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NATIONAL GUARD BUREAU

111 SOUTH GEORGE MASON DRIVE

ARLINGTON VA 22204-1373

ARNG-IES-D 6 December 2021

MEMORANDUM FOR RECORD

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

Inspection (SI) for Camp Ethan Allen Training Site, Jericho, Vermont

1. References:

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

Polyfluoroalkyl Substances (PFAS) Policy), 8 January 2021

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

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

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

Department of Defense Cleanup Program), 15 September 2021

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

e. Final Preliminary Assessment Report Camp Ethan Allen Training Site, Jericho, 

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

Impacted Sites ARNG Installations, Nationwide, April 2019

f. Final Site Inspection Report Camp Ethan Allen Training Site, Vermont

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

Sites ARNG Installations, Nationwide, August 2021

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

of PFAS under the Comprehensive Environmental Response, Compensation, and 

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

established in References 1.a through 1.d.

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

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

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

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

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

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

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

Inspection (SI) for Camp Ethan Allen Training Site, Jericho, Vermont

2

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

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

ARNG’s determination related to the PFAS PA/SI at Camp Ethan Allen Training Site, 

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

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

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

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

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

4. The PFAS Preliminary Assessment at Camp Ethan Allen Training Site, VT, finalized 

in April 2019, Reference 1.e, concluded further inspection is warranted at one Area of 

Interest (AOI) due to potential release(s) of PFAS to the environment from the use or 

storage of PFAS-containing materials, such as Aqueous Film Forming Foam (AFFF) or 

waxes associated with the Biathlon facility at Camp Ethan Allen.

5. The PFAS Site Inspection at Camp Ethan Allen Training Site, finalized in August 

2021, Reference 1.f, concluded that further inspection under CERCLA is not warranted 

at the one area of interest (AOI) due to concentrations of PFOA, PFOS or PFBS in 

groundwater and soils below the Office of the Secretary of Defense (OSD) screening 

values in Reference 1.c. Concentrations of PFAS equal to or exceeding the screening 

levels established by OSD in Reference 1.c were not found at the one AOI. It should be 

noted that the drinking water well, co-located with this one AOI and associated with the 

Camp Ethan Allen biathlon facility has PFOS/PFOA concentrations that exceed the 

state of Vermont’s drinking water values and has been taken out of service.

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

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

facility based on the data collected during the SI.

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

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

by formalizing the following decision(s) for each AOI at Camp Ethan Allen, VT LA:

a. AOI 1, Biathlon Facility: No further action.

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

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

Inspection (SI) for Camp Ethan Allen Training Site, Jericho, Vermont

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

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

Encl THOMAS K. LAFAVE

Lieutenant Colonel, U.S Army

Chief, Cleanup and Restoration 

 G-9, Army National Guard
ARNG-IES-D

SUBJECT: Determination Documentation of the Preliminary Assessment (PA) / Site Inspection (SI) for Camp Ethan Allen 

Training Site, Jericho, Vermont

Encl

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

Camp Ethan Allen Training Site, Jericho, VT

Location Preliminary Assessment (PA) Site Inspection (SI)

AOI # Area Description Conclusion Determination Conclusion Determination

1 Biathlon 

Facility

Sufficient evidence 

of a potential PFAS 

release warranting 

further investigation

Proceed with

SI

Release of PFAS 

into environmental 

media not 

confirmed above

screening levels

No further 

action