northeast. The southern boundary of the facility runs adjacent to Mill Brook, a tributary of the 

Winooski River. The eastern boundary abuts drainage divide formed by the main ridgeline of the 

Green Mountains. Mt. Mansfield State Forest is located directly east of the facility, on the eastern 

side of the Green Mountains. Land to the north, south, and west of the facility consists of privatelyowned farmland, residences, and undeveloped forests (Figure 2-1).

The majority of the facility’s footprint is undeveloped and forested. Indoor facilities are located 

along the western portion of CEATS, by the main entrance. Approximately 600 acres of fields with 

trails, firing ranges, and other indoor and outdoor facilities occupy the central, south-central, and 

eastern portions of CEATS. A network of trails and paved and unpaved roads is distributed 

throughout CEATS. The current and former uses of CEATS (including separately operated 

portions within the facility boundary) are discussed below.

CEATS is operated by the Vermont ARNG (VTARNG) and hosts the Army Mountain Warfare 

School and Armory. There are several other entities that also use the facilities and ranges for 

training, including other VTARNG units, state and local police forces, and out of state units. The 

facility is sparsely populated; a few offices, barracks, and equipment maintenance buildings are 

primarily located along Ethan Allen Road, in the Lee River Valley. The barracks are occasionally 

used to house a few hundred individuals during training exercises throughout the year. Prior to 

the establishment of CEATS, the area was used for farming and pasture. 

In 1926, the War Department established CEATS as a small arms range, and the area has since 

been used for small arms, medium caliber, and large caliber training. Beginning in 1952, the 

General Dynamics Armament Systems, Inc. (formerly the Armament Systems Department of 

General Electric) began research, design, testing, and evaluation of munitions systems within 

CEATS, including the use of depleted uranium ammunition. Affected soils were subsequently 

removed and shipped off-site (Clark et al., 2005). The DA granted license to the state of Vermont 

for ARNG use beginning 17 December 1976. Since that time, several supplemental agreements 

have been issued to add additional acreage and extend the license until 16 December 2027. 

In addition, CEATS hosts one of the premier cross-country ski and biathlon courses in North 

America and features one of three internationally licensed biathlon courses in the US 

(GlobalSecurity.org, 2011). Vermont became the pinnacle of the US Military Biathlon Program in 

1972; the National Guard Bureau's first biathlon championships were held at CEATS in 1975. 

Since then, CEATS has been used for both military and civilian biathlon training and held national 

and international competitions. Civilian use includes the Ethan Allen Biathlon Club, Mansfield 

Nordic Club, and local high schools. The 5-kilometer Biathlon Course is operated year-round, and

during winter months, the course is supplemented with artificially made snow.

2.2 Facility Environmental Setting

CEATS is located in the Green Mountains of Vermont, within the New England Physiographic 

Province. Surface topography of the facility is rugged, hilly, and mountainous, with a maximum 

elevation of approximately 3,573 feet above mean sea level (amsl) and a minimum elevation of 

approximately 604 feet amsl. The easternmost edge of the property trends north-south along 

western side the main ridge of the Green Mountains. The westward-flowing Lee River originates 

near the eastern boundary, flows westward through the center of the facility, and exits at the 

western boundary. This main drainage and drainages to the north and south are fed by several 
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tributaries located within the facility boundary, some of which form small ponds at low-lying interior 

locations. The area surrounding the facility is rural and supports a variety of wildlife. The 

topography of CEATS is shown on Figure 2-2. The facility geology and groundwater features are 

presented on Figure 2-3, and surface water features are presented on Figure 2-4.

2.2.1 Geology

CEATS is on the western side of the Green Mountains, within a region generally characterized by 

north-south-trending hills, ranges, and intervening valley that are cut by east-west-trending 

drainages. The eastern boundary of the facility corresponds to the drainage divide formed by the 

linear, north-south-trending, main ridge of the Green Mountains.

CEATS is underlain by the western limb of the north-south-trending Green Mountain Anticlinorium, 

an antiformal duplex that is approximately 10 miles wide and consists of Ordovician, Cambrian, 

and Neoproterozoic rock units separated by depositional contacts and thrust faults. The area is 

underlain by lithologically diverse, predominantly metasedimentary rocks of the West Bridgewater 

Formation, Fairfield Pond Formation, Underhill Formation, Hazens Notch Formation, Fayston 

Formation, and Pinnacle Formation. These rocks include schist, phyllite, marble, amphibolite, 

gneiss, quartzite, and greenstone. Depositional contacts, bedding, and thrust faults generally dip 

to the west and strike to the south (Ratcliffe et al., 2011). The bedrock geology for the area is 

presented in Figure 2-3.

Surface materials at CEATS consist predominantly of glacial till mantling bedrock and reflect the 

topography of the underlying bedrock surface, bedrock, and pluvial deposits consisting of swamp, 

peat, and/or muck. Modern, unconsolidated fluvial and glacial outwash deposits are also present 

in areas adjacent to the Lee River in the western half of the facility (Stewart and MacClintock, 

1970).

Northwestern Vermont is an area of greater earthquake hazard potential relative to elsewhere in 

Vermont and the northeast US based on probabilistic seismic hazard analysis performed by the 

US Geological Survey (USGS). The probable intensity of ground shaking in northwestern Vermont 

is less than that in more recognized seismic hazard risk areas of the US; however, northwestern 

Vermont has the fifth highest probable intensity in the continental US. The earthquake shaking 

hazard in northwestern Vermont derives from its proximity to areas of significant seismic activity 

in the northern portion of New York State and the St. Lawrence River Valley in Canada (Lens et 

al., 2013).

The geological data collected as part of the SI is consistent with the regional geology of the 

surrounding area. Observations from shallow borings advanced across AOI 1 indicate that a thin 

layer of glacial till exists overlying weathered bedrock. The glacial till consisted of a heterogeneous 

sand, silt, and clay matrix with small, subangular gravel. The till thickness varied widely from a 

few feet thick to upwards of 20 feet depending on the location within the valley and presence of 

surficial bedrock.

2.2.2 Hydrogeology

As a result of glacial retreat, stratified drift sediments form a confined aquifer in places overlain 

by an unconfined aquifer that make up the stratified-drift aquifers in the Mill Brook and Lee River 

Valleys at the facility. The Pinnacle and Underhill Formations are the major bedrock formations at 

CEATS. These formations contain varied textural and compositional differences; the differences 

are enough to define mappable rock units shown on Figure 2-3 but are not great enough to create 

regional variations in groundwater flow in the bedrock aquifer. 

The overall direction of groundwater flow in the Lee River and Mill Brook Valleys is from east to 

west, while localized flow is from the valley walls to the Lee River or Mill Brook. The regional 

bedrock hydraulic conductivity at the facility is approximated to be 1 foot per day (foot/day) or 
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less. Groundwater flow velocity in the center of the Lee River Valley is estimated to be 0.7 to 2 

feet/day due to the steep gradient of the Valley and relatively coarse stratified drift. The Mill Brook 

Valley has a relatively shallow gradient and fine-grained streambed sediments resulting in an 

estimated velocity of 0.7 foot/day or less (Clark et al., 2005).

Static depth to groundwater in the bedrock aquifer is commonly 10 to 20 feet below ground surface 

(bgs). Depths to groundwater greater than 20 feet bgs usually occur at higher altitudes and ridges, 

whereas shallow groundwater is typically found in topographic low points or near surface water 

bodies. The water table generally follows the land surface. Streams in the center of valleys 

containing stratified-drift deposits typically drain the aquifer, whereas streams that cross from 

upland till into stratified-drift deposits generally lose water to the aquifer (Clark et al., 2005). Depth 

to groundwater in the upper till was observed to range from 5.33 to 14.32 feet bgs in August 2019 

during the SI field event, at temporary monitoring well locations where groundwater was 

encountered. It is suspected that the groundwater present in the till above bedrock is not a 

continuous aquifer.

The primary drinking water source for the facility has been the Champlain Water District system 

since 1999 (Clark et al., 2005). Prior to this period, CEATS was served by three onsite bedrock 

wells. Two bedrock wells, with depths to approximately 300 feet bgs, formerly supplied water to 

the training facilities, and a bedrock well, with a depth of 140 feet bgs, formerly provided water to 

the Cantonment. The Cantonment occasionally uses its well to fill portable drinking water supply 

tanks (Clark et al., 2005). Additional drinking water sources at the facility include a potable well 

(#40293, located south of the Walker Building) used to supply the biathlon facilities located within 

CEATS, with a depth of 225 feet bgs. Within the Walker Building, drinking water is treated using 

a clean water filtration, Point-of-Entry Treatment system manufactured by Kinetico Water 

Systems. However, due to detections of PFAS in well #40293 above the Vermont drinking water 

Maximum Contaminant Level (MCL), units are responsible for providing their own water when 

using the facility. The Vermont MCL is 20 nanograms per liter (ng/L) for PFOA, PFOS, 

perfluoroheptanoic acid (PFHpA), perfluorohexanesulfonic acid (PFHxS), and perfluorononanoic 

acid (PFNA), individually or combined (Vermont Department of Environmental Conservation 

[VTDEC], 202018). The drinking water sampling results for PFAS are discussed in Section 2.4 of 

this report.

In addition to potable well #40293, there are eight other wells at CEATS which supply potable 

water sources (Tetra Tech, 2017). These potable water sources are located within classroom and 

bathroom sinks located within training buildings used intermittently by various entities. The well 

locations are shown on Figure 2-3. General Dynamics Armament Systems, Inc. is still supplied 

by onsite water from a bedrock well. One of the firing ranges is also supplied by a bedrock well 

with a total depth of 226 feet bgs that is infrequently used. An artificial pond, used by CEATS to 

supply snowmaking machines, is fed by 2 wells: one deep well, drilled to a depth of 625 feet bgs, 

and one shallow well, approximately 4 feet bgs, that is fed by a spring. The West Bolton Public 

Water Source Protection area includes land areas within the facility boundaries; however, the 

water system is upgradient of CEATS watershed and not likely to be affected by activities within 

the facility boundary. 

An Environmental Data Resources, Inc. (EDR)TM Report for CEATS, which was included as an 

appendix to the PA Report, included a well search for a 1-mile radius surrounding the facility 

(AECOM, 2019a). Using additional online resources, such as state and local GIS databases, wells 

were researched to a 4-mile radius of the facility. Numerous domestic wells are located 

immediately outside of the northern, western, and southern boundaries of the facility. The 

identified wells are shown on Figure 2-3. Domestic wells are commonly drilled into bedrock in the 

communities surrounding CEATS. Median well depth is approximately 300 feet bgs; hydraulic 

properties and aquifer characteristics vary widely across relatively short distances (Clark et al., 

2005).
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 2-4

Based on the USEPA’s Unregulated Contaminant Monitoring Rule 3 (UCMR3) data, no PFAS 

were detected in a public water system above the USEPA Health Advisory (HA) level within 20 

miles of the facility (USEPA, 2017a). The USEPA HA is 70 ng/L for PFOS and PFOA, individually 

or combined (USEPA, 2016a; USEPA, 2016b). 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.

2.2.3 Hydrology

CEATS is located within three separate sub-watersheds. The majority of the facility lies within the 

Browns River Watershed, which runs through the center of the facility, from east to west, and 

encompasses approximately 6,548 acres of CEATS. The second largest drainage area, covering 

around 3,830 acres, is the Snipe Island Brook-Winooski River Watershed, which drains the 

southern area of the facility to Mill Brook. Lastly, approximately 840 acres of the far northeastern 

portion of the facility lies within Headwaters Browns River Watershed. Watersheds within the 

facility boundary lie within hilly, mountainous terrain and include drainage areas that are mostly 

forested and undeveloped. Watersheds, surface water features, and their associated drainages 

at CEATS are presented in Figure 2-4.

Numerous unnamed tributaries, natural and artificial ponds, springs, and wetlands are located 

within CEATS. These freshwater features predominantly drain into two major waterbodies: the 

Lee River, which subsequently discharges to the Browns River to the northwest, and Mill Brook, 

which drains to the Winooski River to the southwest. The drainage divide between the watersheds 

runs east-west across the southcentral half of the facility. Both systems drain into Lake Champlain, 

a large freshwater lake that forms the western border between New York and Vermont and 

comprises the main freshwater supply for adjacent regions.

The major hydrologic feature of CEATS is the Lee River, which runs through the central portion 

of the facility, flowing generally east to west. Several small, unnamed tributaries flow into the Lee 

River along its length. Data from 2003 showed that the average streamflow that year was 25.4 

cubic feet per second. A comparative analysis of the Lee River to other similar rivers in Vermont 

indicated that groundwater likely contributes largely to streamflow during periods of low rainfall. 

The watershed contains a large area of relatively permeable stratified-drift deposits that may act 

as a storage reservoir for groundwater (Clark et al., 2005).

The southern third of the facility is drained by several southward- and/or southwestward-flowing 

tributaries that feed into Mill Brook. Mill Brook runs along the southern boundary of the facility and 

flows westward towards its confluence with the Winooski River, approximately 4 miles west of 

CEATS.

At low-lying locations within the north-central, central, and south-central portions of CEATS, 

surface water flows into several freshwater surface ponds, forested/shrub wetlands, and 

emergent wetlands. In total, ponds cover approximately 60 acres, forested/shrub wetland cover 

approximately 330 acres, and emergent wetlands cover approximately 15 acres of CEATS (US 

Fish and Wildlife Service [USFWS], 2018).

2.2.4 Climate

CEATS is located in the western half of the Green Mountains physiographic region of Vermont. 

Local rainfall and temperature ranges in this region are strongly affected by factors such as slope, 

elevation, aspect, and urbanization, and they can vary considerably over short distances. 

Temperatures are moderated year-round by the proximity of Lake Champlain to the west. Cool 

breezes blow inland off the lake in the summer, and in the winter, the Lake acts as a heat reservoir 

that moderates local land temperature. Air temperature highs in July and lows in January average 
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 2-5

80 degrees Fahrenheit (°F) and 18°F, respectively (National Oceanic and Atmospheric 

Administration [NOAA], 2019). Rainfall data indicate that CEATS is located in an area that 

averages approximately 38 inches of precipitation per year. Precipitation is well distributed 

throughout the year but typically heavier in the summer than in the winter. Strong thunderstorms 

in the summer produce the heaviest local rainfall intensities (NOAA, 2019). Precipitation remains 

largely locked in snowpack during winter months prior to melt.

2.2.5 Current and Future Land Use

CEATS is used by the VTARNG for weapons-testing and training and is home to the Army 

Mountain Warfare School. There are several other entities that also use the facilities and ranges 

for training, including other VTARNG units, state and local police forces, and out of state units. 

The majority of the facility’s footprint is undeveloped and forested. The few offices, barracks, and 

equipment maintenance buildings are primarily located along Ethan Allen Road, in the Lee River 

Valley. The facility is sparsely populated; however, the barracks occasionally host a few hundred 

individuals during training exercises throughout the year. 

The facility is used for both military and civilian biathlon training and holds national and 

international competitions. Civilian use includes the Ethan Allen Biathlon Club, Mansfield Nordic 

Club, and local high schools. Biathlon training and competitions occur throughout the year; 

traditional snow skis are used for training and competitions during winter months, while roller skis 

are used during the warmer months of the year. During the visual site inspection (VSI), facility 

staff mentioned that people have used Snowmaking Pond for recreational swimming. 

Land to the north, south, and west of the facility is primarily rural, consisting of privately-owned 

farmland, residences, and undeveloped forests. The eastern border of the facility abuts the 

western slope of the Green Mountains and Mount Mansfield State Forest.

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

described above.

2.2.6 Sensitive Habitat and Threatened/ Endangered Species 

The majority of CEATS is forested and supports a variety of wildlife. Additionally, there are several 

small ponds and wetlands within the facility that provide habitat for aquatic species. Wildlife noted 

during the SI field event or reported by CEATS employees include black bear, bobcat, whitetail 

deer, wild turkey, otter, beaver, fisher, mink, squirrel, chipmunk, frogs, and numerous songbird 

and raptor species, including Osprey. 

The following species are listed as federally endangered, threatened, proposed, and/or candidate 

species in Chittenden County, Vermont (USFWS, 2019):

• Mammal: Northern Long-Eared bat, Myotis septentrionalis (threatened)

• Mammal: Indiana bat, Myotis sodalist (endangered)

2.3 History of PFAS Use

As described above, CEATS hosts a premier cross-country ski and biathlon course. High-grade 

commercial ski and snowboard waxes have been found to contain high concentrations of PFAS 

(Kotthoff et al., 2015). Surface water and snowmelt have been shown to have measurable PFAS 

impacts downgradient of ski areas (Kwok et. al., 2013). Remnants of ski wax potentially containing 

PFAS, left in and swept from the Wax Sheds and Walker Building by patrons of the biathlon facility, 

are a potential PFAS source at CEATS. Additionally, residual wax left on the snow surface along 

the 5-kilometer Biathlon Course is a potential source of PFAS. Interviewees noted that high grade 
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 2-6

waxes are almost exclusively used for competition, and that lower grade waxes (reportedly not 

PFAS-containing) are used the majority of the time at the facility. 

2.4 Other PFAS Investigations

As a state action in accordance with the Safe Drinking Water Act (SDWA), VTARNG began 

sampling drinking water at well #40293, located approximately 50 feet south of the Walker 

Building within the biathlon facilities at CEATS, in March 2017. The well is an open bedrock 

borehole with a total depth of 225 feet bgs, which has been cased from the ground surface to 20 

feet bgs. In addition to potable well #40293, the March 2017 sampling and analysis report included 

the eight other wells at CEATS which supply potable water (Tetra Tech, 2017). These potable 

water sources are classroom and bathroom sinks located within training buildings used 

intermittently by various entities. Table 2-1 summarizes the potable well locations sampled in the 

March 2017 and the detected compounds in groundwater. Well locations are shown on Figure 2-

3. 

Of the nine potable wells sampled in the March 2017 sampling event, PFAS were detected in six 

wells. Of those detections, the maximum detection was PFOA at 19.5 ng/L at well #40293 (Walker 

Building well). VTARNG has sampled well #40293 eight additional times between the initial 

sampling event in March 2017 and December 2020, with a maximum detection of PFOA at 40.8 

ng/L in December 2020. The well #40293 sampling is being completed separately from the SI 

described in this report. Table 2-2 summarizes the results for PFOA, PFOS, PFHpA, PFHxS, and 

PFNA, the five compounds applicable to the Vermont MCL, for each round of sampling. Since the 

initial sampling event, PFAS have consistently been detected in well #40293 above the Vermont 

MCL of 20 ng/L but below the USEPA HA of 70 ng/L (VTDEC, 2020; USEPA, 2016a; USEPA, 

2016b). Currently, units are responsible for providing their own water when using the biathlon 

facility. 
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 2-7

Table 2-1: PFAS Detections in Potable Wells at CEATS (March 2017)

Well 

Number Location PFOA PFOS PFHpA PFBA PFTeDA PFTrDA PFHxA PFPeA

40293 Walker Building 19.5 -- 12.2 -- -- -- -- --

40030 Range -- -- -- 1.4 J 0.645 J -- -- --

WAT21 Firing Point Classroom -- -- -- -- -- -- -- --

40163 Range -- -- -- -- 0.456 J -- -- --

WAT19 Range -- -- -- -- -- -- -- --

40167 Range Classroom 0.724 J -- -- -- -- 0.572 J --

40107 Range -- -- -- -- -- -- -- --

40081 Range 1.24 J -- -- 1.59 J -- -- 0.96 J 1.13 J

40054 Pump House #2 8.19 1.54 J -- -- -- -- -- --

Notes: 

1.) Detected concentrations are shown in ng/L.

J = estimated concentration 

ng/L = nanograms per liter

PFBA = perfluorobutyrate

PFHpA = perfluoroheptanoic acid

PFHxA = perfluorohexanoic acid

PFOA = perfluorooctanoic acid

PFOS = perfluorooctanesulfonic acid

PFPeA = perfluoropentanoic acid

PFTeDA = perfluorotetradecanoic acid

PFTrDA = perfluorotridecanoic acid

Table 2-2: Well #40293 (Walker Building Well) Sampling Results

Analyte

Result (ng/L)

March 2017August 2017November 2017February 2018July 2018September 2018January 2019May 2019December 2020

Perfluorooctanoic acid (PFOA) 19.5 29 31 34 30 32 31 24 40.8

Perfluorooctanesulfonic acid (PFOS) -- 1.48 J 0.721 J -- -- -- -- -- --

Perfluoroheptanoic acid (PFHpA) 12.2 19.5 18 21.5 19 17 22 15 26.6

Perfluorohexanesulfonic acid (PFHxS) -- -- -- -- -- -- -- -- --

Perfluorononanoic acid (PFNA) -- 1.96 J 1.93 J 1.76 J -- -- 2 -- 2.53

Total Vermont 5 PFAS1 32 52 52 57 49 49 55 39 70

Notes: 

1.) The Vermont MCL 20 ng/L for PFOA, PFOS, PFHpA, PFHxS, and PFNA, individually or combined (VTDEC, 2020)

-- = not detected

J = estimated concentration 

ng/L = nanograms per liter
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

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3. Summary of Areas of Interest 

Based on the PA findings, one AOI was identified at CEATS: AOI 1 Biathlon Facility, which includes 

the Walker Building, Waxing Sheds, Snowmaking Pond, and Biathlon Course (Figure 3-1). A 

summary of the AOI is presented below.

3.1 AOI 1 – Biathlon Course

AOI 1 includes four potential release areas associated with the Biathlon Course at CEATS: the 

Waxing Areas, Biathlon Course, Walker Building, and Snowmaking Pond. Remnants of ski wax 

potentially containing PFAS at the potential release areas are a potential PFAS source. 

3.1.1 Waxing Areas (Walker Building and Waxing Sheds)

As part of the biathlon facility, 20 Wax Sheds (two rows of ten [10] huts) used by biathletes during 

training and competitions for ski maintenance and ski waxing are located on the western side of 

the Walker Building, at geographic coordinates 44°28'3.07"N; 72°56'12.84"W. Each shed stands 

above grade, is approximately 15 feet long by 10 feet wide, and is constructed with a wooden 

(plywood) floor and work benches, an exhaust fan, and a window. Multiple entities use these 

facilities, inclusive of the National Guard (see Section 2.2.5).

During the VSI, hardened wax was observed on the floor and work benches of the sheds. 

Discarded wax shavings were also observed in plastic waste bins within the sheds. Interviewees 

were not sure where the bins were emptied but speculated they were likely emptied in facility 

trash bins for municipal waste disposal. An empty waste bin with wax remnants was observed 

during the VSI lying on its side in the strip of grass between the two rows of sheds. Interviewees 

also noted that wax shavings from the floors of the warming huts have typically been swept out 

of the sheds onto the grassy area, between the two rows of sheds. 

Additionally, inside the Walker Building are rooms for applying ski wax and a wax storage room. A 

French drain surrounds the Walker Building and is connected to the facility’s storm water drainage 

network. Wax may have been swept from inside the building and entered the drainage system.

Remnants of ski wax left in and swept from the Waxing Sheds and Walker Building by patrons of 

the biathlon facility are potential PFAS sources. 

3.1.2 Snowmaking Pond

Located approximately 130 feet to the west and upgradient of the Wax Sheds is an artificial pond 

used to supply snowmaking machines with water. The approximate geographic coordinates are 

44°28'1.80"N; 72°56'15.93"W. Historical aerials provided in the EDRTM report show that the pond 

was built between 1986 and 1999. Portions of the biathlon track are supplemented with artificial 

snow during the winter, as needed. The pond is fed by two wells: one deep well, drilled to a depth 

of 625 feet bgs, and one shallow well, approximately 4 feet bgs, that is spring-fed. Based on 

interviews with facility staff during the VSI, approximately 3.3 kilometers of the 5-kilometer track 

can be covered by the artificial snow. The Snowmaking Pond may be a secondary source of PFAS 

because the pond is fed by groundwater wells.

3.1.3 Biathlon Course

The Biathlon Course is a 5-kilometer asphalt-paved track averaging about 20 feet in width that starts 

at a newly constructed building located immediately to the south of the Walker Building. The course 

is situated to both the north/northwest and south of the Walker Building. Biathlon training and 
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competitions occur at the course throughout the year. Traditional snow skis are used for training and 

competitions during winter months, while roller skis are used during the warmer months of the year. 

At select locations along the course, snow is supplemented with water from the Snowmaking Pond (a 

potential secondary source of PFAS). Normal use of the Biathlon Course during winter months results 

in wax from skis, incidentally, transferring from the ski to snow. This residual wax left on the snow 

surface may be a potential source of PFAS in snowmelt along the 5-kilometer track.

Off-Site Snow for the Biathlon Course

During the 2017 ski course season, a combination of low snow and snowmaking machine failure 

required off-site snow to be transported to the facility for use at the Biathlon Course. Interviews 

with facility staff have indicated that about 120 to 160 tons of snow were trucked in from South 

Burlington Airport, down-gradient of CEATS, declination station, and Hyde Park (approximately 

30 to 40 tons from each location). The PFAS concentrations (if any) in the off-site snow are

unknown and may have contributed to the detected levels of PFAS in groundwater from infiltration 

due to snow melt.
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4. Project Data Quality Objectives

Project Data Quality Objectives (DQOs) are qualitative and quantitative statements that specify 

the quality of data and define the level of certainty required to support project decision-making

process. The specific DQOs established for this facility are described below. These DQOs were 

developed in accordance with the USEPA’s seven-step iterative process (USEPA, 2006).

4.1 Problem Statement

The following problem statement was developed during project planning:

The presence of PFAS, which may pose a risk to human health or the environment, in 

environmental media at the facility is currently unknown. PFAS are classified as emerging 

environmental contaminants that are garnering increasing regulatory interest due to their potential 

risks to human health and the environment. The regulatory framework for managing PFAS at both 

the federal and state level continues to evolve. 

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

SLs for soil and groundwater, as described in a memorandum from the Office of the Secretary of 

Defense (OSD) dated 15 October 2019 (Assistant Secretary of Defense, 2019). The ARNG 

program under which this SI was performed follows this DoD policy. Should the maximum site 

concentration for sampled media exceed the SLs established in the OSD memorandum, the AOI

will proceed to the next phase under CERCLA. The SLs established in the OSD memorandum 

apply to three compounds: PFOS, PFOA, and PFBS. The SLs are presented in Section 6.1 of 

this Report. 

The following quotes from the DA policy documents form the basis for this project (DA, 2016a; 

DA, 2018): 

• “The Army will research and identify locations where PFOS- and/or PFOA-containing 

products, such as aqueous film forming foam (AFFF), are known or suspected to have been 

used. Installations shall coordinate with installation/facility fire response or training offices to 

identify AFFF use or storage locations. The Army will consider fire training areas, AFFF 

storage locations, hangars/buildings with AFFF suppression systems, fire equipment 

maintenance areas, and areas where emergency response operations required AFFF use 

as possible source areas. In addition, metal plating operations, which used certain PFOScontaining mist suppressants, shall be considered possible source areas.” 

• “Based on a review of site records...determine whether a CERCLA PA is appropriate for 

identifying PFOS/PFOA release sites. If the PA determines a PFOS/PFOA release may 

have occurred, a CERCLA SI shall be conducted to determine presence/absence of 

contamination.” 

• “Identify sites where perfluorinated compounds are known or suspected to have been 

released, with the priority being those sites within 20 miles of the public systems that tested 

above USEPA HA levels” (USEPA, 2016a; USEPA, 2016b).

4.2 Goals of the Study

The following goals were established for this SI:

1. Determine the presence or absence of PFOA, PFOS, and PFBS at or above SLs.

2. Develop information to potentially eliminate a release from further consideration because 

it is determined that it poses no significant threat to human health or the environment.
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3. Determine the potential need for a removal action. 

4. Collect data to better characterize the release areas for more effective and rapid initiation 

of an RI.

5. Identify within 4 miles of the installation other potential PFAS sources (fire stations, major 

manufacturers, other DoD facilities) and receptors, including both groundwater and 

surface water receptors, to determine whether the ARNG is the likely source of PFAS, or 

whether there is an off-facility source of PFAS responsible for installation detections of 

PFAS (USEPA, 2005).

6. Determine whether a potentially complete pathway exists between the source and 

potential receptors and whether ARNG is the likely source of the contamination. 

4.3 Information Inputs:

Primary information inputs included:

• The PA for CEATS (AECOM, 2019a);

• Analytical data collected as part of VTARNG drinking water sampling efforts at the Site;

• Analytical data from groundwater, surface water, sediment, and soil samples collected as 

part of this SI in accordance with the site-specific Uniform Federal Policy (UFP)-Quality 

Assurance Project Plan (QAPP) Addendum (AECOM, 2019b); and

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

parameters measured at the time of sampling.

4.4 Study Boundaries

The scope of the SI was bounded by the property limits of the facility (Figure 2-2). Off-site sampling 

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

will be notified, and necessary rights of entry will be obtained by ARNG with property owner(s).

4.5 Analytical Approach

Samples were analyzed by Pace Analytical Gulf Coast, accredited under the DoD Environmental 

Laboratory Accreditation Program (DoD ELAP; Accreditation Number 74960) and the National 

Environmental Laboratory Accreditation Program (NELAP; Certificate Number 01955). Data were 

compared to applicable SLs and decision rules as defined in the SI QAPP Addendum (AECOM, 

2019b). These rules governed response actions based on the results of the SI sampling effort.

The decision rules described in the Worksheet #11 of the SI QAPP Addendum identify actions 

based on the following:

Groundwater:

• Is there a human receptor within 4 miles of the facility?

• What is the concentration of PFOA, PFOS, and PFBS at the potential release areas?

• What is the concentration of PFOA, PFOS, and PFBS at the facility boundary upgradient 

and downgradient of the potential release areas?

• What does the conceptual site model (CSM) suggest in terms of source, pathway and 

receptor? 
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Soil:

• What is the concentration of PFOA, PFOS, and PFBS in shallow surface soil (0 to 2 feet 

bgs)?

• What is the concentration of PFOA, PFOS, and PFBS in deep soil (i.e., capillary fringe)?

• What does the CSM suggest in terms of source, pathway, and receptor? 

Soil, groundwater, surface water, and sediment samples were collected from each of the potential 

PFAS release areas within AOI 1. Depth to groundwater in the upper till was observed to range 

from 5.33 to 14.32 feet bgs in August 2019.

4.6 Data Usability Assessment

The Data Usability Assessment (DUA) is an evaluation at the conclusion of data collection 

activities that uses the results of both data verification and validation in the context of the overall 

project decisions or objectives. Using both quantitative and qualitative methods, the assessment 

determines whether project execution and the resulting data have met installation-specific DQOs. 

Both sampling and analytical activities are considered to assess whether the collected data are 

of the right type, quality, and quantity to support the decision-making (DoD, 2018a; DoD, 2018b; 

USEPA, 2017b).

Data Quality Indicators (DQIs) (Precision, Accuracy, Representativeness, Comparability, 

Completeness and Sensitivity) are important components in assessing data usability. These DQIs 

were evaluated in the subsequent sections and demonstrate that the data presented in this SI 

report are of high quality. Although the SI data are considered reliable, some degree of uncertainty 

can be associated with the data collected. Specific factors that may contribute to the uncertainty 

of the data evaluation are described below. The Data Validation Report (DVR) (Appendix A) 

presents explanations for all qualified data in greater detail.

4.6.1 Precision

4.6.2 Precision

Precision is the degree of agreement among repeated measurements of the same characteristic 

on the same sample or on separate samples collected as close as possible in time and place. 

Field sampling precision is measured with the field duplicate relative percent differences (RPD); 

laboratory precision is measured with calibration verification, internal standard recoveries, 

laboratory control spike (LCS) and matrix spike (MS) duplicate RPD.

Extraction internal standards (EIS) were added by the laboratory during sample extraction to 

measure relative responses of target analytes and used to correct for bias associated with matrix 

interferences and sample preparation efficiencies, injection volume variances, mass spectrometry 

ionization efficiencies, and other associated preparation and analytical anomalies. Several field 

samples displayed EIS area counts less than the outside the quality control (QC) limits of 50-

150%. The field sample results associated with EIS area counts greater than the upper QC limit 

were non-detect and were qualified “UJ”. The qualified results should be considered usable as 

estimated values with a positive bias. The positive field sample results associated with EIS area 

counts less than the QC limit, but greater than 20 percent (%), were qualified “J+”, while nondetects were qualified “UJ”. The qualified results should be considered usable as estimated 

values with a positive bias. The field sample results associated with area counts less than 20% 

were qualified “X” for positive field sample results and “UX” for non-detect field sample results. 

The qualified field sample results associated with EIS area counts less than 20%, but greater than 

10%, are recommended for use as estimated values with a positive bias and are reported with 
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interpreted qualifiers of “J+” for the positive associated field sample results and “UJ” for the 

associated non-detect field sample results.

Calibration verifications were performed routinely to ensure that instrument responses for all 

calibrated analytes were within established QC criteria. All calibration verifications were within the 

project established precision limits presented in the QAPP Addendum (AECOM, 2019b).

LCS/LCS duplicate (LCSD) pairs were prepared by addition of known concentrations of each 

analyte in a matrix-free media known to be free of target analytes. LCS/LCSD pairs were analyzed 

for every analytical batch to demonstrate the ability of the laboratory to detect similar 

concentrations of a known quantity in matrix-free media. The LCS/LCSD samples were within the 

project established precision limits presented in the QAPP Addendum (AECOM, 2019b).

MS/MS duplicate (MSD) samples were prepared, analyzed, and reported for all preparation 

batches. MS/MSD samples demonstrated that the analytical system was in control for the matrix 

being tested. MS/MSD samples were submitted to the laboratory for analysis at a rate of 5%. The 

MS/MSD performed on parent sample AOI1-SW06 displayed a RPD greater than the upper QC 

limit of 30% for perfluorotridecanoic acid (PFTrDA). The parent sample result associated with this 

positive bias was non-detect; therefore, no data qualifying action was required.

Field duplicate samples were collected at a rate of 10% to assess the overall sampling and 

measurement precision for this sampling effort. The field duplicate samples were analyzed for 

PFAS and general chemistry parameters. The field duplicate samples were within the project 

established precision limits presented in the QAPP Addendum (AECOM, 2019b).

4.6.3 Accuracy

Accuracy is a measure of confidence in a measurement. The smaller the difference between the 

measurement of a parameter and its "true" or expected value, the more accurate the 

measurement. The more precise or reproducible the result, the more reliable or accurate the 

result. Accuracy is measured through percent recoveries in the LCS/LCSD, MS/MSD, and 

surrogates.

LCS/LCSD samples were prepared by addition of known concentrations of each analyte in a 

matrix free media known to be free of target analytes. LCS/LCSD samples were analyzed for 

every analytical batch and demonstrated that the analytical system was in control during sample 

preparation and analysis, with one exception. The LCS/LCSD pairs prepared in batch 665135 

displayed a percent recovery greater than the upper QC limit of 130% for PFTrDA. The associated 

field sample results were non-detect; therefore, no data qualifying action was required. 

MS/MSD samples were prepared, analyzed, and reported at a rate of 5%. MS/MSD samples 

demonstrated that the analytical system was in control for the matrix being tested, with a limited 

number of exceptions. Two MS/MSD pairs displayed percent recoveries outside the QC limits. 

The MS/MSD performed on parent sample AOI1-GW05 displayed a percent recovery less than 

the lower QC limit of 70% for perfluorobutyrate (PFBA). The parent sample result associated with 

this negative bias was positive and was qualified “J-”. The qualified result should be considered 

usable as an estimated value with a negative bias. The MS/MSD performed on re-extracted parent 

sample AOI1-SW06 displayed a percent recovery greater than the upper QC limit of 170% for 

PFTrDA. The parent sample result associated with this positive bias was non-detect; therefore, 

no data qualifying action was required.

4.6.4 Representativeness

Representativeness qualitatively expresses the degree to which data accurately reflect site 

conditions. Factors that affect the representativeness of analytical data include appropriate 

sample population definitions, proper sample collection and preservation techniques, analytical 
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holding times, use of standard analytical methods, and determination of matrix or analyte 

interferences. 

Relating to the use of standard analytical methods, the laboratory followed the method as 

established in PFAS by liquid chromatography tandem mass spectrometry (LC/MS/MS) 

compliant with Quality Systems Manual (QSM) 5.1 Table B-15, including the specific preparation 

requirements (i.e. ENVI-Carb or equivalent used), mass calibration, spectra, all the ion transitions 

identified in Table B-15 were monitored, standards that contained both branched and linear 

isomers when available were used, and isotopically labeled standards were used for quantitation.

Field QC samples were collected to assess the representativeness of the data collected. Field 

duplicates were collected at a rate of 10% for all field samples, while MS/MSD samples were 

collected at a rate of 5%. All preservation techniques were followed by the field staff, and all 

technical and analytical holding times were met by the laboratory. The laboratory used approved 

standard methods in accordance with the QAPP Addendum (AECOM, 2019b) for all analyses.

Instrument blanks and method blanks were prepared by the laboratory in each batch as a negative 

control. Several PFAS instrument blanks and method blanks displayed detections greater than 

the detection limit for multiple target analytes. In total, 277 field sample results for various analytes 

were qualified “U” during data validation due to associated detections in instrument and/or method 

blanks. The reported field sample result values were adjusted to be equal to the limit of detection 

(LOD); the LOD was elevated to the concentration of the blank detection in instances where the 

blank concentration was greater than the LOD. The results are usable as qualified but should be 

considered false positives and treated as non-detect.

One field reagent blank (FRB) was collected during the event. Equipment rinsate blanks (ERBs) 

were also collected for groundwater, soil, and sediment samples. The ERBs and the FRB were 

non-detect for target analytes.

A sample of the water used for decontamination of the drill rig was collected in advance of the 

field effort. The decontamination sample, CEATS-PW-01, displayed a detection for PFOS greater 

than the detection limit, at 4.06 ng/L. The positive associated field sample results were greater 

than five times the concentration found in the decontamination sample; therefore, no data 

qualifying action was required. Based on the sample results, the potable water source was 

deemed acceptable for use during the investigation for decontamination of drilling equipment and 

during well installation.

Overall, the data are usable for evaluating the presence or absence of PFAS at the facility. 

Sufficient usable data were obtained to meet the objectives of the SI.

4.6.5 Comparability

Comparability is the extent to which data from one study can be compared directly to either past

data from the current project or data from another study. Using standardized sampling and 

analytical methods, units of reporting, and site selection procedures help ensure comparability. 

Standard field sampling and typical laboratory protocols were used during the SI and are 

considered comparable to ongoing investigations.

4.6.6 Completeness

Completeness is a measure of the amount of valid data obtained from a measurement system 

compared to the amount of data expected under normal conditions. The laboratory provided data 

meeting system QC acceptance criteria for all samples tested. Project completeness was 

determined by evaluating the planned versus actual quantities of data. Percent completeness per 

parameter is as follows:
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• PFAS in groundwater by LC/MS/MS compliant with QSM 5.1 Table B-15 at 100%

• PFAS in soil by LC/MS/MS compliant with QSM 5.1 Table B-15 at 100%

• PFAS in surface water by LC/MS/MS compliant with QSM 5.1 Table B-15 at 100%

• PFAS in sediment by LC/MS/MS compliant with QSM 5.1 Table B-15 at 100%

• pH in soil by USEPA Method 9045D at 100%

• Total organic carbon (TOC) by USEPA Method 9060 at 100%

4.6.7 Sensitivity

Sensitivity is the capability of a test method or instrument to discriminate between measurement 

responses representing different levels (e.g., concentrations) of a variable of interest. Examples 

of QC measures for determining sensitivity include laboratory fortified blanks, a method detection 

limit (MDL) study, and calibration standards at the limit of quantitation (LOQ). In order to meet the 

needs of the data users, project data must meet the measurement performance criteria for 

sensitivity and project LOQs specified in the QAPP Addendum (AECOM, 2019b). The laboratory 

provided the requested MDL studies and provided applicable calibration standards at the LOQ. In 

order to achieve the DQOs for sensitivity outlined in the QAPP Addendum (AECOM, 2019b), the 

laboratory reported all field sample results at the lowest possible dilution. Additionally, any 

analytes detected below the LOQ and above the MDL were reported and qualified “J” as estimated 

values by the laboratory.
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5. Site Inspection Activities

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

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

in accordance with the following approved documents:

• Final Preliminary Assessment Report, Camp Ethan Allen Training Site, Jericho, Vermont

dated April 2019 (AECOM, 2019a);

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

dated March 2018 (AECOM, 2018a);

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

Camp Ethan Allen Training Site, Jericho, Vermont dated July 2019 (AECOM, 2019b);

• Final Programmatic Accident Prevention Plan dated July 2018 (AECOM, 2018b); and

• Final Site Safety and Health Plan, Camp Ethan Allen Training Site, Jericho, Vermont dated 

July 2019 (AECOM, 2019c).

The SI field activities were conducted from 2 to 8 August 2019 and consisted of direct push boring,

soil sample collection, temporary monitoring well installation, grab groundwater sample collection, 

and surface water and sediment sample collection. Field activities were conducted in accordance 

with the QAPP Addendum (AECOM, 2019b), except as noted in Section 5.7.

The following samples were collected during the SI and analyzed for a subset of 18 PFAS by 

LC/MS/MS compliant with QSM 5.1 Table B-15 to fulfill the project DQOs:

• 21 soil samples from 10 locations (soil borings or hand auger locations);

• Four grab groundwater samples from four of the five temporary well locations; 

• Six sediment samples; and

• Eight surface water samples, six of which were co-located with sediment samples, and two 

of which were located downgradient from soil borings where groundwater was unavailable

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

list of samples collected for each media. Field documentation is provided in Appendix B. A Log 

of Daily Notice of Field Activity was completed throughout the SI field activities, which is provided 

in Appendix B1. A Nonconformance and Corrective Action Report is provided in Appendix B2.

Additionally, a photographic log of field activities is provided in Appendix C. 

5.1 Pre-Investigation Activities

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

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

water. Details for each of these activities are presented below.

5.1.1 Technical Project Planning

The USACE TPP Process, Engineering Manual (EM) 200-1-2 (DA, 2016b) defines four phases to 

project planning: 1) defining the project phase; 2) determining data needs; 3) developing data 

collection strategies; and 4) finalizing the data collection plan. The process encourages 

stakeholder involvement in the SI, beginning with defining overall project objectives, including 
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quantitative and qualitative DQOs, and formulating a sampling approach to address the AOIs 

identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 25 June 2019, prior to SI field activities. Meeting 

minutes are provided in Appendix D. The combined TPP Meeting 1 and 2 was conducted in 

general accordance with EM 200-1-2.

The stakeholders for this SI include ARNG, VTARNG, USACE, and VTDEC representatives 

familiar with the facility, the regulations, and the community. Stakeholders were provided the 

opportunity to make comments on the technical sampling approach and methods at the combined 

TPP Meeting 1 and 2. The outcome of the combined TPP Meeting 1 and 2 was memorialized in 

the SI QAPP Addendum (AECOM, 2019b). Future TPP meetings will provide an opportunity to 

discuss the results and findings, and future actions, where warranted. 

5.1.2 Utility Clearance

AECOM contacted the “Dig Safe®” one-call utility clearance contractor to notify them of intrusive 

work at CEATS. However, because CEATS is a private facility, Dig Safe® contractors do not enter 

the facility. Therefore, AECOM contracted Vermont Underground Locators (VTUL), a private utility 

location service, to perform utility clearance. VTUL performed utility clearance of the proposed 

boring locations on 2 August 2019 with input from the AECOM field team and CEATS Biathlon 

Facility staff. General locating services and ground-penetrating radar (GPR) were used to 

complete the clearance. Additionally, the first 5 feet of each boring were pre-cleared using a hand 

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

encountered. 

5.1.3 Source Water and PFAS Sampling Equipment Acceptability

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

PFAS-free prior to the start of field activities. Because the potable water source at CEATS is 

known to contain PFAS, an offsite source of potable water was identified. A sample from a potable 

water source at the office of AECOM’s drilling subcontractor, Cascade Technical Services, LLC, 

was collected on 26 June 2019, prior to mobilization, and analyzed for PFAS by LC/MS/MS 

compliant with QSM 5.1 Table B-15. The results of the potable well sample are provided in 

Appendix F. A discussion of the results is presented in Section 4.6.4.

Materials that were used within the sampling zone were confirmed as acceptable for use in the 

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

environment was provided in the Standard Operating Procedures (SOPs) appendix to the SI 

QAPP Addendum (AECOM, 2019b). Prior to the start of field work each day, a PFAS Sampling 

Checklist was completed as an additional layer of control. The checklist served as a daily reminder 

to each field team member regarding the allowable materials within the sampling environment. 

5.2 Soil Borings and Soil Sampling

Soil samples were collected via direct push technology (DPT), in accordance with the SI QAPP 

Addendum (AECOM, 2019b). A GeoProbe® 7822DT dual-tube sampling system was used to 

collect continuous soil cores to the target depth. A hand auger was used to collect soil from the 

top five feet of the boring, in accordance with AECOM utility clearance procedures. 

Three discrete soil samples were collected for chemical analysis from each soil boring, with the 

exception of location AOI1-SB03, which had only two soil samples collected due to shallow 

refusal. Refer to Section 5.7 for additional details on deviations from the SI QAPP Addendum. At 

locations other than AOI1-SB03, one surface soil sample (0 to 1 feet bgs) and two subsurface soil 

samples (one approximately 1 foot above the groundwater table and one at the mid-point between 
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Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 5-3

the surface and the groundwater table) were collected from each boring. At AOI1-SB03, bedrock 

refusal was encountered at 5.8 feet bgs. Two offset locations (approximately 25 feet downgradient 

from original location) were attempted, but bedrock refusal was encountered at 3 feet bgs at both 

locations. Therefore, only two soil samples were collected from AOI1-SB03. 

Additionally, four surface soil locations (AOI1-SB07 through AOI1-SB10) were completed to 1 feet 

bgs using a hand auger. AOI1-SB10 was added during the field effort to replace the third sample 

from AOI1-SB03 via the Nonconformance and Corrective Action Report process (Section 5.7). 

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

Table 5-1. The soil boring locations were selected based on the available information for the AOI 

and were agreed upon through the TPP process and SI QAPP Addendum review. 

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

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

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

and measurements were recorded on sampling forms (Appendix B3) and in a non-treated field 

logbook (i.e., composition notebook). Depth interval, recovery thickness, PID concentrations, 

moisture, relative density, color (using a Munsell soil color chart), and texture (using the USCS) 

were recorded. The boring logs are provided in Appendix E.

Each sample was collected into laboratory-supplied PFAS-free high-density polyethylene (HDPE) 

bottles and labeled using a PFAS-free marker or pen. Samples were packaged on ice and 

transported via Federal Express (FedEx) under standard chain of custody (CoC) procedures to 

the laboratory and analyzed for PFAS by LC/MS/MS compliant with QSM 5.1 Table B-15, TOC 

(USEPA Method 9060A), and pH (USEPA Method 9045D) in accordance with the SI QAPP 

Addendum (AECOM, 2019b). 

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

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

same parameters as the accompanying samples. In instances when non-dedicated sampling 

equipment was used, such as a hand auger for the 0 to 1 feet bgs soil samples, ERBs were 

collected at a rate of 5% and analyzed for the same parameters as the soil samples. A temperature 

blank was placed in each cooler to ensure that samples were preserved at or below 6 degrees 

Celsius (°C) during shipment.

DPT borings were converted to temporary wells, which were subsequently abandoned in 

accordance with the SI QAPP Addendum (AECOM, 2019b) using bentonite chips at completion 

of sampling activities. Borings were installed in grass areas to avoid disturbing concrete or asphalt 

surfaces.

5.3 Temporary Well Installation and Groundwater Grab Sampling

Temporary wells were installed using a GeoProbe® 7822DT dual-tube sampling system. 

Temporary wells were installed at five of the six boring locations (AOI1-SB01, AOI1-SB02, AOI1-

SB04, AOI1-SB05, and AOI1-SB06). A temporary well was not installed at location AOI1-SB03 

due to shallow refusal at 5.8 feet bgs before groundwater was encountered in the boring (refer to 

Section 5.7 for additional details on deviations from the QAPP Addendum). Once the borehole 

was advanced to the desired depth, a temporary well was constructed of a 10-foot section of 1-

inch Schedule 40 poly-vinyl chloride (PVC) screen with sufficient casing to reach ground surface. 

The screen intervals for the temporary wells are provided on Table 5-2. New PVC pipe and screen 

were used at each location to avoid cross contamination between locations. 

The temporary wells were allowed to recharge for a minimum of 24 hours after installation before 

collection of groundwater samples. After the recharge period, one of the five temporary wells 

(location AOI1-SB02) was dry; therefore, a groundwater sample could not be collected at this 

location. Surface water samples were collected downgradient of locations AOI1-SB02 and AOI1-
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Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 5-4

SB03 since groundwater could not be obtained at these locations. Refer to Section 5.4 for 

additional details on surface water sampling. 

Groundwater samples were collected using a peristaltic pump with PFAS-free HDPE tubing. The 

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

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

dissolved oxygen [DO], oxidation-reduction potential [ORP], and turbidity) were measured using 

a water quality meter and recorded on the field sampling form (Appendix B3) after each grab 

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

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

foaming was noted in any of the groundwater samples. 

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

a PFAS-free marker or pen. Samples were packaged on ice and transported via FedEx under 

standard CoC procedures to the laboratory and analyzed for PFAS by LC/MS/MS compliant with 

QSM 5.1 Table B-15 in accordance with the QAPP Addendum (AECOM, 2019b).

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

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

same parameters as the accompanying samples. One FRB was collected, in accordance with the 

PQAPP (AECOM, 2018a). A temperature blank was placed in each cooler to ensure that samples 

were preserved at or below 6°C during shipment.

Temporary wells were abandoned in accordance with the QAPP Addendum (AECOM, 2019b) by 

removing the PVC and backfilling the hole with bentonite chips. Temporary wells were installed in 

grass areas to avoid disturbing concrete or asphalt. 

5.4 Surface Water and Sediment Sampling

Co-located surface water and sediment samples were collected from tributaries flowing to Mill 

Brook and Lee River, downgradient of AOI1. Additionally, two stand-alone surface water samples 

(AOI1-SW07 and AOI1-SW08) were collected as replacement samples downgradient of soil 

boring locations where groundwater could not be obtained. AOI1-SW07 was collected from a 

natural spring emergence point as replacement sample for groundwater at AOI1-SB02. AOI1-

SW08 was collected from a pond as a replacement sample for groundwater at AOI1-SB03. 

Sediment samples were co-located with surface water samples and were collected in accordance 

with the SI QAPP Addendum (AECOM, 2019b). Surface water samples were collected from a 

single point in the waterbody by dipping the laboratory-supplied bottle into the water, 

approximately two-thirds up from the bottom of the water body. For the co-located surface water 

and sediment samples, the surface water sample was collected before the co-located sediment 

sample. Sampling was performed in a manner to minimize disturbance of bottom sediments and 

as quickly as possible to ensure a representative sample was collected. Additionally, a subsample 

of each surface water sample was collected in a separate container, and a shaker test was 

completed to identify if there were any foaming. No foaming was noted in any of the surface water 

samples.

After collection of the surface water sample, a sediment coring device (hand auger) was used to 

collect the sediment sample from the first 1 foot of sediment. The sediment was transferred to a 

Ziploc bag, where the sample was homogenized, and stones in excess of 1 centimeter were 

removed. After collection of the surface water and sediment samples from each location, general 

water quality parameters (i.e., temperature, pH, conductivity, DO, ORP, and turbidity) were 

collected with a water quality meter and recorded on the field sampling form (Appendix B3). The 

surface water and sediment sample locations are shown on Figure 5-1, and sample depths are 

provided Table 5-1. 
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AECOM 5-5

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

a PFAS-free marker or pen. Samples were packaged on ice and transported via FedEx under 

standard CoC procedures to the laboratory for analysis of PFAS by LC/MS/MS compliant with 

QSM 5.1 Table B-15. Sediment samples were also analyzed for TOC (USEPA Method 9060A) 

and pH (USEPA Method 9045D), in accordance with the SI QAPP Addendum (AECOM, 2019b). 

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

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

same parameters as the accompanying samples. In instances when non-dedicated sampling 

equipment was used, ERB samples were collected at a rate of 5% and analyzed for the same 

parameters as the soil samples. A temperature blank was placed in each cooler to ensure that 

samples were preserved at or below 6°C during shipment. 

5.5 Investigation-Derived Waste

As of the date of this report, the disposal of PFAS investigation-derived waste (IDW) is not 

regulated federally. PFAS IDW generated during the SI is considered non-hazardous waste and 

was managed in accordance with the SI QAPP Addendum (AECOM, 2019b) and with the DA 

Guidance for Addressing Releases of PFAS, Q18 (DA, 2018).

Soil IDW (i.e., soil cuttings) generated during the SI activities were left in place at the point of the 

source. The soil cuttings were distributed on the ground surface on the downgradient side of the 

boring. The soil IDW was not sampled and assumed the PFAS characteristics of the associated 

soil samples collected from that source location. Geographic coordinates were collected using a 

Global positioning system (GPS) around each location where IDW was placed (i.e., an IDW 

polygon). The IDW polygons are displayed on the figure in Appendix F.

Liquid IDW generated during the SI activities (i.e., purge water and decontamination fluids) were 

containerized in one properly-labeled 55-gallon drum. Approximately 10 gallons of liquid IDW 

were generated over the course of the event. One sample of the liquid IDW was collected and 

submitted to the laboratory for analysis of PFAS by LC/MS/MS compliant with QSM 5.1 Table B15. While pending analytical results, the drum was staged on the North side of the Snowmaking 

Building, at approximate geographic coordinates 44°28'06.9"N, 72°56'15.0"W, as designated by 

the VTARNG.

Analytical results for the IDW sample indicated that PFOS was not detected and PFOA was 

detected at 2.46 J. The laboratory report for the IDW sample is included in Appendix G. In 

accordance with the QAPP Addendum (AECOM, 2019b), because the combined PFOA+PFOA 

concentration was less than the 20 ng/L combined value established in the Vermont Hazardous 

Waste Management Regulations (VHWMR), the liquid IDW was discharged the ground surface 

downgradient of one of the investigation borings, in accordance with the SI QAPP Addendum 

(AECOM, 2019b). Discharge of the liquid IDW was completed by Cascade Technical Services on 

18 October 2019. 

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

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

activities were disposed of at a licensed solid waste landfill

5.6 Laboratory Analytical Methods

Samples were analyzed for a subset of 18 PFAS by LC/MS/MS compliant with QSM 5.1 Table B15 at Pace Analytical Gulf Coast in Baton Rouge, Louisiana, a DoD-ELAP and NELAP certified 

laboratory. The 18 PFAS analyzed as part of the ARNG SI program include the following: 

• 6:2 fluorotelomer sulfonate (6:2 FTS) • Perfluorohexanoic acid (PFHxA)
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Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 5-6

• 8:2 fluorotelomer sulfonate (8:2 FTS)

• N-ethyl 

perfluorooctanesulfonamidoacetic acid 

(NEtFOSAA)

• N-methyl 

perfluorooctanesulfonamidoacetic acid 

(NMeFOSAA)

• Perfluorobutyrate (PFBA)

• Perfluorobutanesulfonic acid (PFBS)

• Perfluorodecanoic acid (PFDA)

• Perfluorododecanoic acid (PFDoA)

• Perfluoroheptanoic acid (PFHpA)

• Perfluorohexanesulfonic acid (PFHxS)

• Perfluorononanoic acid (PFNA)

• Perfluorooctanoic acid (PFOA)

• Perfluorooctanesulfonic acid (PFOS)

• Perfluoropentanoic acid (PFPeA)

• Perfluorotetradecanoic acid (PFTeDA)

• Perfluorotridecanoic acid (PFTrDA)

• Perfluoroundecanoic acid (PFUdA)

Soil and sediment samples were also analyzed for TOC using USEPA Method 9060A and pH by 

USEPA Method 9045D.

5.7 Deviations from SI QAPP Addendum

Derivations from the SI QAPP Addendum occurred due to field conditions and discussion between 

AECOM, ARNG, and USACE. Deviations from the SI QAPP Addendum are noted below and are 

documented in the Nonconformance and Corrective Action Report (Appendix B2):

• A soil boring adjacent to the Walker Building at CEATS (AOI1-SB03) was proposed in the 

SI QAPP Addendum, with collection of three samples in the boring. However, refusal was 

encountered at 5.8 feet bgs. Two offset locations (approximately 25 feet downgradient 

from original location) were attempted, but bedrock refusal was encountered at 3 feet bgs 

at both locations. Therefore, only two soil samples were collected from the original location 

due to the shallow depth of refusal. To replace the third sample from AOI1-SB03, an 

additional surface soil sample (AOI1-SB10) was collected via hand auger in the vicinity of 

the Walker Building. The location was placed in a low-lying spot alongside one of the main 

thoroughfares of the course, between the Walker Building and firing range.

• Additionally, the following field decisions were made in accordance with the procedures 

established in the SI QAPP Addendum (AECOM, 2019b):

o A temporary well was not installed at location AOI1-SB03 due to shallow refusal at 

5.8 feet bgs; therefore, a groundwater sample could not be collected at this 

location. Surface water sample AOI1-SW08 was collected from a downgradient 

pond as a replacement sample.

o A temporary well was installed at location AOI-SB02. The temporary well was 

allowed to recharge for 24 hours after installation but was dry after the recharge 

period; therefore, a groundwater sample could not be collected. Surface water 

sample AOI1-SW07 was collected from a nearby natural spring emergence point 

as replacement sample. 
Table 5-1

Samples by Medium

Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont

Sample Identification

Sample

Collection 

Date/Time

Sample Depth 

(ft bgs) 1

PFAS by LC/MS/MS compliant with QSM 5.1 Table B-15TOC(USEPA Method 9060A)pH (USEPA Method 9045D)

Comments

AOI1-SB01-00-01 8/6/2019 8:45 0 - 1 x x x

AOI1-SB01-05-06 8/6/2019 10:30 5 - 6 x x x

AOI1-SB01-14-15 8/6/2019 10:40 14 - 15 x x x

AOI1-SB02-00-01 8/5/2019 15:30 0 - 1 x x x

AOI1-SB02-04-05 8/5/2019 15:45 4 - 5 x x x

AOI1-SB02-13-14 8/5/2019 15:55 13 - 14 x x x

AOI1-SB03-00-01 8/5/2019 11:20 0 - 1 x x x

AOI1-SB03-00-01-D 8/5/2019 11:20 0 - 1 x x x FD

AOI1-SB03-05-06 8/5/2019 11:55 5 - 6 x x x

AOI1-SB04-00-01 8/5/2019 9:40 0 - 1 x x x

AOI1-SB04-00-01-MS 8/5/2019 9:40 0 - 1 x x x MS

AOI1-SB04-00-01-MSD 8/5/2019 9:40 0 - 1 x x x MSD

AOI1-SB04-03-04 8/5/2019 10:20 3 - 4 x x x

AOI1-SB04-07-08 8/5/2019 10:30 7 - 8 x x x

AOI1-SB04-07-08-D 8/5/2019 10:30 7 - 8 x x x FD

AOI1-SB05-00-01 8/6/2019 14:15 0 - 1 x x x

AOI1-SB05-04-05 8/6/2019 14:55 4 - 5 x x x

AOI1-SB05-08-09 8/6/2019 15:05 8 - 9 x x x

AOI1-SB06-00-01 8/6/2019 13:05 0 - 1 x x x

AOI1-SB06-08-09 8/6/2019 13:10 8 - 9 x x x

AOI1-SB06-13-14 8/6/2019 13:20 13 - 14 x x x

AOI1-SB07-00-01 8/5/2019 17:05 0 - 1 x x x

AOI1-SB08-00-01 8/8/2019 8:50 0 - 1 x x x

AOI1-SB09-00-01 8/8/2019 9:05 0 - 1 x x x

AOI1-SB10-00-01 8/7/2019 16:00 0 - 1 x x x

AOI1-GW01 8/7/2019 14:15 5 - 15 x

AOI1-GW04 8/7/2019 10:00 6 - 11 x

AOI1-GW04-D 8/7/2019 10:00 6 - 11 x FD

AOI1-GW05 8/7/2019 15:20 4 - 9 x

AOI1-GW05-MS 8/7/2019 15:20 4 - 9 x MS

AOI1-GW05-MSD 8/7/2019 15:20 4 - 9 x MSD

AOI1-GW06 8/7/2019 14:55 4 - 14 x

AOI1-SW01 8/7/2019 13:40 2 in x

AOI1-SW02 8/2/2019 15:15 4 in x

AOI1-SW02-D 8/2/2019 15:15 4 in x FD

AOI1-SW03 8/2/2019 16:30 4 in x

AOI1-SW04 8/7/2019 11:30 5 in x

AOI1-SW05 8/7/2019 10:40 4.5 in x

AOI1-SW06 8/2/2019 17:10 2.5 in x

AOI1-SW06-MS 8/2/2019 17:10 2.5 in x MS

AOI1-SW06-MSD 8/2/2019 17:10 2.5 in x MSD

AOI1-SW07 8/7/2019 9:25 1.5 in x

AOI1-SW08 8/7/2019 15:45 5 in x

AOI1-SD01-00-01 8/7/2019 13:50 0 - 1 x

AOI1-SD02-00-01 8/2/2019 15:20 0 - 1 x

Soil Samples

Sediment Samples

Groundwater Samples

Surface Water Samples

AECOM 5-7
Table 5-1

Samples by Medium

Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont

Sample Identification

Sample

Collection 

Date/Time

Sample Depth 

(ft bgs) 1

PFAS by LC/MS/MS compliant with QSM 5.1 Table B-15TOC(USEPA Method 9060A)pH (USEPA Method 9045D)

Comments

AOI1-SD02-00-01-D 8/2/2019 15:20 0 - 1 x FD

AOI1-SD03-00-01 8/2/2019 16:40 0 - 1 x

AOI1-SD04-00-01 8/7/2019 11:40 0 - 1 x

AOI1-SD05-00-01 8/7/2019 10:50 0 - 1 x

AOI1-SD06-00-01 8/2/2019 17:20 0 - 1 x

AOI1-SD06-00-01-MS 8/2/2019 17:20 0 - 1 x MS

AOI1-SD06-00-01-MSD 8/2/2019 17:20 0 - 1 x MSD

CEATS-EB01 8/2/2019 15:45 NA x EB on ziploc bag

CEATS-EB02 8/2/2019 15:55 NA x EB on hand auger

CEATS-EB03 8/6/2019 10:20 NA x EB on shoe of drill rig

CEATS-FRB01 8/2/2019 15:50 NA x FRB

CEATS-IDW01 8/8/2019 12:20 NA x

Notes:

1

 Sample depths for surface water samples are inches (in) below water surface

Acronyms and Abbreviations:

bgs = below ground surface

EB = equipment blank

FD = field duplicate

FRB = field reagent blank

ft = feet

IDW = invetigation-derived waste

in = inches

LCMSMS = Liquid Chromatography Mass Spectrometry

MS/MSD = matrix spike/ matrix spike duplicate

PFAS = per- and polyfluoroalkyl substances

QSM = Quality Systems Manual

TOC = total organic carbon

USEPA = United States Environmental Protection Agency

Quality Control Samples

IDW Sample

Sediment Samples (continued)

AECOM 5-8
Table 5-2

Soil Boring Depths and Temporary Well Screen Intervals

Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont

Area of 

Interest

Boring 

Location

Soil Boring Depth 

(ft bgs)

Temporary Well 

Screen Interval 

(ft bgs)

AOI1-SB01 19 5 - 15 1

AOI1-SB02 14 1 - 11 1,2

AOI1-SB03 5.8 NA

AOI1-SB04 11 6 - 11 

AOI1-SB05 10 4 - 9

AOI1-SB06 14.5 4 - 14 1

AOI1-SB07 1 NA

AOI1-SB08 1 NA

AOI1-SB09 1 NA

AOI1-SB10 1 NA

Notes:

1

 Temporary well screens set above total depth to capture intervals of highest moisture content

2

 Temporary well was dry after a minimum of 24 hours allotted for recharge

Acronyms and Abbreviations:

bgs = below ground surface

ft = feet

NA = not applicable

1

AECOM 5-9
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 5-10

THIS PAGE INTENTIONALLY BLANK
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!?

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!?

!?

!?

!?

!?

!?

!?

"J

"J

"J

"J

"J

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!?

Walker Building

Snowmaking Pond

Waxing Sheds

Biathlon Course

AOI1-SD06/SW06

AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB03/GW03

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

AOI1-SB07

AOI1-SB08

AOI1-SB09

AOI1-SD01/SW01

AOI1-SD02/SW02

AOI1-SD03/SW03

AOI1-SD04/SW04

AOI1-SD05/SW05

AOI1-SW07

AOI1-SW08

AOI1-SB10

Mill Broo

M

k

ill Brook

Mill Bro ok

AOI 1

Legend

!? Soil Boring/Ground Water

Location

!? Soil Hand Auger

"J Surface Water/Sediment

Location

Area of Interest

Potential PFAS Release

Facility Boundary

Water Body

Wetland

River/Stream

0 500 1,000 2,000

Feet

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AM

12/17/2019

12/17/2019

NOTES Site Inspection UFP-QAPP at Ethan Allen Training Site, VT

12/17/2019

1:12,000 ­ Figure 5-1 PM RG 12/17/2019

12420 Milestone Center Drive

Germantown, MD 20876

Site Inspection Sample Locations

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\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_5-1_TS-Ethan_Allen_SI.mxd

Note: Hand auger soil samples were 

collected along the most frequently-used

trails on the biathlon course.

5-11
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AECOM 5-12

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Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 6-1

6. Site Inspection Results 

This section presents the analytical results of the SI. The SLs used in this evaluation are 

presented in Section 6.1. A discussion of the results for AOI 1 is provided in Section 6.3. Table 

6-2 through Table 6-6 present PFAS results for samples with detections in soil, groundwater, 

surface water, and sediment; only constituents detected in one or more samples are included. 

Tables that contain all results are provided in Appendix F, and the laboratory reports are provided 

in Appendix G.

6.1 Screening Levels

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

SLs for soil and groundwater, as described in a memorandum from the OSD dated 15 October 

2019 (Assistant Secretary of Defense, 2019). The ARNG program under which this SI was 

performed follows this DoD policy. Should the maximum concentration for sampled media exceed 

the SLs established in the OSD memorandum, the AOI will proceed to an RI, the next phase under 

CERCLA. The SLs apply to three compounds, PFOA, PFOS, and PFBS, for both soil and 

groundwater, as presented in Table 6-1. 

All other results presented in this report are considered informational in nature and serve as an 

indication as to whether soil, groundwater, sediment, and surface water contain or do not contain 

PFAS within the boundaries of the facility.

Table 6-1: Screening Levels (Soil and Groundwater)

Analyte

Residential

(Soil)

(μg/kg)a

0-2 feet bgs

Industrial/ 

Commercial 

Composite Worker

(Soil)

(μg/kg)a

2-15 feet bgs

Tap Water

(Groundwater)

(ng/L)a

PFOA 130 1,600 40

PFOS 130 1,600 40

PFBS 130,000 1,600,000 40,000

Notes:

a.) Assistant Secretary of Defense, 2019. Risk Based Screening Levels Calculated for PFOS, PFOA, PFBS in 

Groundwater and Soil using United States Environmental Protection Agency’s (USEPA’s) Regional Screening 

Level Calculator. Hazard quotient (HQ) = 0.1. 15 October 2019.

6.2 Soil Physicochemical Analyses

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

are important for evaluating transport through the soil medium. Appendix F contains the results 

of the TOC and pH sampling. 

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

appropriate, to assess fate and transport of PFAS contaminants. According to the Interstate 

Technology Regulatory Council (ITRC), several important PFAS partitioning mechanisms include 

hydrophobic and lipophobic effects, electrostatic interactions, and interfacial behaviors. At 

relevant environmental pH values, certain PFAS are present as organic anions and are therefore 

relatively mobile in groundwater (Xiao et al., 2015), but tend to associate with the organic carbon 

fraction that may be present in soil or sediment (Higgins and Luthy 2006; Guelfo and Higgins, 
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AECOM 6-2

2013). When sufficient organic carbon is present, organic carbon normalized distribution 

coefficients (Koc values) can help in evaluating transport potential, though other geochemical 

factors (for example, pH and presence of polyvalent cations) may also affect PFAS sorption to 

solid phases (ITRC, 2018).

6.3 AOI 1

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

1, which includes four potential PFAS release areas: the Waxing Areas, Biathlon Course, Walker 

Building, and Snowmaking Pond. The detected compounds in soil, groundwater, surface water, 

and sediment are summarized on Table 6-2 through Table 6-6. The detections of PFOS and 

PFOA in soil, groundwater, surface water, and sediment are presented on Figure 6-1 through 

Figure 6-5.

6.3.1 AOI 1 Soil Analytical Results

PFOA, PFOS, and PFBS did not exceed the SLs in soil at the four potential PFAS release areas: 

the Waxing Areas, Biathlon Course, Walker Building, and Snowmaking Pond. Figure 6-1 and

Figure 6-2 present detections in soil for PFOS and PFOA, respectively. The detected compounds

in surface soil and shallow subsurface soil are summarized on Table 6-2 and Table 6-3, 

respectively.

Soil was sampled from surface soil (0 to 1 feet bgs) and shallow subsurface soil (3 to 15 feet bgs)

from boring locations AOI1-SB01 through AOI01-SB09. Up to three soil samples were collected 

from each boring: one surface soil sample and two subsurface soil samples (one approximately 

1 foot above the groundwater table and one at the mid-point between the surface and the 

groundwater table). PFOA, PFOS, and PFBS were detected in soil at concentrations several 

orders of magnitude lower than the SLs. In surface soil, PFOA was detected at five locations, with 

concentrations ranging from 0.012 J micrograms per kilogram (μg/kg) to 0.193 J μg/kg. PFOS 

was detected at seven locations, with concentrations ranging from 0.026 J μg/kg to 0.123 J μg/kg. 

PFBS was detected at seven locations, with concentrations ranging from 0.00168 J μg/kg to 0.019

J μg/kg.

In shallow subsurface soil, PFOA, PFOS, and PFBS were also detected in soil at concentrations 

several orders of magnitude lower than the SLs. PFOA was detected at three locations, with 

concentrations ranging from 0.012 J μg/kg to 0.018 J μg/kg. PFOS was detected at two locations,

with concentrations ranging from 0.048 J μg/kg to 0.279 J μg/kg. PFBS was detected at two 

locations, with concentrations ranging from 0.00237 J μg/kg to 0.00277 J μg/kg.

6.3.2 AOI 1 Groundwater Analytical Results

PFOA and PFBS were detected in groundwater at AOI 1 at concentrations below SLs. PFOS was 

not detected in groundwater at AOI 1. Figure 6-3 present the ranges of detections for PFOA and 

PFOS in groundwater. The detected compounds in groundwater are summarized on Table 6-4. 

Groundwater samples were collected from temporary monitoring well locations AOI1-GW01, 

AOI1-GW04, AOI1-GW05, and AOI1-GW06. PFOS was not detected in any of the four locations 

sampled. PFOA and PFBS were detected but were below the SLs of 40 ng/L and 40,000 ng/L, 

respectively. PFOA was detected in all four temporary monitoring wells samples, with 

concentrations ranging from 3.03 J ng/L to 10.9 ng/L. PFBS was detected in two temporary 

monitoring wells, with concentrations ranging from 1.77 J ng/L to 2.33 J ng/L.
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 6-3

6.3.3 AOI 1 Surface Water Analytical Results

Surface water samples were collected from tributaries flowing to Lee River to the north and Mill 

Brook to the south, both downgradient of AOI 1. Additionally, AOI1-SW07 was collected from a 

natural spring emergence point along the Biathlon Course and AOI1-SW08 was collected from a 

pond near the rifle range along the Biathlon Course. Table 6-5 summarizes the detected 

compounds in surface water. Figure 6-4 presents the ranges of detections for PFOA and PFOS

in surface water.

PFOA was detected at two locations in surface water with concentrations ranging from 1.59 J ng/L 

to 1.72 J ng/L. PFOS and PFBS were not detected in surface water. There were no detections of 

PFOA, PFOS, or PFBS in surface water at locations AOI1-SW01 (representing surface water 

flowing away from AOI 1 to the north), AOI1-SW05 (representing surface water flowing away from 

AOI 1 to the south), and AOI1-SW06 (the snowmaking pond). 

6.3.4 AOI 1 Sediment Analytical Results

Sediment samples were collected from tributaries flowing to Lee River to the north and Mill Brook 

to the south, which are both considered downgradient of AOI 1 due to a surface water divide near 

the Walker Building. Table 6-6 summarizes the detected compounds in sediment. Figure 6-5

presents the ranges of detections for PFOA and PFOS in sediment.

PFOA, PFOS, and PFBS were detected in sediment. PFOA was deected at two locations, with 

concentrations ranging from 0.121 J μg/kg to 0.144 J μg/kg. PFOS was detected at three locations 

with concentrations ranging from 0.032 J μg/kg to 0.082 J μg/kg. PFBS was detected at two 

locations with concentrations ranging from 0.0029 J μg/kg to 0.0057 J μg/kg. 

There were no detections of PFOA, PFOS, or PRBS in sediment at locations AOI1-SW04 and 

AOI1-SW05 (representing surface water flowing away from AOI 1 to the south).

6.3.5 AOI 1 Conclusions

Based on the results of the SI, PFOA, PFOS, and PFBS were detected in soil at AOI 1. The 

detected concentrations indicate there was likely a release of PFAS-containing materials, with 

highest concentrations found in surface soils nearest the Waxing Areas (Walker Building and 

Waxing Sheds); however, the results in soil were orders of magnitude lower than the SLs. PFOA 

and PFBS were detected in groundwater at concentrations below SLs; PFOS was not detected 

in groundwater. Based on these results, no further evaluation at AOI 1 is warranted under 

CERCLA at this time. 
Table 6-2

PFAS Detections in Surface Soil

Site Inspection Report, Camp Ethan Allen Training Site

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Resu

6:2 FTS - ND ND ND 0.019 J 0.025 J ND ND ND ND 8:2 FTS - 0.017 J 0.012 J 0.015 J ND 0.013 J ND 0.013 J ND ND 

NEtFOSAA - 0.00653 J ND ND ND 0.014 J ND ND ND ND NMeFOSAA - 0.00929 J ND ND ND ND ND ND 0.00613 J 0.0074

PFBA - 0.014 J ND ND ND 0.028 J 0.00792 J ND ND 0.012 

PFBS 130000 0.019 J 0.00209 J 0.00376 J 0.00482 J 0.00427 J 0.00330 J 0.00168 J 0.00777 J ND PFDA - ND ND ND ND 0.118 J ND ND 0.120 J ND 

PFDoA - 0.015 J ND ND ND 0.065 J 0.00972 J 0.410 J 0.033 J ND PFHpA - 0.023 J ND ND ND 0.077 J 0.016 J ND ND ND 

PFHxS - ND 0.00444 J 0.00294 J 0.013 J 0.00681 J ND 0.00366 J 0.00747 J ND 

PFNA - ND 0.016 J 0.013 J 0.017 J 0.066 J ND 0.014 J 0.053 J ND 

PFOA 130 0.079 J 0.012 J 0.039 J 0.048 J 0.193 J ND ND 0.044 J ND PFOS 130 0.123 J 0.077 J 0.026 J 0.034 J 0.046 J 0.058 J ND 0.112 J 0.041 PFPeA - ND 0.00542 J 0.00509 J 0.00365 J 0.044 J ND 0.00635 J 0.013 J ND 

PFTrDA - ND 0.031 J 0.00515 J 0.00832 J 0.032 J ND 0.00340 J 0.037 J ND 

PFUnDA - 0.023 J 0.055 J ND ND 0.054 J 0.011 J ND 0.047 J ND 

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations

6:2 FTS 6:2 fluorotelomer sulfonate8:2 FTS 8:2 fluorotelomer sulfonateNEtFOSAA N-ethyl perfluorooctane- sulfonamido

References NMeFOSAA N-methyl perfluorooctanesulfonamido

PFBA perfluorobutanoic acidPFBS perfluorobutanesulfonic acidPFDA perfluorodecanoic acidPFDoA perfluorododecanoic acidPFHpA perfluoroheptanoic acidPFHxS perfluorohexanesulfonic acidPFNA perfluorononanoic acid

Interpreted Qualifiers PFOA perfluorooctanoic acid

J = Estimated concentration PFOS perfluorooctanesulfonic acid

PFPeA perfluoropentanoic acidPFTrDA perfluorotridecanoic acidPFUnDA perfluoro-n-undecanoic acidAcronyms and Abbreviations

AOI Area of InterestD Duplicateft feetHQ Hazard quotientLCMSMS Liquid Chromatography Mass SpectroLOD Limit of DetectionND Analyte not detected above the LODOSD Office of the Secretary of DefenseQSM Quality Systems ManualQual Interpreted QualifierSB Soil boringUSEPA United States Environmental Protectioug/Kg micrograms per Kilogram- Not applicable

Area of Interest

Sample ID

Sample Date

Depth

AOI1-SB01-00-01

08/06/2019

0 - 1 ft

AOI1-SB02-00-01

08/05/2019

0 - 1 ft

AOI1-SB03-00-01

08/05/2019

0 - 1 ft

08/06/2019

0 - 1 ft

AOI1-SB03-00-01-D

08/05/2019

0 - 1 ft

AOI1-SB04-00-01

08/05/2019

0 - 1 ft

a. Assistant Secretary of Defense, 2019. Risk Based Screening Levels Calculated for PFOS, PFOA, PFBS in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1. 15 October 2019. Soil screening levels based on residential scenario for direct ingestion of contaminated soil.

AOI1

Soil, PFAS by LCMSMS Compliant with QSM 5.1 Table B-15 (ug/Kg)

AOI1-SB07-00-01

08/05/2019

0 - 1 ft

AOI1

0

AOI1-SB05-00-01

08/06/2019

0 - 1 ft

AOI1-SB06-00-01

AECOM 
Table 6-3

PFAS Detections in Shallow Subsurface Soil

Site Inspection Report, Camp Ethan Allen Training Site

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Resu

6:2 FTS - 0.015 J ND 0.014 J 0.031 J 0.016 J 0.030 J 0.015 J ND ND 

8:2 FTS - ND 0.010 J ND 0.020 J ND ND ND ND ND 

NEtFOSAA - ND ND ND ND ND 0.010 J ND ND ND NMeFOSAA - ND ND ND ND ND ND ND ND ND PFBA - ND ND ND ND ND ND ND ND ND PFBS 1600000 0.00277 J ND ND ND 0.00237 J ND ND ND ND PFDA - ND ND ND ND ND ND ND ND ND PFDoA - ND ND ND ND ND ND ND ND ND PFHpA - ND ND ND ND ND ND ND ND ND PFHxA - ND ND ND ND ND ND ND ND ND PFHxS - 0.00358 J 0.00266 J 0.00904 J 0.013 J 0.010 J 0.00779 J 0.00194 J 0.00170 J 0.0020PFNA - 0.00456 J 0.00254 J 0.00769 J 0.00812 J 0.00910 J 0.041 J 0.00333 J 0.00779 J 0.0031PFOA 1600 ND ND 0.012 J ND ND 0.018 J 0.013 J 0.012 J ND PFOS 1600 ND ND ND 0.279 J ND 0.048 J ND ND ND 

PFPeA - 0.00967 J 0.00332 J 0.014 J ND 0.016 J 0.020 J 0.00892 J 0.00718 J 0.0072

PFTeDA - ND ND ND ND ND ND ND ND ND PFTrDA - 0.00362 J 0.00545 J 0.00329 J 0.00377 J 0.00704 J 0.012 J 0.00303 J 0.00695 J 0.0086PFUnDA - ND ND ND ND ND ND ND ND ND 

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations

6:2 FTS 6:2 fluorotelomer sulfonate8:2 FTS 8:2 fluorotelomer sulfonateNEtFOSAA N-ethyl perfluorooctane- sulfonamido

References PFBA perfluorobutanoic acid

PFBS perfluorobutanesulfonic acidPFHxS perfluorohexanesulfonic acidPFNA perfluorononanoic acidPFOA perfluorooctanoic acidPFOS perfluorooctanesulfonic acidPFPeA perfluoropentanoic acidPFTrDA perfluorotridecanoic acid

Interpreted Qualifiers PFUnDA perfluoro-n-undecanoic acid

J = Estimated concentration

Acronyms and AbbreviationsAOI Area of InterestD Duplicateft feetHQ Hazard quotientLCMSMS Liquid Chromatography Mass SpectroLOD Limit of DetectionND Analyte not detected above the LODOSD Office of the Secretary of DefenseQSM Quality Systems ManualQual Interpreted QualifierSB Soil boringUSEPA United States Environmental Protectioug/Kg micrograms per Kilogram- Not applicable

a. Assistant Secretary of Defense, 2019. Risk Based Screening Levels Calculated for PFOS, PFOA, PFBS in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1. 15 October 2019. Soil screening levels based on industrial/commercial composite worker scenario for incidental ingestion of contaminated soil.

AOI1

Soil, PFAS by LCMSMS Compliant with QSM 5.1 Table B-15 (ug/Kg)

AOI1-SB04-07-08-D

08/05/2019

7 - 8 ft

AOI1

0

AOI1-SB04-03-04

08/05/2019

3 - 4 ft

AOI1-SB04-07-08

08/05/2019

7 - 8 ft

AOI1-SB02-13-14

08/05/2019

13 - 14 ft

AOI1-SB03-05-06

08/05/2019

5 - 6 ft

AOI1-SB01-14-15

08/06/2019

14 - 15 ft

AOI1-SB02-04-05

08/05/2019

4 - 5 ft

Area of Interest

Sample ID

Sample Date

Depth

AOI1-SB01-05-06

08/06/2019

5 - 6 ft

AECOM 
Table 6-4

PFAS Detections in Groundwater

Site Inspection Report, Camp Ethan Allen Training Site

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual

6:2 FTS - 9.05 3.58 J ND 1.68 J ND

PFBA - 4.55 J 3.47 J 3.45 J 3.09 J- 1.93 JPFBS 40000 1.77 J ND ND 2.33 J NDPFHpA - 2.11 J 5.63 J 5.64 J 5.65 J NDPFHxA - 5.94 J 9.24 9.59 7.55 J 4.02 J

PFNA - 1.54 J ND ND ND 1.68 J

PFOA 40 6.82 J 6.75 J 6.97 J 10.9 3.03 JPFPeA - 2.69 J 5.32 J 8.77 J 5.25 J 4.14 J

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations

6:2 FTS 6:2 fluorotelomer sulfonatePFBA perfluorobutanoic acidPFBS perfluorobutanesulfonic acid

References PFHpA perfluoroheptanoic acid

PFHxA perfluorohexanoic acidPFNA perfluorononanoic acidPFOA perfluorooctanoic acidPFPeA perfluoropentanoic acidAcronyms and AbbreviationsAOI Area of Interest

Interpreted Qualifiers D Duplicate

J = Estimated concentration GW Groundwater

J- = Estimated concentration, biased low HQ Hazard quotient

LOD Limit of DetectionND Analyte not detected above the LODOSD Office of the Secretary of DefenseQual Interpreted QualifierUSEPA United States Environmental Protectiong/L nanogram per liter- Not applicable

a. Assistant Secretary of Defense, 2019. Risk Based Screening Levels Calculated for PFOS, PFOA, PFBS in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1. 15 October 2019. Groundwater screening levels based on residential scenario for direct ingestion of groundwater.

Water, PFAS via PFAS by LCMSMS Compliant with QSM 5.1 Table B-15 (ng/L)

AOI1

AOI1-GW05

08/07/2019

AOI1-GW06

08/07/2019

AOI1-GW04

08/07/2019

AOI1-GW04-D

08/07/2019

Area of Interest

Sample ID

Sample Date

AOI1-GW01

08/07/2019

AECOM 
Table 6-5

PFAS Detections in Surface Water

Site Inspection Report, Camp Ethan Allen Training Site

Area of Interest

Sample ID

Sample Date

Analyte Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

PFBA ND ND ND 2.14 J 2.91 J ND ND 1.84 J 2.83 J

PFOA ND 1.59 J 1.70 J ND ND ND ND 1.72 J ND

Interpreted Qualifiers Chemical AbbreviationsJ = Estimated concentration PFBA perfluorobutanoic acid

PFOA perfluorooctanoic acidAcronyms and Abbreviations

AOI Area of InterestDUP DuplicateLOD Limit of DetectionND Analyte not detected above Qual Interpreted QualifierSW Surface water ng/L nanogram per liter

AOI1-SW02

08/02/2019

AOI1-SW08

08/07/2019

Water, PFAS via PFAS by LCMSMS Compliant with QSM 5.1 Table B-15 (ng/L)

AOI1

AOI1-SW06

08/02/2019

AOI1-SW07

08/07/2019

AOI1-SW04

08/07/2019

AOI1-SW05

08/07/2019

AOI1-SW02-D

08/02/2019

AOI1-SW03

08/02/2019

AOI1-SW01

08/07/2019

AECOM 
Table 6-6

PFAS Detections in Sediment

Site Inspection Report, Camp Ethan Allen Training Site

Area of Interest

Sample ID

Sample Date

Depth

Analyte Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

PFBA 0.063 J 0.052 J 0.072 J 0.010 J ND ND 0.00411 J

PFBS ND 0.00570 J 0.00615 J 0.00290 J ND ND NDPFDA 0.063 J ND 0.042 J ND ND ND ND

PFDoA 0.024 J 0.012 J 0.013 J 0.012 J ND ND 0.00587 J

PFHpA 0.074 J 0.055 J 0.073 J ND ND ND NDPFHxA ND 0.095 J 0.124 J ND ND ND NDPFHxS ND ND 0.015 J ND ND ND NDPFNA 0.078 J ND ND ND ND ND NDPFOA 0.144 J 0.121 J 0.125 J ND ND ND NDPFOS 0.065 J 0.032 J 0.082 J 0.034 J ND ND NDPFPeA 0.089 J 0.081 J 0.091 J ND ND ND NDPFUnDA ND 0.022 J 0.022 J 0.021 J ND ND 0.00661 J

Interpreted Qualifiers Chemical AbbreviationsJ = Estimated concentration PFBA perfluorobutyrate 

PFBS perfluorobutane sulfonatePFDA perfluorodecanoatePFDoA perfluorododecanoic acidPFHpA perfluoroheptanoic acidPFHxA perfluorohexanoic acidPFHxS perfluorohexanesulfonic acPFNA perfluorononanoic acidPFOA perfluorooctanoic acidPFOS perfluorooctane sulfonatePFPeA perfluoropentanoic acidPFUnDA perfluoro-n-undecanoic acidAcronyms and Abbreviations

AOI Area of InterestD Duplicateft feetLOD Limit of DetectionND Analyte not detected above Qual Interpreted QualifierSD Sedimentug/Kg micrograms per Kilogram

AOI1-SD06-00-01

08/02/2019

0 - 1 ft

Sediment, PFAS via PFAS by LCMSMS Compliant with QSM 5.1 Table B-15 (ug/Kg)

AOI1

AOI1-SD04-00-01

08/07/2019

0 - 1 ft

AOI1-SD05-00-01

08/07/2019

0 - 1 ft

AOI1-SD02-00-01-D

08/02/2019

0 - 1 ft

AOI1-SD03-00-01

08/02/2019

0 - 1 ft

AOI1-SD01-00-01

08/07/2019

0 - 1 ft

AOI1-SD02-00-01

08/02/2019

0 - 1 ft

AECOM 
AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB03/GW03

AOI1-SB04/GW04 AOI1-SB05/GW05

AOI1-SB06/GW06

AOI1-SB07

AOI1-SB08

AOI1-SB09

AOI1-SB10

AOI 1 AOI 1

AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB03/GW03

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

AOI 1

AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

Figure 6-1

PFOS Detections in Soil

12420 Milestone Center Drive ­ Germantown, MD 20876

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_6-1_TS_Ethan_Allen_Soil_PFOS_Results.mxd

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12/21/2020

1:11,400

Shallow Intermediate Deep

Area of Interest

Facility Boundary

Water Body

Wetland

River/Stream

PFOS Results (μg/Kg)

ND

>ND - 10

>10 - 130

>130 - 1,600

>1,600

0 475 950 1,900

Feet

6-9
AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB03/GW03

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

AOI1-SB07

AOI1-SB08

AOI1-SB09

AOI1-SB10

AOI 1 AOI 1

AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB03/GW03

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

AOI 1

AOI1-SB01/GW01

AOI1-SB02/GW02

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

Figure 6-2

PFOA Detections in Soil

12420 Milestone Center Drive ­ Germantown, MD 20876

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_6-2_TS_Ethan_Allen_Soil_PFOA_Results.mxd

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1:11,400

Shallow Intermediate Deep

Area of Interest

Facility Boundary

Water Body

Wetland

River/Stream

PFOA Results (μg/Kg)

ND

>ND - 10

>10 - 130

>130 - 1,600

>1,600

0 475 950 1,900

Feet

6-10
AOI 1

AOI1-SB01/GW01

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

AOI 1

AOI1-SB01/GW01

AOI1-SB04/GW04

AOI1-SB05/GW05

AOI1-SB06/GW06

Figure 6-3

PFOA & PFOS Detections in Groundwater

12420 Milestone Center Drive

Germantown, MD 20876

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_6-3_TS_Ethan_Allen_GW_PFOA_PFOS.mxd

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12/21/2020

PFOA PFOS

PFOS Results (ng/L)

ND

>ND - 20

>20 - 40

>40 - 70

>70 - 400

>400

PFOA Results (ng/L)

ND

>ND - 20

>20 - 40

>40 - 70

>70 - 400

>400

Legend

Area of Interest

Facility Boundary

Water Body

Wetland

River/Stream

0 475 950 1,900

Feet

6-11
AOI 1

AOI1-SD06/SW06

AOI1-SD01/SW01

AOI1-SD02/SW02

AOI1-SD03/SW03

AOI1-SD04/SW04

AOI1-SD05/SW05

AOI1-SW07

AOI1-SW08

AOI 1

AOI1-SD06/SW06

AOI1-SD01/SW01

AOI1-SD02/SW02

AOI1-SD03/SW03

AOI1-SD04/SW04

AOI1-SD05/SW05

AOI1-SW07

AOI1-SW08

Figure 6-4

PFOA & PFOS Detections in Surface Water

12420 Milestone Center Drive

Germantown, MD 20876

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_6-4_TS_Ethan_Allen_SW_PFOA_PFOS.mxd

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12/21/2020

PFOA PFOS

Area of Interest

Facility Boundary

Water Body

Wetland

River/Stream

PFOA Results (ng/L)

ND

>ND - 10

>10 -100

>100 - 1,000

>1,000

PFOS Results (ng/L)

ND

>ND - 10

>10 - 100

>100 - 1,000

1:11,400

>1,000 ­

0 475 950 1,900

Feet

6-12
AOI 1

AOI1-SD06/SW06

AOI1-SD01/SW01

AOI1-SD02/SW02

AOI1-SD03/SW03

AOI1-SD04/SW04

AOI1-SD05/SW05

AOI 1

AOI1-SD06/SW06

AOI1-SD01/SW01

AOI1-SD02/SW02

AOI1-SD03/SW03

AOI1-SD04/SW04

AOI1-SD05/SW05

Figure 6-5

PFOA & PFOS Detections in Sediment

12420 Milestone Center Drive ­ Germantown, MD 20876

C:\Users\stankevichm\OneDrive - AECOM Directory\ARNG_PFAS_GIS_60552172\MXDs\VT\TS_Ethan_Allen\TS_Ethan_Allen_SI\TS_Ethan_Allen_SI_Report\Fig_6-5_TS_Ethan_Allen_Sed_PFOA_PFOS.mxd

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1:17,155

PFOA PFOS

Area of Interest

Facility Boundary

Water Body

Wetland

River/Stream

PFOA Results (μg/Kg)

ND

>ND - 10

>10 - 100

>100 - 1,000

>1,000

PFOS Results (μg/Kg)

ND

>ND - 10

>10 - 100

>100 - 1,000

>1,000

0 475 950 1,900

Feet

6-13
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 6-14

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

Camp Ethan Allen Training Site, Jericho, Vermont 

AECOM 7-1

7. Exposure Pathways

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

the current understanding of the site conditions with respect to known and suspected sources, 

potential transport mechanisms and migration pathways, and potentially exposed human 

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

conditions are present:

1. Contaminant source;

2. Environmental fate and transport;

3. Exposure point;

4. Exposure route; and

5. Potentially exposed populations.

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

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

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

PFOA, PFOS, or PFBS are detected, in which case the CSM figure uses a half-filled circle symbol 

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

is used to indicate when a potentially complete exposure pathway has detections of PFOA, PFOS, 

or PFBS above the SLs. Areas with an identified potentially complete pathway may warrant further 

investigation or action.

In general, the potential routes of exposure to PFAS 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. The receptors evaluated are 

consistent with those listed in USEPA guidance for risk screening (USEPA, 2001). Receptors at 

the facility include site workers (e.g., facility staff and visiting soldiers), construction workers, 

trespassers, residents outside the facility boundary, and recreational users outside of the facility 

boundary. 

7.1 Soil Exposure Pathway

The SI results for PFOA, PFOS, and PFBS in soil were used to determine whether a potentially 

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

aforementioned criteria.

7.1.1 AOI 1

From approximately 1972 to present, PFAS may have been released to soil at four potential 

release areas associated with the biathlon facility at CEATS: the Waxing Areas, Biathlon Course, 

Walker Building, and Snowmaking Pond. Remnants of ski wax swept from the Wax Sheds and 

Walker Building by patrons of the biathlon facility are a potential PFAS source, as is the residual 

wax left on the snow surface along the 5-kilometer Biathlon Course.

PFOA, PFOS, and PFBS were detected in soil in three source areas (the Waxing Areas, Biathlon 

Course, and Walker Building). Based on the results of the SI, ground-disturbing activities to 

surface soil could result in site worker, construction worker, recreational user, and trespasser 

exposure to PFOA, PFOS, and PFBS via inhalation of dust and ingestion. Ground-disturbing 

activities to subsurface soil could result in construction worker exposure to PFOA, PFOS, and 
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AECOM 7-2

PFBS via ingestion. Therefore, the exposure pathways for inhalation and ingestion are potentially 

complete for these receptors. The CSM is presented in Figure 7-1.

7.2 Groundwater Exposure Pathway

The SI results for PFOA, PFOS, and PFBS in groundwater, in addition to the results of drinking 

water samples collected under the SDWA, were used to determine whether a potentially complete 

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

aforementioned criteria.

7.2.1 AOI 1

The overall direction of deep, bedrock groundwater flow in the Lee River and Mill Brook Valleys 

is east to west, while localized flow is from the valley walls to the Lee River or Mill Brook. The 

primary drinking water source for CEATS since 1999 has been the Champlain Water District 

system; however, bedrock wells are still occasionally used at the facility. Additionally, numerous 

domestic wells are located off-facility in both Lee River and Mill Brook Valleys. The domestic wells 

are commonly drilled into bedrock with median well depths of approximately 300 feet bgs. 

Hydraulic properties and aquifer characteristics vary widely across relatively short distances 

(Clark et al., 2005).

Drinking water sources at the facility include a potable well (#40293, located south of the Walker 

Building) used to supply the biathlon facilities located within CEATS. As a state action in 

accordance with the SDWA, the VTARNG has sampled well #40293 nine times between March 

2017 and December 2020. The well #40293 sampling was completed separately from the SI 

described in this report. Since the initial sampling event, PFAS have consistently been detected 

in well #40293 above the Vermont MCL, with a maximum detection of PFOS at 40.8 ng/L in 

December 2020.

The SI groundwater sampling program at CEATS focused on groundwater present in the till above 

bedrock. Depth to groundwater in the till was observed from 5.33 to 14.32 feet bgs in August 

2019. It is suspected that the groundwater present in the till above bedrock is not a continuous 

aquifer, and that the majority of shallow groundwater flows toward and discharges into nearby 

surface water drainage features. Among the four groundwater samples collected from temporary 

wells during the SI, PFOS was not detected. PFOA and PFBS were detected but were below the 

SLs of 40 ng/L and 40,000 ng/L, respectively. 

Based on the results of the SI, in addition to the detections of PFAS in drinking water samples 

from well #40293 above the Vermont MCL of 20 ng/L (VTDEC, 2020), the groundwater ingestion 

exposure pathway is considered potentially complete for site workers, recreational users, 

trespassers, and nearby off-site residents. Additionally, the ingestion exposure pathway is 

considered potentially complete for construction workers during trenching activities deep enough 

to encounter shallow groundwater. The CSM is presented in Figure 7-1.

7.3 Surface Water and Sediment Exposure Pathway

The SI results for PFOA, PFOS, and PFBS in surface water and sediment were used to determine 

whether a potentially complete pathway exists between the source and potential receptors at each 

AOI based on the aforementioned criteria.

7.3.1 AOI 1

PFOS, PFOA, and PFBS were detected in surface water and sediment samples collected from

tributaries flowing to Lee River to the north and Mill Brook to the south, both downgradient of AOI 

1. Therefore, the ingestion exposure pathway for surface water and sediment is considered
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potentially complete for site workers, construction workers, and trespassers/recreational users. 

No PFOS, PFOA, or PFBS were detected in surface water or sediment at location AOI1-SW05 

(representing surface water flowing off the facility to the south). Therefore, the ingestion exposure 

pathways in surface water and sediment are considered incomplete for nearby offsite residents. 

The CSM is presented on Figure 7-1.
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Media

SOURCE PATHWAY REC

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

Particulate

Surface Soil 

at AOI

Surface 

Water/ 

Sediment

Subsurface 

Soil

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Huma

Curr

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

Site 

Worker

Construct

Worker 

Site 

Worker

Construct

Worke

/ / 

/ 

LEGEND

/ // / 

Figure 7-1

Conceptual Site 

AOI 1 – Biathlon 

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

/

/ 

AOI 1 

Potential 

releases PFAScontaining ski 

wax

PFAS in 

Surface Soil

NOTES1. The resident and recreational userreceptors refer to an off-site resident orrecreational user.2. Dermal contact exposure pathway isincomplete for PFAS.

/
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8. Summary and Outcome

This section summarizes SI activities and findings. The most significant findings are summarized 

in this section and are reproduced directly or abstracted from information contained in this report. 

The outcome provides general and comparative interpretations of the findings relative to the SLs.

8.1 SI Activities

The SI field activities at CEATS were conducted from 2 to 8 August 2019. The SI field activities 

included soil, groundwater, surface water, and sediment sampling. Field activities were conducted 

in accordance with the SI QAPP Addendum (AECOM, 2019b), except as previously noted in 

Section 5.7.

To fulfill the project DQOs set forth in the approved SI QAPP Addendum (AECOM, 2019b),

samples were collected and analyzed for a subset of PFAS by LC/MS/MS compliant with QSM 

Table B-15 as follows. The 18 PFAS analyzed as part of the ARNG SI program are specified in 

Section 5.6 of this Report.

• 21 soil samples from 10 locations (soil borings or hand auger locations);

• Four grab groundwater samples from four of the five temporary well locations; 

• Six sediment samples; and

• Eight surface water samples, six of which were co-located with sediment samples, and two 

of which were located downgradient from soil borings where groundwater was unavailable.

The information gathered during this investigation was used to determine if PFOA, PFOS, and/or

PFBS were present at or above SLs. Additionally, the CSM was refined to assess whether a 

potentially complete pathway exists between the source and potential receptors for potential 

exposure to PFOA, PFOS, and PFBS, as described in Section 7.

8.2 SI Goals Evaluation

As described in Section 4.2, the SI activities were designed to achieve six main goals or DQOs. 

This section describes the SI goals and the conclusions that can be made for each based on the 

data collected during this investigation. 

1. Determine the presence or absence of PFOA, PFOS, and PFBS at or above SLs.

PFOA, PFOS, and PFBS were detected at the facility in soil, groundwater, surface water, 

and sediment. PFOA, PFOS, and PFBS were detected in the potential PFAS release 

areas, as well as near the facility boundary between source areas and potential drinking 

water receptors. However, the detections of PFOA, PFOS, or PFBS in soil or groundwater 

did not exceed the SLs. 

2. Develop information to potentially eliminate a release from further consideration because 

it is determined that it poses no significant threat to human health or the environment.

All potential PFAS release areas (the Waxing Areas, Biathlon Course, Walker Building, 

and Snowmaking Pond) were removed from further consideration under CERCLA based 

on the soil and groundwater data collected during the SI. PFOA, PFOS, and PFBS were 

not detected in soil or groundwater above the SLs at AOI 1.

However, in light of the detections of PFAS in drinking water samples from well #40293 

above the Vermont MCL of 20 ng/L, which were collected under a separate action in 
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accordance with the SDWA, there is a potentially complete pathway to drinking water 

receptors, which include DoD and civilian users of the biathlon facility. Therefore, 

additional action will be considered under the SDWA. At the time of this report, units are 

responsible for providing their own water when using the facility.

3. Determine the potential need for a removal action. 

Based on the data collected during this SI, no need for a removal action was identified.

4. Collect data to better characterize the release areas for more effective and rapid initiation 

of an RI.

The geological data collected as part of the SI are consistent with the regional geology of 

the surrounding area. Observations from shallow borings advanced across AOI 1 indicate 

a thin layer of glacial till exists overlying weathered bedrock. The glacial till consisted of a 

heterogeneous sand, silt, and clay matrix with small, subangular gravel. The till thickness 

varied widely from a few feet thick to upwards of 20 feet depending on the location within 

the valley and presence of surficial bedrock.

Depth to water measured from the temporary monitoring wells installed in August 2019 

ranged from 5.33 to 14.32 below top of casing; however, it is unlikely the till unit represents 

a continuous aquifer across AOI 1 given the surficial geology of the area. These geologic 

and hydrogeologic observations inform development of technical approach for any further 

investigation.

5. Identify within 4 miles of the installation other potential PFAS sources (fire stations, major 

manufacturers, other DoD facilities) and receptors, including both groundwater and 

surface water receptors, and sample accordingly, in order to determine whether the ARNG 

is the likely source of PFAS or whether there is an off-facility source of PFAS responsible 

for installation detections of PFAS (USEPA, 2005).

Based upon the evaluation of groundwater and soil results in comparison to SLs, in 

combination with the groundwater flow direction analysis, the results of the SI indicate that 

the source of detected concentrations of PFOA, PFOS, and PFBS in soil and shallow 

groundwater at the facility is likely attributable to ARNG activities at the Biathlon Course; 

however, the hydrogeological connection and potential migration pathways between the 

overburden (soil and shallow groundwater) and deep bedrock groundwater are not fully 

understood and, as a result, it is not understood whether these detections are the source 

of the PFAS detections in well #40293 (Walker Building well), which has a depth of 225 

feet bgs.

6. Determine whether a potentially complete pathway exists between the source and 

potential receptors and whether ARNG is the likely source of the contamination. 

Detections of PFOA, PFOS, and PFBS in soil and groundwater at the potential PFAS 

release areas indicate there was likely a release of PFAS-containing materials, with 

highest concentrations found in surface soils nearest the Waxing Areas (Walker Building 

and Waxing Sheds). These detections, in addition to the detections PFAS in drinking water 

samples from well #40293 above the Vermont MCL of 20 ng/L, indicate there is a 

potentially complete pathway between source and receptor.

8.3 Outcome 

Based on the CSM developed and revised in light of the SI findings, in addition to the results of 

drinking water samples collected under the SDWA, there is potential for exposure to drinking 

water receptors from AOI 1 from sources on facility resulting from historical DoD activities.
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Sample analytical concentrations collected during the SI were compared against the project SLs

for PFOA, PFOS, and PFBS in soil and groundwater, as described in Table 6-1. The following 

bullets summarize the SI results: 

• While detected concentrations indicated a release of PFAS materials, the detected 

concentrations of PFOA, PFOS, and PFBS in soil samples from AOI 1 were orders of 

magnitude below the SLs. 

• PFOS was not detected in groundwater. PFOA and PFBS were detected in groundwater at 

AOI 1 at maximum concentrations of 10.9 ng/L and 2.33 J ng/L, respectively, below the SLs 

of 40 ng/L and 40,000 ng/L, respectively.

Table 8-1 summarizes the SI results for soil and groundwater. Table 8-2 summarizes the rationale 

used to determine if an AOI should be considered for further investigation under CERCLA and 

undergo an RI. Based on the results of this SI, no further evaluation under CERCLA is warranted 

at this time. 

However, in light of the detections of PFAS in drinking water samples from well #40293 above the 

Vermont MCL of 20 ng/L, which were collected under a separate action in accordance with the 

SDWA, there is a potentially complete pathway to drinking water receptors, which include DoD and 

civilian users of the biathlon facility. Samples of soil and groundwater collected as part of the 

CERCLA SI show detections of PFOA, PFOS, and PFBS, but they were detected at levels below 

the OSD SLs. Therefore, additional action will be taken under the SDWA.

Table 8-1 Summary of Site Inspection Findings

AOI Potential PFAS 

Release Area

Soil –

Source Area

Soil –

Near Facility 

Boundary

Groundwater –

Source Area

Groundwater –

Facility 

Boundary

1

Walker Building NA NA

Waxing Sheds NA NA

Snowmaking Pond NA NA NA NA

Biathlon Course

Legend:

NA = not applicable

= detected; exceedance of SLs

 = detected; no exceedance of SLs

 = not detected

Table 8-2 Site Inspection Recommendations

AOI Description Rationale Future Action

1

Walker Building

Detections in soil and groundwater were 

below SLs.

No further action under 

CERCLA

Waxing Sheds

Snowmaking Pond

Biathlon Course
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