PB98-963911
EPA 541-R98-067
Novemberl998
EPA Superfund
Record of Decision:
Letterkenny Army Depot
(PDO & SE Areas)
Chambersburg, Franklin County, PA
9/30/1998
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I
LETTERKENNY ARMY DEPOT
PHASE I PARCELS
CHAMBERSBURG, FRANKLIN COUNTY, PENNSYL V AN1A
RECORD OF DECISION
SEPTEMBER 28. 1998
OeCLARA TIOH FOR THE
RECORD OF DECISION
SITE NAME AND LOCA 1ION
Lctterlcenny Anny Depot
Cbambcrsburg. Franklin County. Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision docUJ1\ent presents the selected remedial action for
the Phase I Parcels II Letterkenny Anny Depot (LEAD).
Chambersburg. Pennsylvania. which wu chosen in KCOrdance
with the Comprehensive Environmental Response. Compensation,
and Liability Act of 1980 (CERCLA), as amended by the
Superfund AmendmentS and Reauthorization Act.of 1986
(SARA), and to the extent practicable. the National Oilllld
Hazardous Substances Pollution Contingency Plan (NCP). This
decision document is based on the Administntive Record for this
site.
The Commonwealth of Pennsylvania concurs with the selected
remedy .
A....m.,,' of tit. Site
Actual or threatened releases of hazlrdous substances &om the
site. if not addressed by implementing the response action selected
in this Record of Decision (ROD). may prcscat an immiDent and
substantial endan&erment to public heaJtb. welfare. or the
environmenL
Description of the S.,8d8d R8Ift8dy .
This is the final actioa with rcprcI to soils ad 1ft interim action
with regard to grouDdw8ra'. wbieb toptbcr 8ddrea tbc
contamination at die Pba8 1 Parcels II LEAD (lite Pb8se I Parcels
arc a subset of die BRAe PII'ceI). There Ire three 8fOW1dw1lCr
operable units (QUI) ..... ill die BRAC P8n:e1- Property
Disposal Office (PDO) OUt 21Dd 4. UId Sou1basrern Area (SE
~~
AbBham Ferdas
Director. Hazardous Sites Cleanup Division
EPA. Reaion III
'l J-'JO (~V
Date oJ .
C.\VWC)OWI\TEW\FNL_ROeC.DOC(W2MI»
Area) OU 3. These OUs arc bein& addressed 5epamely and final
measures with regard to pounc1W81Cr contamination will be
presented in the RODs for those OUs.
The selected remedy is the implemenWion of institUtional
controls.
SIaUIfaIy DetemJ/ltatlon8
The selected rmal remedy with reprd to soils is protective of
human health and the environment. complies with Federal and
stale requirements tlw arc leaally applicable or relevant and
appropriaae (ARARs) to the remedial action and is cost~ffective.
This soils remedy utilizes permanent solutions and alternative
tre8!ment (or resource recovery) technology to the maximum
extent praciicable (or the Phase I Pwccls. With respect to
grounc1waler contamin8&ion, the interim measure is protective of
human health and the environment. waives Fedenl and S88fC
ARARs (ARARs will be Iddressed under the final measures
presented in RODs for the relevant operable units) and is cost-
effective. This portion of the lCbon is inlErim and is not intended
to utilize permaacnt solutions and altemllive treaanent (or
resource recovery) technologies to the muimum extent
practicable. Because this portion of the lCbon docs not constitUte
a final remedy for the pouDdW8ter, the statUtOry preference for
remedies that employ tr'aJment tlw reduces toxicity, mobility. or
volume as. principal element will be addressed by the final
groundwater response action.
Because this remedy will result in hazardous substances remainin&
on-site above heallh-based levels. . review will be conduc:u:d
within' years after the dale of this ROD to ensure thai the remedy
continues to provide adeqU8le protection of human health and the
environment.
This '-year review will also include an evaluation of the swus of
the grounc1w8Ier remedy to deccrmine if deed restrictions related
to groundWllCr can be removed when groundwater response
KUoas arc complctecl.
~ v. ,C)~<-
Larry V. Gull
Deputy to the Commander
U.S. Army IndusIriaI Operuions Command
~
DIIe
FINAL
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C ~NL_RFM2 00CIW2W181 .
Fin.'
Record of Decision
for Phase I Parcels
Letterkenny Army Depot
. u.s. Anny Corps of Engineers
Baltimore District
September 1998
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~ . .
o Pnnted on m:}',1cd paper
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TABLE OF CONTENTS
SECTION
PAGE
DECLARATION FOR THE RECORD OF DECISION................................ i
SITE NAME AND LOCATION [[[ i
STATEMENT OF BASIS AND PURPOSE ..,....,..........,~,...."....................,..,...........,......... i
Assessment of the Site.................... ,...............,.,....." ........,;, ................ .......... ......... ........ i
Description of the Selected Remedy. .................. ........ [[[ i
Statutory Detenninations.......... ................... .................. .... .;.. .......... ............................... i
RECO RD 0 F D ECIS ION [[[ t
SECTION I SITE NAME. tOCA TION.~ND DESCRIPTION........................................ I
IN FO RMA TION """""""""""""""""'" ....... .................... ......... ......., ......,.. ....................... I
TOPOGRAPHY AND SURFACE DRAINAGE [[[ ,..... 1
GEOLOGY..... ....... ............................. ................................. ""'''''''''''''''''' ...................... ..;. 1
HYDROGEOLOGY............ ................ '''''''' ......... ......... ......... .......... ...:.... ........ ....., ............. 5
NATURAL RESOURCES.... ......... .... ............ .......... .-... .............."...... ...... .....................,..... 6
SECTION 2 SITE HISTORY AND ENFORCEMENT ACTIONS.._...__................6
PROPERTY HISTORY. ............" .... ....... ............. ....... ................ .......................... .............. 6
TEN ANT ACTIVITIES ..... ........,. ....... ............".... ....,. ....... ............. ............ ......... ............... 7
C ERCLA STATUS ...... ........ ............ ..... ........ ................ ............."...................... ................... 7
PDO AREA............... "'''''''''' .......... .... .................. ........ .................... ....... ....... ............. ........ 7
SOUTHEASTE RN AREA............. ................................... ..................................................9
. "
ENFORC EMENT ACTIVITIES ........ ... ................ [[[ ..........9
SECTION 3 COMMUNITY PARTICIPATION HIGHLIGHTS ....-....-.......................- 9
SECTION" SCOPE AND ROLE OF RESPONSE ACTION ....-....................................10
SECTION 5 SUMMARY OF SITE CHARACfERlSTICS ...........--.........-.............. 10
NATURE AND EXTENT OF CONTAMINATION .........:"............................................ 10
Soil...........,.........".,.., ............".".,.,.....,..".,.....,.."....,.... e,"""""""""""""""""""""'" 1 0
Groundwater. ....... ........ ........... .... ......"..... ........ ..............".............................. ...... ............ 11
Routes of Exposure................ [[[ 11
SECTION 6 SUMMARY OF SITE RlSKS.........................._............._-_.............12
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TABLE OF CONTENTS
(Continued)
SECTION
PAGE
Noncarcinogens [[[ ........... ........... .......... 13
.......................
RISK CHARACTERIZATION [[[~.... 13
Carcinogenic Risks................................ ""'"'''''''''''' ........... ......... ................................ 1 3
Noncarcinogenic Risks ........ [[[ "'"'''' ......... 13
ECOLOGICAL CONSIDERATIONS [[[ '"'''''' 14
RISK UNC ER T AINTY . [[[ ..... .......... 14
REMEDIAL ACTION OBJECTIVES (RAO) [[[ 14
SECTION 7 DESCRIPTION OF REMEDIAL ALTERNATIVES .................................14
ALTERNATIVE 1: NO ACTION [[[ 14
AL TERNA TIVE 2: INSTITUTIONAL CONTROLS [[[ 14
SECTION 8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ...15
THRESHOLD CRITERIA ....... ..... ...... .............. .....:.. .... ................................... ""'" ;......... 15
Overall Protection of Human Health and the Environment ........................................ IS
Compliance with ARARs [[[ .... .... 15
PRIMARY BALANCING CRITERIA """""""'"'''''''''''''''''''''''''''''''''''''''''''''''''''''''''''' 16
Long- T enn Effectiveness and Permanence [[[ 16
Reduction in Toxicity. Mobility. or Volume [[[ 16
Short- T enn Effectiveness.......... ...... .......... .............. ..... """'"'''''''''''''''''' .................... 16
Implementability ....................... .... ........... ....... ............... .................... .......................... 16
Cost.......................... ................................ .................... .................... ............ ................ 16
MODIFYING CRITERIA ............. [[[~............... ....... 1 7
State Acceptance......... ............... ...."........ ........... ...... ..... ""'''''','''''''' ............................ 1 7
Community Acceptanc:e..... ................... ............ ........................................... ................ 1 7
SECTION 9 THE SELECTED REMEDY -.--......--.--.-.-....-..-........_17
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TABLE OF CONTENTS
(Continued)
SECTION
PAGE
SECT ION lOVE R V I E W [[[ I
SECTION 2 BACKGROUND ON COMMUNITY INVOLVEMENT..............................!
CHRONOlOG Y OF COMMUNITY INVOLVEMENT [[[ 1
KEY COMMUNITY CONCERNS..... .................... .............. ...... .......... ...... ........ ........... ..... 2
Cleanup Activities.... .......... ....... ........... ......... .......... ........... ..... ................ .................. .... 2
Reuse......... .......... ....... :...... ........ ............. ............... ............ ............ .....,...... .................... 2
C ontarnination .................... ........... ......... ....." ........... .................................~. ....... """" ... 2
Air Quality. ........................ ........................... .... ........ ............. ....... ............... ..... ............: 3
Ammunition Detonation. ................................... .......... ......... .......... ................. '''''''''''''' 3
. Government.............................. ....... ....... ....................... "'" ............ ..............;................. J
Anny .................................... ..... ....... ............ ............ ..... ............ .;...................... ............. J
SECTION J SUMMARY OF COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND AGENCY RESPONSES._.._..................._J
RESULTS OF THE SCREENING INVESTIGATIONS[[[ 3
PARCEL-SPECIFIC COMMENTS [[[ .............4
RlSK ASSESSMENTS ...... ..,......... ...................................... .............. ..... ....... ........ .............4
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LIST OF FIGURES
TiTlE
PAGE
Figure I Site Location Map ........ .......... ................................................ ................... ...... :....... ....2
Figure 2 BRAC Parcel Map.................... [[[ ...... ..........3
Figure 3 Major Drainage Divides [[[ ................... ....... ...,.. ........ 4
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I
LETTERKENNY ARMY DEPOT
PHASE I PARCELS
CHAMBERSBURG. FRANKLIN COUNTY. PENNSYLVANIA
RECORD OF DECISION
SEPTEMBER 28. 1998
SECTION 1
SITE NAME, LOCATION,
AND DESCRIPTION
INFORMATION
LenerXenny Anny Depot (LEAD) is located in Southcentral
Pennsylvania in Franklin County. S miles north of the
Borough of Chambers burg (see Figure I). The Depot covers
19.243 acres. most of which is devoted to ammunition
storage (16.89S acres). The indusuial and maintenance areas.
which are primarily located in the southeast comer of LEAD
and encompass approximately 3.088 acres, are the focus of
the Base Realignment and Closure (BRAC) initiative.
The BRAC Parcel is concentrated in the soUtheast ponion of
LEAD. which includes warehousing. vehicle storage.
industrial/maintenance. administration and recreationaJ
activities. and housing. This entire area. with the excepcion
of selected retained areas. has been designated for
realignment (see Figure 2). The infrastructure of this area
includes roads: permanent. semipennanent. and temporary
structures: and utilities.
TOPOGRAPHY AND SURFACE DRAINAGE
LEAD is located in the Great Valley section of the Valley
Ridge Province of the easICm United Swcs. and referred to
locally as the Cumberland Valley. The Cumberfand Valley
trends northeast to SOUthwest throu&h c:entraJ Pennsylvania
and is bordered to the weSI by the Appalachian Mountain
Province. The SoudI Mountain section of the Blue Ridge
Province is situ8led CUI of Chambersburg and marks the
eastern edge of the Cumbertand Valley.
The Cumberland Valley is chancterized by southwest-
trending limestone ridges and valleys. The valley floors are
filled with rocks of the MartinsburJ Formation. Weathering
of the folded and faulted underlying geologicformalions
impans ~ gently rolling aspect to the local topography. The
majority of LEAD is located within "the Martinsburg Shale
terrain, excepc for bands of carbonate rockS along the eastern
and western edges of LEAD. The PDO Area and the
~utheast Indusuial Area (SIA) of LEAD are underlain by
limestone. Surface elevations throughout LEAD range from
approximately 600 to 750 feet above mean sea level (msl),
C WUomLEAOIF"'_ROO DOC(IOI'/II)
except for the northwest ponion of LEAD. where the
elevation increases abruptly to more Ihan 2.300 feet (ft)
above msl in the vicinity of Broad Mountain (EA. 1991).
Streams cuning thl'C?ugh the limestone lerrain !low through
broad. open valleys and are usually interminent. In contrast
" to this. streams cuning through the upper shale unils of the
Martinsburg Formation usually meander in small. steep-
~all~ vall~ys and are perennial. Surface drainage at LEAD
IS divided Into two watersheds-the Susquehanna River to
the nonheast and the Potomac River to the southwest. Both
the Susquehanna and PotomK Rivers eventually drain into
the Chesapeake Bay.
Two major stormwarer drainage systems serve the southeast
ponion of LEAD and conuibute to local surface drainage.
One system serves the area nOtth of Coffey A venue and
discharges near the Industrial Wastewater Treatment Plant
(IWTP) into the indusuiaJ plant outfall ditch (located nonh
of the IWTP), which discharges to Rowe Run. The other
system serves the southeast warehouse area. Water drains
into the storm drain system. is discharged through the stonn
drain outfall, and joins other surface runoff flowing
southward to Conococ:heague Creek (USATHAMA. 1980).
Figure 3 illustrates the major drainage divides at LEAD.
GEOLOGY
LEAD straddles two major structural features-the South
Mountain anticlinorium to the east and the Massanuncn
synclinorium to the west. The eastern portion of the Depot
(underlain by carbonate rocks) is pan of the anticlinorium.
whereas the western ponion of the Depot (underlain by
shale) is part of the synclinorium. These structures resulted
from folding
FiNAL.
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nCUREl
PROPERTY LOCATION
f'-:.JT: v'tTTI ;-;:
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OMdk<9 ktt
SC and POO *r.«
Letlerkennjr Army Depot
Chambersburg, PA
Location ol St. PDO.
•od Encl>*«4 Are«« mi
LEAD
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SC *r»o North
drain* lo Hw Su»ojj*r>onn >
Ri»»r *ol»» •»>•(( via "ow« Run
POO »»*o
to th« Polomoc Ri
vto Rocfcy
SC Aroo South
Drain* lo tno
Potomac Rfvor
^^-at*w^ tt - -- —
V" V^VO VV
ConocochoaaiM Crook
Out fat of Storm
S«w«r> (ram SC Aroa
lo
lo
ConococMoauo C'***
MM Boe* «r
00*09*
Enctovod
Trancfor/l
Wo|or Wator
SubBOOlii Drotoog* OMtf*
Conor dFkm
OOP
2600
1
Letterkenny Army Depot
Chambersburg, PA
Location of Dralncfowcy* and
Major Dr«lo««o Dlrlde* «l
LEAD
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LETTERKENNYARMYDEPOT
PHASE I P "RCELS-RECORD OF DEC ISIO~
that occurred during the close of the Paleozoic era. High-
angle reverse faulting accompanied the folding of rocks in
the eastern portion of LEAD. Several major faults. ~hich
strike north to northeast and dip to the southeast at fairly
steep angles. cross the PDO Area (WESTON. 1984).
In the vicinity of LEAD. the Great Valley is floored by
Ordovician age carbonate rock. as well as Ordovician age
shale and greywacke of the Martinsburg Fonnation. The five
formations oc:curring at LEAD are the shales of the
Martinsburg Formation. the limestones of the Chambersburg
Formation and the St. Paul Group. the limestones and
dolomites of the Roc:kdale Run Fonnation. and the dolomites
of the Pinesburg Swion Formation. These geologic:
formations are fractured and deformed to varying degrees
from past geologic activity (ESE. 1993).
Several faults extend through LEAD. including the Pinola
and Lenerkenny Faults. Although an east-to-west cross fault
was identified between these two faults. both the position
and surface trace are open to question (Becher and Taylor.
1982). Northeast of LEAD. the Pinola Fault truncates the
Lenerkenny Fault. indicating that the latter fault is older.
The Lenerkenny Fault is one of the few faults in the region
that parallels the tectonic: grain, yet is an early formed.
westward~ipping thrust that moved material fiom within the
syncline to the west up onto the anticline to the east (EA.
199\).
The Pinola Fault. Ioc:ated to the west of the Letterkenny
Fault. is considered to be an east-dipping. high-angle thrust
fault (based on the fact that older beds are to the east of the
fault). Because it is almost impossible to trace faults through
the Martinsburg terrain. the fault trace is projected through
the Martinsburg Fonnation on the basis of a ridge-forming
unit that extends through it (Becher and Taylor, 1982).
HYDROGEOLOGY
The regional surface water flow syscem of Franklin County
controls the gencn1 groundwater flow patterns within
LEAD. The surfIIC8 water drainage divide. discussed
previously. also divides the groundwater flow system into
two basins. Groundwater elevation contours within LEAD
generally reflecl surface topography. The water table is
Ioc:ated at moderate depth in areas of topographic: highs and
is shallow near stream valleys and other topographic lows
. (ERM. 1995). .
The shaie and carbona1e rock that underlie LEAD have been
disturbed and faulted during defonnational events thai
ultimately formed the Great Valley. The two major faults
Ioc:ated within the confines of LEAD (the Pinola Fault and
the Lenerkenny Fault) influence groundwater flow. When:
faulting is present and dissimilar roc:ks have been brought
into contact. the fault tends to act as a banier to groundwater
movement. occasionally forcing water within the formation
to discharge as a fault spring. Where similai rocks are in
contact along a fault (i.e.. two limestone units,. the
groundwater movement may be only minimally affected
(ERM. 1995).
Fracture systems within the Martinsburg Formation are small
and well connected. thus allowing groundwater 10 generally
follow a regional now path. Groundwater now within the
limestone of the Chambenburg Formation and St. Paul
Group is more complex because it occurs predominantly
through individual fractures and solution cavities rypical of
karst terrain. Fractures in the limestones are mostly aligned
with the regional northeast tectonic grain and are much more
irregular and widely spaced than those in the adjacent shales.
Where. solution cavities are present in the limestone.
groundwater flow more closely resembles open channel now
rather than the fracture flow described above. The quantity
and density of fractures within the limestone units increase
with proximity to the bedrock surface. During seasonal
periods when the water table is at its highest (early spring.
late autumn). water levels commonly rise above the
bedrock/surfxe marerial contact. Leaching or resuspension
of any materials or pot~tial contaminants buried in the
surficial sediments may be enhanced during high water table
conditions (ERM. 1995).
Groundwaler recharge oc:c:urs primarily through
precipiwion. Recharge areas oc:c:ur throughoul the central
pan of LEAD. wherever sandstone. siltstone. or joints are
close to the surface. Actual points of recharge for the
limestone aquifers have not been determined: however. the
many faultS. joints.. and sinkholes prescnt at LEAD are the
most likely routes (ERM. 1995).
Groundwater underlying. LEAD generally oc:curs under
unconfined. conditions. with local areas of artesian
conditions. TheSe artesian conditions occur along a
moderately steep slope. located ncar the northwest edge of
LEAD in the Ammo Area. .
A groundwaterscudy completed for the U.S. Army Corps of
Engineers (USACE) in the 19505 concluded thai there was
not a viable source of groundwater available within LEAD
boundaries to supply the Depot's indusaial mission (Acker.
1995). The only use of groundWater in the area is outside
LEAD. where some individual homes depend on
groundwater for their domestic: supply and othcn are
connected to the Guilford Water Au~ty waterline.
Groundwater is also used outside LEAD as a water supply
for livestock. Any homes on well water thai exceeded an
applicable ARAR were initially supplied with bottled water.
and later connected to public water.
NATURAL RESOURCES
The properly included in the Phase I Parcels consists of
primarily indusuiaJ and developed land. small stands of trees
and open grassy areas. and agricultural areas. No wetlands
C >NIM't\lEADlfHt._ROO 00<:410111111
FINAL
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LEITERKENNY ARMY.DEPOT
are located within the Phase I Parcels. and no Federal or
state threatened or endangered species are known or
suspected to have habiws within the Phase I Parcels.
SECTION 2
SITE HISTORY AND
ENFORCEMENT ACTIONS
PROPERTY HISTORY
The Lenerkenny Ordnance Depoc was established in January
1942 as an ammunition storage facility. In subsequent years.
the following missions were added:
. Reserve storage and expon advanc:e storage of pans.
. tools. supplies. and equipment for combat vehicles.
artillery. small munitions. and vehicle fire conb'ol
equipment ( 1943).
. Receipt and storage of hardware. heavy~uty trucks. and
pans ( 1944).
. Establishment of tnnspon and combat vehicle shops and
expansion of the maintenance program ( 194 7).
. Establishment of a rebuild system for guided missile .
ground control. launching. and handling equipment:
missile propellant systems; and internal guidance systems
( 19S4). .
. Assignment of the special weapons mission ( 19S8).
. Designation of the Depot as the Eastern Equipment
Assembly Area (19S9). This mission gave the Depoc
responsibility for the handling and shipment of equipment
for guided missile and special weapons units to overseas
Io<:ations.
. Acceptance and destruction of contaminated U.S. Air
Force (USAF) missile fuel (1961).
. Lenerkenny Ordnance Depot renamed as LenerkCMY
Army Depot ( 1962).
. DisposaJ of explosive ordnance Icnerued from the Army
as well as stare and local police ( 1964).
. Maintenance and sconae of USAF missiles (1966).
. Receipt. stOflp. and dispenaJ ofblUerics and tires to
Army units ( 1972).
. . Operation of a washout facility to reclaim explosives fTom
munitions ( 1973).
These operations consisted of cleaning. saipping. painting.
lubrication. and plating activities. which involved the use of
solvents. blast media. paints. chemicals. petroleum products.
and metals. Storage spills. releases. and disposal of these
materials led to the. current environmental concerns at
LEAD.
PHASE I P ~RCEl.S--R[CORD Of D[ClSIO~
Prior to the establishment of LEAD. the area consisted of
a~icultura.1 and forestlands. The area was predominantly
sIngle-famIly farms used for both subsistence and
commercial purposes.
The Base Closure and Realignment Act of 1988 (Public law
100-526. 102 Stat. 2623) (BRAC 88) and Ihe Defense Base
Closure and Realignment Act of 1990 (Public: Law 10 I-51 O.
104 Stat. 1808) (BRAC 91.93,95) designated more than
100 Depattrricnt oflhe Army facilities for closure and/or
realignment. On 28 February 1995. the United States
Secretary of Defense submined a recommendation 10
Congress that LEAD be selected for realignment.
The BRAC Commission recommended "transferring the
towed and self-propelled combat vehicle mission to AnniSlon
Army Depot. Alabama: retain(ing) an enclave for
conventional ammunition storage and tactical missile
disassembly and storaae: and change(ingJ the 1993 [BRAC)
Commission's decision regarding the consolidation of
tactic:aI missile maintenance at Lene~enny by transfefTing
missile guidance system workload to Tobyhanna Army
Depot (TV AD). Pennsylvania. or private sector commercial
activities."
In antic:ipation of the realignment of the LEAD mission. an
Environmental Baseline Survey (EBS) was conducted for the
to-be-exc:esSed property (Phase I. August 1996: Phase II.
Draft. July 1997). The EBS process includes visual
inspections of each propeny as well as record reviews and
penonnel interviews. which are used to document current
and historical conditions wittl regard to use. storage. or
release of hazardous substances and petroleum products.
None of the parcels and buildings covered under this ROD
were identified as having any significant environmental
conc:ems. aside from the documented VOC groundwater
contamination.
The Letterkenny Indusaial Development Authority (LlDA)
developed a list of priority buildings and parcels based on
the potential for reuse and redevelopment planning. The
Phase 1 Parte" represent those buildings and propenies
identified by LIDA that the Anny deemed suitable 10 transfer
at this time. as will be documented in the FOST for Phase I
Parcels. The Phase I Parcels consist of the following:
. Parcels I and 2 (Open land near Gate 6)
. Parcels 3 and 4 (Buildings 6 and 9)
. Parcel' (Buildings S20-1 through S2o-S)
. Parcel 6 (Open storage south of Parcel 7)
. Parcel 7 (Buildin.238)
. ParcelS (Buildings S26-1 through S26-4)
. Parcel 9 (Open storage east of Parcel 8)
. Parcels 10 through 13 (Sheds at Docks 35.36.45. and 46',
. Parcels 16 through 21 (Warehouses 34.43.44.52.53. I
and 54)
!
i
c WIIML.UoD\F"'-"OO ~8I2M8)
FINAL
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LETTERKENNY ARMY DEPOT
# Parcels 22 and 31 (Railroad Parcels)
• Parcel 23 (Buildings T410.411,412.416-418. and T455)
• Parcel 24 (Building 500)
• Parcel 25 (Building 19)
• Parcel 26 (Building SSI)
• Parcel 27 (Cargo Road Parcel)
• Parcel 28 (Building 524)
• Parcel 29 (Agricultural lease parcel)
• Parcels 33 and 34 (Buildings 637 and 639 and parking
area)
These parcels are shown in Figure 4.
TENANT ACTIVITIES
One of the major tenant activities at LEAD that impacts
environmental conditions at the Depot is the Defense
Realization and Marketing Office (DRMO). This
organization is responsible for the reuse, recycling, handling.
and disposal of excess U.S. Department of Defense (DoD)
property, including waste and hazardous waste.
There are four agricultural lease areas within the BRAC
Parcel. One of these areas, land south of Vehicle Road and
west of Scale House Road near the DRMO area, is leased by
Mr. Douglas Bricker. This lease was recently extended to 30
December 2001. This parcel is Parcel 29. which included in
the Phase I Parcel property.
CERCLA STATUS
Between 1980 and 1998. numerous environmental
investigation programs were conducted at LEAD to evaluate
potential contamination in die soil and groundwater at the
Depot. In 1986. the U.S. Environmental Protection Agency
(EPA) ranked the LEAD Southeastern (SE) Area (including
the Disposal Area (DA] and the Southeast Industrial Area
[SI A]) and the PDO Area under the Uncontrolled Hazardous
Waste Site Ranking System and proposed these two areas for
inclusion on the National Priorities List (NPL)- Figure 2
shows the general locations of die PDO and the SE Areas.
As a result of the proposed NPL ranking, the U.S. Army
Environmental Center (USAEC) took the initiative in
conducting the response actions at LEAD in accordance with
Executive Order 12316. signed on 14 August 1981 by
President Reagan, which delegates to the Secretary of
Defense the authority to take the lead on CERCLA activities
at Federal facilities, and a Memorandum of Understanding
(MOU) of 12 August 1983. between EPA and the DoD.
which defines the relationship for Federal facilities to take
the lead on such activities with EPA input
Executive Order 12580 was signed in January 1987. which
superseded Executive Order 12316. This Executive Order
C MmiWt.EAD\FNI..ROO OOCOO't'M)
PHASE 1 PARCELS
transferred authority for site investigations (Sis) and
remedial actions (RAs) at Federal facilities to the secretaries
of the applicable Federal agencies.
On 3 February 1989. a Federal Facilities Agreement (FFA)
was reached under CERCLA Section 120 between the DoD.
EPA. and Pennsylvania Department of Environmental
Protection (PADEP). The Southeastern Area was added to
the NPL in July 1987 with a Hazard Ranking System (HRS)
score of 34.21. and the PDO Area was added to the NPL in
March 1989 with an HRS score of 37.51. Remedial actions
are underway at both NPL sites.
POO AREA
The PDO Area encompasses approximately 1.490 acres in
the southern portion of the Depot It extends approximately
from the combat vehicle test track and heads south to Rocky
Spring Lake. The groundwater discharges at Rocky Spring.
which flows into the Rocky Spring Branch of the
Conococheague Creek.
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LECM)'
Hi
Or'
Cndrn* *•«•
uoo
MOO
Letterkennjr Army Depot
Chambersburg. PA
Fl|ure 4
Location ol PhM* I
Paretlt at LEAD
M 0* 1}
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LE1TERKENNY ARMY DEPOT
Analysis of soil. surfac:e water. and groundwater samples
. colletted during the investigatory programs conduc:ted in the
19805 indic:ated conc:entrations of chlorinated solvents. such
as tric:hloroethene (TCE). I.I.I-trichloroethane (TCA). and
their associated breakdown products. These constituents are
consistent with those used at LEAD for degreasing and
cleaning operations. Conc:entrations of total volatile organic:
compounds (VOCS) detec:ted in Rocky Spring have averaged
50 to 80 pans per billion (ppb) during t~ period 1981 to
1995.
Based on the information colletted to date for the POO Area.
six OUs have been created. These six OUs are:
. OU I:
Sourc:e Area Soils (soils from the Oil Bum Pit
(OBP] and drum storage revetments).
POO Area Groundwater and Surface Water.
Mercury Detettions in Rocky Spring Lake.
Groundwater Divide at 81-5 and Off-POO
Groundwater (Ammunition Area and OfT-
Post Residential Wells).
PCB Investigation of the Rocky Spring
System.
BRAC Waste Sites.
.OU2:
. OU 3:
. OU 4:
. OU S:
.OU6:
OUs I and 2 were originally established w~n the FFA was
signed. OU 3 and OU 4 were created in December 1992
based on data obtained during remedial investigations (RIs)
conducted in 1991. T~ creation of these two OUs permitted
the continued remedial action at OUs I and 2. while funher
investigation was conducted at OUs 3 and 4. OU 5 was
created in September 1995. with EPA and PADEP consent,
based on the detettion of PCBs in the sediments of Rocky
Spring. OU 6 is composed of waste sites. located in the to-
be-excessed part of the POO Area. that were identified as
pan of the EBS process. PDO OU 2 underlies the following
Phase I Parcels: 28.29.33. and 34. None of the other PDO
OUs are located within the Phase I Parcels.
The main source areas of contamination identified in the
POO Area are the drum stonge revetments (part of PDO OU
I ). the PDO Oil Bum Pit (part of PDO OU 4). the Open
Trench Landfill. and the DRMO Scrap Yard (PDQ OU 5).
None of these soun:e area are locared within the Phase I
Parcels.
SOUTHEASTERN AREA
The SE Area consists of the SIA and the DA and
encompasses approximately I. I 36 acres. Eight individual
OUs have been created in the SE Area at LEAD:
. OU I: K Area Contaminated Soils.
. OU 2: Industrial Wastewater Sewers and
Contaminated Soils.
~
PHASE I P ~RCELS-R[CORD OF OE("ISIO",
. OU 3:
SE Area On-Post Contaminated
Groundwater.
Storm Sewers and Contaminated Soils and
Sediments.
Area A and Area B Contaminated Soils.
SE Area OfT-Post Contaminated
Groundwater.
Truck Open Storage Area (north of
Buildings 32133YWaste Oil Sump.
BRAC Waste Sites.
.OU4:
. OU 5:
.OU6:
. OU 7:
. OU 8:
SE OUs 2 and 3 underlie the following Phase I Parcels: 1-13.
16-2 I. and 23-27. Portions ofSE OUs ~ and .,J are included
in the Phase 1 Parcels.
The main sources of contamination in the SE Area are the K
Areas (SE OU I). the former industrial wastewater lagoons
(addressed under the Resource Consel"lation and Recovery
Ac:t [RCRA). and the leaking industrial wastewater $ewen
(IWWS) (SE OU 2). None of these source areas are locared
within the Phase I Parcels. with the exception of portions of
SE OU 2. All of the leaking sewer lines have been repaired.
and there is no known soil contamination in the Phase I
Parcels associ81ed with leakage of the IWWS.
.:t.
, ';!
. .
ENFORCEMENT ACTIVITIES
Since the listing of the two NPL sites at LEAD. all of the
remedial activities at the site have been Army-led. in
coordinarion with the EPA Region III and PADEP
Southcentfal Region. No other potentiarJy responsible parties
(PRPs) have been identified. .
SECTION 3
COMMUNITY PARTICIPATION
HIGHLIGHTS'
Pursuant to CERCLA fI13(k)(2)(B)(i-v) and ~ 117. rhe
Proposed Plan for the Phase I Parcels at LEAD was released
to the public for comment on 30 Man:h 1998. This document
was made available to the public in the Administrative
Retord. located at the Coyle Free Library in Chambcrsburg
and at Building 6 I 8 at LEAD. .
The notice of availability of notification of the Proposed
Plan Public Meeting was published in ~ NnIIS CJrro,uc'~.
~ R«orrJ HrrJd. and 1M PNbIic OpinIOn on 30 March
1998. A public comment period was held from 30 March
1998 to 29 April 1998. On 7 April' 998. a public meeting
was held at the Building 500 Auditorium to present the
Proposed Plan and to entertain questions and comments from
the public. A response to the comments received during the
C 1AA/llY\l.EADlfM._ROO 00CIW2M8)
FINAL
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LETTERKENNY ARMY DEPOT
, .
[
comment period. including those raised during the public
meeting. are addressed in the Responsiveness Summary.
which is included as part of this Record of Decision. A
transcript of the Proposed Plan public meeting is provided as
Anachment 3 to this ROD.
SECTION 4
SCOPE AND ROLE OF
, RESPONSE ACTION
The response action selected for this site is a tinal action
with regard to soils and an interim measure with regard to
VOC-contaminated groundwater. which together address the
environmental concerns at the Phase I Parcels. This response '
action is limited to the Phase I Parcels. and is NOT intended
as a tinal measure to address the VOC-contaminated on-post
groundwater operable units (PDQ OUs 2 and 4. and SE OU
3). Final remedial actions for these OUs are being developed
separately. A Draft Final ROD' for PDQ OU 2 is currently
, under regulatory review. Draft Remedial Investigation (RI)
reports have been prepared for PDQ OU 4 and SE OU 2. and
SE OU 3 is in the Focused Feasibility Study (FFS) stage. '
The role of the response action selected for the Phase I
Parcels is to mitigate environmental threats at the properties
while making the partels available for beneficial reuse in a
timely fashion. ' '
SECTION 5
SUMMARY OF SITE
CHARACTERISTICS
NATURE AND EXTENT OF CONTAMINATION
Soli
Numerous studies have been conducted in both the PDQ and
SE Areas at LEAD. These studies identified several areas of
soil contamination. None of the identified soil contamination
areas that require action lie within the Phase I Parcels. Most '
of the other accessible contaminated soils have already been
addressed (e.g., the K Areas. IWWS soils, etc.) by on-site
treatment, or excavation and off-site disposal, co the extent
practicable.
Based on the Environmental Baseline Survey (EBS), several
of the Phase I Parcel areas underwent limited investigations
of the soils co rule out the potential for soil contamination
due to past operations. A screening protocol (including
methodology for the field investigations and comparison of
the results to available risk-based criteria) was developed by
the Anny. EPA. and PADEP. and the subsequent
investigations were completed in Fall 1997. The results of
these investigations were compared against the following
risk-based screening criteria:
C \ARM'I'\L~Nl_ROO DOC(1Q/1198'
PH~SE I P.\RCELS-RECORDOF OEClSIO'i
. EPA Region III Risk-Based Concentrations (RBCs) for
Industrial Use (October 1991).
. PADEP Act 2 Medium-Specific Concentrations. Used
Aquifers. TDS <2.500. Nonresidential Soil to
Groundwater Pathway. and Direct Contact Values.
No Further Action Decision Documents have been prepared
to administratively close out these areas of concern (AOCs).
Pareel 24
Parcel 24. which includes Building 500 and adjacent lands.
was identified through historical aerial photographs as
having been used for open vehicle storage early in LEAD's
operation (post World War II). Two test trenches were
completed in this partel. and one sample was analyzed for
Target Analyre List (TAL) metals and total petroleum
hydrocarbons (TPH). The only compound that exceeded the
screening criteria was arsenic. which slightly exceeded the
EPA RBC. EPA and PADEP. along with the Amy. as part
ofthc BRAC Cleanup Team (BCT). agreed that the detected
concentration did not warrant further remedial action for
industrial use. Arsenic is a naturally occurring metal. and
arsenic results obtained at LEAD are not inconsistent with
the published background concentrations for this '!Jdal in
Pennsylvania (Shackleue and Boemgen, 1984). Residential
and child-intense use scenarios were not evaluated.
Pare'" 1 and 2
Parcels I and 2 are open land located south of Coffey
Avenue near Gate 6. Historic vehicle storage and temporary
coal storage were observed in aerial photographs. which
prompted the screening investigation. Eight test trenches
were completed in these parc:els. and no visual evidence of
contamination was noted. Six soil samples were collected
and submitted to the laboratory for analysis. Only arsenic
and beryllium were detected at concentrations that exceeded
the EPA RBCs. EPA, PADEP. and the Anny agreed that the
detected concentrations did not Wamu1t further remedial
action for induStrial use; Arsenic and beryllium are naturally
occurring metals. and arsenic and beryllium results obtained
at LEAD are not inconsistent with the published background
concentrations for these rwo metals in Pennsylvania.
Residential and child-intenSe use was not characterized.
Pareel 2t
Parcel 29 is 'a large undc~eloped parcel that is leased to a
private farmer for agricultunl use. Evidence from historic
aerial photography indic:ated temporary vehicle storage in
this area. Sixteen test trenches were completed in Parcel 29.
and eight soil samples were collected and submitted to the
laboratory for analysis. Only arsenic and beryllium were
detected at concentrations that exceeded the EPA Region II'
RBCs. EPA, PADEP, and the Army agreed that these
concentrations did not warrant further remedial action for
continued commercial/industrial use. Arsenic and beryllium
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LETTERKEMVYA&WYDEPOT
are naturally IXcurring metals, and arsenic and beryllium
resultS obtained at LEAD are not inconsistent with the
published background concentrations for these tWo metals in
Pennsylvania. Residential and child-intense use was not
characterized.
Soil borings were advanced within the perimeter of Parcel 29
as pan of the investigations for PIX> OU S. (Parcel 29.
although initially included as pan of PIX> OU S. is being
addressed as pan of the Phase I Parcels.) Only sanered low
levels of PCBs were observed. at concentrations well below
action levels. The BCT agreed that no further action was
warranted based on continued industrial use.
Paree'.'0 through 13
An Installation Assessment Repon ( 1980) indicated that a
spill of pesticides had IXcurred near Dock 4S and that
damaged pesticide containers had been stored at this dlXk. .
However. a figure in the repon showed a much larger area as
the site for the spill. To detennine whether residual levels of
pesticides were present from these incidents. a sampling
program was conducted thaC included all of the sheds along
the docks. sampling of adjacent railroad tracks. and
topographic: low areas (where runoff may have collected).
Fifty-one soil borings were completed during the Dock 4S
investigations. All samples were analyzed using field
screening test kits.. which would identify the presence of a
wide scan of pesticides. including the target pesticides
malathion and diazinon. None of the soil samples were
positive for pesticide content. To continn these results. 20%
of the samples were randomly selected and submined to the
laboratory for confirmatory analysis. No pesticides were
detected in the laboratory analyzed samples.
R8i1ffMd Traclca WIthin the Ph..., Pare.
Infonnation from interviews with former employees
indicated thilt heavy doses of herbicides were routinely used
along the railroad tracks. and thaCoils may have been applied
to suppress vegetation. Com posited soil samples were
collected along the railroad tracks in the SE Area warehouse
district. The only constitucnu that were detected above the
screening criteria were arsenic and ~lIium. which
exceeded the EPA RBCs. EPA. PAQEP. and the Anny
agreed that these concentrations did not warrant further
remedial action for continued indusUiaJ use. Arsenic: and
, beryllium are naturally occurring metals. and arsenic and
beryllium results obtained aC LEAD are not inconsistent with
the published background concentrations for these tWo
metals in Pennsylvania. Residential and child-intense use
was not evaluated.
Groundwater
VOC-contaminated groundwater exisU beneath all of the
PDQ and SE Areas. which include aU of the Phase I Parcels.
The primary contaminanu of concern detected are
trichloroethene (TCE). I. I ,I-trichloroethane (TCA), 1.1-
PHASE I P -'RCELS-RECORD OF OECISIO'
dichlorethane (DCA). 1.2-dichlorethene I DeE). and
tetrachloroethene (PeE). all of which have been detected at
concenrrations exceeding their respective Maximum '
Contaminant Levels (MCLs).
Route. of Exposure
The VOC-contaminated groundwater has been identified
migrating off-post for several miles from the SE Area. with
VOC detections in numerous springs. On-post. contaminated
, groundwater is highly interconnected with the surface water:
this situation does not occur in the Phase" Parcels. In the
PDQ Area. a sinkhole is located in the recreational area to
the north of South Patrol Road. This sinkhole serves as a
conduit for surface water to now into the groundwater
system. Groundwater then surfaces downgradient at the
Rocky Spring House. where it nows into RlXky Spring lake.
and then across a man-made dam to an off-Depot stream.
which eventuaUy discharges into the Conodoguinet
watershed.
Potential routes of exposure include:
. Dennal contact with sOil and groundwater.
. Inhalation of soil dust and vapors.
. Ingestion of soil and or groundwater. ,
;'.'-
..: .w
,/-
...,..,;
, .:::;
<""'
For the risk assessments conducted previously for the SE and
PIX> Areas. all of the above exposure pathways were
considered for on-Depot workers. since that was the current
and anticipated future use of the propeny. The probable
exposure pathways under the future uses proposed by LI DA
are consistent with those for current on-Depot workers.
"
SECTION 6
SUMMARY OF SITE RISKS
Risk Assessmenu (RAs) were conducted for specific: areas
within the PIX> and'SE Areas'. LEAD. These RAs provide
the basis for taking action and indicated the exposure
pathways that need to be addressed by the remedial action. It
served as the baseline indicating the risks thai could exist if
no action is taken aC the Phase I Pan:els. This section of the
ROD summarizes the results of the RAs conducted for th is
Site.
CONTAMINANTS OF CONCERN
Soil and groundwater data collected during the RJs were
reviewed and evaluated to detennine the contaminants of
concern at the Site that are mosi likely to pose riw to public
health. None of the soil samples collected during the Rls
were located on the Phase I Parcels. However. these data
have been considered to include conservative soil
concentration values. The selected contaminants of concern
for the site groundwater are shown in Table I (Tables are
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C IARM'tlLEADlfNl_ROO DOCI1CIII/I8)
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LETTERKENNY ARMY DEPOT
presented in AttKhment :!).
EXPOSURE ASSESSMENT
The objective of the exposure assessment was to estimate the
magnitude of potential human exposure to the contaminants
of concern at LEAD. Current and future receptors were
evaluated based on current industri~ and potential future
(indusU'ial) land use.
Currently. there are workers on-site. The exposure pathways
for the current worker sc:el\,8rio group included dennal
contact with. and incidental ingestion of. contaminants in
surface soils along with the inhalation of soil gases from the
volatilization of groundwater VOCs.
tuture potential receptors included an on-site construction
worker who would be in contact with and would be using
groundwater at the site.
The future on-site consU'Uction worker potential exposure
pathways included dermal contaCt with. and incidental
ingestion of. contaminants in surface and subsurface soils.
inhalation of soil gases. and consumption of. and dennal
contact with. groundwater.
At the time that the POO and SE Area risk assessments were
conducted. the anticipated future use of the property was
indusU'ial. Therefore. no other usesc:enarios were
considered.
The exposure scenarios. mathemlUital models. and the
assumptions that were used to talculare the intakes (i.e..
doses) of the chemitals of concern for each receptor through
the applicable exposure route are presented in Tables 2
and).
TOXICITY ASSESSMENT
In evaluating potential health risks. both c:an:inogenic and
noncarcinogenic effects were considered. The potential for
producing c:an:inogenic effects is limited to substances that
have been shown to be c:II'Cinopnic in animals and/or
humans. Excessive exposure to all substances. carcinogenic
or noncarcinogenic. C8II produce noncarcinogenic effects.
Therefore. reference doses. when available. are identified for
every chemical selected regardless of its classifJC&tion. and
cancer slopes are identified for those chemitals classified as
carcinogenic.
Carcinogen.
Slope factors (SFs) have been developed by EPA for
estimlUing excess lifetime cancer risks assoc:ilUed with
exposure to potentially carcinogenic contaminants of
concern. SFs. which are expressed in unitS of(m~g-dayr'.
are multiplied by the estimated intake of a porential
carcinogen in m~g-day to provide an upper bound estimate
C IARII'I"LEAD\FNl_AOO OOC!1Q111t8)
'.
PHASE I P ARCEa..s--RECORD OF O[n~lo'
of the excess lifetime cancer risk associated wilh the
exposure at the intake level. The term "upper bound" rel1ec!)
the conservative estimate of the risk calculated from the SFs,
Use of these approaches makes underestimation of the ac!ual
cancer risk highly unlikely. Sfs are derived from the results
of human epidemiologital studies of chronic animal
bioassays to which animal.to-human extrapolation and
uncertainty factors have been applied (e.g.. to account for the
use of animal data to predict effects on humans).
The EPA weightooOf-evidence classification systems for
carcinogenicity is presented in Table 4. and the
carcinogenicity classification for the contaminants of
concern is presented in Table S.
Noncarcinogena
Reference doses (RIDs) have been developed by EPA for
indicating the potential for adverse health effects from
exposure to contaminants of concern exhibiting
noncarcinogenic effects. RfDs. which 'are expressed in units
of m&fkg-day. are estimates of lifetime daily exposure levels
for humans. including sensitive individuals. Estimated
intakes of contaminants of concern from environmental
media (e.g.. the amount of a contaminant of concern ingested
from contaminated drinking water) can be compared to the
RIDs. RIDs are derived fTom human epidemiological studies
or animal studies to which uncertainty factors have been '
applied (e.g.. to account for the use of animal data to predict
effects on humans). The RIDs used in this evaluation and the
references used for each contaminant are listed in Table S.
RISK CHARACTERIZATION
This risk characterization is an evaluation of the nature and
degree of potential carcinogenic and noncarcinogenic health
risks posed to the cumnt woriter and future consU'UCtion
workers receptorS at LEAD. In this section. human health
risks are discussed independently for potential c:an:inogenic
and,nonc:arc:inogenic effects for cOfltaminants because of the
different toxicological endpoints. relevant exposure duration.
and methods employed in chanlCtCrizing risk.
Carcinogenic Fel.ka
For c:arc:inogens. risks are estimated u the incremental
probability of an individual developing c:anc:er over a
lifetime as a result of exposure to the c:arc:inogen. Excess
life-time c:anc:er risk is calculated from the following
equation:
Risk a CDI X SF
where:
risk - a unit less probability (e.g.. 2 x 10") of an
individual developing cancer:
COI = chronic daily intake averaged over an
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LEITER KENNY .4&WY DEPOT
PHASE I P "'RCElS-RECORD OF OECISIO'
SF:
eseimated exposure period (mglkg-day); and
slope factor. expressed as
(mi'k&-dayrl
These risks are probabilieies that are generally expressed in
scieneific notation. An excess lifetime cancer risk of I x 10"
indicates thac. as a reasonable maximum eseimate. an
individual has a 1 in 1.000.000 chance of developing cancer
as a result of lEAD-related exposure to a carcinogen over a
working lifetime under the specific exposure conditions at
the Site.
For ehe currene on-site worker scenario. ehe lifetime excess
cancer risk was estimated to range from 9.6 x 10.11 to 7.5 x
10" in the SE Area. and 4.2 x 10" to 1 x 10.0 in the PDO
Area. For the future consb'Uceion worker scenario. the
lifeeime excess cancer risk were estimated to range from 2.4
x 10'~ to 6 x 10'~ in the SE Area and from I.S x 10~ to 4.1 x
IO~ in ehe PDO. The primary ditTerence betWeen the current
and future worker scenarios was the consumpeion and use of
VOC-concaminated groundwater.
Noncarcinogenic Risks
The poeential for noncarcinogenic: effects is evaluated by
comparing an exposure level over a specific eime period
(e.g.. lifetime) with a referenc:e dose derived for a similar
exposure period. The ratio of exposure to toxicity is called a
hazard quotient (HQ). By adding the HQs for all
concaminantS of concern that atTect the same target organ
(e.g.. liver) widtin a medium or across all media to which a
given population may reasonably be exposed. the Hazard
Index (H I) can be generated.
The HQ is calculated as follows:
Nonc:ancer HQ - CDI/RFD
where:
COt : Chronic Daily Intake
RID ... Reference dose; and
CDI and RID ate exprased in the same unitS and represent
the same exposun period (i.e.. chronic. subchronic. or short-
tenn).
The results of the risk calculations indicated that the HI for
the current WOR. scenario ranged belwcen 3.6 x 10.0 and 2.5
X 10'2 for the SE Area. and well below I for the PDO Area.
For fucure worker scenarios. however. the His ranged from
3.3 to 3.5; attributable mainly to the assumed ~ and
consumption of groundwater.
ECOLOGICAL CONSIDERATIONS
The Phase I Partels include several commercial and
industrial buildings. paved roadS and paved parking areas. an
C IARM'llLEADlFM._ROO DOC( 1011191)
agricultural parcel. and areas of mowed grassy lields and
small stands of trees. This configurarion inhibits the
formation of habiw areas. as it is completely de...eloped.
Given the nature and future use of the Phase I Parcels. it is
unlikely that the site would constitute a significant habital or
atreci threatened or endangered species idenlified as being
polentially present aalEAD.
RISK UNCERTAINTY
There is a generally recognized .uncertaintY in human risk
values developCd from experimental data. This is primarily
due to the uncenainty of data extrapolation in the areas of ( I )
high to low dose exposure. (2) modeling of dose response.
effectS observed. (3) route 10 route extrapolation. and (4)
animal data 10 human data excrapolation. The site.specific
uncertainty is mainly due to the degree ofaccurac:y ofthe
exposure assumptions;
In the presence ofsuch uncenainty. the EPA and the risk
assessor have the obligation to make conservative
assumptions such dtat the chance is very small for the actual
health risk to be greater than ~at determined through the risk
process. On the ocher hand. the process is not to yield
absurdly conservative risk values that have no basis in
reality. That balance was kept in mind in the development of
exposure assumptions and pathways and in Ihe interpretation
of data and guidance for the baseline risk assessment for this
Site. The environmental condition oflhese parcels is
expected to improve based on actions plan~ed or in progress
at the other OUs.
d'.
.;...'i..
-.
REMEDIAL ACTION OBJECTIVES (MO)
Remedial action objectives for the contaminants of concem
in the Phase I Parcels were developed to prevent direct
contICt and ingestion of soil under residential and other
nonindustrial exposure scenarios. to prevent direct contact
and ingestion of groundwater under any scenario. and to
reduce exposure 10 levels of concaminants that produce
unacceptable risk levels.
Selection of final.remedial measures regarding groundwater
will be presenced in separate RODs.
SECTION 7
DESCRIPTION OF REMEDIAL
ALTERNATIVES
CERCLA requires thai each selected final site remedy be
prolective of human hea1d1 and the environment. be cost
effective. comply with other statutory laws. and use .
permanent solutions and alternative treatment technologies
and resource recovery alternatives to the maximum extent
practicable. In addition. the statute includes a preference. for
the use of treatment as a principal element for the reduction .
FINAL -...
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LETfERKENNY ARMY DEPOT
of toxicity. mobility. or volume (TMV) of the hazardous.
substances.
Based on the available information. the Army has evaluated
the following two alternatives: -
Alternative I: No Action
Alternative 2: Institutional Controls
These alternatives are discussed below. The evaluation of the
alternatives against the nine CERCLA-mandated criteria are
presented in the following section.
ALTERNATIVE 1: NO ACTION
. Capital Cost:
S- Vear Review Cost:
Present Worth Cost:
so
S15.000/review
535.000
CERCLA guidance requires that the no-action alternative be
considered as a baseline for comparison of other alternarives.
No remedial actions would be implemented under this
technology. The present worth cost is based on tWo S-year
performance evaluation reviews/reports.
ALTERNATIVE 2: INSTITUTIONAL CONTROLS
Capital Cost:
S-Vear Review Cost:
Present Wortb:
Annua. Recurring Cost:
51.500
S15.OOOIrevlew
S41.!OO
51,000
This alternative involves the use of institutional controls.
Initially. the institutional controls to prohibit nonindustrial
use of the parcels and activities that would result in any
exposure to the contaminants in the groundwater will
become part of LEAD policy via an amendment to the
LEAD Master Plan. At the time of me property transfer. the
institutional controls will take the form of environmental
deed restrictions. The environmental deed restrictions shall
be protective of human health and the environment by:
. Restricting the property for commerciat and industrial use
only.
. . Not permining soil excavation activities below a depth of
3 feet above the water table without prior approval of the
Anny.
. Not permitting construction of any subsurface structure
for human occupation. without the prior approval of the
Anny. PADEP. and the EPA.
. Restricting access or use of the groundwater underlying
the property without the prior written approval of the
Anny. PADEP. and the EPA.
These restrictions will be instituted through an amendment of
LEAD's Master Plan for the Phase I Parcels to reflect these
controls until the date of transfer. At the time the property is
C ~"'_ROO ~1Q/'/I8)
PHASE ( PARCELS-RECORD OF Of.( I~IO'
transferred. the restrictions will be implemented through tr
use of appropriate deed restricrions. which will be recordeo
at the time of transfer. In addition. upon transfer of the
property. the Anny. in consultation with EPA and PADEP.
will establish periodic inspection procedures to ensure
adherence to the institutional controls. The present wonh
cost includes tWo S.year perfonnante evaluarion
reviews/reports.
SECTION 8
SUMMARY OF COMPARATIVE"
ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives. each
alternative is assessed against the following nine evaluauon
criteria: overall protection of human health and the
environment: compliance with applicable or relevant and
appropriate level requirements (ARARs); long-tem
effectiveness and pennanence; reduction of toxicity.
mobility. andlor volume: short-term effectiveness;
implementability; cost; regulatory acceptance: and
community acceptanCe.
A comparative analysis of the two altemarives based on
these evaluation triteria is presented in the following
sections.
THRESHOLD CRITERIA
Overall Protection of Human Health and the
Environment
AIt8m.t1v8 1: No Action
No remedial action would be implemented under this
alternative. The cunent site conditions and property use
present no risk to human health because the groundwater is
not used and conscituentS in the soils do not exceed industrial
RBCs. This altemative. however. is not protective of an
unrestntted use scenario. Furthermore. since soils were
evaluated only for indusaial use scenarios. there may be
potential risk under different types of use s<:enarios. The
potential fOr exposure and associated risk for exposure to
VOC-contarninated groundwater to future land usen is high
considering activities such as constrUCtion. .
During periods ofhiah groundwater table elevations. the risk
of exposure to VOC-contaminated groundwater would
increase.
No permanent habiws for aquatic life exist within the BRAC
. Parcels. Therefore. no evaluation of aquatic risk was
necessary. No significant risk to terrestrial recepton was
identified for the Pttase I PIIIQ!s due to both a lack. of
sustainable habiw and insignificant levels of
bioaccumularing contaminants.
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LEITERKENNY ARMY DEPOT
Alternative 2: Institutional ContlOla
Institutional controls would be implemented under this
alternative. The enf~ment of the institutional controls.
specifically the requirement for industrial use only and the
prohibition of contact with. and consumption of. soil and
groundwater would eliminate exposure pathways that could
present significant risk (0 future users. The institutional
controls would mitigate both the carcinogenic and
noncarcinogenic risks described in Section 6 above.
No pennanent habitats for aquatic life exist within the BRAC
Parc:els. Therefore. no evaluation of aquatic risk was
necessary. No significant risk to terrestrial receptors was
identified for the Phase I Parc:els due to both a lack of
sustainable habitat and insignificant levels of
bioaccumulating contaminants.
Compliance with AMRa
Since this ROD involves an interim measure with regard to
groundwater contamination. final remediation goals and.
hence. ARARs are not identified here. This ROD. however
does present a final action for soils. The soils under boch
alternatives would be in complianCe with all.ARARs.
Chemlcal-Sp«iflc ARARa'
. PADEP Act 2 Medium-Specific Concentrations.
Appendix A. Tables 3A and 4A. Nonresidential Surface
Soil 0-2 Feet; and Tables 38 and 48. Used Aquifers. TDS
<2.500. Nonresidential. Generic Value.
Action-Specific ARARs
Neither alternative would be subject to action-specifIC
ARARs. .
Location-Sp«lfIc ARARa
No location-specific ARARs are required.
PRIMARY BALANCING CRITERIA
Long-Term EtrKtiveneu and Permanence.
Altematlve1: No Ac:fIon
Implemenwion of the ncHCtion alternative could be
effective and permanent in the long-tenn if considering the
soil alone because no significant contamination is presenl.
assuming continued industrial use. However. in the long
tenn. other tenants/owners of the property could be exposed
to contamination through excavation and contact with the
groundwater. and the property could be used for
nonindustrial purposes. possibly increasing the risk to human
health. Therefore. Alternative I does not meet the
requirements for long-tenn effectiveness and pennanence.
C \NIM'tILEADlFIIIL_ROO OOC( 1011111)
~
-
PHASE I P~RCELS-RECORD Of DEnSIO'lt
Altemative 2: InStitutiona' Controls
The long-renn effectiveness of the institutional controls ~ill
be contingent upon enforcement of use restrictions initially
by the Anny through the LEAD Master Plan. and after
transfer. through enforcement of the environmental deed
restrictions. The enforcement of these restrictions will be the
responsibility ofLiDA. the Anny. EPA. and PADEP.
Implementation of this alternative would mainrain the
indusuial use of the property and reduce the future risk of
exposure to groundwater by the development and
enforcement of environmental deed restrictions. Because
these restrictions would become a pennanent part of the real
estate documentation and would be required to be included
in any subsequent sales. transfers. and/or lease agreementS.
this alternative would be a long-tenn and pennanent
remedial action.
Reduction in Toxicity, Mobility, or Volume
Neither altemaaive results in a change in toxKity. mobili!)';
or volume. since the alternatives do not involve physical
remedial actions. Thesoil~ do not contain levels of
constituents above the EPA Region III industriaf RBCs or
the PADEP Act 2 criteria. with the previously noted
exceptions that are the result of background conditions.
Furthermore. because groundwater contamination and the
source areas are being addressed under separate operable
units. the statutory preference for remedies that employ
treaanent thai redllCe5 the toxicity, mobility. and/or volume
as a principal element will be addressed by the tinal
groundwater response.
Short. Term Effectivene..
Ah8matIve 1: No Adiolt
Alternative I would not meet the requirementS for shon-tenn
effectiveness. Currently. LEAD prohibitS use or contact with
groundwater. and there is only indusaial use of the property
on die PtIue I P1rte1s. Once die property is transferred to a
private entity. there is no legal provision to keep future land
users from being exposed to the contaminated groundwater.
and from using the property for nonindustrial purposes.
Ah8matIve 2: InMJtutIonM Contt'oM
Under this alternative. institUtional controls would be
implemented to mitipre risk due to exposure to
groundwater. This alternative would have short-tenn
eft'ec:tiveness because the Anny will formally document the
requirements of the institulionaJ contrOls by amending the
LEAD Master Plan. This will pro"ide effectiveness from the
finalization of the ROD until the date of transfer. The
environmental deed rescriCtions would be in place from the
date ofuansfer. which will provide for long-tenn
effectiveness (see above).
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LETITRKENNYARMYDEPOT
Implementabillty
Altemativ8 1: No Action
Under the no-action alternative. there are no measures to
implement.
Altflmdv8 2: Institutional Contro18
Alternative 2 can be easily implemented. The short-tenn
implementation of the preferred alternative would involve
amending the LEAD Master Plan to include the irwitutional
controls that are already in place infonnally at the Depot.
Once the amendment is added. appropriate direc:torates at
LEAD (the environmental division. Public Works. securicy)
will be provided with a copy and with the enforcement action
chain-of-command for infractions. .
Concurrent with this activicy. the Depanment of the Anny
would be developing deed restrictions for the Phase I
Parcels. The BCT has already discussed the propercy transfer
environmental restrictions. and the deed restrictions will be
presented to the regulatory representatives for concurrence.
Cost
Alternative I.solely has the estimated costs of the two S-year
reviews associated with its implementation. The costS
presented for Alternative 2 are estimated. and may vary
depending on the number of parcels that are transferred
separately.
MODIFYING CRITERIA
State Acceptance
PADEP. on behalf of the Commonwealth of Pennsylvania.
concurs with the selected remedy.
Community Acceptance
Only one set of commentS was rec:eived on the Proposed
Plan during the Public Comment Period. These comments
and responses to these comments are provided in the
Responsiveness Sununuy of this ROD.
SECTION 9
THE SELECTED REMEDY
Based on consideration of me CERCLA requirements, the
NCP. the detailed analysis of the alternatives using the nine
criteria. and public and state comments, the Anny and EPA
have selected an institutional controls remedy for this Site.
The total present worth costs of the selected remedy are
estimated at $42.500. with an annual rec:urring cost of
SI.OOO/year.
The selected remedy. Institutional Controls. shall include the
following components:
C \MIIIMI.£AD\FNL-"OO 00C4 10"l1li
PHASE I PARCELS-RECORD OF OECISIO'
. Restricting the propeny for commercial and industrial US(
only.
. Not pennining soil excavation activities below a depth of
3 feet above the water table without prior approval of the
Anny. .
. Not pennining construction of any subsurface structure
for human occupation without the prior approval of the
Anny, PADEP. and the EPA. .
. Restricting access or use of the groundwater underlying
the propercy without the prior wrinen approval of the
Anny, PADEP. and the EPA.
These restrictions will be instituted through an amendment of
LEAD's Master Plan for the Phase I Parcels to retlect these
controls until the date of transfer. At the time the property is
transferred., the restrictions will be implemented through the
use of deed restrictions, which will be recorded at the time of
transfer. In addition. upon transfer of the propeny. the Army.
in consultation with EPA and PADEP. will establish periodic
inspection procedures to ensure adherence to the institutional
controls.
SECTION 10
STATUTORY DETERMINATIONS
. UnderCERCLA Section 121. EPA must select remedies that
are protective of human health and the environment comply
with applicable or relevant and appropriate requirements
(unless a statutory waiver is justified), are cost-effective. and
utilize pennanent solutions and alternative lreaanent
technologies or resource rec:overy technologies to the
maximum extent practicable. In addition. CERCLA includes
a preference for remedies that employ trcaanent that
permanently and significantly reduce the volume. tOJ(i~icy. or
mobiliry of hazardous waste as their principal element The
following sections discuss the remedy in light of these
statutOry requirements.
PROTEcnON OF HUMAN HEALTH AND THE
ENVIRONMENT
The remedy shall be protective of human health and the
environment. The institutional controls will mitigate both the
carcinoaenit and nonQI'Cinogenic risks described in Section
6.~ .
COMPLIANCE WITH APPLICABLE OR
RELEVANT AND APPROPRIATE
REQUIREMENTS
The selected final remedy with regard to soils will be in full
compliance with all applitable or relevant and appropriate
requirements (ARARs). Since the remedy regarding.
groundwater is an interim measure. final cleanup obJecuves
FINAL
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LETTERKENNYARMYDEPOT
and ARARs will be addressed in subsequent OU RODs.
COST EFFECTIVENESS
The selected remedy. Instinltional Concrols. was chosen
because it provides the best balance among criteria used to
evaluate the alternatives considered in the Detailed Analysis.
The altem~ive was found to achieve bom adequarc
protection of human health and me environment and to meet
the stanltory requirementS of Section 12 I of CERCLA. The
selected remedy was found to be cost-effective. The cost of
Alternative 2 has been established to be $7.500.
. UTILIZATION OF PERMANENT SOLUTIONS
AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
EPA and PADEP have determined that the selected remedy
representS the maximum extent to which permanent solutions
C ~_ROO oocc 1 011/11)
'"
~
,
PHASE ( P ARCEl.s--RECORD OF OECISIO'
and treatment technologies can be utilized in a COSf-dfccti"c
and timely manner for the Phase I Parcels. The ground~ater
panion of this action. however. is interim and is not intended
to utilize permanent solutions and altematiye treatment (or
resource recovery) technologies to the maximum extent
practicable.
PREFERENCE FOR TREATMENT AS A
PRINCIPAL ELEMENT
. The selected remedy for the Phase I Parcels. Institutional
Controls. does not wisfy the SWutory preference for
treatment as a principal element ofthe remedy. With
respect to me soils. as long as the property is noc used for
non-industrial purposes."a treatment remedy is not
required. As for the groundwater. since the selected action
docs not constitute a final remedy. the statutory preference
for remedies that employ rrcatment.that reduces toxicity.
mobility. or volume as a principal clement will be
addressed by the final groundwater response action. .
. ~
..
FINAL.
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1
. .
LETTERKENNY ARMY DEPOT
PHASE I PARCELS
CHAM8ERSBURG. FRANKLIN COUNTY. Pf:NNSYlVANIA
RESPONSIVENESS SUMMARY
SEPTEMBER 28. 1998
SECTION 1
OVERVIEW
Based on an assessment of site conditions and remedial
alternatives. the Army and EPA selected a preferred remedy
for the Phase I Parcels at Lettertenny Army Depot.
Chambersburg. Pennsylvania. The selected remedy addresses
the threat associated with the contaminated groundwater
beneath the parcels and the potential threat associated with
the soils in the event of non-industrial land use. As specified
in the Record of Decision (ROD). the remedy involves the
implementation of deed restrictions and other institutional
controls that will be protective. of human health and the
environment.
Based on the comments received during the public comment
period. the residents and Letterkenny Industrial Development
Authority (LIDA) strongly support the implementation of the
institutional controls altentative for the Phase I Parcels. Only
one set of written comments was received during the public
comment period on the Proposed Plan; these comments came
from the legal counsel representing LlDA.
SECTION 2
BACKGROUND ON COMMUNITY
INVOLVEMENT
CHRONOLOGY OF COMMUNITY
INVOLVEMENT
Community relalionl aictivities . LEAD to date have
included public meednp; review and coordination ~inp
with Federal and SI8I8 repIItory personnel: site visits;
meetinp with elected Federat. swe. and local officials and
with community groups: news releases to the local media;
and direct contaa with nearby property owners.
Community interviews were conducted in 1988 as pan of the
process of developing the Public Involvement and Response
Plan. which was published in 1990. At the time of the 1918
community interviews. the ~rimary areas of concern to the
community were the groundwater contamination problem
and associated health and property value issues. .
LEAD has a Restoration Advisory Board (RAB). which
began meeting in 1996 and focuses primarily on the
C ~NL_ASUM OOCIW2MI}
restoration activities related to DERA and BRAC actions.
The RAB replaced the Technical Review €omminee (TRC).
formed in 1988. which was the previous vehicle by which the
community could provide comments and review progress on
the environmental programs at LEAD. LEAD representatives
attend RAB meetings and meetings of the Letterkenny
Industrial Development Authority (LlDA) (fonnerly the
Franklin County Reuse Committee) and provide status
updates on environmental activities at LEAD.
Meetinp with regulatory agency personnel have been
conducted regularly and are held with representatives from
lEAD. U.S. Anny Corps of Engineers (USACE). PADEP.
EPA Region III. Department of the Army. and U.S. Anny
Materiel Command (AMC). Topics of discussion at these
meetings generally include review of project status. review
of new technical information. resolution of problefn areas.
and direction and schedule of funher studies. In addition to
the formal meetinp. LEAD. USACE. PADEP. and EPA
personnel maintain frequent telephone and E-mail contact on
an as-needed basis.
Site visits to LEAD have been made by representatives ofthe
RAB. USACE. PADEP. EPA Region III. and contractors.
Numerous site visits by the regulatory agency representatives
have promoted communication betWeen lEAD. PADEP. and
EPA.
Periodically since June 1912. when the groundwater
contaminabon problem was first identified. fannal news
releases have been issued by LEAD concerning the
groundwater issue and Other sources of contamination. These
news releases typically conllin information on the initial
phases of investiplion and/or remedial worlL Recently.
much of the news coverage has concerned cleanup with
regard to the BRAC parcels and the statuS of lease and
transfer of the property.
The residents in the vicinity of LEAD have generally reacted
favorably to the efforts made by the Depanment of the Anny
with regard to the identification and cleanup programs
underway and proposed. The oft'-post sampling of wells for
potential groundwalcr contamination during the 1910s made
nearby residents more aware of the contamination problems.
existing at LEAD. However. the prOactive approach by the
Army to identify potential problems and mitigate exposure
(by providing connection to a public drinking water soun:e
for residents whose wells had potential or known .
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LETTERKENNYARMYD£POT
PHASE I PARCELS-RECORD OF OECISIO'
contamination) was received favorably.
KEY COMMUNITY CONCERNS
The community is greatly concerned about the Superfund
sites and LEAD in the long-tenn future. Community
interviews were conducted on 26-28 June 1997 at the Depot
,as part of the revised Community Relations Plan. Telephone
interviews were conducted prior to and after the on-site
interviews. Each interview participant was 'asked 37
questions. Nineteen individuals participated in the
interviews: 2 Depot residents and 17 Chambersburg-area
residents. Persons interviewed for the revised Community
Relations Plan identified seven areas of concern.
Cleanup Activitie.
Generally. the interviewees were pleased with the ongoing
environmental cleanup activities. Several noted that for the
, last 8 to 10 years. Depot staff have worked hard to solve
environmental problems at the site. Some interviewees
expressed concern that the cleanup activities were taking too
long. The majority of interviewees agreed that the
government is committed to cleaning up the hazardous waste
at LEAD. Most of the interviewees wanted to know the I
status of specific cleanup activities (e.g.. data. results. costs.
and schedule). One mentioned that some of the
environmental repons were too technical to understand.
Some wanted the government to finish the remedial process
as quickly as possible. whereas others thought that the
government should take the time needed to be sure to do a
thorough remedial process. One individual believed that the
Anny's environmental standards may not be as suingent as
the' public's standards in the leve. of cleanup activities.
Several expressed a concern to return areas to fannland use
and to coordinate effortS to preserve existing farmland. A
few residents noted that farmers do not seem to be concerned
about contamination because fanning activities continue on
property adjacent to LEAD.
Some were conccmed that cleanup activities would continue
after areas were open for public: reuse. One resident said that
$350 million was too much toP8)' for groundwat~
contamination cleanup on-site and thai documentation of the
historic value of a warehouse before tearing it down was
"foolish."
Reu..
Noting the economical impact of having fewer civilian jobs
with the realignment of LEAD. the majority of the
interviewees have accepted LlDA's reuse plan. '
Some thought the reuse of areas of LEAD ~as a positive step
in preserving farmland/agriculture and pristine areas of
Franklin County.
Some thought the reuse plan was overly optimistic and that
the public would have to pay for the reuse activities. Many
interviewees were concemed about the feasibility of taking
, care of the reuse areas of LEAD. Many were concerned with
potential liability jf additional Anny-generated
contamination is discovered in the reuse areas.
A few were concerned about the typeS of industry that may
be brought in and the potential for re-contaminating the site
and creating noise or traffic problems. Some were concerned
how the Army wili provide access to the reuse areas. grant
public use of the reservoir. and share the Depot infrastructure
(electricity. water. sewer. etc.). One person suggested that
the state site a low-level radioactive waste disposal facility as
a reuse option at LEAD. '
Contamination
Several intervieweeS stated that the extent of contamination
is unknown and that more contamination may bedisco\fcred.
One said that the Army brought materials from across the
country for disposal at the DepoL Another said that studies
show that the contamination is spreading. Residents are
concerned that the solvents in the groundwater and streams
will directly affect the population. Several mentioned
concerns about specific areas at the Depot:
. The apartment complex (Kenny Gardens Housing).
. The old quarT)' (Fagan's Quarry).
. Rocky Spring Lake.
. Mercury in the lake.
. Fire practice training areas.
. Lead contamination at the ammunition detonation area.
. Discharge &om LEAD (belo~ Gate 6) into streams after a
heavy rain. ' '
Air Quality
A few residents said thar the" Army needs to address air
quality in addition to soils and groundwater contamination.
Ammunition Detonation
Many residents expressed concern about the ammunition
detonation activities at the Depot. They said the Army
sometimes conducts this activity on weekends during the
noon hour. Some interviewees believe that the blasting is
causing plaster to cruk in homes adjacent to and about a
mile from LEAD. One resident said tha& the impact of the
detonations is worse for homes a greater distanCe ITom
LEAD than the homes nearer to the Depot. Several
mentioned that contaminants must be released into the air as
a result of the ammunition detonation. Residents voiced
concern about noise. air quality. and dust control regardin(
the detonation activities.
Government
C IARW'tILEADlfff._AStM ooc(iI'29Ii8l
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LEITERKENNY ARMY DEPOT
Half of the interviewees said that the general public mistrusts
Federal and state government agencies. One resident said.
"No matter what an individual thinks. the government will do
what they want and thai the government does not think an
individual is important to consider," However. the majority
of the interviewees believe that the Pennsylvania Depanment
of Environmental Protection is the most credible government
agency regarding environmental issues.
Army
The majority of the interviewees believe that the Anny is
commined to cleaning up the contamination at LEAD. One
resident was pleased that LEAD is a government site because
the Anny is obligated to clean up the site. whereas a
commercial venture could opt to abandon a contaminated
property. Some specific concerns include:
. The Army is rushing to transfer areas to the public
because of community pressure and could compromise -
environmental cleanup activities.
. The Anny cannot meet the deadlines because of the
holdup caused by complex environmental problems.
. Some individuals have reservations about some
information received from LEAD and are concerned that
they may nor be getting all of the information. One
individual panicipaced in tWo tours of the facility and
questioned the use and contents of a building with
concenina wire. The question was not answered to the
individual's satisfaction: therefore. this person believes
the Anny is hiding something. .
. There was a lack ofresponse from the LEAD Public
Affairs Officer when residents complained about the
blasting and poor quality of the office's answering
machine (very shan tape).
Eighteen of the 19 interviewees said they had an
understanding of the Base Realignment and Closure
activities at LEAD. The majority of the inrerviewees were
favorable towards the cleanup activities related to the Base
Realignment and Closure parcels. In addition. the majority of
the interviewees were supportive ofLlDA's reuse plan. Most
individuals also were favorable tOwards the cooperation and
interaction between me Anny and LlDA in freeing the to-be-
excessed parcels as soon as possible. .
SECTION 3
SUMMARY OF COMMENTS
RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY
RESPONSES .
The public comment period on the Proposed Plan. for the
Phase I Parcels was held from 26 March to 27 April 1998.
Comments received during this time arc summarized below.
PHASE I P"RCELS-RECORO Of OE<.I~IO'
RESUL 1S OF THE SCREENING
I NVESTtGA TIONS
Comment I: "I'M resullS of the soil sampling conducted
on ~a' of the parcels indicated
concentrations of annric and beryllium
that acettkdEPA Region III Risk &ued
Concentrations (RBCs) for the industrial
ingntion scenario. LIDA expressed a
concern chat the reuse plan cails fOT a mix
of commercial and industrial uses in the
Ph~ I Parcels area, and requested that
confiTJ'I'JIZtion ~ maM as to whether the
8no furUwr action" decision is consistent
with the proposed reust. LIDA also
requested that DEP provitk concurrence
on the "no furthe-r action" deczsion.
Response I: The levels of arsenic and beryllium that were
found ~n the Phase I P~cls are believed (0 be naturally
OCCUlTing. and not a result of operations and/or disposal
practices. The BRAC Cleanup Team (BeT). comprised of
represcnwives from LEAD. EPA Region III. and PADEP.
reviewed these results with consideralion of the proposed
reuse. and unanimously agreed that no soil remediation is
warranted. The reference to a "no further action" decision is
more accurately a decision to implement an institutional
conll'Ols remedy to maintain continued like use of the
propeny. The arsenic and beryllium results obtained al
LEAD arc not inconsistent with the published background
concentrations for these two metals in Pennsylvania. The
BCT believes thai the commereiallindusuial uses outlined in
the reuse plan are consistent with the current use of these
parcels. In addition. the Anny and EPA are signatories on
the decision documents for each of the parcels where
screening sampling WIS conducted and PADEP concurs with
the decision.
PARCEL-8PECIFIC COMMENTS
ComlM1l~ 2: UDA npms«J C01lCems about tTl10 fuel
spiJ/s rrporced to haw occurmJ on the
Building 4) parcel, and the sU/flCimcy of
tht clu"..". .
Response 1: The two spills are documented in the Phase I
Environmental Baseline Survey (WESTON. Augus& 19%).
The first spill occurred on the paved road adjacent (0
Building 43 and consisted of leakage of approximately 10
gallons offucl ontO me road. At the time oftne ~pi".lhe fuel
was soaked up with absorbent materials. The second release
occurred during tank tiptness testing. Contaminated soils
were excavated and removed.
C ~NL_ASUM.OOCIW2MII)
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LETnRKENNYARMYDEPOT
RISK ASSESSMENTS
Comment J: 1M Proposed Plan cites risk assessments
chat ~ performed at a time when CM
luturt use of LEAD was continued
industriaL LIDA requested confirmation
that these risk assessments art consistent
wich their reuse plans.
Response J: The risk assessments that were performed
included evaluation of future worker scenarios with the
assumption of use and consumption of groundwater. at the
request of PADEP. The implementation and enforcement of
the institutional controls will keep the exposure (and the
resulting risk) within acceptable bounds. The two risk
assessments (for the PDQ and SE Areas) can be found in the
C IARM'tlLEAOIfNL_ASUM DOC(!iI2MI1
PHASE I P "RCElS-RECORD OF DECISIO'
Administrative Record for LEAD. eilher al Building 618 or
at the Coyle Free Library in Chambersburg. .
ENFORCEMENT OF THE INSTITUTIONAL
CONTROLS
Commmt 4: 711e enforcement 01 the deed restrictions is
cited as being the responsibility 01 LIDA,
the Army. EPA, and PAD£P. LlDA
. commented that since t/1ese restrictions
wi/L be bound by t:ked. adjoining propercy
owners haw jurisdiction to enforce the
actions via a private action.
Response 4: The Anny and EPA concur.
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LEITERKENNY A~\1Y DEPOT
ATTACHMENT 1
REFERENCES
C 1ARM'tIUAW"'_RT8l.~'OI".}
FINAL
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LE7TERKENNY ARMY DEPOT
ATTACHMENT 1
REFERENCES
Acker. R.C. 1955. Water Supply from Wells for Letterlunny Ordnance. Letter Report 10 District
Engineer. U.S. Anny Corps of Engineers. Baltimore District.
Archaeological &: Historical Consultants. Inc. December 1996. PhaH I A rchaeologrcal SuT't.~,
Lmvlunny Anny DqJot. Franklin County, Pennsyl\'ania.
Battelle. June 1983. Geophysiclli Surwoy ofeM SoUeMIISt Aru of LEAD.
Battelle. September 1983. Emnronmtnllli ConCAminallOn SuJ"tlt'y OJ LEAD: Sout~lIStl"dust""I
A TrA.
Battelle. October 1983. Environmtntlli Contaminalion Su""'Y of LEAD: Pro~ DISposal Office
Dra'nag~ Sysmn.
Battelle-. December 1983. Ellvironmtntlli ConCAmi1J4110n SuJ"tlt'y of LEAD: Exploratory and
Confirmalory Phasn..
Battelle. May 1984. En'Cllronmtnllli ConCAmi1J4lion SU""'Y of LEAD: Mulll'P~ Inwmgatlon
Summary.
Becher. A.E. and L.E. Taylor. 1982. GroundW41n' Resources in eM Cumbnland and Conllguol4S
Valkys of Franklin County. PtnnsylvaniA. Pennsyl\'ania Geological SUr\'ey Water R~sources
Report 53. HarTisburg. PennsylvaniL
Berger Asso<:iates. 1981. Army Pol/ulion AbrJumtnl Program SludUs.
Building Technology Incorporated. July 1984. Historic Propmies Report, Lettn*mny A rmy
Depot.
Dames and Moore. Inc. 1993. AsbalOf Surwoy . uturltenny Army [)qIot.
Dames arid Moore. Inc. 1996. Lud.&std Paint Surwy- utterlrmny A rmy Depot.
Dragun. J~ and A. Chiasson. 1991. ElmltnlS in North American Soils. Hazardous Materials
Control Resources Institute. Greenbelt. MD. .
EA (EA Engineering. Science. and Technology). 1991. Siu Inwstigalion. LEAD.
EMC (En\'ironmental Management Consultants). July 1988. AsbalOf Su~. B"ildin8 663.
Lettnltmrry A mry DqJoL
EMC (Environmental Management Consultants). 1988. AsbatOf Su""'Y' BuiJdJng 1. uturirmny
Army DqoL
EMS (Environmental Management Systems)~ 1989. Asmtos Asussmtnl SU""'Y 101' uturltmny
Army Depor.
EQM (Environmental Quality Management). August 1995. Dock)$ CJOfMrr! Report. utteTltmny
Army Depor.
ERM (Environmental Resources Management. Inc.). January 1995. uturltmrry Army [)qJo1-
SWMU Siu /rrwmgation FoUO'fIH)n Report, fUN A 009. .
ESE (En\'ironmental Science &: Engineering. Inc.). August 1986. RmudiM InwstigallOn of tM
Dupoul A ru al LEAD.
C INWYILEJ\C'#HlJ"Tk.OOC(,~,/II)
FINAL
-------
LETTERKE.:,,'NY .4~\1Y DEPOT
ATT-\CH\IE'iT t
REFERE'CES
. ESE (Environmental Science &. Engineering. Inc.). September 1981. Rem~dl41 Inf,'emgatlon ofeh..
Propmy DispowJ Offict ATta ar LEAD. .
ESE (Environmental Science &. Engineering. Inc.). December 1981.Remtdi4/ In1.l~mgaclon ofche
SolirMASC~ AP'l'a ar LEAD. .
ESE (Environmental Science Ik. Enaineering. Inc.). 1988a. FtASibrliry Srudy oft~ Propmy
DispoSid OfficI A I'U ar Lmclm,,,., A mry Dtpor. Gainesville. Florida. .
ESE (Environmental Science Ik. Enaineerina. Inc.). I 988b. Fus,biliry Study of ~ SoMC~ASC~
A rell of Ltturlcm"., A"", £Ape. First Opnabk Unu. Gainesville Florida. .
ESE (Environmental Science Ik. Engineerina. Inc.). \989. FtAS,bility Study of t~ SoUChtASltTTl A Tta
of LtltMm"., A""y DqJor. Second Opnabk UrUL Gainesville Florida.
ESE (Environmental Science Ik. Enaineerina. Inc.). August 1993. Draft AdikndMm to ehe
Remtdial lnwstigaflon of eM SolirMAScem A P'l'a at uttvltm"., A""y Dtpot Contammatlo"
Assessmmr of K A Tta Sow.
ESE (Environmental Science Ik. Engineering. Inc.). September 1995. PDO Nt'fIJ au IS Silt
Inwsrigarion. PCBs in Rocky Spri"g l.4Jte. Draft Report.
FCADC (Franklin County Area Development Corporation). 1993. 199) FranJJi" Cou"ry Dac.
Boo"
Franklin County Reuse Comminee (now know as the Lctterkenny Industrial Development
Authority [LIDA). May 1991. u~"., Army Drpol Rt'" Scrattg] s"mtrJAry Report.
. .
Geonex Corporation. August 1995. Drllft Wetlands Mappi"g RqIOrr for United StattS A ""y.
L~tlerltenny Army DtpoL
John Milner Associates. 1981. An A rchMoJogic," RtCon1l4JisSAnet of Propowi Dtw/opmml SUtS at
th~ Ltltn/rm"., A rmy lNpot
Kearney. A.T. and The Eanh Technology Corporation. February 1988. RCIU Fac,/ity Assnsmml
Phase I ~/jminary Rt'tIIew of Solid W/ISU Ma1l4Jge'Mml Units.
Nature Conservancy. Pennsylvania Science Office. December 1992. An Irwmtory ofS,gruficani
£coJogiaJ FeatMra of eM Ltttniem", A rmy Depot, "",.},liPl eoNn". PmnryJwPlia.
PCMSylvania State Univenity and Envirosphere Company. January \985. API ArchMoiogac,"
Owm&w and MaMgerMIIl PIAn for the ultvltmny A rmy {)qoL
R.E. Wright Environmental. Inc. July 1994. Dr4ft Reporr for Built.Ung Inwstigal,ons for Radon
Recommmtliuions.
R.E. Wright Environmenral. Inc. July 1995. RMiIJ,. Tuti", Pl4J1. Leturltmny A rmy Depot
R.E. Wright Environmental. Inc. March 1991. Draft Reporrfor Building Inwstigal,ons fOT Rado"
R«ommma.cions. utttriemny Army Depot
Root. 5.1. 197\ (Reprinted 1914). ~/ogy "nJ Miner," RaourctS of Norrhusum Franle/in
CONney. PmrsryJw,.... Pennsylvania Deparancnt of Environmental Resources. Atlas 119ab.
Harrisburg. Pennsylvania.
Shacklette. H.J. and J.G. Boemgen. \984. "Element Concentrations in Soils and Other Surficial
Materials of the Conterminous United States." u.s. Geologic," SNrwy Profmiorwi P4fJt1" 1270.
U.S. Department of the Interior.
C WtM\'\LEADlFNl_RTk QOC{1Q111!111
F 1NA1..
-------
LE7TERKENNY ARMY DEPOT
ATT~CH\'E'T I
REFERE'([S
SS&M (spots. Stevens and McCoy). December 1991. letterto P ADEP on Closure of Storage Pad
at Building S26-5. Letterkenny Army Depot.
USA THAMA (U.S. Army Toxic and Hazardous Materials Agency). 1980. ("seallaCto" ASStSsm~"c
of utrmunny Arm)' ~t, Rqx1rf No. /61., Abmkm Proving Ground, Maryland.
U.S. Department of Defense. Fall I9CJS. BIUC Cleanup Plan (BCP) Guidebook.
U.S. Departmenl of Defense. 1995. DoD Base RtUH Impkmmeation Manual.
U.S. Department of the Army. February 1987. Evaluation of Solid Wastt Manag~mt Uniu.
U.S. Department of the Interior. National Park Service.I9CJ2. Seandardsfor R~habz{ieauo" 411d
illustrated GuideJi7U$ for Rehabilitating Histonc BUIldings. .
V ersar. Inc. May 1994. Rmutiiallnwstigalion/FeaibiJicy Study uttmmny Army DqJot
Property Disposal Office A /'ta, Operable U",u J and 4, Work Plan. .
WESTON (Roy F. Weston. Inc.). 1984. LEAD RemedWllnWJtigation and Feailnlity Scudy.
WESTON (Roy F. Weslon. Inc.). 19%. Phase I EnvironmmcaJ Baseline Surwy, ultmmny
Arm)' lXpoc. BRAC 9' Action.
WESTON (Roy F. Weston. Inc.). 1997. CERFA utter Repon (Firwi) utterltmnyArmy Dqot.
WESTON (Roy F. Wescon. Inc.). 1997. T«hnioU Pt.n for Inwstigalion of PCBs in eM Rocky
Spring S)'StmJ Propnry DispouJ O/fict(PDO)Area, Oprrabk Unit' (OU 5), utterltmny Army
lXpot. ..
WESTON (Roy F. Weslon. Inc.). 1997. Finding ofSuicabiJicy to UIW (FOSL) for BUIldings 6, 9,
19.411,416, 500, 511, and 1291 (Firwi) Letur/r.mny A,.",., ~t.
WESTON (Roy F. Weslon.lnc.). 19988. Dtcis,on DocummtforBIUC Parcels 1 and 2.
uturltmny Army Dqot. ..
WESTON (Roy F. Weston. Inc.). 19CJ8b. Dtcision Documentfor BRAC Parcels 8 chrough 13,
Lettnkm", Army DqoL
WESTON (Roy F. Weston. Inc.). 1998c. Dtcisiora Docummtfor BRAC P4rcel24. ucur/r.m",
Army lApoL
WESTON (Roy F. WestOn. Inc.). 1998d.Dtcision Document for BRAC Ptlrctl29. ucterlemny
Army lApor.
WESTON (Roy F. Weston, Inc.). 1998e. Dtcision Documnttfor BRAC FtaiJroad Parcels,
utterltmny Army DqoL
WESTON (Roy F. Weston. Inc.). 1998f. Dtcision Documentfor BRAC Buildings 6 and 9,
utterlrnlny Army Dq10L
WESTON (Roy F. Weston. Inc.). 1998g. ~ II EmJironmmtaL BaseliM Surwy (!>raft)
LettnlmJ", Army Dqot, BRAC 95 Action.
Weston Services. Inc. 1989. £PmA Soil Ga ll1wstiguioll RtpOrt.
C IAAMYlLEADlFML_RTk 00(;('0I'1tIn
FINAL
i
'I!
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LEITERKENNY ARMY DEPOT
ATTACHMENT 2
RISK ASSESSMENT TABLES
C \ARImL£ADIF"'_RTk 00CI1Q11/18)
FiNAl
-------
LETTERKENNY ARMY DEPOT
Table 1-Contaminanta of Concern (COC) in the SE and PDO Areas at LEAD
() r~.11I II. ( ()(, I 11111,:.:.1111'. «)(,
Acetone (ACET) Arsenic (AS)
Benzene (C6H6) Beryllium (BE)
Bromodichloromethane (BRDCLM) Cadmium (CD)
Carbon tetrachloride (CCL4) Chromium (CR)
Chlorofonn (CHCL3) Copper (CU)
I.I-Dichloroethane ( II DCLE) Lead (PB)
1.2-Dichloroethane (12DCLE) Manganese (MN)
t .2-Dichloroethene (12DCE) Nickel (NI)
I.I-Dichloroethene (II DCE) Thallium (TL)
Methylene chloride (CH2CL2) Zinc (ZN)
Tetrachloroethene (TClEE)
Trichloroethene (TRCLE)
1.1./- Trichloroethane (111 TCE)
1.1.2- Trichloroethane (112TCE)
Trichlorofluoromethane (CCL3 F)
Toluene (MEC6HS)
Trans-I.2-dichloroethylene (T 12DCE)
Vinyl chloride (C2H3CL)
Chlordane (CLDAN)
Heptachlor (HPCL)
Diethylphthalate (DEP)
Bis (2-ethylhexyl) phthalate (B2EHP)
Pentachlorophenol (PCP)
C ~NL_RT8l.DOC('OI'''1
FiNAl
:III
,
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LETTERKEV'vY A~\.fY DEPOT
:\ TTACH\IE~T 2-RISK ASSESS'InT T ",8LES
Table 2-Expo8ure Scenarios with App~icable Sites and Exposure Pathways
Curran
Worker
F uturc
Worker
-S
x
x
x
-s
.0-
.0-
x
x
x
Note:
AA = ambient air (vapors).
FS = fish.
G W = groundwater.
SE = sediment.
50 = soil.
S W = surface water.
der = dennal.
inh = inhalation. .
X = This receptor/padlway is evaluated based on measured chemical concentrations at the (sub)
contamination area. . .
~ = This receptor/pathway is evaluated to estimate the risks associated with future worker use
of site groundwater should it ever be used as a Waler supply.
-S = This receptor/pathway is evaluated based on modeled chemical concentrations in air at the
source (over the contamination area). .
Source: ESE (Environm~ntal Science ct Engineering. Inc.). 1994. RisJt Asussmml 01 ~ So~lISurn A rr:a at
utterlmrrry A may Dq1oI, Ofwrabk Uniu OM and Tlnw-FirwJ RqJO'ff.
C IAAM'tII.£AO\FNL- AT1IL 00CI10111181
FINAL
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LE7TERKE.Vl../Y ARMY DEPOT
A TT-\CH"E~T 2-RISK ASSESS\IE'T T -\BLES
Table 3-Fonnula8lAasumptions for Intake Calculations
Ambient Air. Inhalatloa Exposure (Volatilization rrom Soilaad Surface Wlter to Outdoor Air)
Where:
CAa =
IRaa =
EFaa =
ED =
BW =
AT =
CAa x IRaa x EFaa:c ED
Intalee (mg/kg/day) =
BW x AT
chemical concentration in ambient air (mglm\
intake rate for ambient air (m~/day).
exposure frequency for ambient air (days/year).
exposure duration (years).
body weight (kg).
period of rime over which expo,sure is averaged (days).
Groundwater. InhalaUon Exposure (Theoretical Worker Exposure 10 Vapors While. Showering)
Where:
CAs =
IRas =
EFas =
ED =
BW =
AT =
CAs x IRas x EFas x ED
[ntake (mg/lcg/day) = BW x AT
chemical concentration in shower air (mglm]).
intake rate for shower air (m]/day).
exposure frequency for shower air (days/year).
exposure duration (years).
body weight (kg).
period of time over which exposure is averaged (days).
Groundwater. Ora. Exposure
Where:
CGW =
IRgw -
EFgw -
ED -
BW -
AT =
CGW:c IRgw x EFgw x ED
[nlalee (mg/lcg/day) = BW x AT
chemical concencraiion in groundwater (mglL).
intake rate for groundwater (LIday).
exposure frequency for contaminated groundwater (days/year).
exposure duration (years).
body weight (kg).
period of time ovet which exposure is averaaed (days).
C \ARamlENN"'_ATIl OO<:{'QI'~I
FINAL
-------
LEITERKE.V.VY ARMY DEPOT
ATTACH"E~T 2-RISK ASSESS\IDiT T .\SLES
Table 3-FormulasJAssumptions for Intake Calculations
(Continued)
Soil. Dermal Elposure
Where:
CSo =
FCs =
SAso =
AF =
ABS =
EFso =
ED =
BW =
AT =
CSo x FCs x SAso x AF x ASS x EFso x ED
Imau(mg~~~) = BWxAT
chemical concentration in soil (mg/kg).
conversion factor for soiVsediment (kgtmg).
skin surface area available for soil conraet (cm~/event).
soil/sediment to skin adherence factor (mgtcm~).
chemical-specific absorption factor (unitless).
exposure frequency for soil (eventS/year).
exposure duration (years).
body weight (kg).
period of time over which exposure is averaged (days).
Soil. lahalallo'n Exposure (Suspended Puticulates in Ambient Air)
Where:
CSo =
PEF =
IRaa =
EFaa =
ED =
BW =
AT '"
Soil. Oral Exposure
Where:
CSo -
IRJo ..
FCs -
Flso ..
EFso ..
ED ..
BW ..
AT =
C IARM'I'II.EAOIINL_ATk DOC(1Q11111'
CSo x (IIPEF) x IRaa x EFaa x ED
. In/ake (mg/lcg/~) = BW x AT
chemical concentration in soil (mglkg).
paniculate emission factor (m)lkg).
intake rate for ambient air (mJ/day).
exposure frequency for ambient air (days/year).
exposure duration (years).
body weight (kg).
period of time over which exposure is averaged (days).
- --
CSo x IRso x FCs x FIso x EFso x ED
Imake(m~qv~)= BWxAT
chemical concentration in soil (mg/kg).
soil ingestion rate (mgtday).
c:onvmion factor for soiVsediment (kgtmg). .
fraction of soil ingested from contaminated source (unitless).
e~ frequency for soil (days/year). .
exposure duration (yean).
body weight (kg).
averaging time (days).
FINAL.
-------
~
LETTERKENNY A~\1Y DEPOT
ATT..\CH:\o'E~T 2-RISK ASSESS\IE'T T\BLES
Table 3-Formulas/Assumptions for Intake Calculations
(Continued)
What ElpGSure P....meten Were Used ror LEAD SE?
ABS
Chromium VI
Inorganic chemicals (other than Cr VI)
Polychlorinated biphenyls
Semivolatile organic chemicals
Volatile organic chemicals
0.15
0.01
0.05
0.10
0.25
Hawley. 1985
Ryan et al.. 1987
Ryan et al.. 1987
Ryan et al.. 1987
Ryan et a I.. .1987
AF
1.0 mglcm1
kaolin clay on hands
EPA. 1992a
Site soils consist predominantly of silty loam (ESE. 1992). Since clay has a higher AF than sand or paning soil.
the AF for clay is used as a conservative RME.
AT
carcinogenic effectS
noncarcinogenic effects
70 years x 365 days/year
ED (years) x 365 days/year
EPA.1989c
EPA.1989c
BW
Adult (Residential. Worker)
70 kg average (male and female) of 5011t percentile
values for age = 18 to 75 years
EPA.I99la
CA.
The concentrations of chemicals in ambient air (at the source and 400 meters downwind of the source) that have
volatilized for soil are modeled values based on chemical-specific parameten (i.e.. soil concentration. Henry's
Law COnstlnr. K.. etc.) and site-specific parameters (i.e.. soil depth. soil porosity. wind velocity. etc.).
CAs
. .
The conc:enlJ'ltion ofVOCs in shower air is a modeled value based on the average values presented by McKone
(1987) for the chemicals of concern at the site. McKone values were used because they are the mOSt realistic and
most conservative,
I) CGW
. 2) Ratio of chemical concentration in shower air
to chemical concentration in water (mglL).
measured value.
.
18 11m'
,. J
CAs(mglm) x CGW(mglL)xI8(Um)
C IAAM't\L£ADIFNL_RT8L 00<:1101'11181
FINAL
-------
LE7TERKENNY ARMY DEPOT
:\ TT -\CH\lE~T 2-R'SK ASSESS\lE'\T T 'BLES
Table 3-FormulaalAssumptions for Intake Calculations
(Con~nueci)
CGW I cSe I CSo I CSW
The upper 95 percent confidence limit (UC[.q,) of the mean chemical concenuation was used to represent the
RME exposure concentration. If the UCI,.q, exceeded the maximum detected chemical concentration. the
. maximum concentration was used to represent the RME.
ED
Adult (Worker)
25 years
national 9Sth percentile time at one workplace
EPA. 1991b
EF..
.
Worker ( Adult)..-..C urrent
12 days/year Assumes that grass in the contamination areas is cut 2 times per month during the average
growing season of 162 days/year.
Other than incidental dermal. inhalation. and oral exposure to soil by maintenance personnel cuning grass or
performing other minor duties in the potentially contaminated areas. no other worker exposure to soil is expected
to occur at these sites.
. . .
.: ... ,~;~.
Worker (Adult)-Future
250 days/year
amount of time spent at work
EPA. 1991b
EFaw
2S0 days/year
.
number of days spent at work
EPA.I99lb
Site groundwater is not cwrently used as a water supply on the base. Evaluation of future worker exposure to
groundwater has been requested by the regulatory agencies; therefore. this pathway has been included as a
conservative estimate of possible theoretical future exposure.
[Fso
Worker (Aduh)....Current .
12 daysiyear assumes that grass in the contamination areas is cut 2 times per month during the average
growing season of 162 days/year.
Other than incidental dermal. inhalation. and oral exposure to soil by maintenance personnel cuning grass or
performing other minor duties in the potentially c:oncaminarid areas. no other worker exposure to soil is expected
. to occur at these sites.
Worker (Adult)-Future
2S0 days/year
amount of time spent at work
EPA.I99lb
C 1ARM'IIL~"'_RT1IL.DOC( 1011181)
FINAL
-------
LEITERKES.VY .-\RMY DEPOT
A TT ACH\IE'iT 2-RISk; ASSESS\IE"'T T -\BLES
Table 3-Formulas/Assumptions for Intake Calculations
. (Continued)
FCs
I X 100{) kglmg
FCw
0.00 I UcmJ
IRaa
Worker (AduIO-Cummt
5 m '!day based on a reasonable upper-bound occupational inhalation rate for an 8-hour workday (20
m)/day (EPA. 1991b») and assumes that maintenance personnel may work in the area 2
hours/day. .
Worker (Adu\t}-Future
20 mJ/day reasonable upper-bound occupational inhalation
rare for an 8-hour workday.
EPA 1991b
IRp
1.0 Uday
reasonable occupational ingestion rate
EPA.I99lb
Site groundwater is nor currently used as a water supply on the base. Evaluation of future worker exposure to
groundwater has been requested by the regularory agencies: therefore. this pathway has been included as a
conservative estimate of possible theoretical fuhU'C exposure.
.
I RIo
Worker (Adult}-('urrent
12.5 mglday based on the typical adult workplace ingestion rate for an 8-hour wortc.day [50 m8lday (EPA.
1991b») and assumes that a person works in the area 2 hours/day.
Worker (Aduh\-Future
50 mglday typical adult workplace ingestion rate for an
8-hour workday.
EPA 1991b
C IARMYlLEAWNL_RT8L OOC(IQjllW'l
FINAL
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LEITERKENNY ARMY DEPOT
A TT -\CH\1E'ltT 2-RISI\: ASSESS\IE'T T \BlES
Table 3-FormulasJAssumptions for Intake Calculations
- (Continued)
SAso '
Values are based on the average adult (male and female) 50'h percentile body pan surface areas (m!) in EPA.
1985 multiplied by a conversion factor of 10.000 cm!/m!. 50th percentile values are used because surface area is
related to body weight and average body weights over rhe ED were used in the exposure calculations. It is
assumed t.hat work.er:s at LEAD will wear long pants. a long-sleeved shin. and gloves while at the facilicy. For
conservativeness. It IS also assumed that personnel will remove their gloves occasionally. allowing for incidental
contact of the hands and half of the head.
hands
'/z head
904
~
1.506 cm2
References
Environmental Science &. Engineering. Inc. (ESE): 1998. EndAngtT'Mmt A!SaSmmt of the Southeast"" A ITa at
uClvlemny Army DqJot. Final R~rt. U.S. Amy Toxic and Hazardous Materials Agency. Installation
Restoration Division. Contract No. DAAA I S-8S-()'()() 17. Gainesville. FL.
Environmental Science &. Engineering. Inc. (ESE). 1992. RnnedW Investigation of eM SoUtMAs'"" A ru at
Letcmm,ny Army lApot (LEAD). PJ.rlimi""." Drfl/t RqJ07'f. U.S. Anny Toxic: and Hazardous Materials Agency. -
Installation Restoration Division. Contract No. DAAA I S-8S-D-0017. Gainesville. FL. -
Hawley. J.D. 1985. "Assessment of Health Risks from Exposure to Contaminated Soil." Risk A1J4/ysi,s. 5(4):289-302.
Hazardous Substanc~ DataBank (HSDB). 1993. National Library of Medicine (NLM). Mic:romedex TOMES PLUS.
System CD/ROM. Version 16. Expires 4/30/93. Managed by Micromedex. Inc.. Denver. CO.
Integrated Risk Infonnation System (IRIS). 1993. U.S. Environmental Protection Agency (EPA). Micromedex TOMES
PLUS. System CD/ROM. Version 18. Expires 10/31/9). Managed by Micromedex. loe.. Denver. CO.
McKone. T.E. 1987. "Human Exposure to Volatile Organic Compounds in Household Tap Water: The Indoor
Inhalation Pathway." £nwr. Sci. and Tech. 21(12): 1/94-1201.
National Oceanic and Armospheric Administration (NOAA). Naval Oceanography Command Detachment Asheville.
and USAfETAC. 1990. International Station Meteorological Climarc Summary for Glenview.lllinois. Version
1.0. National Climatic: Data Center. Federal Clima&c Complex. Asheville. NC.
Ryan. E.A.. Hawkins. E.T.. Maaee. B.. and Santos. S.L. 1987. "Assessing RisktTom Dermal Exposure at Hazardous
Waste Sites."!n: PnxtetIin" of the ". NAtional Superfund Confnmct. Hazardous Materials Control Research
Institute. Silver Spring. MD.
U.S. Environmental Protection Agency (EPA). 1985. Dcwlopmnrc ofSl4listietJ Distributions or Ranges ofSC4ndArd
Faaon UsaJ in UposMfT AJrasmtna. Office of Health and Environmental Assessment. Offi<:e of Research and
Development. Washington. DC. EPA/600/8-8S/010. -
U.S. Environmental Protection Agency (EPA). 19898. Exposure Faaon H"ndbooIe. Firlili RqIOrt. Offi<:e of Health and
Environmental Assessment. Washington. DC. EPA/600/8-89/043.
U.S. Environme_ntal Protection Agency (EPA). 1989b./nterim Final GMiJ.n" for Sod Ingestion Raus. Office of Solid
Waste and Emergency Response. Washington. DC. OSWER Directive 98S0.4.
U.S. Environmental Protection Agency (EPA). I 989c. Risk Assmmmt GMitJ.ncrfo-r Supnfund (TuGS). Volum~ 1:
HUmiln Htaith Evlliuatio" Manual. Part A. Offi<:e of Emergency and Remedial Response. Washington. DC.
EPA/S40/1-89/002.
U.S. Environmental Protection Agency (EPA). 1991a. Risk ASStSfmmc GMitJ.ncrfor Supnfund(RAGS). Volume 1:
HUTn4n Heaith £ vaJ""tion ManwJ. Part B ~pmmt of Risk.&u«J PITlimirl4ry RnnediAtJort Coals). Office of
Emergency and Remedial Response. Washington. DC. OEM 928'.7-:OIB.
'. -.
C \l\RM\'lL£AD\FNl- An&.. OOCI , 011/18)
FINAL
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L£1TERKE.NNY ARMY DEPOT
ATTACHME~T 2-RISK ASSESS\1E'T T \8lES
Table 3-Formulas/Assumptions for Intake Calculations
(Continued)
U .5. Environmental Protection Agen<:y (EP A). 1991 b. Risk Assnsmmt Gu""'nc~ forSuprrfund (RA CS). Vo'um~ 1:
HunJ4n Hullh Evaluation Manual, SupplemmuJ GuIdAnce (StaniUrd Dt/auil £XpoSI4~ Factors). Intenm Fl71al.
Office of Emergency and Remedial Response. Washington. DC. OSWER Directive 9285.6-03.
U.S. Environmental Protection Agen<:y (EP A). 1992a. DermAJ Expos"", Assmmml: PrinCIples and ApplicatIons.
. lntmm Rt'fx)Yt. Offi<:e of Research and Development. Washington. DC. EPAl6001 8-91/0 II B. NTIS No. PB92-
205665.
U.S. Environmental Protection Agen<:y (EPA). 1992b. Htalth ElfteD Assmmmf Summary Tabln (HEAS7]. Annual FY
. /992. Office of Research and Development and Office of Emergency and Remedial Response. Washington. DC.
OEHA ECAO-CIN-82I. NTIS No. PB92-92 I 199. .
U.S. Environmental Protection Agenc)' (EPA). 1992c. Hellilh EIf"ts Assmmmi SMmmary Tabks (HEAS7]. A 1'1 1'1 uaL FY
/992; Supplemmt No.1. Office of Research and Development and Offi<:e of Emergency and Remedial Response.
Washington. DC. OEHA ECAO-CIN-82IA. NTIS No. PB92-921199A. .
U.S. Environmental Protection Agenc)' (EPA). 1992d. Hulth El!tCfS Assmmmt Summ"ry Tabks (HEAS1). Annual FY
/992; SuppJemmuJ No.2 Office of Research and Development and Office of Emergenc)' and Remedial
Response. Washington. DC. OEHA ECAO-CIN-82IB. NTIS No. PB92-92 I 102.
C \AIUI'I'\L£ADIF",-_ATk OOC(10111t8)
FINAL
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LE7TERKENNY ARi\1Y DEPOT
A TT ~CH"E~T 2-RISK ASSESS\IE'T T -'8LES
Table 4-Welght of Evidence Classification System for Potential Carcinogens
. I' \ 11'"""/'1'1'"'' I
, I
( ;1":~lIr\ I IIIC.rlllll' ! Ih""I'I,,,"," 1,"luln"
Group A Human can:inogen Sufficicnt cvidence from epidemiologic studies 10 support a
casual associalion bdween exposure and cancer.
Group 8 I Probable human carcinogen Limiled evidence of tarCinogenicity in humans from
epidemiologic studies.
Group 82 Probable human carcinogen Sufficient evidence of carcinogenicity in animals. but
inadequate data in humans.
Group C Possible human carcinogcn Limited evidence of tarCinogenicity in animals and no data
in humans.
Group D Not classified Inadequate evidence of can:inogenicity in animals.
Group E No cvidence of carcinogenicity in No evidence of carcinogcnicity in alleast two adequaIC
humans animal tests or in both epidemiologic and animal studies.
Soun:e: U.S. Environmental Protection Agency (EPA). 1989. RisJr Assasmmc G..it/imctfo1' SKfW"IKrui. (RAGS).
Vo/JUne I: HImI4'11 Htlllth Ew/wJlIo'll M.nlM/., P.rr A. Offic:e of Emergency and Remedial Response.
Washington DC. EPAlS40/1.89/002.
C ~"'_AT8&."DOC('O/'-1
FINAL
,~
-------
\8LES
Table 5-Chronic Dose.Response Toxicity Constants for the COCs in the SE and PDQ
Are.. at LEAD
I 0,.01 f~"1 I I"".d U II) I f ), ." I o..,, ! Intr.,r i
11"",'1
( ""1111<." I ( ~, i II II ( ,,~ I \\... ( '. \\ II.
i
Jnora..ie Chemicals (JOC)
Arsenic J.OE-04 (J) - I. 8 E +0011 A '.OE+-OI A
Beryllium .5.0E-03 (100) - 4.3E+OO B2 8.4E+OO' 82
Cadmium (aqueous matrix) '.OE-04 (10) - - -
Cadmium (solid matrix) t.OE-O) (10) - - &.IE.OO' 81
Chromium. lotal': .5~OE-03 (.500) ndlJ - 4.IE-oI" ..\
Copper 3.7E-OZ'.I. (Z) - - -
Lead - I~ - ndl6 B2 ndl6 82
Manganese
(aqueous matrix) .5.0E-03 (I) - - -
Manganese
(solid matrix) 1.4E-OI (I) I.IE-04 (900) - -
~ ickel 2.0E-OZ (300) - - 8.4E-OI.I7. A
Thallium 7.0E-O.5,.I'O (3.000) - - -
Zinc 3.OE-OI (10) - - -
PestlcideslPolychlori.ated Bipbenyls (PCBs)
Ch lordane. lotal 6.0E-O.5 (1.000) - 1.3E+OO B2 1.3E+W 82
Hepta.:hlor .5.0E-04 (100) - .4..5E+OO B2 4..5 E +00' 82
Sem~olatile Oraaaie Checaicals (SOC)
BiS( 2-ethy lhexyl )phthalate: 2.0E-02 (1.000) - 1.4E-02 B2 nds, 82
Diethyl phthalate 8.0E-01 (1.000) - - -
Pentac:hlorophenol ).OE-02 ( 100) - I.2E-OI 82 nds, 82
Volatile Ora.aie Chemicals (VOC)
Acetone I.OE-OI (1.000) - - -
Benzene 2.0E-02\1I (na) .5.7E-O.5VJ (na) 2.9E-02 A 2.9E-02' A
~'J
LEITERKENNY ARMY DEPOT
,\ TT .\CH\tE'wT 2
8romodlchloromedl8nc
2.0E-02 ( 1.000)
RISK '\SSESS\1E'T T
.IJE-OI
82
82
nd
Carbon letrachloride 7.0E-04 (1.000) 1.3E-01 B2 .5.JE-02' 82
Chlorofonn I.OE-02 ( 1.000) 6.1 E-O) B2 8.1 E-02' 82
Dichloroelhane. I. I- I .OE-OI' (1.000) I.OE~)J (1.000) ndV) C ndv, C
Dichloroethane. I. 2- 7.0E-02vS (100) 2.9E-O)VJ (na) 9.IE-02 B2 9.1 E-02' 82
Dichloroethene. I. \ - 9.0E-O) ( \ .000) 6.0E-01 C 1.8E-O I C
Dichloroethene. I. 2-.
total 9.0E-O] ( 1.000)
Methylene chloride 6.0E-02 (100) 8.6E-OI' (100) 7..5E-O) B2 1.6E-OJ 82
T cuachloroethenc I.OE-02(1.000) 5.1 E-02v6 82v. 1.8E-O]H 82~.
C IARII'I'\L.EAO\FM._ATk OOCI101'1W1 FINAL
-------
LE1TERKENNY ARMY DEPOT
A TT ~CHM[~T 2-R'SK ASSESS\IE'oT T -'BLES
Table 5--Chronic Dose-Response Toxicity Constants for the COCs in the SE and PDO
Area. at LEAD (Continued)
I 1II,oIUI1> I Inll.ll 1{1l1 ' ()".I I 11..01 i I
I 1111>..\ loh..1
( 11"111".01 (I I J II II ( 'I . I
I I I \\ .... i ( 'I I \\ IIf:
Toluene 2.0E'()1 (1.000) 1.1 E.()I' (100) - -
Trichloroethane. I. I. I- 9.0E'()2 (1.000) J.OE.() ,. (1.000) - -
Trichloroethane. I. I. 2- 4.0E'()] (1.000) - '.7E-02 C '.7E-OZ. C
TrichloroetJicne 6.0E'()] V2 - 1.1 E'()2 V6 8ZV6 6.0E-o] \ ~ 8Z\6
T richlorot1uoromcthane 3.0E-ol (1.000) Z.OE.()I' (10.000) - -
Vinyl chloride - - 1.9E+OO' A J.OE-o,. ~
Note:
RID .. Reference dose [mglkgldayJ.
UF = Uncertainty factor (inc:ludes any applicable modifying factor).
CSF = Cancer slope factor [(mglkglday}"').
WoE = Weighl of evidence for ranking as a human carcinogen (see Table 4).
inhal = Inhalalion.
na = Not available.
nd = NOI deaermined.
(II) CSF for arsenic based on unit cancer risk of.5 x 10" (JiglL)"' proposed by Risk Assessment FONm (EPA.,.I99,la). . - .','
(12) All values are for hexavalenl chromium: a less conservative oral RfD of I E+OO mglkglday for trivalent chromium ::.< -0
is also available. .
; ,,-
(13) Inhalation RID for chromium has been withdrawn from IRIS pending funher EPA review.
(14) RID for copper based on the MCL of 1.3 mglL (.56 FR 26460) and assumes that a healthy 70-kg adull consumes .,
Uday water.
(1.5) EPA prefers 10 use a biokinetic uptake model 10 evaluate lead exposure rather than the reference dose method.' : .'
(16) Although EPA has classified lead as a Group 82 suspect human c:an:inogen via ing~ion and inhalation. no CSF" v
has been developed for either of these exposure pathways.
(17) Inhalarion ofCSf for nickel refinery dust.
(110) This vaJue (for soluble thallium salts) has becfi withdrawn from IRIS pending further review,
(S I) Althoush EPA has classified this SOC as a Group 82 suspect human c:an:inogen via inhalation. no CSF has been
developed for this exposure palhway.
(V I) RID for benzene based on the EPAIG-day Health Advisory of 0.235 mr/L (EPA. 1917) and assumes that a
heahhy lo-ka child consumes I Uday water.
(V2) Interim value obCained ftoom EPA Environmental Criteria and Assessment Office (ECAO). as recommended by
EP A Region III.
(V3) Allhough EPA has classified this chemical as a Group C possible human c:an:inogen via ingestion. no CSF has
been developed for this exposure pathway.
(V4) Although EPA has classified this chemical as a Group C possible human can:inogen via inhalalion. no CSF has
been developed for this exposure pathway.
(VS) RID for 1.2-dichloroethane based on a chronic oral NOAEL for rats of 7 mglkglday (A TSDR. 1981) and an
uncertainty factor of 100 (lOX for sensitive human subpopulalions and lOX for animat-t~human extrapOlation).
(V6) CSFs and Woes for this VOC have been withdrawn from IRIS pending further review: the listed value is from
EPAlHEAST (1991).
':' i J'
C IAIIII't\L!AO\fHL_AT8I. ooc:c lOtI /88)
FiNAl
I
~I
-------
LETTERKENNY A~WY DEPOT
A TT.\CH'fE~T 2-RISK ASSESS'IE'T T .\BLES
Table 5-Chronic Do.e-Re.ponse Toxicity Constants for the COCa in the SE and POO
Area. at LEAD (Continued)
-All RIDs. CSFs. and WoEs are available in IRIS (1993). unless otherwise noted.
"This value is available in EPAlHEAST (1992).
Sources:
U.S. Environmental Protection Agency (EPA). 1987. HtalthAd1Jisonnfo1' 25 (ftgan,a. Office of Drinking
Water. Washington. DC. NTIS No. PB81-23SS78.
Agency for Toxic Substance and Disease Registry (A TSDR). 1988. Toxicological Profilt fo1' /.2-
Dichlorotthant. Prepared by Clement Associates. U.S. Public Health Sef\'ice. Adanta. GA. NTIS No. PBQO-
17/422.
U.S. Environmental Protection Agency (EPA). 1991. Ht4Ith Effieu ASStSSmtnf Summary Tabln (HEAST).
Annual FY /99/. Office of Research and Development and Office of Emergency and Remedial Response.
Washington. DC. OERR 92006-303(91-1).
C ~NL_RTaDOC('Ct,/I8)'
FINAl.
-------
LETITRKENNYA&~YD£POT
I
ATTACHMENT 3
TRANSCRIPT OF THE PUBLIC MEETING ON THE PROPOSED PLAN
i'
C ~"'_AT8LOOCIIQM"1
FINAL
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-. ".--... -,-
,r.....-.""-,,,,,-,, .) -
; ( 1-'
'- \...-i"' '. '--' I ---
_./ '-_.~ .-
1
1
2
3
4
5
6 IN RE:
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
LETTER KENNY ARMY DEPOT
Public Meeting for the
Proposed Plan for the
Phase I Parcels at
Letterkenny Army Depot
TRANSCRIPT OF PROCEEDINGS
BEFORE:
BRYAN HOKE, BRAC Environmental
Coordinator
DATE:
Tuesday, April 7, 1998
at 7:02 p.m.
PLACE:
Letterkenny Army Depot
Building 500, Auditorium
Chambersburg, Pennsylvania
Jan L. Bucher
Court Reporter-Notary
-------
2
1
2 SPEAKERS
3 Bryan Hoke
4 DeEtta Antoun
5 Bill Arguto
6 Carl Silverman
I N D E X
PAGE
3 '
12
12
21
21 '
7 'Gary Gontz
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
.24
25
-------
.24
3
1
MR. HOKE:
My name is Bryan
Good evening.
2
Hoke, BRAC Environmental Coordinator at Letterkenny Army
3
Depot.
I'd like to welcome you to the public meeting for
4
the proposed plan for the Phase I parcels at Letterkenny
5
Army Depot.
6
I'm going to give a brief presentation,
7
probably last about 10 or 15 minutes, and open up the
8
floor to questions.
And I want to remind everybody that
9
if you ask a question, please state your. name first.
It's
10
being recorded for the transcript and we want to be sure
11
we get your names.
12
Letterkenny Army Depot is located in South
13
Central Pennsylvania within Franklin County.
And on the
14
map here, this is the bottom, this is Chambersburg in
15
relationship.
This is the outline of the entire depot.
16
The entire depot is a little over 1~;000 acres.
17
We have an industrial area here in our
18
southeastern corner of the depot.
The remainder of the
19
depot comprises approximately of about 16,000 acres for
20
ammunition and storage.
We have about 900 igloos for
21
We also do open burning, open demolition on
storage.
22
those parcels.
We will be concentrating on the
23
southeastern corner tonight for Letterkenny.
The very next slide, please.
25
MR. GONTZ:
(Complied. )
-------
4
1
MR. HOKE:
This slide shows the corner of the
2
depot which I showed previously.
The red area that you're
3
looking at here is the properties that are going to be
4
retained by- the government by the year 2001 when BRAC is
complete.
5
6
The white anq gold parcels and also the green
7
parcels, this property is going to be transferred to the
8
public.
In this case it's going to be the local reuse
9
agency, which is the Letterkenny Industrial Development
10
Authority, which is known as LIDA, which I'll be referring
11
to as LID A from now on.
12
These green parcels, this property, is going to
13
be transferred back, leased back by the government.
Md
14
we'll keep this map out here for all night so you can keep
15
that for reference.
In this case the gold parcels that
16
you see up here are in blue here.
These are the same
17
parcels.
Here is the red property which is being retained
18
by the government.
19
Just for reference, this is Gate 6, 997; Gate 1
20
(indicating) .
We are here tonight in Building 500.
It's
21
located right here (indicating).
22
Next slide, Gary.
23
MR. GONTZ:
(Complied.)
24
MR. HOKE:
The Phase I parcels were identified
25
by LIDA as priority parcels primarily for early
-------
s.
1
transferals.
They could redevelop in any markets.
. There
2
are 28 parcels including rail lines, and they comprise of
3
approximately 240 acres.
We are handling all these
4
parcels and the rail lines as one unit which we refer in
5
turn as the Phase I parcel.
6
Next slide, please.
7
MR. GaNTZ:
(Compl ied. )
8
MR. HOKE:
Condition of the~e parcels, all the
9
parcels are underlain by VOC-contaminated groundwater.
10
For environmental background, here locating we have two
11
Superfund sites.
We take a line approximately from this
12
point all the way to Gate 1.
You can have it at two
13
sites, eastern side, what we call our southeaster~ area;
14
the western side is where our property disposal office
IS
area is.
16
In the '50s and '60s within the southeastern
17 area, we had a series of lagoons and other disposal sites
18 where they put solvents into the ground. The solvents
19 were used for degreasing purposes. At that point in time
20
it was an accepted practice to put them into the ground.
21
What has happened is that we developed soil
22
contamination and subsequent groundwater contamination
23 that has migrated on these - - the whole parcel. It has
24 migrated off Post. Down in our industrial area we have
25 another lagoon over near our Building 350. Industrial
-------
6
1
lines serving these buildings also leak causing soil
2
contamination and subsequent groundwater contamination.
3
This whole side of the parcel is underlain by
4
contaminated groundwater, contaminated by solvents, and
5
they've migrated off Post.
On the western side of this
6
parcel is the property disposal office area, other storage
7
areas that cause soil contamination and subsequent
8
groundwater contamination of solvents that it migrates
9
underneath.
And it's all -- these parcels are all
10
underlain by contaminated groundwater which migrates off
11
to the west and surfaces at Rocky Spring.
12
None of these parcels warrant any remedial
13
action based on -- soils based on industrial use.
Some
14 sites that we some did - - did some work for, Gate 6, this
15 open. parcel - - the field right now is open parcel,
16 agricultural, Building 500. These sites right. after World
17
War II were used for the storage of vehicles.
Our
18 concerns at that point in time were anything that was
19
leaking into the ground, any minerals or oils.
20
We did samples there and nothing showed up
21
above the industrial risk standards that would cause any
22 type of remediation to be required.
In.addition, we also
23
sampled the railroad tracks.
We 'were concerned about the
24
past uses of the railroad tracks plus the herbicides being
25
dumped on there and also 01ls used for vegetation
-------
7
1
suppression on these tracks.
2
We did samples along these railroad tracks.
We
3
found nothing in there that exceeded at a great extent
4
that required any type of remedial action be dbne at these
5
railroad tracks.
6
Next slide, Gary.
7
MR. GONTZ:
(Complied. )
8
Remedial action objectives for these
MR. HOKE:
9
Phase I parcels was to manage a potential long-term
10
contaminant migration and protect human health and the
11
environment.
The main thing is we want to prevent the
12
human exposure to the groundwater and using the
13
contaminated groundwater.
14
Secondly, we also want to provide a suitable
15
remedial alternative such that the land transfer recipient
16
can have beneficial reuse of the prop~rty with minimal
17
limitations.
Primarily what we're looking here for is to
18
help LIDA deal -- we changed this property to LIDA, that
19
they can market that property and bring in prospective
20
customers with new jobs to the community. .
21
Next slide, please.
22
MR. GONTZ:
(Complied. )
23
MR. HOKE:
The two remedial alternatives that
24
were evaluated is no-action and institutional controls.
25
Now, no-action is a CERCLA requirement to compare all
-------
B
1
other alternatives against a no-action.
So always -- at
2
least have no-action that's comparing.
3
Second one was institutional controls which
4
comprise of deed provisions and a master plan amendment.
5
The master plan is a document with our Public Works
6
folks.
We do an amended master plan to include these
7
institutional controls.
50 once the ROD is signed, this
8
would be an action until the property would be
9
transferred.
10
Secondly, with the deed provisions, these
11
institutional controls would be written up as deed
12
provisions and they would stay with the life of the deed
13
through the subsequent landowners.
14
Next line.
15
MR. GONTZ:
(Complied. )
16
There are nine criteria which are
MR. HOKE:
17
specified by EPA, and they are used to compare against the
18
alternatives.
The nine criteri~ are, number one, the
19
overall protection of human health in the environment;
20
number two, compliance with applicable or relevant and
21
appropriate requirements otherwise known as °ARARs; third,
22
long-term effectiveness and permanence; fourth, short-term
23
effectiveness; fifth, reduction of toxicity, mobility; and
24
volume through treatment; six, implementability; number
25
cost; eight, state acceptance; nine, community
seven,
-------
9
1
acceptance.
2
There's a little more write-up in your handout,
3
goes into a little more detail of what these nine criteria
4
And, also, in the proposed plan it gives you a
are.
5
little more detailed analysis of all these nine criteria
6
with these two alternatives.
7
Next line.
8
MR. GONTZ:
(Compl ied. )
9
MR. HOKE: . One of the main drivers of the
10
remedy selection is a site risk.
EPA's target risk range
11
for carcinogens is 1 times 10 to the sixth to 1 times 10
12
to the minus 4.
And basically what that translates as is
13
looking for an increased chance of one additional case of
14
range of one in a million to 1 in 10,000.
If you
cancer,
15
see that 1-in-10,000 range, that requires some type of
16
action to be taken.
17
There were -- risk assessments were done for
18
carcinogenic risk under industrial-use scenario with the
19
assumption that the workers would be drinking the
20
groundwater.
In the southeastern area the assessment was
21
done in 1993.
As you can
The PDO area was done in 1994.
22
see the numbers there, both of those, the upper range is 6.
23
times 10 to the minus third and 4.1 times 10 to the
minus
24
4 exceed that 1-in-10,OOO-target risk range, thus,
25
requiring some type of action to be taken.
-------
"
10
1
Next slide.
2
(Complied. )
MR. GONTZ:
3
However, the risk is also calculated
MR. HOKE:
4
if you eliminate the groundwater pathway under
5
industrial-use scenario, here you see the risks now are
6
much less than the 1 times 10 to the minus 6 or the one in'
7
a million; therefore, it's within the target range.
And,
8
therefore, no action would be taken.
So the key is to
9
eliminate that exposure pathway to the groundwater.
10 .
Next slide.
11
MR. GONTZ:
(Compl ied. )
12
Our preferred alternative is
MR. HOKE:
13
Alternat,ive 2, Institutional Controls.
First off,
Why?
14
it mitigates the risk effectively.
It eliminates the
15
groundwater risk by preventing exposure to groundwater; no
16
wells; no drinking; no any other type of use for that
17
groundwater.
18
Also, it establishes -- institutional controls
19
establish guidelines to prevent groundwater exposure
20
during any type of excavation-type procedures.
Secondly,
21
it's easily implemented.
First off, with amending the
22
lead master plan during the ROD sign until prior to
23
transfer, it's easy to amend that document.
And that
24
document will remain with the Public Works here at
25
Letterkenny.
-------
11
1
Once the property is transferred, these
2
institutional controls that were written as deed
3
provisions are inserted into the deed and will stay the
4
lifetime of the 'deed with subsequent landowners..
5
Thirdly, and probably m~st importantly, this
6
provides for timely reuse and community benefits.
This
7
allows LIDA to market this property and develop this
8
property, and bring in prospective businesses to bring new
9
jobs to our community.
10
I want to clarify that this alternative will
11
not address all groundwater here at Letterkenny Army
12
Depot.
We are working on a separate access to the
13
southeastern area and also the property exposed to the
14
opposite area.
There are several studies that cover
15
groundwater strategy to address the background water and
16
come up with remedial strategy to affect of the
17
groundwater to prevent the -- protect the human health and
18
the environment.
19
Next line.
20
MR. GONTZ:
(Complied. )
21
MR. HOKE:
A reminder.
The public comment
22
period ends April 29, 1998.
Any written comments can be
23
sent addressed to myself.
There's my name and my address
24
up there.
The address is in your handout.
25
And also a copy of the proposed plan is
-------
12
1
currently down at the Coyle Free Library in Chambersburg.
50 anytime you want to take a look at the proposed plan,
2
3
it will be on file down there until April 29.
4
At this point I'm going to open the floor to
5
questions.
And I'll remind you if you have a question,
6
please state your name before you state your question.
7
MS. ANTOUN:
DeEtta Antoun, Restoration
8
Advisory Board Co-Chair.
I have a question.
If something
9
changes in this proposed plan, does it then have to go
10
through the public meeting procedure again and have
11
another 30-day comment period?
12
MR. HOKE:
If the proposed plan would be
13
changed somewhat, I mean, it's going to be addressed in
14
the -- probably a response in the summary within the broad
15
process in the record of the decision.
16
At this point in time the only changes I would
17
see is,
like, public comments that would warrant the
18
change.
And those comments would then be addressed in
19
response to this portion of the record of decision.
But
20
there would not be another 30-day public comment period
21
unless -- trying to think.
Even if the alternative would
22
be changed, I don't think there would be --
23
MR. ARGUTO:
Probably would depend on how
24
significant the change would be.
If something happened
25
that would significantly change what this proposed plan
-------
18
.24
13
1
was saying, it would be appropriate to probably reannounce
2
it and give the public an opportunity to comment on that.
3
What will happen -- what's generally known as a
4
response in this summary is the summarization qf all the
5
public comments and Letterkenny's response to those
6
comments.
7
Bryan, do you agree with that?
8
MR. HOKE:
Um hum.
9
MS. ANTOUN:
If there are little clarification
10
things in there, that's not going to affect whether it has
11
to go through the whole process again, right?
12
MR. ARGUTO:
Right.
13
MS. ANTOUN:
I agree with the choice of the
14
alternative that you're going to use in the proposed
15
plan.
But I just have a couple questions about some of
16
the information in the proposed plan itself.
17
Is it appropriate that I ask those questions
now?
19
MR. HOKE:
Okay.
20
MS. ANTOUN:
Okay.
On page 6, whEm you talk
21
about industrial ingestion scenario, could somebody
22
clarify what an industrial ingestion scenario is?
23
MR. HOKE:
Page 6?
MS. ANTOUN:
Yeah, page 6 up on the first
25
column, left-hand side.
It refers to concentration RBCs
-------
14
1
for industrial ingestion scenario.
2
MR. HOKE:
Industrial ingestion.
I'm assuming
3
that you're making the assumption that the worker would be
4
exposed through ingestion of soils or something like that,
5
dust.
That would be the pathway through.
Worst case --
6
this is ~ stupid example.
A worker takes his lunch out --
7
and you're never supposed to do this.
8
But he's working a site, doing some
9
excavations, and they're digging.
Right away the whistle
10
blows.
He sits down, opens up his lunch, and eats his
11
lunch with dirty hands and things like that.
That would
12
be an industrial ingestion scenario.
13
MS. ANTOUN:
Okay.
That makes sense.
Okay.
14
But that doesn't necessarily have anything to do with the
15
groundwater because it's not -- unless there's, like,
16
groundwater that's worked its way to the surface?
17
MR. HOKE:
Right.
Take the same example, doing
18
excavation.
And the ground is damp from the groundwater,
19
and they're in the bottom of a hole.
He's got that mud -~
20
he's got that mud on his hands, and now he's eating an
21
Oreo cookie with dirty hands.
That's some of the
22
assumptions they do when they do their assessments.
23
That's a way of ingestion.
24
MS. ANTOUN:
Arsenic and beryllium keep showing
25
up here and there.
Why is that?
Why do I keep finding
-------
15
1
them?
Arsenic and beryllium are like a
3
natural -- showing up as background with the soils and
Also, backgrounds tend to vary from
5
site to site.
And with the values that we're seeing, they
6
weren't exceeding it greatly.
We were kind of attributing
7
that value as to what Letterkenny's background is.
Have you ever tested off Post to
9
see what the background is in adjoining areas?
We have never tested off Post
11
ourselves.
These, the background standards, are developed
12
from existing data from other locations; but not for
13
Franklin County specific have we done any sampling off
And the last thing is would
16
arsenic and beryllium be components of the explosions that
17
you -- the ammo demolition?
Would they be by-products of
For ammunition, from what! know,
20
you'd probably be seeing, like, lead.
You primarily would
But not arsenic?
No.
The main thing you'd be seeing
2
MR. HOKE:
24
would be the explosive compounds like TNT, RBX.
And what are the ingots?
Refresh
4
things like that.
8
MS. ANTOUN:
10
MR. HOKE:
14
Post.
15
MS. ANTOUN:
18
doing that?
19
MR. HOKE:
21
be seeing, ~ike, lead.
22
MS. ANTOUN:
23
MR. HOKE:
25
MS. ANTOUN:
-------
16
1 my memory as to what we have in those big piles of ingots.
2 MR. HOKE: The ingots are stored right across
3 the road from Building 441, which is lead. Another area
4 here in the white is nickel and zinc.
5
6 zinc'?
7
8'
9 right?
10
MS. ANTOUN:
50 we have lead, nickel, and
MR. HOKE:
Right.
MS. ANTOUN:
And you test around those areas,
MR. HOKE:
We will be.
We've done a little bit
11
in the past.
And we will be doing additional in order to
12
facilitate that transfer.
13
MS. ANTOUN:
But they're not on the land
14
that's been transferred --
15
MR. HOKE:
No, they are white parcels.
16
MS. ANTOUN:
I have one overall concern about,
17
this.
The basis of the proposed plan talks about cleaning
18
the land to an in?ustrial usage.
And I have a question
19
about the gymnasium and -- I think I brought this up at
20
the last RAD meeting -- the gymnasium and the church.
21
Those two facilities won't necessarily be used for
22
industrial usage or commercial usage.
23
Do you consider a gymnasium a commercial usage
24
or --
25
MR. HOKE:
To me a gym falls into an
-------
17
1
industrial/commercial scenario.
When -- anything you take
2
because of future activities of -- which you're restricted
3
to indoor activities.
There won't be ariy outdoor
4
activities such as any outdoor volleyball or playgrounds
5
or any daycare.
So that's where it falls entirely in
6
industrial/commercial setting.
In order to do anything
7
additional in residential, you have to do more sampling
8
and do additional risk calculations in order to support
9
that usage.
10
At this point in time -- that is not what the
11
reuse for thpse two parcels are at this point in time.
12
M5. ANTOUN:
What is the difference between an
13
industrial usage and a residential usage environmentally
14
when you guys are talking about -- I believe you said
15
something about it has to do with how long a person is
16
exposed to the materials.
17
50 an industrial usage is -- how long are you
18
exposed to materials to qualify it as an industrial usage
19
as opposed to a residential usage?
20
MR. HOKE:
Under industrial scenario you're
21
looking at eight hours, which is -a typical working day.
22
Under residential exposure, you're looking at 24 hours a
23
day.
So that's a big difference.
That's the assumptions
24
that you make from industrial to residential.
25
M5. ANTOUN:
50 that what makes
-------
18
1
industrial/commercial okay for the gymnasium is the fact
2
that even though you're breathing real hard when you're
3
there --
4
MR. HOKE:
The big difference also is that you
5
are inside.
6
MS. ANTOUN :
Yeah, I know, but -- just because
7
you're not touching the soil.
We kind of went
Okay.
8
through that one.
One more questio~ about the church and
9
the -- the church and the gymnasium.
On page 10 under
10
parcel 33 and 34 in the proposed plan, every other parcel
11
that you comment on in the proposed plan has a statement
12
in there that says there is documented VOC-contaminated
13
groundwater beneath parcel whatever.
14
And in parcel 33 and 34 that statement isn't
15
included in the description of those two parcels.
Is
16
there a particular reason for that omission?
17
18 in time.
19
20
21 well?
22
23
24 there in
I would have to say no at this point
MR. HOKE:
I don't think that's --
A VOICE:
It's just an oversight.
MS. ANTOUN :
That should be part of that as
MR. HOKE:
It should have said that, yeah~
MS. ANTOUN :
Because I thought if it wasn't on
the proposed plan, then someone could say then it
25
doesn't have to adhere to all the deed restrictions.
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1
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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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23
19
MR. HOKE: Right. Right. That is an
oversight. At least somebody's reading these documents.
MS. ANTOUN: I just find them so fascinating.
Let me see what else I've got here. I have a question
about the agricultural field that you've done all sorts of
tests on and you know there's groundwater pollution,
etcetera, etcetera. But you're still finding arsenic and
beryllium on that land that you think is background, but
it's still above the levels that are accepted. And that's
used for agriculture, right?
yes
MR. HOKE: Currently at this point in time,
MS. ANTOUN: And it said that agriculture is
not an industrial use, but the land is going to be okayed
for industrial use. I'm kind of wobbly on that. I don't
understand if that's going to stay with --at least as an
agricultural usage, then how can it be okay for
agriculture one minute and then only okayed for industrial
another minute? I'm kind of --
MR. HOKE: From risk-wise pertaining to that
property it still falls into, like, an industrial exposure
for a farmer. He's farming that property eight hours.
MS. ANTOUN: But how about the product that
24 comes off that land? When the product comes off that land
25 if it's contaminated with arsenic or beryllium, it goes
-------
20
1 into the food supply.
2 on their corn or --
3 MR. HOKE:
I assume -- what are they putting
Like I said, these values which
4
people contribute the background as natural soil that
S
you're going to find elsewhere --
6
MS. .ANTOUN:
But you've never tested it
7
elsewhere.
8
MR. HOKE:
No, we haven't tested it elsewhere.
9
But we have no inkling that it's any different from any
10
other farming properties around here at all.
11
MS. ANTOUN:
But it does go above the accepted
12
standards?
13
MR. HOKE:
Yes, it does.
14
MS. ANTOUN:
50 I was just wondering if that
lS
agricultural usage was a good usage for that land
16
considering the fact that it has those contaminants on it.
17
MR. HOKE:
That's been farmed for almost 40
. 18
years.
And based on these_results, it doesn't -- if it
19 really blew the limit way above it, then that would be a
20 concern. But at this point in time it's creeping above
21 the limit only by a little bit.
22
MS. ANTOUN:
Is that done with no-till?
Does.
23
that have pesticides?
24
MR. HOKE:
He's doing both there, both no-till
25
and farming.
-------
"'j
21
1
MS. ANTOUN:
Okay.
You can take someone else's
2
question while I go over what I have here.
3
MR. SILVERMAN:
Carl Silverman, Waynesboro.
I
4
just want to ask what Army agency is in charge of actually
5
transferring the properties to the development authority?
6
And can you give me a contact name because I have an issue
7
not related to environmental that I need to contact them
8
about.
9
MR. HOKE:
The Army agency in this case, I
10
would say -- Gary, you want to help me out, AMC?
11
MR. GONTZ:
Army Material Command.
They are
12
the proponents responsible for the actual transfer.
13
Jeannie Gillen would be the point of contact.
And if you
14
give me your name and number afterwards, I can see that
15
you get it.
16
MR. SILVERMAN:
I have to leave in a second.
17
I'll give it to you.
18
Anybody else have questions?
MR. HOKE:
19
I'm back.
Back in the deed
MS. ANTOUN :
20
covenant back there, I just have a question about one
21
term.
And I couldn't contact my attorney to get a
22
definition for it.
He's out of town.
What can I say?
23 MR. HOKE: What page are you on now?
24 MS. ANTOUN: Page 4 of the covenant. It's
25 Section E of Section 4, letter E. Goin.g down to that
-------
-J
22
1
section it says, Or is not sage for a particular purpose.
2
MR. HOKE:
That should be safe.
3
MS. ANTOUN:
Oh, safe.
I
Oh, thank you.
4
thought maybe someone -- I was going to ask my legal
5
counsel what sage is in the legal world.
And what is the
6
Federal Facilities Agreement?
Is that the agreement that
7
you were talking about before or is that a separate thing,
8
Letterkenny's Federal Facilities Agreement.
9
MR. HOKE:
That is what we call our lAA,
10
interagency agreements signed between EPA, 'DEP, and the
11 Army.
12 once.
13
It was signed in 1989.
Going'
Any other questions?
Okay.
One more.
You always put
MS. ANTOUN:
14
advertisements for these public meetings and the little
15
public service ads in the back of the newspaper.
I was
16
wondering if it would be possible to somehow, using tag
17
money or something, have a display ad advertising any
18
environmental meetings that are back here.
Is that an
19
issue that -- I know that's not necessarily related
20
directly to this particular issue, but it's something that
21
might improve the attendance at meetings if it was a
22
little more in people's face.
23
We can look into that.
You're
MR. HOKE:
24
looking for in the advertisement section or somewhere
25
within the newspaper?
-------
'1
:
,
,
23
1
2
prominent.
3
MS. ANTOUN:
Anywhere that it would be more
MR. HOKE:
Okay.
Take note~
Weill ask the --
4
I didn't work the ad myself.
I had someone else work the
5
ad.
I can find out a more prominent place to do that to
6
make sure that people see it.
7
Any other questions?
Last chance.
1\11 right.
8
Like I say, the public comment period ends April 29.
Any
9
questions, you can call me.
I don't see my phone number
10
anywhere.
11
12
next time.
13
14
15
16
17
18
19
20
21
22
23
24
25
My phone number is 267-9836.
Thank you very much for coming.
See you the
(Whereupon, the hearing was concluded at
7: 30 p:m.)
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24
1
I hereby certify that the proceedings and
2
evidence are contained fully and accurately in the notes
3
taken by me on the within proceedings, and that this copy
4
is a correct transcript of the same.
5
6
o~; I ') ~' !1U? /:.J. t
Jan y. Bucher
Co~r~ Reporter-Notary Public
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10
Notarial Seal
Jan L. Bucher. Nota'Y PubliC
I C.C!.rlisle Bora. Cumbertand County
; . \"CoMmlsSlon '=-JtP,res June 5. 2000
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