Amendment 0006_PFAS Addendum.pdf

Directorate of Public Works – Environmental Division

Management Policy for PFAS Contaminated Soils Originating on Fort Drum

EXTERNAL DISTRIBUTION ONLY

Current as of 30-Jan-2026

Fort Drum PFAS Contaminated Soils Management Policy A. Background Information

1. A PFAS Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Remedial Investigation (RI) is currently underway at Fort Drum to determine the extent of PFAS contamination in soil, groundwater, and surface water at a minimum of 27 locations (“Areas of Interest or “AOIs”) across the installation.

2. The RI is a multi-year effort through 2027 at minimum.

3. The intent of this policy is to avoid creating additional PFAS hazardous waste sites on Fort Drum when relocating contaminated soils from a construction site to an alternative Fort Drum location, including the Land Clearing Debris (LCD) Landfill.

B. Protocol:

Until contamination has been thoroughly delineated, Environmental Division will utilize all existing analytical results, groundwater flow models, and project characteristics to make soil management determinations on a case-by-case basis according to the following and associated decision tree (Appendix A):

1. During the project citing and planning process, Directorate of Public Works

(DPW) EP&S staff should avoid construction in areas of known PFAS contamination to the greatest extent possible in accordance with Installation Management Command (IMCOM) Policy Memorandum – Timely Identification and Mitigation of Contaminated Soil at Proposed Construction Sites on Installation Management Command Installations (Appendix B).

2. For projects that are known or suspected of having PFAS contamination and avoiding construction in the area is not possible, contract Statements of Work shall specify that contractors are required to maintain all soil within the construction footprint and proximal to the original source of the material.

Excavated soil should first be used as backfill and then spread/feathered when no additional backfill material is required near the source of the material.

Contractors are not authorized to haul excess soil off the project site. Given the variability of contamination across the installation, consult with Fort Drum DPW Environmental Division to ensure proper placement of excess soil.

3. If the contractor is unable to use excess soils within the construction footprint but review of historic analytical sampling results performed by the Environmental Division shows favorable results (i.e., no exceedances compared to Office of the Secretary of Defense (OSD) 2023 Risk Screening Levels for Soil (RSLs)1) then excess soil can be directly hauled to the designated location at the Fort Drum Land Clearing Debris (LCD) Landfill (Appendix C). No temporary stockpiling on site or composite sampling required. Access to the LCD Landfill will be coordinated through DPW. DPW staff will control access to the LCD Landfill and will ensure that no soil relocated to the designated area (surrounded by silt fence and posted with off-limits signage) is used for future projects.

Contract Statements of Work shall require/direct:

a) The placement of excess spoils at the LCD Landfill after the Contractor has exhausted all means to manage excess soils on site. Every effort should be made to keep as much soil on site as possible to minimize the amount of soil that is hauled to the LCD Landfill.

b) The Contractor to report the total cubic yards to the Project COR after soils have been relocated to the LCD Landfill. The report will include marked up maps showing excavation location(s) and a log detailing dates hauled, and volumes moved (Appendix D) to accurately and thoroughly document how much soil has been relocated from a given project area to the LCD Landfill.

4. If the contractor is unable to use excess soils within the construction footprint and review of historic analytical sampling results performed by the Environmental Division show exceedances compared to OSD 2023 Risk Screening Levels1 then:

a) If the project footprint accommodates the temporary stockpiling of excess soils, the contractor will temporarily stockpile excess soils onsite. All excess soils from a given project area will be consolidated and stockpiled in one location as proximal to the original source of the material as possible. A Construction Representative (CON REP) from Fort Drum DPW EP&S will provide oversight when temporary stockpiles are developed to ensure proper placement within the project footprint/area. Fort Drum will complete all required PFAS sampling2/testing to determine management strategy for all soils that will require removal from the site. A minimum of seven business days of advanced notification will be required to complete soil sampling.

Analytical analysis costs will be at the contractor’s expense.

i. If results indicate that PFAS contamination exceeds OSD 2023 Risk

Screening Levels1 the contractor will be required to dispose of excess soils IAW all applicable legal guidelines and OSD policies. Fort Drum will review all disposal documentation prior to removal. Disposal of contaminated soils will be at the contractor’s expense.

ii. If results indicate that PFAS contamination is below OSD 2023 Risk

Screening Levels1, excavated soils will be hauled to a designated location at the Fort Drum LCD Landfill. Hauling of excess soils will be at the contractor’s expense and will be reported per the guidance in Section 3(b) above.

b) If the project footprint cannot accommodate the temporary stockpiling of excess soils, the contractor will haul and temporarily stockpile excess soils at a designated location outside of the project footprint, on hardstand and surrounded by silt fence, identified by EP&S Division in coordination with Environmental Division. All excess soils from a given project area will be consolidated and stockpiled in one location. Fort Drum will complete all required PFAS sampling2/testing to determine management strategy for all soils that will require removal from the site. A minimum of seven business days of advanced notification will be required to complete soil sampling.

Analytical analysis costs will be at the contractor’s expense.

i. If results indicate that PFAS contamination exceeds OSD 2023 Risk

Screening Levels1, the contractor will be required to dispose of excess soils IAW all applicable legal guidelines and OSD policies. Fort Drum will review all disposal documentation prior to removal. Disposal of contaminated soils will be at the contractor’s expense.

ii. If results indicate that PFAS contamination is below OSD 2023 Risk

Screening Levels1, excavated soils will be hauled to a designated location at the Fort Drum LCD Landfill. Hauling of excess soils will be at the contractor’s expense and will be reported per the guidance in Section 3(b) above.

Kurt W. Hauk, P.E.

Director Public Works

Footnotes

1. OSD 2023 Residential Risk Screening Levels (RSL) for Soil*

Chemical RSL (mg/kg)

PFOS 0.013

PFOA 0.019

*Detections of target PFAS constituents greater than OSD 2023 RSLs would trigger a CERCLA investigation.

2. Soil Sampling Methodology

a. PFAS are considered Semi-Volatile Organic Compounds (SVOCs) therefore the number of samples will be based on cubic yards of “spoils”.

b. Table for determination of the number of composite samples to pull from the stockpile

Cubic Yards (yd3) of “Spoils” Number of Composite Samples 0-300 1

300-1,000 2

>1,000 1 additional composite for each additional 1,000 yd3 of “spoils”

c. Each composite sample for analysis is created from 3-5 discrete samples from representative locations of the “spoils”.

When siting project footprint, can areas of known or suspected PFAS contamination be avoided?

Yes No

Given the project scope, can all excavated soils be maintained within the construction footprint and proximal to the original source of the material?

Based on Environmental Division review of historic analytical sampling results, can excess spoils be directly hauled to the

LCD without stockpiling/sampling?

Can the project footprint accommodate temporary stockpiling of excess spoils to complete necessary sampling to determine way forward for all soils requiring removal from the site?Yes No

Project will proceed with no management requirements for

PFAS contaminated soils.

Project will proceed with requirement that all excess soils must remain within the construction footprint and as close to the point(s) of excavation to the greatest extent practicable. Excess soils may be used as backfill and/or spread on site to match existing grades and feathered along the edges to blend into existing grades. Contractor(s) are not authorized to haul excess soils off-site.

Project will proceed with the condition that any excess soils that cannot be used as backfill or spread within the construction limits may be directly removed to a designated location at the Fort Drum Land

Clearing Debris (LCD) Landfill and documented accordingly. No temporary stockpiling on site or sampling required.

Historic analytical soil results below OSD

2023 Risk Screening Levels for PFOS (0.013 mg/kg) and PFOA (0.019 mg/kg).

Historic analytical soil results above OSD 2023 Risk Screening Levels for PFOS (0.013 mg/kg) and

PFOA (0.019 mg/kg) or no sampling results available.

Project will proceed with the condition that any excess soils from a given project area that cannot be used as backfill or spread/feathered will be temporarily stockpiled in one location near the original source material. Given a minimum of 1-week advance notice, the Environmental Division will complete all sampling2, testing and analysis to determine if the excess excavated soil exceeds the OSD 2023 Risk Screening

Levels for PFOS and PFOA.

Does composite sampling of the excess excavated soils exceed OSD 2023 Risk Screening Levels for PFOS

(0.013 mg/kg) and/or PFOA (0.019 mg/kg)?Yes No

Project will proceed with the condition that any excess soils from a given project area that cannot be used as backfill or spread/feathered will be temporarily stockpiled at a designated location outside of the project footprint. Given a minimum of 1-week advance notice, the Environmental Division will complete all sampling2, testing and analysis to determine if the excess excavated soil exceeds the

OSD 2023 Risk Screening Levels for PFOS and PFOA.

Excess excavated soil must be disposed of off government property at a licensed facility in accordance with all applicable federal, state, and local criteria at no additional cost to the government. Provide weight tickets from the approved license facility for all contaminated material disposed of off government property.

Excess excavated soil will be hauled to a designated location at the Fort Drum Land

Clearing Debris (LCD) Landfill at no additional cost to the government and documented accordingly.

Management Policy for PFAS Contaminated Soils Originating on Fort Drum Decision Tree

EXTERNAL DISTRIBUTION

Current as of 30-January-2026

Notes/Background Information The PFAS CERCLA Remedial Investigation (RI) currently underway at Fort Drum is to determine the extent of PFAS contamination in soil, groundwater, and surface water at a minimum of 27 locations (“Areas of Interest or “AOIs”) across the installation and will continue through 2027 at minimum.

Until contamination has been thoroughly delineated, Environmental Division will utilize all existing analytical results, groundwater flow models, and project characteristics to make soil management determinations on a case-by-case basis per this decision tree.

^Policy Memorandum – Timely Identification and Mitigation of Contaminated Soil at Proposed Construction Sites on Installation Management Command Installations.

OSD 2023 Risk Screening Levels (RSLs) for PFOS and PFOA are being used as the decision point because exceedances trigger a CERCLA investigation.1 1

In accordance with IMCOM Contaminated Soil Policy (NOV 25)^.

May require ETP per IMCOM

Contaminated Soil Policy (NOV 25)^.

Given the variability of contamination across the installation, coordinate with Environmental

Division to ensure proper placement of excess soils. A temporary stockpile site, on hardstand and surrounded by silt fence, will be identified by EP&S in coordination with Environmental Division.

EP&S CON REPs will provide oversight when siting temporary stockpile locations.

1. PFAS Contaminated Soil Guidance Values

Organization Guidance/Screening Value PFOA (ppm or mg/kg)

PFOS

(ppm or mg/kg)

NYSDEC Unrestricted Site Use 0.00066 0.00088

NYSDEC Protection of Groundwater 0.00080 0.00100

NYSDEC Ecological Screening Value -- 0.00870

NYSDEC Residential Use 0.00660 0.00880

OSD Residential RSL 0.01900 0.01300

NYSDEC Restricted Residential 0.03300 0.04400

NYSDEC Commercial 0.50000 0.44000

NYSDEC Ecological Screening Value 0.57000 --

NYSDEC Industrial 0.60000 0.44000

− NYSDEC Guidance and Screening Values from CP-51, Soil Cleanup Guidance (June 2024 Proposed Revisions).

− OSD Residential Risk Screening Levels (RSLs) from OSD Memorandum: Investigating Per- and Polyfluoroalkyl Substances within the Department of Defense Cleanup Program, August 2023. Detections of target PFAS constituents greater than the 2023 RSLs have and would currently trigger a CERCLA investigation.

2. Soil Sampling Methodology

a) PFAS are considered SVOCs therefore the number of samples will be based on cubic yards (yd3) of “spoils”.

b) Table for determination of number of composite samples to pull from the stockpile:

c) Each composite sample for analysis is created from 3-5 discrete samples from representative locations of the “spoils”.

Cubic Yards (yd3) of “Spoils” Number of Composite Samples

0-300 1

300-1,000 2

>1,000 1 additional composite sample for each additional 1,000 yd3 of “spoils”

Management Policy for PFAS Contaminated Soils Originating on Fort Drum Decision Tree

EXTERNAL DISTRIBUTION

Current as of 30-January-2026

DEPARTMENT OF THE ARMY

US ARMY INSTALLATION MANAGEMENT COMMAND

2405 GUN SHED ROAD

JOINT BASE SAN ANTONIO FORT SAM HOUSTON, TX 78234-1223

AMIM-PWE (200)

MEMORANDUM FOR SEE DISTRIBUTION

SUBJECT: Policy Memorandum – Timely Identification and Mitigation of Contaminated Soil at Proposed Construction Sites on Installation Management Command Installations

1. References.

a. Department of Defense Instruction (DoDI) 4715.08; Remediation of Environmental Contamination Outside the United States; 1 Nov 13 (Change 2, 31 Aug 18).

b. Department of Defense Manual (DoDM) 4715.20; Defense Environmental

Restoration Program (DERP) Management; 9 Mar 12 (Change 1, 31 Aug 18).

c. Army Regulation (AR) 200-1; Environmental Protection and Enhancement; 13 Dec 07.

d. AR 210-20; Real Property Master Planning for Army Installations; 16 May 05.

e. AR 420-1; Army Facilities Management; 12 Feb 08 (Admin Revision, 1 Aug 24).

f. Department of the Army (DA) Pamphlet (PAM) 420-1-2; Army Military Construction and Nonappropriated-Funded Construction Program Development and Execution; 2 Apr 09.

g. U.S. Army Environmental Funding Guidance FY2025-30; 1 Jul 25.

h. Handling of Environmental Contaminants on Military Construction (MILCON) Sites;

Office of the Deputy Chief of Staff, 9 Jan 23.

2. Purpose. Establish a standardized process for investigating, documenting, and managing environmental contaminants at proposed construction sites. This approach aims to prevent cost exceedance, ensure the timely completion of mission-critical infrastructure, and protect the health of personnel. In addition, provide a standard procedure for developing exception to policy (ETP) requests to support informed decision-making regarding site conditions.

3. Applicability. This policy applies to Headquarters, Installation Management

Command (HQ IMCOM), Installation Directorates, Installations, and the United States Army Environmental Command (USAEC) and supersedes IMCOM Policy Memorandum 200-1f (same title), August 29, 2023. Further, the policy scope encompasses all on-post construction sites (both MILCON and non-MILCON) where the proponent includes but is not limited to, Department of Defense (DoD) tenants, non-DoD tenants, retail activities, and partners. This policy does not cover renovations of existing facilities or related Operations and Maintenance (O&M) activities. MILCON projects with a site approval validated by HQ IMCOM, as of the policy’s effective date, are not subject to these requirements.

4. Authority. The HQ IMCOM Commanding General retains approval authority for exceptions to this policy.

5. Policy. Installations should avoid, to the extent feasible, construction on sites with established land use controls or known contamination. In some instances, the preferred course of action is to choose an alternative construction site. If contamination on a construction site cannot be avoided, and would subsequently lead to project delays, cost increases, or unacceptable risk to human health, the installation shall submit a request for an ETP (paragraph 6.e.) to the HQ IMCOM Commanding General. For all projects, the installation shall not commit funds for design or construction until in possession of an approved ETP. Specific to MILCON projects, an approved ETP is required prior to site approval validation by HQ IMCOM.

6. Procedures. As early as possible, the installation shall initiate investigation(s) on all proposed construction sites. When assessing a site for suitability, fully comply with the requirements of references 1.a. through 1.h.

a. Installations shall conduct a comprehensive record review and physical inspection of the proposed project site(s). Examining historical records, land use (e.g., fuel or chemical usage), and documented spills can offer valuable insights into potential soil contamination. Physical site inspections allow for visual assessments to identify locations and evidence of environmental impacts. Furthermore, data from prior restoration studies should be reviewed for applicability to the construction footprint.

Contact USAEC for technical assistance.

b. Soil sampling shall be conducted at project sites where contamination is expected during construction, but the concentration levels are uncertain due to the absence of previous environmental investigation data. This information will support potential design modifications to avoid or minimize excavation of contaminated soil. The sampling should be representative of the proposed project footprint and target specific contaminants of concern identified by the record review and/or physical inspection.

c. If contamination is identified, some degree of remediation and/or mitigation may be required. USAEC can evaluate the site’s eligibility for cleanup under the Defense Environmental Restoration Program (DERP). If determined as DERP eligible, the time needed to complete cleanup actions may be significant and impact construction timelines.

d. For all projects, installations shall include cost estimates associated with environmental requirements in requisite project documents. Specific to MILCON projects and the DD Form 1391, installation personnel shall specify environmental-related requirements in Tab J and the Tab A cost estimates.

e. At a minimum, the ETP request shall include the following components.

(1) Details of the construction project, including the project proponent, proposed schedule, and all associated costs. Describe any anticipated delays in the project timeline due to contamination. Provide general cost estimates for remediation, soil removal and disposal, and other mitigation measures. If required, include costs to complete additional sampling and site characterization.

(2) Information on the nature and extent of the contamination. The request should also indicate whether contamination poses a potential risk to human health, considering future land use. This assessment should account for possible changes in land use (e.g., from industrial to residential) and potential impact on future receptors.

(3) Analysis of an alternative site. This should include an evaluation and discussion of the assessment conducted and consideration given to use of alternative construction site(s).

(4) If applicable, include site-specific regulatory requirements and necessary actions to maintain compliance, informed by engagement and communication with the appropriate regulatory authority.

7. Proponent. HQ IMCOM, G4, Environmental Division is the proponent of this policy.

The Environmental Division email is usarmy.jbsa.imcom.list.hq-g4-env@army.mil.

JAMES M. SMITH

Lieutenant General, U.S. Army mailto:usarmy.jbsa.imcom.list.hq-g4-env@army.mil

Commanding General

Distribution:

IMCOM Directorates (E,P,R,S,T) Commander, U.S. Army Environmental Command Commanders/Managers, U.S. Army Garrisons

HQ IMCOM G4

THIS MAP IS FOR PLANNING PURPOSES ONLY. IT SHOULD NOT BE USED FOR DESIGN, CONSTRUCTION, OR TARGETING. QUESTIONS OR UPDATES TO THE DATA REPRESENTED HERE SHOULD BE DIRECTED TO THE FORT DRUM DIRECTORATE OF PUBLIC WORKS (DPW), ENVIRONMENTAL DIVISION-GIS/MAPPING OFFICE.

UPON COMPLETION OF SERVICE OR INTENDED MISSION SUPPORT OF THIS DOCUMENT IT MUST BE PROPERLY DISPOSED OF AS PER THE CLASSIFICATION LEVEL.o

0 30 60 90 120 METERS

0 150 300 450 600 FEET

UNITED STATES ARMY GARRISON - FORT DRUM

DIRECTORATE OF PUBLIC WORKS

ENVIRONMENTAL DIVISION - GIS/MAPPING OFFICE

COMM: 315-772-1502/DSN: 772-1502/CELL: 315-408-5089

REPRODUCE IN COLOR ONLY

UNCLASSIFIEDUNCLASSIFIED

UNCLASSIFIEDUNCLASSIFIED

Basemap: Esri, NASA, NGA, USGS, Sources: Esri, TomTom, Garmin, FAO, NOAA, USGS, © OpenStreetMap contributors, and the GIS User Community

CURRENT AS OF 1/9/2026 9:35 AM COORDINATE SYSTEM: NAD 1983 STATEPLANE NEW YORK CENTRAL FIPS 3102 FEET

DATA SOURCES

Vector: ISDB Raster: 2022 Ortho

(3-inch Res.)

FORT DRUM MILITARY INSTALLATION, FORT DRUM, NEW YORK

R E L O C A T I O N O F P F A S C O N T A M I N A T E D S O I L S I N V I C I N I T Y O F L C D L A N D F I L L

4E 5B 1A

3D

3B 3C 4D

5D 3A

4B

4A

6A

SCALE: 1:240,000

Location Map:

Area for Relocation of

PFAS Contaminated Soils

05D

05E

20571

SOUTH TANK TRAIL

MUNNS CORNER RD

20617

20621 20619

BRK08BRK01

21544

Wellhead Protection Area

Wellhead Protection Area

Land Clearing Debris

Landfill

Land Clearing Debris

Landfill

Notional Location for Relocation of PFAS Contaminated Soils (0.98 acres)

Notional Location for Relocation of PFAS Contaminated Soils (0.98 acres)

LEGEND

[ Access Control

Fence

Building

Designated Area for Relocation of PFAS Contaminated Soils*

Land Clearing Debris (LCD) Landfill

Wellhead Protection Area (WPA)

Training Area and ID

*The designated area for the relocation of PFAS contaminated soils will be surrounded on all sides with silt fence except to allow movement of vehicles in/ out of the area, posted with signage identifying the area and soil contents as off-limits and prohibited for any future uses, and maintained by DPW-O&M- Roads & Grounds as needed to ensure proper drainage of surface water runoff (i.e., grading, feathering,etc.).

Log_Instructions

Hauling information to be completed by Contractor

No. Starting with 1, sequential count of records populated for project.

Project Name/ID Name/ID of construction project

Contractor Name Name of Contractor of record for the project

Haul Date Date material was hauled to the designated area at the LCD Landfill.

Format: DD/MM/YYYY.

Excavation Location Detailed description of location of excavation within the project footprint.

Use in conjunction with marked up maps showing specific location(s) of excavation.

Total Cubic Yards (yd3) Total cubic yards associated with specific hauling record.

There may be multiple hauling records on a given date and/or for a given project.

See "Log_Example_Relocatd_PFAS_Soils" tab for example of contractor populated information

Log_Example_Relocatd_PFAS_Soils

Hauling information to be completed by Contractor Associated analytical sampling results to be completed by Environmental Division (IRP)

No. Project Name/ID Contractor Name Haul Date Excavation Location Total Cubic Yards (yd3) Sample ID Area of Interest (AOI) PFOS (mg/kg) Compared to NYSDEC GVs for PFOS PFOA (mg/kg) Compared to NYSDEC GVs for PFOA Highest Sampled NYSDEC Designation

1 WSAAF Lighting Upgrade Construction Inc. 1/8/2026 Marked on map titled "WSAAF Lighting Upgrade Soil Relocation - Map 1", trench drawn in RED and labeled as AREA 1. 10-feet off of southern shoulder to Taxiway K. Depth of excavation 0-5 feet. Grid point for trench: 44.068538N, 75.712626W. 10

2 WSAAF Lighting Upgrade Construction Inc. 1/8/2026 Marked on map titled "WSAAF Lighting Upgrade Soil Relocation - Map 1", trench drawn in BLUE and labeled as AREA 2. 10-feet off of eastern shoulder to Taxiway J. Depth of excavation 0-5 feet. Grid point for trench: 44.069999N, 75.712981W. 20

3 WSAAF Lighting Upgrade Construction Inc. 1/9/2026 Marked on map titled "WSAAF Lighting Upgrade Soil Relocation - Map 2", trench drawn in RED and labeled as AREA 3. 10-feet off of FOB Shank Road. Depth of excavation 0-8 feet. Grid point for trench: 44.059733N, 75.709189W. 5

&"-,Bold"Report of PFAS Contaminated Soils Relcoated to the Fort Drum LCD Landfill

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Log_Relocated_PFAS_Soils

Hauling information to be completed by Contractor Associated analytical sampling results to be completed by Environmental Division (IRP)

No. Project Name/ID Contractor Name Haul Date Excavation Location Total Cubic Yards (yd3) Sample ID Area of Interest (AOI) PFOS (mg/kg) Compared to NYSDEC GVs for PFOS PFOA (mg/kg) Compared to NYSDEC GVs for PFOA Highest Sampled NYSDEC Designation

&"-,Bold"Report of PFAS Contaminated Soils Relcoated to the Fort Drum LCD Landfill

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