United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/118
August 1991
SEPA
Superfund
Record of Decision:
USA Letterkenny - PDO, PA
-------
S0272-1ff1
REPORT DOCUMENTATION 1. REPOBTNO. 2-
PAGE EPA/ROD/R03-91/118
'endSubMe
ERFUND RECORD OF DECISION
A Letterkenny - PDO, PA
First Remedial Action
7. Autiort.*)
9. Perforating OrgeMzrion Heine end Addrae*
12. Sponsoring Orgenfntion Neme end Addraee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipience Aceeulon No.
5. RepertDete
08/02/91
6.
8. PeilomiJng Orgvuzttion Repl No.
10. Pro|ecVTeeUWork Unit No.
11. Contnct(C) or Grant(G) No.
(C)
(G)
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Note*
16. Abstract (Umtt: 200 word*)
The 250-acre USA Letterkenny - PDO site is within the 19,500-acre active U.S. Army
facility in Chambersburg, Franklin County, Pennsylvania. Land use in the area is
primarily agricultural, with scattered residences and military facilities. Shallow
ground water at the head of the site flows toward and into Rocky Spring and Rocky
Soring Lake. Since 1942, the U.S. Army has used the PDO Area to overhaul, rebuild, and
3t wheeled and tracked vehicles; distribute class III chemicals and petroleum; and
.ore, maintain, demilitarize, modify, and demolish ammunition. These past industrial
activities involved the onsite use of solvents, oils, hydrocarbons, and metals, which
were disposed of in an oil burning pit and several drum storage revetments. From 1987
until 1989, a number of EPA investigations documented soil contamination near the drum
storage area and the oil burning pit; and these areas are thought to be the primary
sources of onsite contamination. This Record of Decision (ROD) addresses remediation
of onsite soil as the first operable unit (OU1). A subsequent ROD will address ground
water contamination as OU2. Because a majority of the soil contaminants have already
moved down into the clays and silts of the underlying bedrock and ground water, soil
contaminants now pose low risks for humans at the site, and no remediation of the soil
(See Attached Page)
17. Document Anelyele a. Descriptor*
Record of Decision - USA Letterkenny - PDO, PA
First Remedial Action
Contaminated Medium: soil
Key Contaminants: None
b. Mentifiera/Open-Ended Term
c. COSATI Held/Group
-f libifty Statement
19. Security d*M (Thto Report)
None
20. Security due (Thl* Ptge)
None
21. No. ofPege*
26
22. Price
(See ANSI-Z3t.1B)
See (netructioiM on Rewrae
OPTIONAL FORM 272 (4.77)
(Formerly NT1S-35)
Department of Commerce
-------
EPA/ROD/R03-91/118
USA Letterkenny-PDO, PA
FJ ~5t Remedial Action
« cract (Continued)
is necessary. Based on this rationale, there are no primary contaminants of concern
affecting this site.
The selected remedial action for this site is no action. There are no costs associated
with this no action remedy.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
-------
RECORD OF DECISION
ACCELERATED REMEDIAL ACTION
PROPERTY DISPOSAL OFFICE AREA
OPERABLE UNIT ONE
LETTERKENNY ARMY DEPOT
CHAMBERSBURG, PENNSYLVANIA
June 27, 1991
-------
LIST OF TABLES
PAGE
1. Current and Pas\ Activities Within the PDO 8
Drainage Area
2. Summary of Analytical Data - Oil Burn Pit Area 11
(ISV study)
3. Summary of Analytical Data - PDO Area 13
(Drum Revetments)
4. Summary of Carcinogenic Risk and Noncarcinogenic 14
Hazard Levels for PDO Area Contaminants
-------
LIST OF FIGURES
PAGE
1. Location Map of LEAD and Vicinity 4
2. Surface Water and Groundvater Basins and SE Study Area 5
3. PDO Area Potential Contaminant Source Areas 7.
-------
TABLE OF CONTENTS
PAGE
1. DECLARATION . 1
2. DECISION SUMMARY ....... 3
2.1 Site Name, Location, and Description . . 3 .
2.2 Site History and Enforcement Activities . . 3
2.2.1. Site History. . . ... 3
2.2.2. CERCLA Enforcement Activities . . 6
2.3 Highlights of Community Participation . . 6
2.4 Scope and Role of Operable Unit ... 9
2.5 Site Characteristics ..... 10
2.'6 Summary of Site Risks . . . . . 12
2.7 Description of the "No Action" Alternative . 16
2.8 Explanation of Significant Changes ... 16
3. RESPONSIVENESS SUMMARY . . . . . . 17
-------
1. DECLARATION
Site Name and Location
U.S. Army Department of Army
Property Disposal Office Area
Letterkenny Army Depot
Franklin County
Chambersburg, Pennsylvania
>.
Statement of Basis and Purpose ""
This decision document presents the elected final remedial
action for the Property Disposal Office (PDO) Area, Operable Unit
One at Letterkenny Army Depot (LEAD). Operable Unit One is
comprised of the PDO drum storage revetments and the oil burning
pit. This action was chosen in accordance with the requirements
of 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 Oil and Hazardous Substances
.Pollution Contingency Plan (NCP). This decision document explains
the factual and legal basis for selecting the final remedy for
this site. This decision is based on the administrative record
file for LEAD.
The U.S. Environmental Protection Agency (EPA), Region III
and the Pennsylvania Department of Environmental Resources (PADER)
concur with the selected remedy. The information supporting this
remedial action decision is contained in the administrative record
for LEAD.
Description of the Selected Remedy
The PDO Operable Unit One is the first of two operable units
for the PDO Area. This operable unit addresses the contaminated
soils beneath the drum storage revetments and oil burning pit,
which are suspected sources of groundwater contamination at the
PDO Area. A complete assessment of the PDO Area sources and
groundwater/surface water contamination will be documented in the
final Remedial Investigation (RI), Ehdangerment Assessment,
Feasibility Study (FS) and Record of Decision upon completion of
the ongoing RI/FS program. Remedial action alternatives were not
developed for the drum storage revetments nor the oil burning pit,
based on the results of the Endangerment Assessment (EA) for the
PDO Area (ESE, 1988). Results of the EA indicate that the
contaminated soils at these locations do not pose a current or
-------
potential threat to human health or the environment, as most of
the contamination has migrated to the bedrock and groundwater. AS
such, the selected remedy for this operable unit is "no action".
Declaration of Statutory Determinations
No remedial action for the soils at the drum storage
revetments or the oil burning pit is necessary to ensure
protection of human health and the environment. This is based on
the results of the Endangerment Assessment, which indicate that
concentrations of indicator contaminants in the PDO Area soils do
not pose an unacceptable human health risk. r
Lewis D. Walker Date
Deputy Assistant Secretary of the Army
for Environment, Safety, and Occupational
Health
Edwin B. Erickson Date
Regional Administrator
U.S. Environmental Protection Agency, Region III
-------
2. DECISION SUMMARY
2.1. Site Name, Location and Description.
s
This Record of Decision (ROD) is for final action at the
Property Disposal Office (PDO) Area Operable Unit One within
Letterkenny Army Depot (LEAD). LEAD, formerly known as
Letterkenny Ordance Depot, is located in south-central
Pennsylvania in the central portion of Franklin County, in
Letterkenny, Greene, and Hamilton Townships, about 5 miles north
of Chambersburg (Figure 1). Chambersburg is the nearest
population center, with about 15,000 persons. The installation
occupies 7,899 hectares (19,520 acres) situated in the western
side of the Cumberland Valley, which is characterized by gently
rolling terrain underlain by folded and faulted geologic
formations. Approximately 5,600 civilians and 140 military
personnel are employed at LEAD, and roughly 1,862 buildings and
1,096 miles of road are on the installation.
The Property Disposal Office (PDO) Area occupies roughly 250
acres in the southern section of the depot (Figure 2). The PDO
.Area is one of the two CERCLA National Priorities List (NPL) sites
at LEAD. The other NPL site is the Southeastern (SE) Area. Each
site contains a number of specific sources of contamination. The
two sites are in different drainage basins, as shown in Figure 2.
The dashed lines that separate the two sites in Figure 2 indicate
approximate surface water and groundwater boundaries.
The PDO Area consists of shaly ground underlain by fractured
limestone bedrock, sloping towards the end of its drainage basin
on depot, Rocky Spring Lake. The area is a mixture of wooded and
open land interspersed with past and present military uses, such
as the ongoing scrap/materiel reuse operations of the PDO (now
named the Defense Reutilization and Marketing Office). Adjacent
land uses off-depot are primarily agricultural, mainly dairy farms
and orchards, with scattered single family homes. Shallow
groundwater at the head of the PDO Area flows within one bedrock
aquifer toward Rocky Spring, discharging at the spring and
possibly directly into Rocky Spring Lake.
2.2. Site History and Enforcement Activities
2.2.1. Site History
LEAD is owned and operated by the Army. Although established
in 1942 with the mission of ammunition storage, the principal
missions at LEAD currently include overhauling, rebuilding, and
testing of wheeled and tracked vehicles; the issuance and shipment
-------
tJUMUIA /
\COIINIf /
A turn . u H .
LETTERKENNY
L «
te
"X*"1?. / A
5 10 MILES
mmmm*
S 10 KILOMETERS
SOURCES: M«M«. l»»3«
CSC. t MM
Figure 1
LOCATION MAP OF LEAD AND VICINITY
REMEDIAL INVESTIGATION/
FEASIBILITY STUDY
Lellerkenny Army Depot
U.S. Army
Toxic and Hazardous Materials Agency
Aberdeen Proving Ground, Maryland
-------
SCALE
600 0 600 1.200 FEET
200 0 200 400 METERS
SOUTHEASTERN
AREA
AMMUNITION DISPOSAL AREA
AND AMMUNITION STORAGE AREA
DISPOSAL AREA
DASHED LINES INDICATE APPROXIMATE
SURFACE AND GROUND WATER BASIN BOUNDARIES
PROPERTY DISPOSAL
OFFICE AREA
ROCKY SPRING
ROCKY SPRING
LAKE
a
o
4
I
SOURCE: ESC. IM1«.
Sf
B
CE WATER AND GROUNDWATER
3 AND SE STUDY AREA AT LEAD
REMEOIA
FEAS
Lellerke
m
inRy 4
VESTIGATION/
Y STUDY
Army Depol
U.S. Army
Toxic and Hazardous Materials icy
Aberdeen Proving Ground, Mai id
-------
of Class III chemicals and petroleum; and the storage,
maintenance, demilitarization, and modification of ammunition.
Operations associated with current or prior missions have included
cleaning and stripping, plating, lubrication, demolition, chemical
and petroleum transfer and storage, and washout/deactivation of
ammunition. Many of these activities, except those associated
with ammunition, were conducted using significant quantities of
trichloroethylene, other chlorinated hydrocarbons, hydrocarbons,
and other solvents.
Figure 3 is a map showing locations of all known and
suspected sources of contamination within the PDO Area -;
contributing to onpost contamination. Table 1 lists activities
that occurred at each of the potential contamination locations
shown in Figure 3.
2.2.2. History of CERCLA Enforcement Activities
The PDO Area was listed on the National Priorities List (NPL)
on March 17, 1989 with a Hazard Ranking Score of 37.51. The POO
Area is also the subject of a Federal Facility Interagency
Agreement (IAG) under CERCLA Section 120, signed on 3 February
1989 by the U.S. Department of the Army, U.S. Environmental
Protection Agency (EPA), Region III, and Pennsylvania Department
of Environmental Resources (PADER). The purposes of the Agreement
are to ensure that contamination from past and present activities
is completely investigated and cleaned up, to provide a framework
and schedule for cleanup activities, and to promote cooperation
and communication concerning the cleanup among the three parties.
2.3. Highlights of Community Participation
The Focused Feasibility Study (FFS) and Proposed Plans (PP)
for the SE Area and the PDO Area at LEAD were released to the
public on April 6, 1991. These two documents were made available
to the public in both the administrative record and an information
repository maintained at the EPA Docket Room in Region 3,
Philadelphia, Pa., at Building 663 at LEAD, and at the Coyle Free
Library in Chambersburg. The notice of availability for these two
documents was published in the Chambersburg daily newspaper, the
Public Opinion, on April 6, 13, 20, and 27, 1991. A public
comment period was held from April 6, 1991 to May 20, 1991. In
addition, a public meeting was held on April 14, 1991. At this
meeting, the Army presented an overview of the proposed plan and
/the preferred alternative being proposed as required under CERCLA.
-------
1.200 2,400 FEET
ROCKY SPRING Cfl«JC
YSPfHNO
SOUMCffc MM**, ttMe.
fSC.11M.
Figure 3
POO AREA POTENTIAL CONTAMINANT
Stt AREAS
REMEDIAL INVESTIGATION/
FEASIBILITY STUDY
Letterke' Army Depot
U.S. Army
Toxic and Hazardous Materials >
Aberdeen Proving Ground, Mai
id
-------
C-RATSSLEAD.2/EA-V111.1
01/27/88
Table 1. Current and Past Activities Within the PDO Drainage Area*
^ S
Location No. Activity
1 Main sewage treatment plant (STP); operations
. began in 1971
r
2 Storage of dichlorodiphenyltrichloroethane (DDT)
powder and DDT solutions
3 Previous storage of herbicides, pesticides, and
insecticides
4 Two revetments used for drum storage; drums
contain expended material including hydraulic
oil, engine oil, transmission fluid, chromic
^ . acid, TRCLE (past only), carbon removers, caustic
compounds, and polychlorinated biphenyls (PCBs)
(past only)
5 and 6 Spreading areas for digested sludge from STP
7 Bldg. 2325, pest control building; herbicide and
insecticide storage
8 Bldg. 2357, laundry for chemicalcontaminated
(including explosives) clothing
9 Ammunition washout plant (explosives)
10 Landfarming of industrial waste treatment plant*
(IWTP) sludge, starting in 1974+
11 Sanitary landfill used from 1952 to 1956; near
current Resource Conservation and Recovery Act
(RCRA) landfill
12 Open landfill near trash-burning pits; closed in
1979; trash-burning pit residue, spent oil
filters, tank periscopes, fluorescent light
tubes, and metal and fiberglass assemblies buried
13 Oil-burning pit used for disposal of waste oil
and organic laboratory wastes and training of
fire fighters**
-------
C-RATSSLEAD.2/EA-V111.2
01/27/88
Table 1 Current and Past Activities Within the PDO Drainage Area*
(Continued, Page 2 of 2)
Location No.
Activity
14
15
16
Trash-burning pits for uncontaminated trash
'Revetted storage area for new drums of hydraulic
and engine oils**
Landfill/burning area reported to USATHAHA by
LEAD personnel in April 1983
*Froo USATHAMA (1980) except as noted.
+From Berger Associates, 1981.
**From discussions with various LEAD personnel.
Source: ESE, 1988.
-------
Community attendance was very low. The Responsiveness Summary of
this ROD provides a discussion of public comments received during
the public comment period. This decision document presents the
selected final remedial action for the contamination sources
within the PDO Area, chosen in accordance with CERCLA, as amended
by SARA and, to the extent practicable, the National Contingency
Plan. The decision for this site is based on the administrative
record.
2.4. Scope and Role of Operable Unit:
Due to the complexity of the contamination problems in th/e
POO Area, the Army has divided the cleanup work into manageable
components for remedial action called "operable units" (OUs).
LEAD has a total of five OUs for its two NFL sites. The OUs for
each of LEAD'S NPL sites, the PDO Area and the SE Area, are
numbered separately. These OUs are:
SOUTHEASTERN AREA
* Operable Unit 1 - K Area Contaminated Soils
* Operable Unit 2 - SE Area Contamination Sources
* Operable Unit 3 - SE Area Contaminated Groundwater
PROPERTY DISPOSAL OFFICE AREA
* Operable Unit 1 - Revetments, Oil Burn Pit Contaminated
Soils
* Operable Unit 2 - PDO Area Contaminated Groundwater
The overall strategy for LEAD is to address the contaminated
soil OUs first and the contaminated groundwater OUs in the future.
The contaminated soil OUs are being considered first because the
soils are often localized and accessible. Therefore, LEAD is
taking immediate actions on the contaminated soils in the PDO and
SE Areas as required to reduce their direct risk to human health
and the environment relatively quickly. These actions will also
help avert the contaminated soils from acting as a continuing
source of groundwater contamination in these areas.
The operable unit addressed by this document, Operable Unit
One, is an accelerated remedial action as required by the IAG,
Section IX.D, and addresses the contaminated soils in the drum
storage revetments and former oil burning pit site. These soils
were studied to assess whether they pose a threat to human health
and the environment from possible ingestion or skin contact. They
were also evaluated to determine whether they are currently
causing groundwater contamination. Past studies have shown that
-------
the contaminated soils of the drum storage revetments and oil
burning pit were the source of contamination for the underlying
groundwater in the POO Area at some time interval. The results of
these studies form a basis for deciding whether and what action is
necessary for these contaminated PDO Area soils. The nature and
extent of groundwater contamination, both onpost and offpost, will
be discussed in further detail in separate reports issued upon
completion of the RI/FS. This CERCLA accelerated remedial action
will be consistent with any planned future actions for this site
to the extent possible.
2.5. Site Characteristics ''
The primary contaminant sources in the PDO Area have been
determined to be the contaminated soils associated with the oil
burning pit, along Georgia Avenue and the drum storage revetments.
These areas were formerly used as hazardous waste disposal areas
for spent solvents such as trichloroethylene and
1,1,1-trichloroethane. The nature and extent of these sources
have been defined in previous reports. The Focused Feasiblity
Study, which evaluated potential final remedial measures,
indicated that soil remediation was not required at these PDO Area
sites. Groundwater contamination in the PDO Area begins at the
.farthest end of the upgradient area, near the trash-burning pit
and the test track, and continues through the PDO drum storage
revetments to the Rocky Spring system. The contaminated soils at
these two sites were believed to be the principal sources of
groundwater contamination in the PDO Area. However, studies
performed at these two sites to date indicate that most of the
contamination has migrated from the soils down to the bedrock and
the groundwater. Offpost migration of the contaminated
groundwater has not occurred in the PDO Area.
The contaminated media in the PDO Area is the soils. The oil
burning pit was found to contain some low levels of volatile
halogenated organics (VHOs) in the surface soils during the RI
study of this area in 1987 (ESE, 1987a). However, the Weston
in-situ volatization (ISV) study (1989b) showed no significant
levels of volatile organics in the soils at the oil burning pit.
Thus, it appears that the levels of volatiles at the oil burning
pit site decreased between 1987 and 1989. Table 2 summarizes the
ISV study analytical data at the oil burning pit.
The area surrounding the drum storage revetments was found to
contain some low concentrations of VHOs and certain priority
pollutant metals during the RI study of the PDO Area (ESE, 1987a).
Most VHO concentrations in the soils were below 1 parts per
million (ppm); the highest was 6.76 ppm for trichloroethylene.
VHOs identified in the PDO drum storage revetment area included
1,1-dichloroethylene (11DCE), 1,1- dichloroethane,
10
-------
TABLE 2
Summary of Analytical Oat*. OIL BURN PIT AREA
Letterkenny Army Depot ISV
VENT
No.
BP5
BP7
BP9
SAMPLE
No.
SS01
SS02
SS01
SS02
SS01
SS02
SS03
DEPTH
(ft)
5-7
10-11
5-7 "
8-9
2-4
4-6
6-6.5
T12DCE
(mg/kg)
0.0718
0.018
0.0021 "
0.0020
_
0.0032*
0.0009
111TCE
(mg/kg)
0.0435
0.00495
_
-
0.0042
TRCLE
(mg/kg)
0.0891
0.0226
0.009
0.0043*
0.006
0.002
TOTAL
(mg/kg)
0.2044
0.04555
0.0111
0.0063
_
0.0092
0.0071
* - Indicates data outside certification range.
-- Not detected.
NOTE: Soil analysis conducted using USATHAMA certified Methods LJ02, LJ03.
Certification Ranges are as follows:
U02: T12DCE - 7.47 to 112.0 ug/g
U02: 111TCE - 6.80 to 117.0 ug/g
LJ02: TRCLE 7.92 to 128.0 ug/g
U03: T12DCE 0.00247 to 0.0896 ug/g
LJ03: 111TCE - 0.00900 to 0.0938 ug/g
U03: TRCLE 0.00519 to 0.1020 ug/g
11
-------
cis/trans-1,2-dichloroethylene (T12DCE), 1,1,1- trichloroethane
(111TCE), trichloroethylene (TRCLE), and tetrachloroethylene
(TCLEE). Various metals have been detected in the soils in this
area. However, groundwater contamination with metals is minimal,
probably due to the retentive properties of the clayey soils with
respect to the>metals. Due to the limestone geology in the PDO
Area, there appears to be natural stabilization occurring with
respect to the metals. The Weston ISV study (October 1989b)
indicated that the majority of the contamination can be found in
the bedrock of the revetment area. Table 3 summarizes the soil
sample data from the PDO revetments, generated as part of the ISV
study.
High levels of organics have been found in wells in the
vicinity of the oil burning pit and the drum storage revetments,
and in the groundwater discharging to the surface waters of the
Rocky Spring system. Groundwater in the PDO Area is contaminated
with the same organic compounds as the soils with concentrations
up to 1,000 parts per billion (ppb).
Details on the toxicity, mobility, and carcinogenicity of
those contaminants are found in the Endangerment Assessment (EA)
for the PDO Area report (ESE, 1988). The EA also evaluated the
following known or potential routes of migration to LEAD workers
and off-post residents: Groundwater to surface water, soil to
air, soil to surface water, surface water to air, and groundwater
to air. The EA concluded that contamination from the PDO Area is
found in the surface water of, but not in the groundwater below,
Rocky Spring Lake. This fact, combined with the known groundwater
flow pattern toward the Rocky Spring system and the correlation of
surface water and groundwater contamination concentrations,
strongly suggests that contaminated groundwater discharges to the
Rocky Springs surface water system.
2.6. Summary of Site Risks
The PDO Area EA (ESE, 1988a) evaluated potential health risks
for workers and offpost residents by activities that would bring
them into contact with the contaminated soils froa the oil burning
pit and the PDO drum storage revetments. Skin absorption,
incidental ingestion of soils, and inhalation of vapors from
contaminated soils were considered to be possible concurrent
exposures for onsite workers. Access onto the installation is
restricted by fences which limits the potential for exposure to
,non-LEAD personnel.
The EA identified eight indicator chemicals as the
contaminants of concern in the PDO Area, as follows: Chloroform
(CHCL3), 1,1-dichloroethane (11DCLE), 1,1,1-trichloroethane
(111TCE), 1,1,2-trichloroethane (112TCE), cis/trans-1,2-
dichloroethylene (C/T12DCE), 1,1-dichloroethylene (11DCE),
12
-------
TABLE 3
Summary of Analytical Data POO ATM
Lattarkanny Army Depot ISV
VENT
No.
SI
S2
S3
S4
S3
se
S7
S8
S8
S10
S11
S12
S13
S14
S1S
S16
sir
S18
S19
S20
S21
S22
S23
S24
S25
SAMPLE
No.
SS01
SS01
SS02
SS01
SS01
SS01
SS02
SS02
SS04
ssot
SS01
ssoi
SS02
SSOI
SSOI
ssot
SSOI
SS02
SSOI
SSOI
SS02
SSOI
SS02
SSOI
SS03
SSOI
SS02
SS01
SSQ1
SS02
ssot
SS04
ssot
. ssot
SS02
DEPTH
m
$-7
5-7
10>12
S-7
5-7
5-7
10-12
10-12
20-22
5-7
5-7
- S-7
10-12
S-7
5-7
5-7
5-7
10-12
5-7
S-7
15-17
5-7
10-12
5-7
15-17
5-7
10-12
5-7
5-7
10-12
5-7
20-22
5-7
5-7
10-12
T12DCE
(mo/kg)
2.0'
0.075*
-
0.0497
0.0124
34.9
44.1
0.0069
0.0058
0.00417
0225*
4.14
3.68
0.048
15.8
0.0148
49.9
107.5
0.044
0.012
0.018
0.0069
0.05
0.0087
0.011
-
7.02
0.047
1.0*
-
0.033
0.020
0.01 S
0.1
0.020
111TCE
(mg/kg)
.
0.712
_
0.073
0.0078*
49.1
Tit
0.0103
0.0027
0.0132
0.034
24.5
29.4
0.017
19.7
0.0058
15.2
22.6
0.072
0.024
0.041
0.0305
0.017
0.013
0.016
-
6.59
0.0143
2.07*
>
0.026
0.034
0.640*
0.0076
0.019
TRCLC
(ma/ka)
0.0041
1.351 *
_
0.075
0.169*
107.3
136
0.0254
0.0256
0.0142
0.01
43.4
48.5
0.0046
213.5
0.394
39.5
72.3
0.045
0.0476
0.162
0.0406
Q.042
0.034
0.041
-
- 3.62
0.0567
7.36*
3.9
0.157*
0.877*
0.096
0.033
0.138
TOTAL
(ma/kg)
£0041
2.138
-
0.1977
02092
191.3
g52,2
0.0426
0.0343
0.03157
0269
72.04
8i.se
0.0696
249
0.4146
104.6
202.4
0.181
0.0836
0221
0.0762
0.109
0.0557
0.068
_
17.43
0.118
10.43
3.9
0218
0.931
0.754
0.1406
0.178
Indteaiaa data outaida certification rang*.
--Notdatactad.
#. Hyrtf rocarbon front
NOTE: Soil analytia conduct** using USATHAMA cartifiad Mathoda U02. U03.
Certification Rangaa a/a aa followa:
U02: T120CE 7.47 to 112.0 ug/g
U02:111TCE 6.80 to 117.0 ufl/g
LJ02: TRCUE 7.92 to 128.0 ug/g
U03: T12OCE 0.00247 to 0.0896 ug/g
U03:111TCE 0.00900 to 0.0938 ug/g
U03: TRCLE 0.00519 to 0.1020 u0/g
13
-------
trichloroethylene (TRCLE),and tetrachloroethylene (TCLEE). These
compounds, all volatile chlorinated hydrocarbons, represent the
most mobile, toxic, and widespread contaminants detected in the
PDO Area.
Key exposure routes evaluated for the PDO Area were:
1. Exposure to contaminants by use of Rocky Spring surface
waters;
2. Direct skin contact with contaminated soils;
«.
3. Incidental ingestion of contaminated soils; *
4. Inhalation of contaminant vapors in ambient air; and,
5. Exposure of aquatic life to contaminated surface water.
Total carcinogenic (cancer-causing) risk for workers in the
oil burning pit was estimated to be 2.4 x 10-7, below the EPA
target risk level of 10-6. (Note that 10-7 is less than 10- 6).
Total carcinogenic risk for workers in the drum storage revetment
area was 2.6 x 10-6, near the EPA target risk level. Offpost
residents downwind of the oil burning pit and the drum storage
.revetments would be exposed to carcinogenic risks on the order of
5.8 x 10-10 and 4.4 x 10-9 respectively, which are very low
levels. EPA's acceptable range for risk levels is 10-4 to 10-6
with the target risk level designated as 10-6. A cancer risk of
10-6 means that one additional person out of a million is at risk
of developing cancer if the site is not cleaned up.
The noncarcinogenic health hazard index (HI) represents the
sum of the calculated exposure levels to the acceptable exposure
concentrations for all chemicals under consideration. When the HI
exceeds unity (>1), there may be concern for a potential health
risk. The noncarcinogenic HI for the drum storage revetments
indicates that, even under the highest concentrations detected in
the soils, a significant health hazard to workers and residents
does not exist. Likewise, the noncarcinogenic His for the
oil-burning pit are all well below unity, indicating low potential
for adverse health effects to workers and downwind residents. Even
the noncarcinogenic HI values repesenting the sum total of all
contaminants for all exposure routes are several orders of
magnitude below unity, the highest value being 4.5 x 10-3
,(=.0045). Table 4 summarizes the EA assessments of the health
risks for PDO Area contaminants.
Based on the EA for the PDO Area, the levels of soil
contaminants at the drum storage revetments and oil burning pit do
not pose a significant hazard to LEAD personnel engaged in
activities around the areas of contamination, nor to offpost
14
-------
TABLE 4
SUMMARY OF CARCINOGENIC RISK AND NONCARCINOGENIC*
HAZARD LEVELS FOR PDO AREA CONTAMINANTS
""" Carcinogenic Noncarcinogenic
Exposure Pathway/Receptor Risk (CRL) Hazard (HI)e
Fish consumption (trout) ITTx^lT* 3.7.x 10"J
Swimming (all routes) 2.0 x 10"7 9.4 x lOT4
Domestic water supply 3T6*xTI(Jsr* 2.5 x 10"l
Workers in drum storage 2T63x7rr(T*' 4.5 x 10"3
revetments (all routes)
Workers in oil-burning pit 2.4 x 10"7 1.2 x 10"J
(all routes)
Workers 100m downwind of 2.2 x 10"' 8.2 x 10~9
drum storage revetments
(inhalation)
Residents 400m downwind of 4.4 x 10"' 1.6 x 10"5
drum storage revetments
(inhalation)
Workers 100m downwind of 2.9 xlO"f 1.7 x 10"5
oil-burning pit (inhalation)
Residents 400m downwind of 5.8 x 10"10 3.3 x 10"'
oil-burning pit (inhalation)
Workers 100m downwind of 6.7 x 10"7 1.5 x 10"5
Rocky Spring Lake (inhalation)
Residents -400m downwind of 4.6 x 10~7 1.1 x 10"5
Rocky Spring Lake (inhalation)
'Source: ESE, 1988
bCRL - Cancer Risk Level. Risk levels equal to or less than 10"' are
preferred by EPA.
CHI - Harard Index. .Represents the sum of the r. :vtos of calculated exposure
levels to acceptable exposure concentrations for all chemicals under con-
sideration. When the HI exceeds unity, there g be concern for a potential
health risk.
15
LEAD 1:18
-------
residents. Because of the low carcinogenic and noncarcinogenic
risks and the fact that a majority of the soil contamination has
already moved down into the clays and silts found within the
underlying fractured bedrock and the groundwater (ESE, 1987a and
1988a) (Weston 1989b), remediation of the surface soils is not
recommended. No remediation of soils is necessary to ensure
protection of human health and the environment.
2.7. Description of the "No Action" Alternative
The finding that "no action" is necessary to ensure adequate
protection of human health and the environment is supported by'the
EA and the various studies already mentioned which showed little
or no concentration of contaminants in the soils of the drum
storage revetments and oil burning pit. The studies indicate that
most of the contamination from the soils has already migrated into
the underlying bedrock and groundwater. Therefore, surface soil
remediation would not lessen any ongoing groundwater contamination
and is not necessary to lessen exposure risks to any populations,
since the exposure risks are already within acceptable limits.
Selection of this action does not expressly or otherwise
waive the Pennsylvania ARAR for groundwater. Evaluation of the
.risks to groundwater posed by contaminants associated with the
bedrock will be addressed in operable unit two.
No more work in connection with the soils will be performed
at the oil burning pit and drum storage revetments.
2.8. Explanation of Significant Changes
"No action" was the selected remedy in both the Focused
Feasibility Study (FFS) and Proposed Plan (PP) for accelerated
remedial action at the drum storage revetments and oil burning pit
in the PDO Area. There has been no significant change in the
selected remedy from the time the FFS and PP were released for
public comment to the final selection of the remedy.
16
-------
3. RESPONSIVENESS SUMMARY
This Responsiveness Summary documents concerns and
comments regarding proposed remedial actions for PDO Area Operable
Unit One as expressed to the United States Department of Army by
members of the community surrounding the site. The remarks were
presented during the public comment period, and they addressed the
Army's FFS and Proposed Plan to remediate contaminated soils at
the PDO Area of the Letterkenny Army Depot.
a. Summary Community Involvement:
»~
Community relations activities at LEAD to date have
included review and coordination meetings with federal and state
regulatory agency personnel; site visits and/or meetings with
elected federal, state and local officials; news releases to the
local media; and direct contact with nearby property owners
through the offsite well sampling program and subsequent
bottled-water provisions and connection to the Guilford Water
Authority (GWA).
Meetings with regulatory agency personnel have been
conducted regularly and are held with representatives from LEAD,
USATHAMA, the Pennsylvania Department of Environmental Resources
.(PADER), EPA Region III, Department of the Army, U.S. Army
Materiel Command (AMC), and Depot Systems Command (DESCOM).
Topics of discussion at these meetings generally included review
of project status, review of new technical information, resolution
of problem areas, and direction and schedule for further studies.
In addition to the formal meetings, LEAD, USATHAMA, PADER, and EPA
personnel maintain frequent telephone contact on an as-needed
basis.
Site visits to LEAD have been made by representatives of
USATHAMA, PADER, EPA Region III, and USATHAMA contractors.
Numerous site visits by PADER representatives have allowed
consistent communications and cooperation between LEAD and PADER.
Formal and informal project briefings and/or site visits have also
been held with local and township officials and state
representatives and senators.
At various times since June 1982, formal news releases
have been issued by LEAD concerning the groundwater contamination
problem. The timing of these releases has generally coincided
.with the availability of significant results from the onpost and
offpost contamination surveys and with the occurrence of status
review meetings between LEAD, USATHAMA, EPA and PADER. The news
releases have provided the local media and general public with
information on the status and results of the contamination
surveys, ongoing actions to protect public health, and plans and
schedules for additional activities.
17
-------
Numerous articles have been published in local and
regional newspapers concerning the contamination problem at LEAD
since the problem was first identified in mid-1982. Topics
covered in the articles has ranged from informational reports on
the results of the technical environmental surveys to interviews
with affected residents and their concerns on the problem.
Public involvement activities regarding the LEAD
contamination problem also have involved direct contact and
communication with local property owners, businesses, churches and
residents. LEAD held four local news conferences in 1982 to
directly brief local citizens, media and officials regarding the
contamination problem. A news conference was also held at LEAD in
August 1985 in conjunction with the pilot thermal stripping
project. The technology presented during that news conference is
the forerunner to the technology being proposed for remediation of
the K Area soils. Contact with the local citizens also has been
made in conjunction with the offsite well sampling program, which
was initiated in certain adjacent areas in mid-1982. Local
residents who have been affected by contamination of their potable
wells have had contact and communication with LEAD through the
Army's program to provide bottled water and, ultimately,
connection to GWA. These contacts have included letters to and
.meetings with residents with affected potable wells.
Since the groundwater contamination problem at LEAD was
identified in mid-1982, overall public interest and concern with
the problem has been relatively high. Identified community
interest and concern with the problem has involved primarily
citizens residing in the potentially affected areas adjacent to
LEAD and the local Chambersburg area. Interest in the
contamination problem at LEAD outside the local area primarily
involves EPA Region III and PADER as part of their regulatory
programs, and state and federal elected officials representing the
local citizens.
Currently, the primary community concerns identified at
LEAD pertain to the contamination of groundwater and the safety of
drinking water. Local concerns with the contamination problem
have been significant since contamination levels in some offpost
drinking water wells were found at higher levels than the
recommended human health criteria. The local residents affected
by the groundwater contamination are satisfied since they are now
connected to GWA. However, many residents interviewed indicated
displeasure with the length of time it took the Army to provide
them with clean water.
More than 9 years have passed since the problem was
initially identified, and, as may be expected, a number of
community concerns have been expressed in association with the
18
-------
groundwater contamination problem. These concerns include the
following:
o Desire to know if well water will be safe to use again
in the future;
o Potential long-term health effects that may have
occurred prior to knowing about the problem;
o Concern about fairness in water bill settlements;
o Concern regarding amount of money spent on research
and studies instead of corrective actions;
o Concern that contamination will continue to spread;
o Schedule or expediency of efforts to remedy problem;
o Effectiveness of remedial actions; and
o Devaluation of property.
The Army, through public meeting, news conferences and
news releases, has provided the local community with all available
information to address the concerns raised over the contamination
problem. The Technical Review Committee (TRC) established in
conjunction with the LEAD installation restoration program
includes representatives of the city of Chambersburg, Greene
Township, Franklin County, and Southampton County. The TRC was
established to provide a forum to address public concerns and
questions and to keep the public informed of installation
.restoration activities at LEAD.
c. Summary of Public Comments and Responses
No written comments were received during the public
comment period for the Proposed Plan. The comment period was held
from April 6, 1991 through May 20, 1991. Also, there was only
limited participation at the public meeting held on May 14, 1991
to discuss the Proposed Plan. No specific comments or concerns
were raised at the public meeting dealing specifically with the
Proposed Plan for the PDO Area Source Areas. One general comment
was raised concerning the overall environmental problem at LEAD as
summarized below:
(1) One citizen was concerned about the overall higher
rate of cancer for residents within the area surrounding
Chambersburg and inquired if the contamination problems at LEAD
could be the cause.
Response; While this was outside the scope of the
Proposed Plan in question, the Army provided a brief explanation
of the risk factors associated with the contamination at the K
Areas and the PDO Area source areas and available pathways from
the site to offpost residents. The low contamination levels,
coupled with the limited pathways to the offpost residents makes
it unlikely that any such increase in cancer could be linked to
19
-------
the environmental problems at LEAD.
d. Remaining Concerns
All concerns raised during the public meeting were
addressed to the satisfaction of all in attendance.
20
------- |