FINAL

Site Inspection Report 

E.J. Garn Aviation Complex

West Jordan, Utah

Site Inspection for Perfluorooctanoic acid (PFOA), 

Perfluorooctanesulfonic acid (PFOS), Perfluorohexanesulfonic 

acid (PFHxS), Perfluorononanoic acid (PFNA), 

Hexafluoropropylene oxide dimer acid (HFPO-DA), and 

Perfluorobutanesulfonic acid (PFBS) at ARNG Installations, 

Nationwide 

September 2023

Prepared for:

Army National Guard Bureau

111 S. George Mason Drive

Arlington, VA 22204

UNCLASSIFIED
 

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM i

Table of Contents

Executive Summary .................................................................................................................... 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 ......................................................................................................2-1

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

2.2.3 Hydrology....................................................................................................2-3

2.2.4 Climate........................................................................................................2-3

2.2.5 Current and Future Land Use......................................................................2-4

2.2.6 Sensitive Habitat and Threatened/ Endangered Species.............................2-4

2.3 History of PFAS Use..............................................................................................2-4

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

3.1 AOI 1 North Hangar...............................................................................................3-1

3.2 AOI 2 Hangar/Ramp Area .....................................................................................3-1

3.3 AOI 3 Armory Dumpster Fire .................................................................................3-2

3.4 Adjacent Sources ..................................................................................................3-2

3.4.1 Emergency Response Area.........................................................................3-2

3.4.2 Private Aviation Companies at South Valley Regional Airport ......................3-2

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

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

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

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

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

4.5 Data Usability Assessment....................................................................................4-1

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 Sampling Equipment Acceptability .................................5-2

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

5.3 Permanent Well Installation and Groundwater Sampling.......................................5-3

5.4 Synoptic Water Level Measurements ....................................................................5-4

5.5 Surveying..............................................................................................................5-4

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

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

5.8 Deviations from SI QAPP Addendum ....................................................................5-5

6. Site Inspection Results .................................................................................................6-1

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

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

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

6.3.1 AOI 1 Soil Analytical Results .......................................................................6-2
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM ii

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

6.3.3 AOI 1 Conclusions ......................................................................................6-3

6.4 AOI 2.....................................................................................................................6-3

6.4.1 AOI 2 Soil Analytical Results .......................................................................6-3

6.4.2 AOI 2 Groundwater Analytical Results.........................................................6-4

6.4.3 AOI 2 Conclusions ......................................................................................6-4

6.5 AOI 3.....................................................................................................................6-4

6.5.1 AOI 3 Soil Analytical Results .......................................................................6-4

6.5.2 AOI 3 Groundwater Analytical Results.........................................................6-5

6.5.3 AOI 3 Conclusions ......................................................................................6-5

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

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

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

7.1.2 AOI 2...........................................................................................................7-2

7.1.3 AOI 3...........................................................................................................7-2

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

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

7.2.2 AOI 2...........................................................................................................7-3

7.2.3 AOI 3...........................................................................................................7-3

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

7.3.1 AOI 1, AOI 2, and AOI 3 ..............................................................................7-3

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

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

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

9. References...................................................................................................................9-1
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM iii

Appendices

Appendix A Data Usability Assessment and Validation Reports

Appendix B Field Documentation

B1. Log of Daily Notice of Field Activities

B2. Sampling Forms

B3. Field Change Request Form

B4. Nonconformance and Corrective Action Report

B5. Survey Data

B6. Investigation-Derived Waste Polygons

Appendix C Photographic Log

Appendix D TPP Meeting Minutes

Appendix E Boring Logs and Well Construction Forms 

Appendix F Analytical Results

Appendix G Laboratory Reports

Figures

Figure 2-1 Facility Location

Figure 2-2 Facility Topography

Figure 2-3 Groundwater Features

Figure 2-4 Groundwater Elevations, November 2021

Figure 2-5 Surface Water Features

Figure 3-1 Areas of Interest

Figure 5-1 Site Inspection Sample Locations

Figure 6-1 PFOA Detections in Soil

Figure 6-2 PFOS Detections in Soil

Figure 6-3 PFBS Detections in Soil

Figure 6-4 PFHxS Detections in Soil

Figure 6-5 PFNA Detections in Soil

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

Figure 6-7 PFHxS and PFNA Detections in Groundwater

Figure 7-1 Conceptual Site Model, AOI 1

Figure 7-2 Conceptual Site Model, AOI 2

Figure 7-3 Conceptual Site Model, AOI 3

Tables

Table ES-1 Screening Levels (Soil and Groundwater)

Table ES-2 Summary of Site Inspection Findings and Recommendations

Table 5-1 Site Inspection Samples by Medium

Table 5-2 Soil Boring Depths

Table 5-3 Permanent Monitoring Well Screen Intervals and Groundwater Elevations

Table 6-1 Screening Levels (Soil and Groundwater)

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

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

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

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

Table 8-1 Summary of Site Inspection Findings and Recommendations
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM iv

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM v

Acronyms and Abbreviations

% percent

°C degrees Celsius

°F degrees Fahrenheit

μg/kg micrograms per kilogram

AASF Army Aviation Support Facility

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 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CoC chain of custody

CSM conceptual site model 

DA Department of the Army

DO dissolved oxygen

DoD Department of Defense

DQI data quality indicator

DQO data quality objective

DUA data usability assessment

DVR data validation report 

EDR Environmental Data Resources, Inc.TM 

ELAP Environmental Laboratory Accreditation Program

ELU Equivalent Livestock Unit

FedEx Federal Express

FRB field reagent blank

HAZMAT hazardous materials

HDPE high-density polyethylene 

HFPO-DA hexafluoropropylene oxide dimer acid

HSA hollow stem auger

IDW investigation-derived waste\ 

ITRC Interstate Technology Regulatory Council

LC/MS/MS liquid chromatography with tandem mass spectrometry\ 

MIL-SPEC military specification

MS matrix spike 

MSD matrix spike duplicate

NCO Non-Commissioned Officer

NELAP National Environmental Laboratory Accreditation Program

ng/L nanograms per liter

ORP oxidation-reduction potential

OSD Office of the Secretary of Defense

PA Preliminary Assessment

PFAS per- and polyfluoroalkyl substances
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM vi

PFBS perfluorobutanesulfonic acid

PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

PID photoionization detector

PQAPP Programmatic UFP-QAPP

PVC polyvinyl chloride

QA quality assurance

QAPP Quality Assurance Project Plan

QC quality control

QSM Quality Systems Manual

RI Remedial Investigation

RPD relative percent differences

SI Site Inspection

SL screening level

SOP standard operating procedure

TOC total organic carbon

TPP Technical Project Planning

UDEQ Utah Department of Environmental Quality

UDWR Utah Division of Water Rights

UFP Uniform Federal Policy

US United States

USACE United States Army Corps of Engineers

USCS Unified Soil Classification System

USDA US department of Agriculture

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

UTARNG Utah Army National Guard
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM ES-1

Executive Summary

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

Inspections (SIs) on the current or potential historical use of per- and polyfluoroalkyl substances

(PFAS) with a focus on the six compounds presented in the memorandum from the Office of the 

Secretary of Defense (OSD) dated 6 July 2022 (Assistant Secretary of Defense, 2022). The six 

compounds listed in the OSD memorandum include perfluorooctanesulfonic acid (PFOS),

perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA), perfluorohexanesulfonic acid 

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

, and perfluorobutanesulfonic acid 

(PFBS). These compounds are collectively referred to as “relevant compounds” throughout the 

document and the applicable screening levels (SLs) are provided in Table ES-1. 

The PA identified three Areas of Interest (AOIs) where PFAS-containing materials may have been 

used, stored, disposed, or released historically (see Table ES-2 for AOI locations). The objective 

of the SI is to identify whether there has been a release to the environment from the AOIs identified

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

to address immediate threats, or no further action is required based on SLs for relevant 

compounds. This SI was completed at the E.J. Garn Aviation Complex in West Jordan, Utah and 

determined further evaluation under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) is warranted for AOI 1 and AOI 2; no further evaluation 

is warranted for AOI 3 at this time. The E.J. Garn Aviation Complex will also be referred to as the 

“facility” throughout this document. 

The E.J. Garn Aviation Complex occupies approximately 57 acres located at 7563 Airport Rd, 

West Jordan, Utah, 84084, within Salt Lake County. The facility was established in 1989 and 

serves as the base operations for military helicopter maintenance and support (Kleinfelder, 2018). 

The facility consists of two main ARNG areas divided by Airport Road, which runs through the 

middle of the facility; the Army Facility Maintenance Support-2 (the Armory) is located on the west 

side, and the Army Aviation Support Facility (AASF) is located on the east side. 

The PA identified three AOIs for investigation during the SI phase. SI sampling results from the 

three AOIs were compared to OSD SLs. Table ES-2 summarizes the SI results for each AOI. 

Based on the results of this SI, further evaluation under CERCLA is warranted in a Remedial 

Investigation (RI) for AOI 1 and AOI 2; no further evaluation is warranted for AOI 3 at this time. 

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as GenX) was not 

included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed during the PA and revised based 

on SI findings, the presence of HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a component of military 

specification (MIL-SPEC) aqueous film forming foam (AFFF) and based on its history including distribution limitations that restricted 

use of GenX, it is generally not a component of other products the military used. In addition, it is unlikely that GenX would be an 

individual chemical of concern in the absence of other PFAS. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM ES-2

Table ES-1: Screening Levels (Soil and Groundwater)

Analyteb

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 19 250 6

PFOS 13 160 4 

PFBS 1,900 25,000 601 

PFHxS 130 1,600 39

PFNA 19 250 6

Notes:

bgs = below ground surface; μg/kg = micrograms per kilogram; ng/L = nanograms per liter

a.) Assistant Secretary of Defense, 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection 

Agency’s (USEPA’s) Regional Screening Level Calculator. Hazard Quotient (HQ) = 0.1. 6 July 2022. 

b.) Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as GenX) was not included 

as an analyte at the time of this SI. Based on the CSM developed during the PA and revised based on SI findings, the presence of HFPODA is not anticipated at the facility because HFPO-DA is generally not a component of MIL-SPEC AFFF and based on its history including 

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

unlikely that GenX would be an individual chemical of concern in the absence of other PFAS. 

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

AOI Potential 

Release Area

Soil –

Source 

Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary

Future 

Action

1 North Hangar Proceed 

Dry Well N/A N/A to RI 

2 

Hangar/Ramp 

Area Proceed 

Tent Storage to RI

Area

3 Armory 

Dumpster Fire

No 

Further 

Action

Legend:

N/A = not applicable 

= detected; exceedance of the screening levels

= detected; no exceedance of the screening levels

= not detected
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 1-1

1. Introduction

1.1 Project Authorization

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

(PAs) and Site Inspections (SIs) on the current or potential historical use of per- and 

polyfluoroalkyl substances (PFAS) with a focus on the six compounds presented in the 

memorandum from the Office of the Secretary of Defense (OSD) dated 6 July 2022 (Assistant 

Secretary of Defense, 2022). The six compounds listed in the OSD memorandum will be referred 

to as “relevant compounds” throughout this document and include perfluorooctanoic acid (PFOA), 

perfluorooctanesulfonic acid (PFOS), perfluorohexanesulfonic acid (PFHxS), perfluorononanoic 

acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA)1

, and perfluorobutanesulfonic 

acid (PFBS) at ARNG facilities nationwide. The ARNG performed this SI at the E.J. Garn Aviation 

Complex in West Jordan, Utah. The E.J. Garn Aviation Complex is also 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; United States [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. 

1.2 SI Purpose

A PA was performed at E.J. Garn Aviation Complex (AECOM Technical Services, Inc. [AECOM], 

2019) that identified three Areas of Interest (AOIs) where PFAS-containing materials may have 

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

there has been a release to the environment from the AOIs identified in the PA and determine 

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

threats, or no further action is required based on screening levels (SLs) for the relevant 

compounds. 

1 Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as GenX) was not 

included as an analyte at the time of this SI. Based on the conceptual site model (CSM) developed during the PA and revised based 

on SI findings, the presence of HFPO-DA is not anticipated at the facility because HFPO-DA is generally not a component of military 

specification (MIL-SPEC) aqueous film forming foam (AFFF) and based on its history including distribution limitations that restricted 

use of GenX, it is generally not a component of other products the military used. In addition, it is unlikely that GenX would be an 

individual chemical of concern in the absence of other PFAS. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 1-2

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 2-1

2. Facility Background 

2.1 Facility Location and Description

The E.J. Garn Aviation Complex is located at 7563 Airport Rd, West Jordan, Utah, 84084, within 

Salt Lake County. The facility was established in 1989 and serves as the base operations for 

military helicopter maintenance and support (Kleinfelder, 2018). The facility consists of two main 

ARNG areas divided by Airport Road, which runs through the middle of the facility; the Army 

Facility Maintenance Support-2 (the Armory) is located on the west side, and the Army Aviation 

Support Facility (AASF) is located on the east side. 

West Jordan is a suburb of Salt Lake City, bordered on the west by the Oquirrh Mountains and 

on the east by the Jordan River. The facility borders the South Valley Regional Airport to the east 

and is situated west of Interstate 15 (Figure 2-1). The facility is about 9.3 miles southwest of Salt 

Lake City.

2.2 Facility Environmental Setting

The E.J. Garn Aviation Complex occupies approximately 57 acres, approximately 77 percent (%)

of which is composed of impervious surfaces. The areas surrounding the facility are primarily the 

railroad to the west, and general aviation facilities at the South Valley Regional Airport to the north

and east. Other surrounding areas include self-storage and manufacturing companies to the 

northwest, a Utah Department of Transportation facility to the southwest, and a water tank facility 

for the City of West Jordan to the east. The facility sits at an elevation of 4,620 feet above mean 

sea level (amsl), with a slight general topographic gradient to the east. There are no significant 

natural topographic features immediately surrounding the facility (Figure 2-2). 

2.2.1 Geology

The E.J. Garn Aviation Complex is located within the Jordan Valley, at the eastern margin of the 

Basin and Range physiographic province. The valley is bounded on the east by the Wasatch 

Range, on the south by the Traverse Mountains, on the west by the Oquirrh Mountains, and on 

the north by the Great Salt Lake and a low east-west salient of the Wasatch Range (Marine and 

Price, 1964). At the facility, Holocene-aged alluvium and Pleistocene-aged silt and clay deposits 

of the regressive Phase of Lake Bonneville overlie volcanic and sedimentary rocks of the Salt

Lake Formation of Tertiary age, which were largely of mud-rock flow origin (Marine and Price, 

1964). Geologic units are depicted on Figure 2-3. 

The uppermost geologic units at the facility are comprised of massive to thinly bedded silt and 

clay deposits (7-16 feet), with boulder to pebble gravel, sand, silt, and clay deposited in channels 

and flood plain of streams (US Department of Agriculture [USDA], 2019). The Jordan Narrows 

unit of the Salt Lake Formation commonly underlies the alluvial or lacustrine material and consists 

of fine-grained sediments with a few thin gravel lenses, principally of andesite. The fine-grained 

sediments are mostly volcanic tuff, freshwater limestone, and clay, and they can be 300 to 

2,000 feet thick (Marine and Price, 1964). 

Soil borings completed during the SI found various mixtures of silt, clay, and sand deposits as the 

dominant lithology of the unconsolidated sediments below the E.J. Garn Aviation Complex. The 

borings were completed at depths between 40 and 70 feet below ground surface (bgs). Many of 

the logs also reported varying percentages of gravel included in the sand packages. Samples for 

grain size analyses were collected at two locations where monitoring wells were installed, EJGMW006 and EJG-MW005, and analyzed via American Society for Testing and Materials (ATSM) 

Method D-422. The results indicated that the soil samples are comprised primarily of silt (59.05% 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 2-2

to 61.78%) and clay (21.27% to 29.17%). These facility observations are consistent with the 

understood alluvial or lacustrine depositional environment. Boring logs are presented in 

Appendix E, and grain size results are presented in Appendix F. 

2.2.2 Hydrogeology

The complex pattern of sediment deposition in the Jordan Valley resulted in a widely-varying 

groundwater reservoir. Specific aquifers are generally not distinguishable over large areas, and 

they are underlain, overlain, and graded into beds with lesser permeability. The Jordan Valley has 

been divided into six groundwater districts based on geology and hydrology. The facility is in the 

West Slope District, within the North Pediment subdistrict (Marine and Price, 1964). 

In the North Pediment subdistrict, groundwater wells obtain water that is perched on the relatively 

impermeable beds of the Jordan Narrows Unit. Most of the ground water in the subdistrict is 

confined in the Jordan Narrows unit or in the overlying Pleistocene or late Tertiary gravel. Shallow 

wells screened in gravel layers, especially those in the lower part of the subdistrict near the facility, 

appear to be under artesian pressure and flow at the land surface. Deep wells (deeper than 

150 feet) set within the Jordan Narrows unit may be under artesian pressure, however, they 

generally do not flow to the land surface. Much of the recharge to the gravel beds comes from 

irrigation water obtained from surface sources (Marine and Price, 1964).

According to Marine and Price, groundwater in the North Pediment subdistrict generally moves 

toward the northeast. Based on the topography and water bodies in the vicinity of the facility, it is 

assumed groundwater moves from west to east, towards the Jordan River. 

Drinking water is supplied at the E.J. Garn Aviation Complex by the local municipal water authority. 

However, a number of groundwater wells exist in the vicinity of the facility. An Environmental Data 

Resources, Inc. (EDR)TM report conducted a well search for a 1-mile radius surrounding the facility

(EDRTM, 2019). Additional online resources, such as state and local geographic information 

systems databases, were utilized to research wells within a 4-mile radius of the facility. The Utah 

Division of Water Rights (UDWR) interactive map was reviewed to determine the status of many 

water rights. The information from UDWR and EDR indicates approximately 500 wells within a 4-

mile radius of the facility, 302 of which are potentially down or cross-gradient of the facility. Of the 

wells within a 4-mile radius, 1 is domestic, 2 are municipal, 45 are monitoring, and the remaining 

are other/unknown use. Active wells located down or cross-gradient to the facility are described 

below and in Figure 2-3. 

• Water Right 59-2123 is an active point of diversion located approximately 1,750 feet 

southeast and cross-gradient of the facility. The well is used for stock water, with a 

beneficial use amount of 400 Equivalent Livestock Units (ELUs). 

• Water Rights 59-1615 and 59-5157 are tied to an active point of diversion located 

approximately 2,400 feet south and cross-gradient of the facility. The well (also known as 

Steadman Well), when active, is used for municipal water for the City of West Jordan, 

limited to the use of 750 families. The well was finished to a depth of 400 feet bgs. 

• Water Right 59-2122 is an active point of diversion water well located approximately 2,700 

feet southeast and cross-gradient of the facility. The well is used for the domestic water 

supply for a single family. 

• Water Right 59-2733 is an active point of diversion located approximately 3,800 feet east 

and downgradient of the facility. The well is used for stock water, with a beneficial use 

amount of 50 ELUs to be used for 45 cattle and 5 horses. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 2-3

During the site visit, it was reported that a groundwater well serving the City of West Jordan was 

located approximately 1,300 feet east and downgradient of the facility, near the water tanks, 

identified as Water Right 59-2024 in the EDRTM. According to the UDWR, this well was formerly 

used for stock water since 1886; however, in 1976, the water right (59-2024) was disallowed, and 

the well was abandoned (UDWR, 2019). According to the facility Utilities Manager, none of the 

wells within the area supply municipal water for West Jordan. The adjacent tanks are supplied by 

piped water from the Jordan Valley Water Conservancy District. Twenty percent of Jordan Valley 

Water’s supply is groundwater, pumped from wells scattered around the Salt Lake Valley (Jordan 

Valley Water Conservancy District [JVWCD], 2022). 

Based on a review of well logs for supply wells located in the vicinity of E.J. Garn Aviation 

Complex, perched water-bearing lenses have been observed above the regional aquifer. Several 

well logs recorded water as shallow as 40-60 feet bgs and were capable of pumping at least 

2 gallons per minute (UDWR, 2019). It is likely these lenses are not continuous across the area 

and are highly influenced by seasonal changes in precipitation. 

Three federal United States Geological Survey (USGS) monitoring wells were identified within 

1 mile of the facility. The wells are inactive; however, according to the most recent groundwater 

levels measured in each well, groundwater in the area ranges from approximately 28 feet bgs to 

68 feet bgs (UDWR, 2019). Several off-facility municipal, domestic, and stock water wells have 

been identified in the vicinity of the facility. Groundwater features are presented on Figure 2-3. 

Depths to water measured in November 2021 during the SI ranged from 26.61 to 60.16 feet bgs. 

Groundwater elevation contours from the SI are presented on Figure 2-4 and indicate 

groundwater flow direction is generally to the east. 

2.2.3 Hydrology 

Based on a desktop review of the National Wetlands Inventory online mapping system (US Fish 

and Wildlife Service [USFWS], 2021), the facility does not contain any mapped wetlands or 

surface waters, although the southern portion is located within the 100-year flood zone. 

Topographic maps depict a portion of Barney’s Creek on the west and south borders of the 

property. The creek follows the location of a historic irrigation system/stormwater discharge canal 

described by the ARNG Environmental Manager, which was reportedly dry 90% of the time and 

filled in circa 2013/2014. No surface water was observed during the site visit. 

Surface water runoff generally drains from west to east, with certain drainage areas draining north 

to south (Kleinfelder, 2018). There is a series of unlined catch basins along the east side of the 

facility, between the airfield and the runways. The catch basins also receive snow plowed from 

the Hangar/Ramp Area in the winter. 

The facility sits within the Jordan River and Utah Lake Watershed Management Unit. According 

to the Industrial Stormwater Pollution Prevention Plan for the facility, stormwater from the facility

enters Barney’s Creek along the southerly perimeter. The creek was observed to be dry during 

the site visit. Barney’s Creek discharges into a large detention pond/sedimentation basin to the 

east, where stormwater velocity is slowed, particulates are allowed to settle, and water is 

discharged through a restricted outfall. Ultimately, the stormwater runoff from the facility 

discharges to the Jordan River, which flows in a north to south direction to Utah Lake (Kleinfelder, 

2018). Surface water features are presented on Figure 2-5.

2.2.4 Climate 

The E.J. Garn Aviation Complex is located in a semi-arid, temperate climate zone with four distinct 

seasons. West Jordan receives some precipitation, on average, 88 days per year. The average 

annual precipitation is 15.52 inches. Summer temperatures peak in July, with an average high of 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 2-4

94 degrees Fahrenheit (°F) and an average low of 68°F. Winter temperatures are lowest in 

January with an average high of 39°F and an average low of 24°F. With the exception of two 

months of westerly winds in the spring, prevailing winds are southerly for the majority of the year 

(National Oceanic and Atmospheric Administration [NOAA], 2022). 

2.2.5 Current and Future Land Use

The E.J. Garn Aviation Complex serves as a Utah ARNG (UTARNG) base of operations for 

military helicopter maintenance and support. The Armory consists of an office building, a garage 

dedicated to light vehicle maintenance, and parking areas. The AASF is comprised of a hangar, 

maintenance and storage areas, operations and administrative buildings, and related 

infrastructure including parking lots, aircraft parking areas, and refueling pads. 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 

A wildlife survey has not occurred at the facility, and the facility does not have any significant areas 

of habitat. The following species have not been identified at the facility but may be present in the 

surrounding area. 

The following insects, mammals, fishes, plants, and birds are federally endangered, threatened, 

proposed, and/ or are listed as candidate species in Salt Lake County, Utah (USFWS, 2022). 

• Insects: Monarch butterfly, Danaus plexippus (candidate)

• Mammals: Little brown bat, Myotis lucifugus (under review); Canada Lynx, lynx canadensis 

(threatened)

• Fishes: Least chub, Iotichthys phlegethontis (resolved taxon)

• Flowering plants: Ute ladies'-tresses, Spiranthes diluvialis (threatened)

• Birds: Yellow-billed Cuckoo, Coccyzus americanus (threatened); Greater sage-grouse, 

Centrocercus urophasianus (resolved taxon)

2.3 History of PFAS Use

A total of 11 potential release areas were identified and grouped into three AOIs at the E.J. Garn 

Aviation Complex during the PA where AFFF may have been used or released historically 

(AECOM, 2020). PFAS-containing materials were potentially released to soil and groundwater 

within the boundary of the E.J. Garn Aviation Complex through fire training exercises, fire 

suppression system testing, and emergency response with confirmed discharges of AFFF to the 

ground surface across the Hangar/Ramp Area. Three AOIs were identified based on preliminary 

data and assumed groundwater flow directions. A description of the AOIs is presented in Section 

3. 
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AG

8/2/2022

8/2/2022

PROJECT Site Inspection at E.J. Garn Aviation Complex, UT

1:63,360

8/2/2022 ­ Figure 2-1 PM CM 8/2/2022

12420 Milestone Center Drive

Germantown, MD 20876

Facility Location

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

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

^_

0 0.5 1 2

Miles

Legend

Facility Boundary

E.J. Garn Aviation Complex

AECOM 2-5
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AG

8/2/2022

8/2/2022

PROJECT Site Inspection at E.J. Garn Aviation Complex, UT

1:6,000

8/2/2022 ­ Figure 2-2 PM CM 8/2/2022

12420 Milestone Center Drive

Germantown, MD 20876

Facility Topography

Base Map: USGS The National Map: National

Boundaries Dataset, 3DEP Elevation Program,

Legend

Facility Boundary

AECOM 2-6
A!

A!AA!!

A!

A!

A!

A!

!

A!

A!

A!

A!

A!

A!

AA!!

AAA!!A!!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

AA!! A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

AA!!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A! A!

A!

A!A!

A! A!

A!

A!

A!

A!

A!

A!

A!

AAA!!!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!A!

A! A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!A!A!!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A! A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

AA!!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A! A!A!

A!

A!

A!

A! A!A!

A!

A!

A!

A!

A!

A!A!

A!

A!

A!

A!

A! !C( !C(

A!

!5

A! A! A!

A!

!5

!5 !P A!

A!

A!

59-1615 ; 59-5157

59-2122

59-2733

59-2123

Dry Cree k

Barneys Creek

Bingham Creek

Bingham Creek

Coo n Creek

Bing ham Creek

Jordan River Brighton Canal

Utah

Lake

DistributingCa n al

North

Jo rdan Canal

Provo

Reser voi r Canal

Utah and Salt Lake Canal

Barneys Wash

South Jordan

Canal

UtahLake Distributing Canal

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AD

8/2/2022

8/2/2022

PROJECT Site Inspection for E.J. Garn Aviation Complex, UT

1:95,040

8/2/2022 ­ Figure 2-3 PM CM 8/2/2022

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Features

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

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

Facility Boundary

Water Body

Wetland

River/Stream

Canal/Ditch

Pipeline

Groundwater Flow Direction

Inferred Groundwater Flow Direction

Geology

Quaternary; clay or sand

Quaternary; alluvium

Quaternary; older alluvium

Well

!P Domestic

!5 Irrigation/Stockwatering

!C( Municipal

A! Other/Unknown

A! Monitoring

0 0.75 1.5 3

Miles

A!

AECOM 2-7
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AD

10/20/2022

10/20/2022

PROJECT Site Inspection at E.J. Garn Aviation Complex, UT

10/20/2022

Figure 2-4 PM CM 10/20/2022

12420 Milestone Center Drive

Germantown, MD 20876

Groundwater Elevations, 

November 2021

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

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

?!

?!

?!

?!

?!

?!

?!

EJG-MW001

4578.91

EJG-MW002

4549.19

EJG-MW003

4570.24

EJG-MW004

4597.94

EJG-MW007

4579.21

EJG-MW006

4590.16

EJG-MW005

4593.35

4550

4550

4560

4560

4570

4580

4570

4590

4580 4590

4600

4600

0 165 330 660

Feet

Legend

?! Soil Boring/Permanent Monitoring Well

Facility Boundary

Groundwater Contour

Inferred Groundwater Contour

Groundwater Flow Direction

Inferred Groundwater Flow Direction

1:3,960 ­

Groundwater elevations in ft NAVD88.

AECOM 2-8
Sedimentation

Basin

Barneys Creek

Provo

Reservoir Canal

Barneys Wash

Utah Lake Distributing Canal

Utah

Lake

Distributing

Canal

Bingham Creek

Watershed

Headwaters

Barneys Creek

Watershed

Barneys

Creek-Jordan

River Watershed

CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AD

8/2/2022

8/2/2022

PROJECT Site Inspection at E.J. Garn Aviation Complex, UT

1:24,000

8/2/2022 ­ Figure 2-5 PM CM 8/2/2022

12420 Milestone Center Drive

Germantown, MD 20876

Surface Water Features

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

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

Legend

Facility Boundary

100 Year Flood Zone

Water Body

River/Stream

Canal/Ditch

Surface Water Flow Direction

0 1,000 2,000 4,000

Feet

AECOM 2-9
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 2-10

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 3-1

3. Summary of Areas of Interest

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

disposed, or released historically. Based on the PA findings, 11 potential release areas were 

identified at E.J. Garn Aviation Complex and grouped into three AOIs (AECOM, 2019; 2021a). 

The potential release areas are shown on Figure 3-1. This figure also shows nearby off-facility 

potential releases for informational purposes.

3.1 AOI 1 North Hangar

AOI 1 comprises the area to the east and southeast of the North Hangar (Building 00001), 

including four potential releases at the firetruck bay/foam storage area and the wash down area. 

Potential releases consist of the North Hangar fire suppression system (no known releases); 

firetruck washing in the fire truck bay; oil/water separator and sanitary sewer drains within the 

hangar; and the former dry well east of the hangar.

The North Hangar is an approximately 52,000 square foot building. The hangar had a fire 

suppression system; however, during AECOM’s site visit, it was under construction, and the 

facility personnel stated that no known releases have occurred. 

A firetruck bay that housed an AFFF-capable firetruck was historically located in the southeast 

corner of the North Hangar. The firetruck was washed in the firetruck bay, or to an area to the 

south of the firetruck bay. Potential discharges of AFFF in the wash down area for an unknown 

time period may have resulted in a release to the ground surface and subsequently to the catch 

basins to the east of the building. 

Drains in the North Hangar currently discharge to the oil/water separator to the east, and then to 

the municipal sanitary sewer system serviced by the City of West Jordan (SVW, 2019). However, 

it is not clear that the drains have always been connected to the sanitary sewer. According to 

UTARNG staff, drains from a different section of the North Hangar were discovered to be 

connected to a dry well to the northeast of the building. It is unknown if a similar pathway ever 

existed for the piping in the firetruck bay. Therefore, potential discharges of AFFF in the firetruck 

bay could have released AFFF to the dry well for an unknown time period prior to 2009.

3.2 AOI 2 Hangar/Ramp Area

AOI 2 comprises the Hangar/Ramp Area east of the South Hangar (Building 00002) and Cold 

Storage building (Building 00004), including six potential releases from the South Hangar, Cold 

Storage Building, and the Tri-Max Fire Area. Potential releases include the South Hangar (Building 

00002) fire suppression system tests from 1991 to 2016; Cold Storage Building (Building 00004) 

fire suppression system tests from 1991 to 2016; a Tri-MaxTM 30-gallon unit discharged in 1998; 

fire training activities from 1995 to 1999; emergency response activities using AFFF dating back 

to 1989; and the storage of 5-gallon 3% AFFF containers in Tent Storage (Building 00010), which 

was formerly located east of its current location. 

The South Hangar is an approximately 52,000 square feet building. The Cold Storage Building is 

an approximately 31,025 square feet building located on the western installation boundary. These 

buildings are equipped with AFFF fire suppression systems. Releases of the fire suppression 

systems in both buildings from approximately 1991 to 2016 resulted in AFFF being pushed onto 

the Hangar/Ramp Area concrete and left in place to evaporate or disperse with the wind. In 

addition, fire training activities were conducted around the Hangar/Ramp Area from at least 1995 

to 1999, and emergency responses using foam may have occurred on the same area since 1989. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 3-2

The Tent Storage area (Building 00010) is also located within AOI 2. According to the PA Report, 

3% AFFF was stored as concentrate in 5-gallon containers within tent storage (which was formerly 

located east of its current location) from at least 1989 to 2009; however, no releases were known 

to have occurred (AECOM, 2019). 

3.3 AOI 3 Armory Dumpster Fire

AOI 3 is located directly west of Building 00003 and comprises one potential release area from a 

former dumpster fire. According to the Safety Non-Commissioned Officer/Hazardous Materials 

(NCO/HAZMAT) Training Manager, the dumpster fire occurred at the Armory in 1997, which he 

extinguished with an AFFF mobile unit. It is unknown how many gallons were discharged. The 

dumpster was located on asphalt, with a grassy area directly to the north of the dumpster. The 

surface drainage in the vicinity of AOI 3 was designed to flow south into a catch basin. 

3.4 Adjacent Sources

Several potential off-facility sources of PFAS adjacent to the E.J. Garn Aviation Complex were 

identified during the PA. A description of each adjacent source is presented below, and the 

adjacent sources are shown on Figure 3-1. 

3.4.1 Emergency Response Area

Many air crashes have occurred on the runway; however, only one incident is known to have been 

handled by the AASF emergency services. In 1989 a civilian plane crashed on the runway east 

of the AASF and west of the city water supply. The crash included a fire suppressed by the AASF 

emergency services. It is presumed they used a fire truck equipped with 3% AFFF, although the 

quantity used is unknown (AECOM, 2019). 

3.4.2 Private Aviation Companies at South Valley Regional Airport 

The South Valley Regional Airport (U42) Fixed Base Operator (FBO) is located north of the West 

Jordan AASF and shares the adjacent runway. The airport is located at 7799 Airport Rd, West 

Jordan, UT 84084. The FBO currently supports business-related flying, law 

enforcement/fire/rescue flying services, recreational flying, flight training, and air charters. Flight 

training is conducted by Randon Aviation and Utah Helicopter, both located at 7220 S 4450 W, 

West Jordan, UT 84084. Two additional aviation companies are reportedly located at 7365 South 

Airport Drive, West Jordan, UT 84084. The exact location of these facilities within the South Valley 

Regional Airport could not be determined (AECOM, 2019). 

The use or storage of AFFF at the airport facilities could not be determined during the PA; 

however, none of the facilities have their own emergency services and are under the municipal 

emergency services. The municipal fire department is located approximately 0.5 miles east of the 

facility at 7602 Jordan Landing Blvd, West Jordan, UT 84084.
A!

A!

A!

A!

A!

A!

!5

!P !5

A!

A!

A!

AOI 2

AOI 1

AOI 3

1989 Civilian Crash

Runways

Sedimentation

Basin

Barneys

Creek-Jordan

River Watershed

Barneys Creek

Utah

Lake

Distributing

Canal

0 500 1,000 2,000

Feet

A!

Fire Training Area/Emergency Response

1997 Dumpster Fire

Dry Well

Building 00002

Building 00004

Tri-Max Training/CFR Nozzle Testing Area 

Catch Basins

Fire Truck Bay/Foam Storage

Wash Down Area

Former Building 00010

Foam Storage Area

Building 00001

Current Building 00010

Barneys

Creek-Jordan

River Watershed

AOI

2

AOI 1

AOI 3

­ Figure 3-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

9/20/2022

9/20/2022

9/20/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

9/20/2022

Area of Interest

12420 Milestone Center Drive

Germantown, MD 20876

Area of Interest

Potential Release Area

Facility Boundary

Water Body

River/Stream

Canal/Ditch

Surface Water Flow Direction

Groundwater Flow Direction

Inferred Groundwater Flow Direction

!P Domestic

!5 Irrigation/Stockwatering

!C( Municipal

A! Other/Unknown

0 150 300 600

Feet

1:12,000

AECOM 3-3
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 3-4

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 4-1

4. Project Data Quality Objectives

As identified during the Data Quality Objective (DQO) process and outlined in the SI Quality 

Assurance Project Plan (QAPP) Addendum (AECOM, 2021a), the objective of the SI is to identify 

whether there has been a release to the environment at the AOIs identified in the PA. For each 

AOI, ARNG determines if further investigation is warranted, a removal action is required to 

address immediate threats, or whether no further action is warranted. This SI evaluated 

groundwater and soil for presence or absence of relevant compounds at each of the sampled 

AOIs.

4.1 Problem Statement

ARNG will recommend an AOI for Remedial Investigation (RI) if related soil and groundwater 

samples have concentrations of the relevant compounds above the OSD risk-based SLs. The 

SLs are presented in Section 6.1 of this report. 

4.2 Information Inputs

Primary information inputs included:

• The PA for E.J. Garn Aviation Complex (AECOM, 2019);

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

with the site-specific Uniform Federal Policy (UFP)-QAPP Addendum (AECOM, 2021a); and

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

parameters measured at the time of sampling. 

4.3 Study Boundaries

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

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

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

owner(s). The SI scope was bounded vertically by the observed depths of the surficial groundwater 

table. Temporal boundaries of the study were limited to the Fall to avoid winter storms and freezing 

conditions. 

4.4 Analytical Approach

Samples were analyzed by Pace Analytical Gulf Coast, accredited under the Department of 

Defense (DoD) Environmental Laboratory Accreditation Program (ELAP; Accreditation Number 

74960) and the National Environmental Laboratory Accreditation Program (NELAP; Certificate

Number 01955). Data were compared to applicable SLs within this document and decision rules 

as defined in the SI QAPP Addendum (AECOM, 2021a). 

4.5 Data Usability Assessment

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

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

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

methods, the assessment determines whether project execution and the resulting data have met 

installation-specific DQOs. Both sampling and analytical activities are considered to assess 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 4-2

whether the collected data are of the right type, quality, and quantity to support the decisionmaking (DoD, 2019a; DoD, 2019b; USEPA, 2017). 

Based on the DUA, the environmental data collected during the SI were found to be acceptable 

and usable for this SI evaluation with the qualifications documented in the DUA and its associated 

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

requirements of the SI QAPP Addendum (AECOM, 2021a). 

 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-1

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 Site Inspection Programmatic Uniform Federal Policy-Quality Assurance Project Plan 

(PQAPP) dated March 2018 (AECOM, 2018a);

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

• Final Preliminary Assessment Report, E.J. Garn Aviation Complex, West Jordan, Utah 

dated December 2019 (AECOM, 2019);

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

E.J. Garn Aviation Complex, West Jordan, Utah, dated June 2021 (AECOM, 2021a); and

• Final Site Safety and Health Plan, E.J. Garn Aviation Complex, West Jordan, Utah dated 

October 2021 (AECOM, 2021b).

The SI field activities were conducted from 25 October to 10 November 2021 and consisted of utility 

clearance, hollow stem auger (HSA) drilling, rotary sonic drilling, soil sample collection, permanent 

monitoring well installation, grab groundwater sample collection, and land surveying. Field activities 

were conducted in accordance with the SI QAPP Addendum (AECOM, 2021a), except as noted in 

Section 5.10. 

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

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

Systems Manual (QSM) 5.3 Table B-15 to fulfill the project DQOs:

• Twenty-five (25) soil samples from ten (10) boring locations; 

• Seven (7) grab groundwater samples from seven (7) permanent wells; and

• Twenty-one (21) quality assurance (QA) samples.

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

list of samples collected for each 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. Sampling forms are provided in Appendix B2, Field Change Request Forms 

are provided in Appendix B3, Nonconformance and Corrective Action Reports are provided in 

Appendix B4, land survey data are provided in Appendix B5, and investigation-derived waste 

(IDW) polygons are provided in Appendix B6. 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 US Army Corps of Engineers (USACE) TPP Process, Engineer Manual (EM) 200-1-2 

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

determining data needs; 3.) developing data collection strategies; and 4.) finalizing the data 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-2

collection plan. The process encourages stakeholder involvement in the SI, beginning with 

defining overall project objectives, including DQOs, and formulating a sampling approach to 

address the AOIs identified in the PA. 

A combined TPP Meeting 1 and 2 was held on 22 December 2020, prior to SI field activities. The 

meeting was conducted in general accordance with Engineering Manual (EM) 200-1-2. The 

stakeholders for this SI include the ARNG, UTARNG, USACE, Utah Department of Environmental 

Quality (UDEQ), and representatives familiar with the facility and the regulations. 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, 2021a). 

A TPP Meeting 3 was held on 27 July 2023 after the field event to discuss the results of the SI.

Meeting minutes for TPP 3 are included in Appendix D of this report. Future TPP meetings will 

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

5.1.2 Utility Clearance 

AECOM’s drilling subcontractor, Cascade Technical Services, LLC placed a ticket with the Blue 

Stakes of Utah 811 utility clearance provider to notify them of intrusive work on 19 October 2021. 

AECOM also contracted ESI Engineering, Inc., a private utility location service, who performed 

utility clearance of the proposed boring locations on 13 October 2021 with input from the AECOM 

field team and E.J. Garn Aviation Complex facility staff. General locating services and groundpenetrating radar 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 Sampling Equipment Acceptability

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

acceptable for use in a PFAS investigation prior to the start of field activities. A sample from a 

potable water source at E.J. Garn Aviation Complex was collected on 12 May 2021, prior to 

mobilization, and analyzed for PFAS by LC/MS/MS compliant with QSM 5.3 Table B-15. The 

results of the decontamination water sample are provided in Appendix F. A discussion of the 

results is presented in the DUA (Appendix A).

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

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

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

(AECOM, 2021a). Prior to the start of field work each day, a 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 HSA rig at AOI01-01, EJG-MW006, and EJG-MW001, in 

accordance with the SI QAPP Addendum (AECOM, 2021a). Due to heaving sands in 

EJG-MW001, the HSA rig was replaced with a sonic drill rig for the installation of EJG-MW001 

and the remaining boring locations (EJG-MW002 to EJG-MW005 and EJG-MW007); the field 

change request is provided in Appendix B3. A hand auger was used to collect soil from the top 

5 feet of each boring, in accordance with AECOM utility clearance procedures. A hand auger was 

also used for the two surface soil sample locations (AOI03-01 and AOI03-02) in accordance the 

QAPP Addendum (AECOM, 2021a). The soil boring locations are shown on Figure 5-1, and 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-3

sample depths are provided in Table 5-1. The soil boring depths are provided in Table 5-2 and 

Table 5-3. 

In general, three discrete soil samples were collected from the vadose zone for chemical analysis 

from each soil boring: one surface soil sample (0 to 2 feet bgs), one subsurface soil sample 

approximately 2 feet above the groundwater table, and one subsurface soil sample at the midpoint between the surface and the groundwater table. At AOI01-01, only two soil samples were 

collected, and only one sample was collected at AOI03-01 and AOI03-02, in accordance with the 

QAPP Addendum (AECOM, 2021a). 

The soil cores were continuously logged for lithological descriptions by an AECOM 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 boring logs (Appendix E) and in a nontreated 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. 

Soil borings completed during the SI found various mixtures of silt, clay, and sand deposits as the 

dominant lithology of the unconsolidated sediments below the E.J. Garn Aviation Complex. The 

borings were completed at depths between 40 and 70 feet bgs. Many of the logs also reported 

varying percentages of gravel included in the sand packages. These facility observations are 

consistent with the understood alluvial or lacustrine depositional environment. 

Each soil 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 by LC/MS/MS compliant with QSM 5.3 Table B-15, total organic 

carbon (TOC) (USEPA Method 9060A), and pH (USEPA Method 9045D) in accordance with the 

SI QAPP Addendum (AECOM, 2021a).

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

as the accompanying samples. Matrix spike (MS)/MS duplicate (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 shallow soil samples, 

equipment rinsate blanks should have been collected at a rate of 5% and analyzed for the same 

parameters as the soil samples. However, collection of this blank for the hand auger was 

accidently missed and is discussed in Section 5.8 below. A temperature blank was placed in each 

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

The laboratory received one of the coolers above the method temperature requirement for 

preservation, as described in Section 5.8 below. 

The seven borings deeper than 8 feet (EJG-MW001 to EJG-MW007) were converted to 

permanent wells. All but two of the borings were installed in grass areas to avoid disturbing 

concrete or asphalt surfaces. 

5.3 Permanent Well Installation and Groundwater Sampling

During the SI, seven permanent monitoring wells (EJG-MW001 to EJG-MW007) were installed 

within or downgradient of potential source areas. The locations of the wells are shown on Figure 

5-1. 

An HSA drill rig system was used at EJG-MW006, and a sonic drill rig system was used at the 

remaining six wells (EJG-MW001 through EJG-MW005 and MW007) to install the seven 2-inch 

diameter monitoring wells. Water was not added during the drilling of the wells. The monitoring 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-4

wells were constructed with Schedule 40 PVC, flush threaded 10-foot sections of riser, 0.010-inch 

slotted well screen, and a threaded bottom cap. A filter pack of 20/40 silica sand was installed in 

the annulus around the well screen to a minimum of 2-foot above the well screen. A 2-foot-thick 

bentonite seal was placed above the filter sand and hydrated with water. Bentonite grout was 

placed in the well annulus from the top of the bentonite seal to ground surface. The bentonite 

grout was allowed to set for 24 hours prior to well completion in accordance with the SI QAPP 

Addendum (AECOM, 2021a). All monitoring wells were completed with flush mount well vaults. 

The screen interval of each of the groundwater monitoring wells is provided in Table 5-3. 

Development and sampling of wells was completed in accordance with the SI QAPP Addendum 

(AECOM, 2021a). The newly installed monitoring wells were developed no sooner than 24 hours 

following installation by pumping and surging using a variable speed submersible pump. Samples 

were collected no sooner than 24 hours following development via low-flow sampling methods 

using a QED Sample Pro® bladder pump with disposable PFAS-free, HDPE tubing. New tubing 

was used at each well and the pumps were decontaminated between each well. The wells were 

purged at a rate determined in the field to reduce draw down prior to sampling. Water quality 

parameters (e.g., temperature, specific conductance, pH, dissolved oxygen, and oxidationreduction potential) were measured using a water quality meter and recorded on the field 

sampling form (Appendix B2). Water levels were measured to the nearest 0.01 inch and 

recorded. 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 by LC/MS/MS compliant with QSM 5.3 

Table B-15 in accordance with the SI QAPP Addendum (AECOM, 2021a).

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

as the accompanying samples. Matrix spike (MS)/MS duplicates (MSDs) were collected at a rate 

of 5% and analyzed for the same parameters as the accompanying samples. One field reagent 

blank was collected in accordance with the Programmatic UFP-QAPP (PQAPP) (AECOM, 

2018a). A temperature blank was placed in each cooler to ensure that samples were preserved 

at or below 6°C during shipment.

5.4 Synoptic Water Level Measurements

A synoptic groundwater gauging event was performed on 15 November 2021. Groundwater 

elevation measurements were collected from the seven new permanent monitoring wells. Water 

level measurements were taken from the northern side of the well casing. Groundwater was 

observed ranging between 26.61 to 60.16 feet bgs, with groundwater elevations ranging between 

4,549.19 to 4,597.94 feet North American Vertical Datum 1988 (NAVD88). Based on the 

groundwater elevations observed during the synoptic groundwater gauging event, the 

groundwater appears to flow predominantly to the east. A groundwater flow contour map is 

provided in Figure 2-4. Groundwater elevation data is provided in Table 5-3. 

5.5 Surveying

The northern side of each well casing was surveyed by Utah-licensed land surveyors following 

guidelines provided in the SOPs provided in the SI QAPP Addendum (AECOM, 2021a). Survey 

data from the newly installed wells on the facility were collected on 10 November 2021, and 

ground surface elevation data were collected on 06 December 20221. Survey data was collected 

in the applicable Universal Transverse Mercator zone projection with World Geodetic System 84 

datum (horizontal) and NAVD88 (vertical). The surveyed well data are provided in Appendix B5. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-5

5.6 Investigation-Derived Waste

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

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

Addendum (AECOM, 2021a) and with the DAGuidance for Addressing Releases of PFAS, Q18 (DA, 

2018). Consistent with the SI QAPP, soil cuttings and liquid IDW were distributed or discharged 

to the ground surface on the immediate downgradient side of the borehole, except where noted 

otherwise below.

EJG-MW001, EJG-MW002, EJG-MW004, EJG-MW005, and EJG-MW006 were located in paved 

or high-profile areas, and therefore IDW (i.e., soil cuttings) generated during the SI activities at

those locations was containerized in ten 55-gallon drums and placed in the drum staging area as 

indicated in the Photographic Log (Appendix C). The drums were labeled to indicate the type of 

media (i.e., soil or water) and the source location. Soil cuttings at all other locations 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 assumes the PFAS 

characteristics of the associated soil samples collected from that source location. Based on 

laboratory results, containerized soil cuttings will be managed and disposed by ARNG, either by 

offsite disposal or, where PFAS concentrations are below the Industrial/Commercial Composite 

Worker OSD SLs, ARNG will distribute the soil on the downgradient side of the associated 

borehole.

Due to the surrounding pavement, liquid IDW generated during SI activities (i.e., purge water, 

development water, and decontamination fluids) at EJG-MW005 and EJG-MW006 was 

containerized in five 55-gallon drums and placed in the drum staging area as indicated in the 

Photographic Log (Appendix C). The drums were labeled to indicate the type of media (i.e., soil 

or water) and the source location. Liquid IDW at all other locations was discharged directly to the 

ground surface slightly downgradient of the source. The liquid IDW was not sampled and assumes 

the PFAS characteristics of the associated groundwater samples collected from that source 

location. Based on laboratory results, containerized liquid IDW will be managed and disposed by 

ARNG under a separate contract for Treating Liquid Investigation-Derived Material (purge water, 

drilling water, and decontamination fluids) (EA Engineering, Science, and Technology, Inc., 2021).

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 B6. 

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.

5.7 Laboratory Analytical Methods

Samples were analyzed by LC/MS/MS compliant with QSM 5.3 Table B-15 at Pace Analytical Gulf 

Coast in Baton Rouge, Louisiana, a DoD ELAP and NELAP certified laboratory. Soil samples 

were also analyzed for TOC using USEPA Method 9060A and pH by USEPA Method 9045D. 

5.8 Deviations from SI QAPP Addendum

Two deviations from the SI QAPP Addendum were identified during review of the field 

documentation. The deviation is noted below and is documented in Field Change Request Forms 

(Appendix B3) and Nonconformance and Corrective Action Reports (Appendix B4): 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-6

• The QAPP Addendum specified a hollow stem auger drill rig to install the soil borings and 

monitoring wells. An HSA truck mounted drill rig was used on AOI01-01, EJG-MW006, and 

EJG-MW001 during the first four days of field work. Heaving sands were encountered in 

EJG-MW001 and prevented the setting of the monitoring well. A sonic drill rig was mobilized 

to the site on 1 November 2021 and utilized for the remaining borings. This action was 

documented in a Field Change Request Form provided in Appendix B3. 

• Although all preservation techniques were followed by the field staff, a four-day delay by 

FedEx resulted in one of the coolers arriving at the laboratory above the QAPP-designated 

temperature of 6 oC. The affected samples were in Sample Delivery Group (SDG)

SDG22110162 and include soil samples EJG-MW006-SB-33-35, EJG-MW001-SB-13-15, 

EJG-MW001-SB-34-36, and QC sample EJG-PLUG-01. The field samples in 

SDG22110162 were received at 19.8 degrees oC; however, the field samples were analyzed 

within the recommended holding time, so the associated field sample results were qualified 

as estimate. All technical and analytical holding times were met by the laboratory with minor 

exceptions. The technical holding time for pH analysis is considered ‘immediate’, so all pH 

sample results have been qualified as estimate. This action was documented in a 

nonconformance and corrective action report provided in Appendix B4. 
Table 5-1

Site Inspection Samples by Medium

Site Inspection Report, EJ Garn Aviation Complex, Utah

Sample Identification

Sample

Collection 

Date/Time

Sample Depth 

(feet bgs) LC/MS/MS compliant with QSM 5.3 Table B-15 TOC (USEPA Method 9060A) pH (USEPA Method 9045D) Grain Size (ASTM D-422) Comments

EJG-MW007-SB-27-29 11/8/2021 13:30 37 -39 x

AOI01-01-SB-00-02 10/26/2021 8:40 0 - 2 x

AOI01-01-SB-06-08 10/26/2021 9:50 6 - 8 x

AOI03-01-SB-00-02 10/25/2021 11:50 0 - 2 x

AOI03-02-SB-00-02 10/25/2021 12:30 0 - 2 x

EJG-MW001-SB-00-02 10/26/2021 10:25 0 - 2 x

EJG-MW001-SB-00-02-D 10/26/2021 10:25 0 - 2 x FD

EJG-MW001-SB-00-02-MS 10/26/2021 10:25 0 - 2 x MS/MSD

EJG-MW001-SB-00-02-MSD 10/26/2021 10:25 0 - 2 x MS/MSD

EJG-MW001-SB-13-15 10/28/2021 8:40 13 - 15 x x x

EJG-MW001-SB-34-36 10/28/2021 10:30 34 - 36 x

EJG-MW002-SB-00-02 10/26/2021 12:30 0 - 2 x

EJG-MW002-SB-13-15 11/2/2021 15:15 13 - 15 x

EJG-MW002-SB-59-61 11/4/2021 10:30 59 - 61 x

EJG-MW003-SB-00-02 10/26/2021 11:45 0 - 2 x

EJG-MW003-SB-13-15 11/4/2021 15:20 13 - 15 x

EJG-MW003-SB-35-37 11/9/2021 10:00 35 - 37 x

EJG-MW004-SB-00-02 10/25/2021 10:30 0 - 2 x

EJG-MW004-SB-13-15 11/9/2021 15:00 13 - 15 x x x

EJG-MW004-SB-13-15-D 11/9/2021 15:00 13 - 15 x x x FD

EJG-MW004-SB-13-15-MS 11/9/2021 15:00 13 - 15 x x x MS/MSD

EJG-MW004-SB-13-15-MSD 11/9/2021 15:00 13 - 15 x x x MS/MSD

EJG-MW004-SB-39-41 11/9/2021 16:00 39 - 41 x x

EJG-MW005-SB-00-02 11/1/2021 15:30 0 - 2 x

EJG-MW005-SB-13-15 11/1/2021 16:10 13 - 15 x x

EJG-MW005-SB-25-27 11/1/2021 16:30 25 - 27 x

EJG-MW006-SB-00-02 10/26/2021 14:15 0 - 2 x

EJG-MW006-SB-00-02-D 10/26/2021 14:15 0 - 2 x FD

EJG-MW006-SB-13-15 10/26/2021 14:55 13 - 15 x x x

EJG-MW006-SB-33-35 10/26/2021 16:00 33 - 35 x x

EJG-MW007-SB-00-02 10/26/2021 9:30 0 - 2 x

EJG-MW007-SB-13-15 11/9/2021 12:55 13 - 15 x

EJG-MW001-110321 11/3/2021 16:15 NA x

EJG-MW001-110321-D 11/3/2021 16:20 NA x FD

EJG-MW002-110921 11/9/2021 12:40 NA x

EJG-MW003-111021 11/10/2021 11:15 NA x

EJG-MW003-111021-MS 11/10/2021 11:15 NA x MS

EJG-MW003-111021-MSD 11/10/2021 11:15 NA x MSD

EJG-MW004-111221 11/12/2021 15:15 NA x

EJG-MW005-110421 11/4/2021 16:00 NA x

EJG-MW006-110321 11/3/2021 11:35 NA x

EJG-MW007-111021 11/10/2021 14:35 NA x

Soil Samples

Groundwater Samples

AECOM 5-7
Table 5-1

Site Inspection Samples by Medium

Site Inspection Report, EJ Garn Aviation Complex, Utah

Sample Identification

Sample

Collection 

Date/Time

Sample Depth 

(feet bgs) LC/MS/MS compliant with QSM 5.3 Table B-15 TOC (USEPA Method 9060A) pH (USEPA Method 9045D) Grain Size (ASTM D-422) Comments

EJG-DECON-01 5/12/2021 9:05 NA x Water source

EJG-DECON-02 11/2/2021 12:15 NA x Water tank on trailer

EJG-DECON-03 11/3/2021 15:30 NA x Portable water tank

EJG-ERB-01 10/26/2021 11:00 NA x Hand Auger

EJG-ERB-02 10/26/2021 11:10 NA x HSA Drill Bit

EJG-ERB-03 11/2/2021 12:00 NA x Sonic Casing (bottom)

EJG-ERB-04 11/2/2021 15:40 NA x Tornado Pump

EJG-ERB-05 11/2/2021 15:45 NA x Wattera Pump

EJG-ERB-06 11/4/2021 13:00 NA x Bladder Pump

EJG-FRB-01 10/26/2021 12:15 NA x

EJG-PLUG-01 10/28/2021 14:20 NA x Wooden Plug MW-1

Notes:

ASTM = American Society for Testing and Materials

bgs = below ground surface

DECON = decontamination

EJG = EJ Garn

ERB = equipment rinsate blank

FD = field duplicate

FRB = field reagent blank

LC/MS/MS = Liquid Chromatography Mass Spectrometry

MS/MSD = matrix spike/ matrix spike duplicate

MW = monitoring well

NA = not applicable

QSM = Quality Systems Manual

SB = soil boring

TOC = total organic carbon

USEPA = United States Environmental Protection Agency

Quality Control Samples

AECOM 5-8
Table 5-2

Soil Boring Depths

Site Inspection Report, EJ Garn Aviation Complex, Utah

Area of 

Interest

Boring 

Location

Soil Boring 

Depth 

(feet bgs)

Temporary Well 

Screen Interval 

(feet bgs)

Top of Casing 

Elevation 

(feet NAVD88)

Ground Surface 

Elevation 

(feet NAVD88)

Depth to 

Water

(feet btoc)

Depth 

Wate

(feet bg

1 AOI01-01 8 NA NA 4627 NA NA 

AOI03-01 2 NA NA 4643 NA NA AOI03-02 2 NA NA 4637 NA NA 

Notes:bgs = below ground surfacebtoc = below top of casingNA = not applicableNAVD88 = North American Vertical Datum 1988

3

AECOM 
Table 5-3

Permanent Monitoring Well Screen Intervals and Groundwater Elevations

Site Inspection Report, EJ Garn Aviation Complex, Utah

Area of 

Interest

Boring 

Location

Soil Boring 

Depth 

(feet bgs)

Permanent Well 

Screen Interval 

(feet bgs)

Top of Casing 

Elevation 

(feet NAVD88)

Ground Surface 

Elevation 

(feet NAVD88)

Depth to 

Water

(feet btoc)

Depth 

Wate

(feet bg

EJG-MW001 45 35 - 45 4613.16 4613.29 34.25 34.38 

EJG-MW002 70 60 - 70 4609.29 4609.35 60.10 60.16 

EJG-MW003 45 35 - 45 4611.79 4612.44 41.55 42.20 

3 EJG-MW004 51 41 - 51 4630.94 4631.30 33.00 33.36 2 EJG-MW005 48 28 - 38 4619.53 4619.95 26.18 26.61 

EJG-MW006 41 31 - 41 4623.98 4624.31 33.82 34.15 

EJG-MW007 40 30 - 40 4613.00 4613.16 33.79 33.95 

bgs = below ground surfacebtoc = below top of casingEJG = EJ GarnMW = monitoring wellNA = not applicableNAVD88 = North American Vertical Datum 1988

21

AECOM 
CLIENT

REVISED

SCALE

ARNG

GIS BY

CHK BY

MS

AD

8/2/2022

8/2/2022

PROJECT Site Inspection at E.J. Garn Aviation Complex, UT

8/2/2022

Figure 5-1 PM CM 8/2/2022

12420 Milestone Center Drive

Germantown, MD 20876

Site Inspection Sample Locations

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

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

?!

?!

?!

?!

?!

?!

?!

"S

?!

"S

AOI 2

AOI 1

AOI 3 EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006 AOI03-01

EJG-MW005

AOI03-02

0 165 330 660

Feet

Legend

?! Soil Boring/Permanent Monitoring Well

?! Soil Boring

"S Surface Soil Sample

Area of Interest

Facility Boundary

Groundwater Flow Direction

Inferred Groundwater Flow Direction

AECOM 

1:3,960 ­

5-11
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 5-12

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

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 each AOI is provided in Section 6.3

through Section 6.5. Table 6-2 through Table 6-5 present results in soil or groundwater for the 

relevant compounds. Tables that contain all results are provided in Appendix 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 6 July 2022 

(Assistant Secretary of Defense, 2022). 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 the five compounds presented on Table 

6-1 below.

Table 6-1: Screening Levels (Soil and Groundwater)

Analyteb

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 19 250 6 

PFOS 13 160 4

PFBS 1,900 25,000 601 

PFHxS 130 1,600 39

PFNA 19 250 6 

Notes:

bgs = below ground surface; μg/kg = micrograms per kilogram; ng/L = nanograms per liter

a.) Assistant Secretary of Defense, 2022. Risk Based Screening Levels in Groundwater and Soil using United States Environmental Protection 

Agency’s (USEPA’s) Regional Screening Level Calculator. Hazard Quotient (HQ) = 0.1. 6 July 2022. 

b.) Of the six PFAS compounds presented in the 6 July 2022 OSD memorandum, HFPO-DA (commonly referred to as GenX) was not included 

as an analyte at the time of this SI. Based on the CSM developed during the PA and revised based on SI findings, the presence of 

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

including distribution limitations that restricted use of GenX, it is generally not a component of other products the military used. In addition, 

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

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

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

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

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

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

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

because 15 feet is the anticipated limit of construction activities. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-2

6.2 Soil Physicochemical Analyses

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

which are important for evaluating transport through the soil medium. One sample was selected 

from each AOI in accordance with the QAPP Addendum (AECOM, 2021a). TOC results for 

AOI01, AOI02, and AOI03 were 1270, 647, and 1800 mg/kg, respectively; and pH results were 

8.52, 8.51, and 8.83, respectively. Appendix F contains the results of the TOC, pH, sampling. 

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

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

Council (ITRC), several important partitioning mechanisms include hydrophobic and lipophobic 

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

certain PFAS are present as organic anions and are therefore relatively mobile in groundwater 

(Xiao et al., 2015), but tend to associate with the organic carbon fraction that may be present in 

soil or sediment (Higgins and Luthy 2006; Guelfo and Higgins, 2013). When sufficient organic 

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

evaluating transport potential, 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: the North Hangar. AOI 1 encompasses the co-located firetruck bay/foam storage area and 

the wash down area, as well as the dry well that may have received discharge from those areas.

The soil and groundwater results are summarized on Table 6-2 through Table 6-5. Soil and 

groundwater results are presented on Figure 6-1 through Figure 6-7. 

6.3.1 AOI 1 Soil Analytical Results

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

6-4 summarize the soil results. 

At the firetruck bay/foam storage area and the wash down area, soil was sampled from surface 

soil (0 to 2 feet bgs), shallow subsurface soil (13 to 15 feet bgs), and deep subsurface soil (33 to 

35 feet bgs) from boring location EJG-MW006. The depth of the former dry well was estimated to 

be 6-8 feet bgs; next to (downgradient of) the dry well, soil from boring location AOI01-01 was 

sampled from surface soil (0 to 2 feet bgs), and shallow subsurface soil (6 to 8 feet bgs), a depth 

representative of soil conditions at the bottom of the former dry well. Downgradient from the 

firetruck bay/foam storage area and the wash down area, soil was sampled from the surface soil 

(0 to 2 feet bgs), shallow subsurface soil (13 to 15 feet bgs), and deep subsurface soil (27 to 29 

feet bgs) from boring location EJG-MW007. 

At AOI 1, PFOA, PFOS, PFHxS, and PFNA were detected in surface soil at all three locations. 

The only SL exceeded was for PFOS (13 μg/kg) at EJG-MW006 with a concentration of 53.6 

μg/kg. PFOA, PFHxS, and PFNA were detected in all three surface soil samples at concentrations 

at least an order of magnitude below their respective SLs. PFBS was not detected in surface soil 

at AOI 1.

PFOA, PFOS, PFHxS, and PFNA were also detected in at least one shallow subsurface soil 

sample at AOI 1, all at concentrations at least one order of magnitude below their SLs. PFBS was 

not detected in shallow subsurface soil at AOI 1.
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-3

In subsurface soil, PFOS and PFOA were detected only at EJG-MW006, with both concentrations 

less than 1 μg/kg and below their SLs. PFNA, PFHxS, and PFBS were not detected in subsurface 

soil at AOI 1.

6.3.2 AOI 1 Groundwater Analytical Results 

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

summarizes the groundwater results. 

Within and downgradient of the North Hangar potential release area, groundwater was sampled 

from permanent monitoring wells EJG-MW006 and EJG-MW007. PFOS, PFOA, PFHxS, and 

PFBS were detected at both locations. The only SL exceedance was for PFOS at EJG-MW006 

with a concentration of 5.30 ng/L (SL of 4 ng/L). All other detected concentrations of PFOS, 

PFOA, PFHxS, and PFBS were below their SLs. There were no PFNA detections in groundwater 

at AOI 1.

6.3.3 AOI 1 Conclusions

Based on the results of the SI, PFOA , PFOS, PFHxS, and PFNA were detected in soil at AOI 1. 

PFOS exceeded the SL in surface soil at one location. PFBS was not detected in soil at AOI 1. 

PFOA, PFBS, and PFHxS were detected in groundwater at concentrations below their SLs. PFOS 

was detected above the SL in groundwater from one location. Based on the exceedance of the 

PFOS SL in surface soil and in groundwater in well EJG-MW006, further evaluation at AOI 1 is 

warranted. 

6.4 AOI 2 

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

2, which includes the hangar/ramp area east of the south hangar, cold storage building, and 

Tri-Max training area. The results in soil and groundwater are summarized on Table 6-2 through 

Table 6-5. Soil and groundwater results are presented on Figure 6-1 through Figure 6-7. 

6.4.1 AOI 2 Soil Analytical Results

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

6-4 summarize the soil results. 

Immediately adjacent to the potential release area, soil was sampled from surface soil (0 to 2 feet 

bgs), shallow subsurface soil (13 to 15 feet bgs), and deep subsurface soil (25 to 27 feet bgs) 

from boring location EJG-MW005. Downgradient from the Tri-Max training area, south hangar, 

cold storage building, soil was sampled from the surface soil (0 to 2 feet bgs), shallow subsurface 

soil (13 to 15 feet bgs), and deep subsurface soil (34 to 36 feet bgs, 59 to 61 feet bgs, and 35 to 

37 feet bgs) from boring locations EJG-MW001, EJG-MW002, and EJG-MW003, respectively. 

PFOS, PFOA, PFNA, PFHxS, and PFBS were detected in at least one surface soil sample at AOI 

2. PFOS was detected in EJG-MW001, EJG-MW003, and EJG-MW002 at concentrations ranging 

from 1.11 μg/kg to 77.3 μg/kg, with the maximum concentration in the duplicate sample for EJGMW001. Concentrations of PFOS in both the regular and duplicate samples for EJG-MW001 

exceeded the SL. Positive detections of PFOA (EJG-MW001 and EJG-MW002), PFNA (EJGMW001, EJG-MW002, and EJG-MW003), and PFHxS (EJG-MW001, EJG-MW002, and EJGMW003) were below their SLs. PFBS was only detected at EJG-MW001 and was below the SL. 

There were no detections in surface soil at EJG-MW005. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-4

PFOS, PFHxS, and PFBS were detected in one or more shallow soil samples at concentrations 

less than 1 μg/kg and below their SLs. PFOA and PFNA were not detected in any shallow 

subsurface soil at AOI 2.

PFOS and PFHxS were detected at concentrations less than 1 μg/kg and below their SLs in 

subsurface soil at AOI 2, and only at locations EJG-MW001 and EJG-MW002. PFOA, PFNA, and 

PFBS were not detected in subsurface soil at AOI 2. 

6.4.2 AOI 2 Groundwater Analytical Results 

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

summarizes the groundwater results. 

East of the Tri-Max Training area, groundwater samples were collected from permanent 

monitoring well EJG-MW001. PFOS, PFOA, and PFHxS were detected above the SLs, at 

maximum concentrations of 698 ng/L, 7.31 ng/L, and 124 ng/L, respectively. PFBS was detected 

below the SL of 600 ng/L, with a maximum concentration of 7.31 ng/L. At EJG-MW001, PFNA 

was not detected.

East of the south hangar and cold storage building, groundwater samples were collected from 

permanent monitoring wells EJG-MW002, EJG-MW003, and EJG-MW005. PFOA, PFOS,

PFHxS, and PFBS were detected below SLs in groundwater at all locations, with maximum 

concentrations of 1.52 J ng/L (EJG-MW003), 1.60 J ng/L (EJG-MW002), 28.6 ng/L (EJG-MW003)

and 3.55 ng/L (EJG-MW002). PFNA was not detected in groundwater samples. 

6.4.3 AOI 2 Conclusions

Based on the results of the SI, PFOA, PFOS, PFBS, PFHxS, and PFNA were detected in soil at 

AOI 2. PFOS exceeded the SL in surface soil at EJG-MW001. At location EJG-MW001, 

associated with the Tri-Max Training area and potentially the south hangar, PFOS, PFOA, and 

PFHxS were detected in groundwater, at concentrations exceeding the SLs. Based on the 

exceedances of the SL for PFOS in soil and exceedances of the SLs for PFOS, PFOA, and PFHxS

in groundwater, further evaluation at AOI 2 is warranted.

6.5 AOI 3 

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

3, which includes the armory dumpster fire potential release area. The results in soil and

groundwater are presented in Table 6-2 through Table 6-5. Soil and groundwater results are 

presented on Figure 6-1 through Figure 6-7. 

6.5.1 AOI 3 Soil Analytical Results

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

6-4 summarize the soil results. 

At the dumpster fire area, soil was sampled from surface soil (0 to 2 feet bgs) at AOI03-01, 

AOI03-02, and EJG-MW004. Soil was also sampled from shallow subsurface soil (13 to 15 feet 

bgs) and deep subsurface soil (39 to 41 feet bgs) from boring location EJG-MW004. 

PFOA, PFOS, and PFNA were detected only in the surface soil samples from at least one location 

at AOI 3, at concentrations at least two orders of magnitude below the SLs. PFOA, PFOS, and 

PFNA were not detected in any shallow subsurface or subsurface soil samples. PFBS and PFHxS 

were not detected in any surface, shallow subsurface, or subsurface soil sample.
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-5

6.5.2 AOI 3 Groundwater Analytical Results 

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

summarizes the groundwater results. 

PFOA, PFOS, and PFBS were detected but did not exceed the SLs in groundwater collected from 

well EJG-MW004 at AOI 3. PFHxS and PFNA were not detected in groundwater samples 

collected from EJG-MW004. Figure 6-4 presents the ranges of detections in groundwater. Table 

6-5 summarizes the detected compounds in groundwater. 

Downgradient of the dumpster fire potential release area, groundwater was sampled from 

permanent monitoring well EJG-MW004. PFOA, PFOS, and PFBS were detected below the SLs

at concentrations of 0.968 J ng/L, 0.786 J ng/L, and 0.985 J ng/L, respectively. PFHxS and PFNA 

were not detected in groundwater at AOI 3.

6.5.3 AOI 3 Conclusions

Based on the results of the SI, PFOA, PFOS, and PFBS were detected only in surface soil at AOI 

3 and at concentrations below the soil SLs. PFOA, PFOS, and PFBS were also detected in 

groundwater and at concentrations below SLs. Thus, further evaluation at AOI 3 is not warranted. 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-6

THIS PAGE INTENTIONALLY BLANK
Table 6-2

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

Site Inspection Report, E.J. Garn Aviation Complex

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual 

Soil, LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)PFBS 1900 ND U ND U ND U ND U ND UJ 0.023 J ND PFHxS 130 1.84 0.528 J 0.448 J 0.057 J 2.13 J+ 4.20 J+ 0.19PFNA 19 0.044 J 1.97 1.87 0.103 J 0.069 J 0.135 J 0.03PFOA 19 0.205 J 3.80 4.98 0.108 J 0.152 J 0.753 J 0.11PFOS 13 4.55 53.6 51.2 1.15 23.8 J 77.3 J 1.11 

Grey Fill Detected concentration exceeded OSD Screening Levels ChemND = Analyte not detected above the LOD. LOD values are presented in Appendix F. PFBReferences PFH

PFNPFOPFO

Interpreted Qualifiers Acro

J = Estimated concentration AOI J+ = Estimated concentration, biased high D U = The analyte was not detected at a level greater than or equal to the adjusted DL DL UJ = The analyte was not detected at a level greater than or equal to the adjusted DL. However, the reported adjusted DL is approximate and may be inaccurate or imprecise. EJG 

ft HQ ID LCMLOD ND OSD QSM QuaSB USEμg/k

Area of Interest

Sample ID

Sample Date

Depth

AOI01-01-SB-00-02

10/26/2021

0-2 ft

EJG-MW006-SB-00-02

10/26/2021

0-2 ft

EJG-MW006-SB-00-02-D

10/26/2021

0-2 ft

10/26/2021

0-2 ft

EJG-MW001-SB-00-02

10/26/2021

0-2 ft

a. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1, May 2022. Soil screening levels based on residential scenario for incidental ingestion of contaminated soil.

AOI01 

EJG-MW001-SB-00-02-D

10/26/2021

0-2 ft

EJ

EJG-MW007-SB-00-02

AECOM 
Table 6-2

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

Site Inspection Report, E.J. Garn Aviation Complex

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual

Soil, LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)PFBS 1900 ND U ND U ND UPFHxS 130 ND U ND U ND UPFNA 19 0.072 J ND U 0.032 JPFOA 19 0.136 J ND U ND UPFOS 13 0.447 J 0.225 J 0.220 J

Grey Fill Detected concentration exceeded OSD Screening Levels Chemic

PFBS 

References PFHxS 

PFNA PFOA PFOS 

Interpreted Qualifiers Acronym

J = Estimated concentration AOI J+ = Estimated concentration, biased high D U = The analyte was not detected at a level greater than or equal to the adjusted DL DL UJ = The analyte was not detected at a level greater than or equal to the adjusted DL. However, the reported adjusted DL is approximate and may be inaccurate or imprecise. EJG 

ft HQ ID LCMSMLOD ND OSD QSM Qual SB USEPA μg/kg 

a. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s Regional Screening Level Calculator. HQ=0.1, May 2022. Soil screening levels based on residential scenario for direct ingestion of contaminated soil.

AOI03-01-SB-00-02

10/25/2021

0-2 ft

AOI03

EJG-MW004-SB-00-02

10/25/2021

0-2 ft

Area of Interest

Sample ID

Sample Date

Depth

AOI03-02-SB-00-02

10/25/2021

0-2 ft

AECOM 
Table 6-3

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

Site Inspection Report, E.J. Garn Aviation Complex

Analyte OSD Screening 

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

PFBS 25000 ND U ND U ND U ND UJ ND U 0.063 J ND U ND U ND U

PFHxS 1600 0.281 J 0.183 J 0.054 J 0.082 J ND U 0.147 J ND U ND U ND U

PFNA 250 ND U 0.172 J ND U ND UJ ND U ND U ND U ND U ND U

PFOA 250 ND U 1.69 ND U ND UJ ND U ND U ND U ND U ND U

PFOS 160 0.213 J 7.60 0.130 J 0.226 J ND U 0.161 J 0.070 J ND U ND U

Grey Fill Detected concentration exceeded OSD Screening Levels Chemical Abbreviations

ND = Analyte not detected above the LOD. LOD values are presented in Appendix F. PFBS perfluorobutanesulfonic acid

References PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

Interpreted Qualifiers Acronyms and Abbreviations

J = Estimated concentration AOI Area of Interest

U = The analyte was not detected at a level greater than or equal to the adjusted DL D duplicate

UJ = The analyte was not detected at a level greater than or equal to the adjusted DL. However, the reported adjusted DL is approximate and may be inaccurate or imprecise. DL detection limit

EJG E.J. Garn Aviation Complex

ft feet

HQ hazard quotient

ID identification

LCMSMS liquid chromatography with tandem mass spectrometry

LOD limit of detection

ND analyte not detected above the LOD

OSD Office of the Secretary of Defense

QSM Quality Systems Manual

Qual interpreted qualifier

SB soil boring

USEPA United States Environmental Protection Agency

μg/kg micrograms per kilogram

Soil, LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)

a. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s

Regional Screening Level Calculator. HQ=0.1, May 2022. Soil screening levels based on industrial/commercial composite worker scenario for incidental ingestion of 

contaminated soil.

AOI01 AOI02 AOI03

EJG-MW004-SB-13-15

11/09/2021

13-15 ft

EJG-MW004-SB-13-15-D

11/09/2021

13-15 ft

EJG-MW003-SB-13-15

11/04/2021

13-15 ft

EJG-MW005-SB-13-15

11/01/2021

13-15 ft

EJG-MW001-SB-13-15

10/28/2021

13-15 ft

EJG-MW002-SB-13-15

11/02/2021

13-15 ft

EJG-MW006-SB-13-15

10/26/2021

13-15 ft

EJG-MW007-SB-13-15

11/09/2021

13-15 ft

Area of Interest

Sample ID

Sample Date

Depth

AOI01-01-SB-06-08

10/26/2021

6-8 ft

AECOM 6-9
Table 6-4

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

Site Inspection Report, E.J. Garn Aviation Complex

Area of Interest

Sample ID

Sample Date

Depth

Analyte Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

PFBS ND UJ ND U ND UJ ND U ND U ND U ND U

PFHxS ND UJ ND U 0.095 J 0.212 J ND U ND U ND U

PFNA ND UJ ND U ND UJ ND U ND U ND U ND U

PFOA 0.139 J ND U ND UJ ND U ND U ND U ND U

PFOS 0.704 J ND U 0.093 J 0.256 J ND U ND U ND U

ND = Analyte not detected above the LOD. LOD values are presented in Appendix F. Chemical Abbreviations

PFBS perfluorobutanesulfonic acid

Interpreted Qualifiers PFHxS perfluorohexanesulfonic acid

J = Estimated concentration PFNA perfluorononanoic acid

U = The analyte was not detected at a level greater than or equal to the adjusted DL PFOA perfluorooctanoic acid

UJ = The analyte was not detected at a level greater than or equal to the adjusted DL. However, the reported adjusted DL is approximate and may be inaccurate or imprecise. PFOS perfluorooctanesulfonic acid

Acronyms and Abbreviations

AASF Army Aviation Support Facility

AOI Area of Interest

DL detection limit

EJG E.J. Garn Aviation Complex

ft feet

ID identification

LCMSMS liquid chromatography with tandem mass spectrometry

LOD limit of detection

ND analyte not detected above the LOD

QSM Quality Systems Manual

Qual interpreted qualifier

SB soil boring

μg/kg micrograms per kilogram

EJG-MW002-SB-59-61

11/04/2021

59-61 ft

EJG-MW006-SB-33-35

10/26/2021

33-35 ft

EJG-MW007-SB-27-29

11/09/2021

27-29 ft

AOI03

EJG-MW004-SB-39-41

11/09/2021

39-41 ft

Soil, LCMSMS compliant with QSM 5.3 Table B-15 (μg/kg)

AOI01 AOI02

EJG-MW003-SB-35-37

11/09/2021

35-37 ft

EJG-MW005-SB-25-27

11/01/2021

25-27 ft

EJG-MW001-SB-34-36

10/28/2021

34-36 ft

AECOM 6-10
Table 6-5

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

Site Inspection Report, E.J. Garn Aviation Complex

Analyte OSD Screening

Level a

Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual Result Qual

Water, LCMSMS compliant with QSM 5.3 Table B-15 (ng/l)

PFBS 601 4.53 3.86 J 12.8 12.5 3.55 J 3.30 J 2.62 J 0.985 J

PFHxS 39 7.58 7.98 123 124 2.31 J 28.6 5.49 ND U

PFNA 6 ND U ND U ND U ND U ND U ND U ND U ND U

PFOA 6 2.42 J 1.37 J 7.18 7.31 1.33 J 1.52 J 1.30 J 0.968 J

PFOS 4 5.30 1.54 J 693 698 1.60 J 0.910 J 0.890 J 0.786 J

Grey Fill Detected concentration exceeded OSD Screening Levels

ND = analyte not detected above the LOD. LOD values are presented in Appendix F. Chemical Abbreviations

PFBS perfluorobutanesulfonic acid

References PFHxS perfluorohexanesulfonic acid

PFNA perfluorononanoic acid

PFOA perfluorooctanoic acid

PFOS perfluorooctanesulfonic acid

Interpreted Qualifiers Acronyms and Abbreviations

J = Estimated concentration AOI Area of Interest

U = The analyte was not detected at a level greater than or equal to the adjusted DL D duplicate

UJ = The analyte was not detected at a level greater than or equal to the adjusted DL. However, the reported adjusted DL is approximate and may be inaccurate or imprecise. DL detection limit

EJG E.J. Garn Aviation Complex

GW groundwater

HQ hazard quotient

ID identification

LCMSMS liquid chromatography with tandem mass spectrometry

LOD limit of detection

ND analyte not detected above the LOD

OSD Office of the Secretary of Defense

QSM Quality Systems Manual

Qual interpreted qualifier

USEPA United States Environmental Protection Agency

ng/l nanogram per liter

EJG-MW001-110321

11/03/2021

Area of Interest

Sample ID

Sample Date

EJG-MW006-110321

11/03/2021

a. Assistant Secretary of Defense, July 2022. Risk Based Screening Levels Calculated for PFOA, PFOS, PFBS, PFHxS, and PFNA in Groundwater or Soil using USEPA’s

Regional Screening Level Calculator. HQ=0.1, May 2022 Groundwater screening levels based on residential scenario for direct ingestion of groundwater.

AOI01 AOI02 AOI03

EJG-MW004-111221

11/12/2021

EJG-MW003-111021

11/10/2021

EJG-MW005-110421

11/04/2021

EJG-MW001-110321-D

11/03/2021

EJG-MW002-110921

11/09/2021

EJG-MW007-111021

11/10/2021

AECOM 6-11
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-12

THIS PAGE INTENTIONALLY BLANK
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

AOI03-01 EJG-MW006

EJG-MW005

AOI03-02

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-1

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFOA Detections in Soil

12420 Milestone Center Drive

Germantown, MD 20876

Shallow Intermediate Deep

Legend

Facility Boundary

0 230 460 920

Depth intervals shown represent respective sampling position within a given soil boring location.

Exceedances of the OSD SL are depicted with a yellow halo.

Feet ­

PFOA Results (μg/Kg)

ND

>ND - 19

>19 - 250

>250 - 2,500

>2,500

AECOM 6-13
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

AOI03-01 EJG-MW006

EJG-MW005

AOI03-02

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-2

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFOS Detections in Soil

12420 Milestone Center Drive

Germantown, MD 20876

Shallow Intermediate Deep

Legend

Facility Boundary

0 230 460 920

Depth intervals shown represent respective sampling position within a given soil boring location.

Exceedances of the OSD SL are depicted with a yellow halo.

Feet ­

PFOS Results (μg/Kg)

ND

>ND - 13

>13 - 160

>160 - 1,600

>1,600

AECOM 6-14
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

AOI03-01 EJG-MW006

EJG-MW005

AOI03-02

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-3

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFBS Detections in Soil

12420 Milestone Center Drive

Germantown, MD 20876

Shallow Intermediate Deep

Legend

Facility Boundary

0 230 460 920

Depth intervals shown represent respective sampling position within a given soil boring location.

Exceedances of the OSD SL are depicted with a yellow halo.

Feet ­

PFBS Results (μg/Kg)

ND

>ND - 10

>10 - 1,900

>1,900 - 25,000

>25,000

AECOM 6-15
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

AOI03-01 EJG-MW006

EJG-MW005

AOI03-02

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-4

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFHxS Detections in Soil

12420 Milestone Center Drive

Germantown, MD 20876

Shallow Intermediate Deep

Legend

Facility Boundary

0 230 460 920

Depth intervals shown represent respective sampling position within a given soil boring location.

Exceedances of the OSD SL are depicted with a yellow halo.

Feet ­

PFHxS Results (μg/Kg)

ND

>ND - 10

>10 - 130

>130 - 1,600

>1,600

AECOM 6-16
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

AOI03-01 EJG-MW006

EJG-MW005

AOI03-02

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

AOI01-01

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-5

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFNA Detections in Soil

12420 Milestone Center Drive

Germantown, MD 20876

Shallow Intermediate Deep

Legend

Facility Boundary

0 230 460 920

Depth intervals shown represent respective sampling position within a given soil boring location.

Exceedances of the OSD SL are depicted with a yellow halo.

Feet ­

PFNA Results (μg/Kg)

ND

>ND - 19

>19 - 250

>250 - 2,500

>2,500

AECOM 6-17
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-6

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

10/5/2022

10/5/2022

10/5/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

10/5/2022

PFOA, PFOS, and PFBS Detections in Groundwater

12420 Milestone Center Drive

Germantown, MD 20876

PFOA Results (ng/L)

ND

>ND - 6

>6 - 40

>40 - 70

>70

PFOA PFOS PFBS

Legend

Facility Boundary

Groundwater Flow Direction

Inferred Groundwater Flow Direction

0 230 460 920

Feet ­

PFOS Results (ng/L)

ND

>ND - 4

>4 - 40

>40 - 70

>70

PFBS Results (ng/L)

ND

>ND - 100

>100 - 601

>601 - 2,000

>2,000

Exceedances of the OSD SL are depicted with a yellow halo.

AECOM 6-18
EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

EJG-MW001

EJG-MW002

EJG-MW003

EJG-MW004

EJG-MW007

EJG-MW006

EJG-MW005

Figure 6-7

CLIENT

REVISED

SCALE

PROJECT

ARNG

Site Inspection at E.J. Garn Aviation Complex, UT

8/11/2022

8/11/2022

8/11/2022

MS

AD

CM

GIS BY

CHK BY

PM

Base Map: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan,

Esri Japan, METI, Esri China (Hong Kong), Esri Korea, Esri (Thailand), NGCC, (c)

8/11/2022

PFHxS and PFNA Detections in Groundwater

12420 Milestone Center Drive

Germantown, MD 20876

PFHxS Results (ng/L)

ND

>ND - 39

>39 - 100

>100 - 1,000

>1,000

PFHxS PFNA

Legend

Facility Boundary

Groundwater Flow Direction

Inferred Groundwater Flow Direction

0 200 400 800

Feet ­

PFNA Results (ng/L)

ND

>ND - 6

>6 - 100

>100 - 1,000

>1,000

Exceedances of the OSD SL are depicted with a yellow halo.

AECOM 6-19
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 6-20

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 7-1

7. Exposure Pathways

The CSMs for each AOI, revised based on the SI findings, are presented on Figure 7-1 through 

Figure 7-3. Please note that while the CSM discussion assists in determining if a receptor may 

be impacted, the decision to move from SI to RI or interim action is determined based upon 

exceedances of the SLs for the relevant compounds and whether the release is more than likely 

attributable to the DoD. A CSM presents the current understanding of the site conditions with 

respect to known and suspected sources, potential transport mechanisms and migration 

pathways, and potentially exposed human receptors. A human exposure pathway is considered 

potentially complete when the following conditions are present:

1. Contaminant source;

2. Environmental fate and transport;

3. Exposure point;

4. Exposure route; and

5. Potentially exposed populations.

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

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

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

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

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

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

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

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

the CSMs indicate whether potentially complete exposure pathways may exist, the 

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

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

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

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

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

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

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

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

workers, trespassers, residents outside the facility boundary, and recreational users outside of 

the facility boundary. 

7.1 Soil Exposure Pathway

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

between the source and potential receptors at AOI 1, AOI 2, and AOI 3 based on the 

aforementioned criteria. 

7.1.1 AOI 1 

AFFF may have been released at AOI 1 at the firetruck bay/foam storage area and the wash down 

area. In addition, potential discharges of AFFF in the firetruck bay could have released AFFF to 

the dry well for an unknown time period prior to 2009. PFOA, PFOS, PFHxS, and PFNA were 

detected in surface and subsurface soil at AOI 1, and PFOS exceeded the SL in surface soil.
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 7-2

Based on the results of the SI in AOI 1, ground-disturbing activities could potentially result in site 

worker, construction worker, or trespasser exposure to constituents via inhalation of dust. 

Additionally, off-facility recreational users may potentially be exposed to constituents via inhalation 

of dust caused by on-facility ground disturbing activities. Ground-disturbing activities could also 

potentially result in site worker, construction worker, or trespasser exposure via ingestion of 

surface soil. Lastly, the exposure pathway to construction workers via subsurface soil ingestion is 

considered potentially complete. The CSM for AOI 1 is presented on Figure 7-1. 

7.1.2 AOI 2 

From approximately 1991 to 2016, releases of the AFFF fire suppression systems in the South 

Hangar and Cold Storage Area resulted in AFFF being pushed onto the Hangar/Ramp Area 

concrete and left in place to evaporate or disperse with the wind. In addition, fire training activities 

were conducted around the Hangar/Ramp Area from at least 1995 to 1999, and emergency 

responses using foam may have occurred on the same area since 1989. PFOA, PFOS, PFBS, 

PFHxS, and PFNA were detected in soil at AOI 2, and PFOS exceeded its SL in surface soil. 

Based on the results of the SI in AOI 2, ground-disturbing activities could potentially result in site 

worker, construction worker, or trespasser exposure to constituents via inhalation of dust. 

Additionally, off-facility recreational users may potentially be exposed via inhalation of dust caused 

by on-facility ground disturbing activities. Ground-disturbing activities could also potentially result 

in site worker, construction worker, or trespasser exposure via ingestion of surface soil. Lastly, the 

exposure pathway to construction workers via subsurface soil ingestion is considered potentially 

complete. The CSM for AOI 2 is presented on Figure 7-2. 

7.1.3 AOI 3 

In 1997 AFFF was released to soil at AOI 3 from a mobile AFFF unit in response to a dumpster 

fire at the Armory. PFOA, PFOS, and PFNA were detected in surface soil at AOI 3, at 

concentrations below the SLs. No constituent was detected in shallow subsurface or subsurface 

soils at AOI 3.

Based on the results of the SI in AOI 3, ground-disturbing activities could potentially result in site 

worker, construction worker, or trespasser exposure to PFOA and PFOS via inhalation of dust. 

Additionally, off-facility recreational users may potentially be exposed to PFOA and PFOS via 

inhalation of dust caused by on-facility ground disturbing activities. Ground-disturbing activities 

could also potentially result in site worker, construction worker, or trespasser exposure via 

ingestion of surface soil. The exposure pathway to construction workers via subsurface soil

ingestion is considered incomplete due to no detections of relevant constituents in subsurface soil 

at AOI 3. The CSM for AOI 3 is presented on Figure 7-3. 

7.2 Groundwater Exposure Pathway

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

exists between the source and potential receptors based on the aforementioned criteria.

7.2.1 AOI 1 

PFOS was detected above its SL in groundwater at AOI 1. It is unknown whether offsite potable 

wells are located downgradient of AOI 1; therefore, the ingestion exposure pathway for off-facility 

residents and off-facility recreational users is considered potentially complete. E.J. Garn receives 

its potable water from the Jordan Valley Water Conservancy District. Twenty percent of Jordan 

Valley Water’s supply is groundwater, pumped from wells scattered around the Salt Lake Valley 

(JVWCD, 2022). Therefore, the ingestion exposure pathway for site workers and trespassers is 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 7-3

considered potentially complete. Depths to water measured in November 2021 during the SI 

ranged from 26.61 to 60.16 feet bgs, deeper than the maximum depth of 15 feet bgs reasonably 

considered for construction activities. Therefore, the ingestion exposure pathway for future 

construction workers is considered incomplete. The CSM for AOI 1 is presented on Figure 7-1. 

7.2.2 AOI 2 

PFOS, PFOA, and PFHxS were detected in groundwater at AOI 2 at concentrations that exceeded

the SLs. Records indicate there may be offsite potable wells located downgradient of AOI 2; 

therefore, the ingestion exposure pathway for off-facility residents and off-facility recreational 

users is considered potentially complete. E.J. Garn receives its potable water from the Jordan 

Valley Water Conservancy District. Twenty percent of Jordan Valley Water’s supply is 

groundwater, pumped from wells scattered around the Salt Lake Valley (JVWCD, 2022). 

Therefore, the ingestion exposure pathway for site workers and trespassers is considered 

potentially complete. Depths to water measured in November 2021 during the SI ranged from 

26.61 to 60.16 feet bgs, deeper than the maximum depth of 15 feet bgs reasonably considered 

for construction activities. Therefore, the ingestion exposure pathway for future construction 

workers is considered incomplete. The CSM for AOI 2 is presented on Figure 7-2. 

7.2.3 AOI 3 

PFOA, PFOS, and PFBS were detected, but did not exceed the SLs in groundwater at AOI 3. It 

is unknown whether offsite potable wells are located downgradient of AOI 3; therefore, the 

ingestion exposure pathway for off-facility residents and off-facility recreational users is 

considered potentially complete. E.J. Garn receives its potable water from the Jordan Valley 

Water Conservancy District. Twenty percent of Jordan Valley Water’s supply is groundwater, 

pumped from wells scattered around the Salt Lake Valley (JVWCD, 2022). Therefore, the 

ingestion exposure pathway for site workers and trespassers is considered potentially complete. 

Depths to water measured in November 2021 during the SI ranged from 26.61 to 60.16 feet bgs, 

deeper than the maximum depth of 15 feet bgs reasonably considered for construction activities. 

Therefore, the ingestion exposure pathway for future construction workers is considered 

incomplete. The CSM for AOI 3 is presented on Figure 7-3

7.3 Surface Water and Sediment Exposure Pathway

The SI results in soil and groundwater, in combination with knowledge of the fate and transport 

properties of PFAS, were used to determine whether a potentially complete pathway exists 

between the source and potential receptors.

7.3.1 AOI 1, AOI 2, and AOI 3 

PFAS are water soluble and can migrate readily from soil to surface water via leaching and runoff. 

Because constituents were detected in soil and groundwater at AOIs 1, 2, and 3, it is possible that 

those compounds may have migrated from soil and groundwater east to the detention 

pond/sedimentation basin, as well as the Jordan River, which flows in a north to south direction 

to the recreational Utah Lake. According to the Industrial Stormwater Pollution Prevention Plan 

for the facility, stormwater from the facility enters Barney’s Creek along the southerly perimeter, 

although the creek was observed to be dry during the investigation. Due to the potential for 

seasonal surface water, surface water and sediment ingestion exposure pathway for site workers, 

construction workers, or trespassers is considered potentially complete. Due to potential use of 

the Jordan River and Utah Lake, the surface water and sediment ingestion exposure pathway for 

off-facility residents and recreational users is also considered potentially complete. The CSMs for 

AOIs 1, 2, and 3 are presented on Figure 7-1, 7-2, and 7-3, respectively.
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 7-4

THIS PAGE INTENTIONALLY BLANK
Media

SOURCE PATHWAY RE

AOI 1

AFFF storage, 

firetruck 

washing

PFAS in 

Surface Soil

PFAS in 

Subsurface 

Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

Surface 

Water/ 

sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Hum

C

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

LEGEND

Figure 

Conceptual Site 

EJ Garn Aviatio

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

PFAS in 

Surface 

Water

Surface 

Water Flow

NOTES1. The resident and recreational usersrefer to off-site receptors.2. Inhalation of dust for off-site receptorsis likely insignificant.3. Human consumption of fish

potentially affected by PFAS is possible.

4. Active construction within AOI 1 was occurring as of the date of SI field work.. 

Site 

Worker

Cons

Wo

Site 

Worker

Cons

Wo

/ 

/ 

/ 

/ / 

AECOM 
Media

SOURCE PATHWAY RE

AOI 2

AFFF Fire 

Suppression 

Systems, fire 

training and 

emergency 

response 

activities, and 

AFFF storage

PFAS in 

Surface Soil

PFAS in 

Subsurface 

Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

Surface 

Water/ 

sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Hum

C

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

LEGEND

/

Figure 

Conceptual Site 

EJ Garn Aviatio

Potential 

Off-Facility 

Source Not 

under 

Control of 

ARNG

PFAS in 

Surface 

Water

Surface 

Water Flow

NOTES1. The resident and recreational usersrefer to off-site receptors.2. Inhalation of dust for off-site receptorsis likely insignificant.3. Human consumption of fish

potentially affected by PFAS is possible.

4. Active construction within AOI 1 was occurring as of the date of SI field work.. 

Site 

Worker

Cons

Wo

Site 

Worker

Cons

Wo

/ 

/ 

/ 

/ 

AECOM 
Media

SOURCE PATHWAY RE

AOI 3

Armory 

dumpster fire

PFAS in 

Surface Soil

PFAS in 

Subsurface 

Soil

Human 

Activities

Precipitation/ 

Run-Off

Leaching/ Infiltration

Airborne Soil 

particulate

Surface Soil 

Surface 

Water/ 

sediment

Subsurface 

Soil

Shallow 

Groundwater

Source Release Mechanism Media Transport and Migration Media Exposure Routes

Inhalation of 

Dust

IngestionIngestion

Ingestion

Ingestion

Hum

C

Flow-Chart ContinuesPartial / Possible FlowFlow-Chart StopsIncomplete PathwayPotentially Complete PathwayPotentially Complete Pathway with Exceedance of SL

LEGEND

Figure 

Conceptual Site 

EJ Garn Aviatio

Potential 

Off-Facility 

Source Not 

Under 

Control of 

ARNG

PFAS in 

Surface 

Water

Surface 

Water Flow

NOTES1. The resident and recreational usersrefer to off-site receptors.2. Inhalation of dust for off-site receptorsis likely insignificant.3. Human consumption of fish

potentially affected by PFAS is possible.

4. Active construction within AOI 1 was occurring as of the date of SI field work.. 

Site 

Worker

Cons

Wo

Site 

Worker

Cons

Wo

/ 

/ 

/ 

/ / 

AECOM 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 7-8

THIS PAGE INTENTIONALLY BLANK
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 8-1

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 were conducted from 25 October to 10 November 2021 and consisted of utility 

clearance, hollow stem auger drilling, sonic drilling, soil sample collection, permanent monitoring 

well installation, grab groundwater sample collection, and land surveying. Field activities were 

conducted in accordance with the SI QAPP Addendum (AECOM, 2021a), except as previously 

noted in Section 5.8. 

To fulfill the project DQOs set forth in the approved SI QAPP Addendum (AECOM, 2021a), samples 

were collected and analyzed for a subset of 18 compounds by LC/MS/MS compliant with QSM 5.3 

Table B-15 as follows. 

• Twenty-five (25) soil samples from ten (10) boring locations; 

• Seven (7) grab groundwater samples from seven (7) permanent wells; and

• Twenty-one (21) QA samples.

An SI is conducted when the PA determines an AOI exists based on probable use, storage, and/or 

disposal of PFAS-containing materials. The SI includes multi-media sampling at AOIs to 

determine whether or not a release has occurred. The SI may conclude further investigation is 

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

required. Additionally, the CSMs were refined to assess whether a potentially complete pathway 

exists between the source and potential receptors for potential exposure at the AOIs, which are 

described in Section 7. 

8.2 Outcome 

Based on the results of this SI, further evaluation under CERCLA is warranted in an RI for AOI 1

and AOI 2; no further evaluation is warranted for AOI 3 at this time (see Table 8-1). Based on the 

CSMs developed and revised in light of the SI findings, there is potential for exposure to drinking 

water receptors from AOI 1 and AOI 2 from sources on the facility resulting from historical DoD 

activities. Sample analytical concentrations collected during the SI were compared against the

project SLs in soil and groundwater, as described in Table 6-1. A summary of the results of the SI 

data relative to the SLs is as follows: 

• At AOI 1: 

• PFOS in surface soil exceeded its SL of 13 μg/kg, with a concentration of 53.6 μg/kg 

at EJG-MW006. PFOA, PFBS, PFHxS, and PFNA in soil at AOI 1 were below their 

respective SLs. 

• PFOS in groundwater exceeded its SL of 4 ng/L, with a maximum concentration of 

5.3 ng/L at location EJG-MW006. PFOA, PFBS, PFHxS, and PFNA in groundwater 

at AOI 1 were below their respective SLs. Based on the results of the SI, further 

evaluation of AOI 1 is warranted in the RI.
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 8-2

• At AOI 2: 

• PFOS in surface soil exceeded its SL of 13 μg/kg, with a maximum concentration of 

77.3 μg/kg at EJG-MW001. PFOA, PFBS, PFHxS, and PFNA in surface, shallow 

subsurface, and subsurface soil at AOI 2 were below their respective SLs. PFOS in 

shallow subsurface and subsurface soil was below the SL. Based on the results of 

the SI, further evaluation of AOI 2 is warranted in the RI.

• PFOS, PFOA, and PFHxS were detected in groundwater at AOI 2 at concentrations 

that exceeded their respective SLs of 4 ng/L, 6 ng/L, and 39 ng/L, with maximum 

concentrations of 698 ng/L, 7.31 ng/L, and 124 ng/L, respectively, at EJG-MW001. 

PFBS and PFNA in groundwater at AOI 2 were below their SLs. Based on the results 

of the SI, further evaluation of AOI 2 is warranted in the RI. 

• At AOI 3: 

• Detected concentrations of PFOA, PFOS, PFHxS, PFNA and PFBS in groundwater 

were below SLs. Based on the results of the SI, no further evaluation of AOI 3 is 

warranted.

• The detected concentrations of PFOA, PFOS, PFHxS, PFNA and PFBS in soil at 

AOI 3 were below their respective SLs. 

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

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

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

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

AFFF and based on its history including distribution limitations that restricted use of GenX, it is 

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

would be an individual chemical of concern in the absence of other PFAS. 

Table 8-1 summarizes the SI results for soil and groundwater used to determine if an AOI should 

be considered for further investigation under CERCLA and undergo an RI. 

Table 8-1: Summary of Site Inspection Findings and Recommendations

AOI Potential 

Release Area

Soil –

Source 

Area

Groundwater – 

Source Area

Groundwater – 

Facility Boundary

Future 

Action

1 North Hangar Proceed 

Dry Well N/A N/A to RI 

2 

Hangar/Ramp 

Area Proceed 

Tent Storage to RI

Area

3 Armory 

Dumpster Fire

No 

Further 

Action

Legend:

N/A = not applicable 

= detected; exceedance of the screening levels

= detected; no exceedance of the screening levels

= not detected
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 9-1

9. References 

AECOM. 2018a. Final Site Inspection Programmatic Uniform Federal Policy-Quality Assurance 

Project Plan, Perfluorooctane Sulfonic Acid (PFOS) and Perfluorooctanoic Acid (PFOA) 

Impacted Sites ARNG Installations, Nationwide Contract No. W912DR-12-D-0014/

W912DR17F0192. 9 March.

AECOM. 2018b. Final Programmatic Accident Prevention Plan, Perfluorooctane Sulfonic Acid 

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

Contract No. W912DR-12-D-0014/W912DR17F0192. July.

AECOM. 2019. Draft Preliminary Assessment Report, the E.J. Garn Aviation Complex, West 

Jordan, Utah. December. 

AECOM. 2021a. Final Site Inspection Uniform Federal Policy-Quality Assurance Project Plan 

Addendum, Army Aviation Support Facility, E.J. Garn Aviation Complex, West Jordan, Utah, 

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

ARNG Installations, Nationwide. June.

AECOM. 2021b. Final Site Safety and Health Plan, Army Aviation Support Facility, E.J. Garn 

Aviation Complex, West Jordan, Utah, Perfluorooctane Sulfonic Acid (PFOS) and 

Perfluorooctanoic Acid (PFOA) Impacted Sites ARNG Installations, Nationwide. October.

Assistant Secretary of Defense. 2022. Investigation Per- and Polyfluoroalkyl Substances within 

the Department of Defense Cleanup Program. United States Department of Defense. 

15 September.

DA. 2018. Army Guidance for Addressing Releases of Per- and Polyfluoroalkyl Substances. 

4 September.

DoD. 2019a. Department of Defense (DoD), Department of Energy (DOE) Consolidated Quality 

Systems Manual (QSM) for Environmental Laboratories, Version 5.3. 

DoD. 2019b. General Data Validation Guidelines. Environmental Data Quality Workgroup. 

4 November.

Environmental Data Resources, Inc. 2019. Geocheck Report for West Jordan AASF, UT.

Guelfo, J.L. and Higgins, C.P. 2013. Subsurface transport potential of perfluoroalkyl acids ad 

aqueous film-forming foam (AFFF)-impacted sites. Environmental Science and Technology 

47(9): 4164-71.

Higgins, C.P., and Luthy, R.G. 2006. Sorption of perfluorinated surfactants on 

sediments. Environmental Science and Technology 40 (23): 7251-7256.

ITRC. 2018. Environmental Fate ant Transport for Per- and Polyfluoroalkyl Substances. March. 

Jordan Valley Water Conservancy District (JVWCD). 2022. Water Sources. Accessed 12 April 

2022 at https://jvwcd.org/water/source

Kleinfelder. 2018. Industrial Stormwater Pollution Prevention Plan. E.J. Garn Aviation Installation 

Army Aviation Support Facility Permit No. UTR000496 7563 South Airport Road, West Jordan, 

Utah 84084 Kleinfelder Project No. 20181545.001A. 12 October. 

Marine, I.W. and Price, D. 1964. Geology and Ground-Water resources of the Jordan Valley, Utah. 

Utah Geological and Mineralogical Survey Water-Resources Bulletin 7. Prepared in 
Site Inspection Report

E.J. Garn Aviation Complex, West Jordan, Utah

AECOM 9-2

cooperation with the Utah State Engineer. Accessed 20 January 2020 at 

https://pubs.er.usgs.gov/publication/70179723. December.

NOAA. 2022. National Centers for Environmental Information. Accessed September 2022 at 

https://www.ncdc.noaa.gov/. 

South Valley Water (SVW), 2019. South Valley Water Reclamation Facility Website. 

https://www.svwater.com/home (Accessed September 2019).

UDWR. 2019. Map Search; Water Right Details. Accessed September 2019 at 

https://maps.waterrights.utah.gov/EsriMap/map.asp. 

USACE. 2016. Technical Project Planning Process, EM-200-1-2. 26 February.

USDA. 2019. Natural Resources Conservation Service Web Soil Survey. Accessed September 

2019 at https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx. 

USEPA. 1980. Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA). 

USEPA. 1994. National Oil and Hazardous Substances Pollution Contingency Plan (Final Rule). 

40 CFR Part 300; 59 Federal Register 47384. September.

USEPA. 2001. Risk Assessment Guidance for Superfund, Volume I: Human Health Evaluation 

Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk 

Assessments). December.

USEPA. 2016a. Drinking Water Health Advisory for Perfluorooctanoic Acid (PFOA). Office of 

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. US USEPA 

Document Number: 822-R-16-005. May 2016.

USEPA. 2016b. Drinking Water Health Advisory for Perfluorooctane Sulfonate (PFOS). Office of 

Water (4304T). Health and Ecological Criteria Division, Washington, DC 20460. US USEPA 

Document Number: 822-R-16-004. May 2016.

USEPA. 2017. National Functional Guidelines for Organic Superfund Data Review. OLEM 

9355.0-136, EPA-540-R-2017-002. Office of Superfund Remediation and Technology 

Innovation. January.

USFWS. 2021. National Wetlands Inventory. Accessed December 2021 at 

https://www.fws.gov/wetlands/

USFWS. 2022. Species by County Report, County: Salt Lake, Utah. Environmental Conservation 

Online System. Accessed 15 March 2022 at https://ecos.fws.gov/ecp/report/

species-listings-by-current-range-county?fips=09003. 

Xiao, F., Simcik, M. F., Halbach, T. R., and Gulliver, J. S. 2015, Perfluorooctane sulfonate 

(PFOS) and perfluorooctanoate (PFOA) in soils and groundwater of a U.S. metropolitan area: 

Migration and implications for human exposure. Water Research 72: 64-74.