MANAGERS DESIGNERS/CONSULTANTS

®

Record of Decision

for Phase I Parcels

Letterkenny Army Depot

U.S. Army Corps of Engineers

Baltimore District

September 1998

98P-2715

LETTERKENNY

PENNSYLVANIA

CHAMBERSBURG,

ARMY DEPOT

BALTIMORE DISTRICT

Proud Past

 Dynamic Future

Final
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Final

Record of Decision

for Phase I Parcels

Letterkenny Army Depot

U.S. Army Corps of Engineers

Baltimore District

September 1998

Printed on recycled 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 Determinations ...................................................................................................... I

RECORD OF DECISION ..................................................1

SECTION 1 SITE NAME, LOCATION, AND DESCRIPTION ...................................1

INFORMATION............................................................................................................................1

TOPOGRAPHY AND SURFACE DRAINAGE ........................................................................1

GEOLOGY......................................................................................................................................1

HYDROGEOLOGY.......................................................................................................................5

NATURAL RESOURCES .............................................................................................................6

SECTION 2 SITE HISTORY AND ENFORCEMENT ACTIONS ...............................6

PROPERTY HISTORY ..................................................................................................................6

TENANT ACTIVITIES..................................................................................................................7

CERCLA STATUS .........................................................................................................................7

PDO AREA.....................................................................................................................................7

SOUTHEASTERN AREA.............................................................................................................9

ENFORCEMENT ACTIVITIES....................................................................................................9

SECTION 3 COMMUNITY PARTICIPATION HIGHLIGHTS..................................9

SECTION 4 SCOPE AND ROLE OF RESPONSE ACTION.......................................10

SECTION 5 SUMMARY OF SITE CHARACTERISTICS...........................................10

NATURE AND EXTENT OF CONTAMINATION................................................................10

Soil...........................................................................................................................................10

Groundwater.........................................................................................................................11

Routes of Exposure ...............................................................................................................11
TABLE OF CONTENTS

(Continued)

SECTION PAGE

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SECTION 6 SUMMARY OF SITE RISKS......................................................................12

CONTAMINANTS OF CONCERN..........................................................................................12

EXPOSURE ASSESSMENT........................................................................................................12

TOXICITY ASSESSMENT..........................................................................................................12

Carcinogens ...........................................................................................................................12

Noncarcinogens ....................................................................................................................13

RISK CHARACTERIZATION...................................................................................................13

Carcinogenic Risks................................................................................................................13

Noncarcinogenic Risks.........................................................................................................13

ECOLOGICAL CONSIDERATIONS........................................................................................14

RISK UNCERTAINTY................................................................................................................14

REMEDIAL ACTION OBJECTIVES (RAO) ............................................................................14

SECTION 7 DESCRIPTION OF REMEDIAL ALTERNATIVES...............................14

ALTERNATIVE 1: NO ACTION...............................................................................................14

ALTERNATIVE 2: INSTITUTIONAL CONTROLS ...............................................................14

SECTION 8 SUMMARY OF COMPARATIVE ANALYSIS OF

ALTERNATIVES ..........................................................................................15

THRESHOLD CRITERIA...........................................................................................................15

Overall Protection of Human Health and the Environment..........................................15

Compliance with ARARs.....................................................................................................15

PRIMARY BALANCING CRITERIA .......................................................................................16

Long-Term Effectiveness and Permanence.......................................................................16

Reduction in Toxicity, Mobility, or Volume .....................................................................16

Short-Term Effectiveness.....................................................................................................16

Implementability...................................................................................................................16

Cost .........................................................................................................................................16

MODIFYING CRITERIA............................................................................................................17

State Acceptance ...................................................................................................................17

Community Acceptance ......................................................................................................17

SECTION 9 THE SELECTED REMEDY .........................................................................17

SECTION 10 STATUTORY DETERMINATIONS.......................................................17

PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT................................17
TABLE OF CONTENTS

(Continued)

SECTION PAGE

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COMPLIANCE WITH APPLICABLE OR RELEVANT AND

APPROPRIATE REQUIREMENTS ....................................................................................17

COST EFFECTIVENESS .............................................................................................................17

UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE

TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY

TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE .............................18

PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT .....................................18

RESPONSIVENESS SUMMARY ....................................1

SECTION 1 OVERVIEW................................................................................................1

SECTION 2 BACKGROUND ON COMMUNITY INVOLVEMENT ..................1

CHRONOLOGY OF COMMUNITY INVOLVEMENT.....................................................1

KEY COMMUNITY CONCERNS ........................................................................................2

Cleanup Activities............................................................................................................2

Reuse ..................................................................................................................................2

Contamination..................................................................................................................2

Air Quality.........................................................................................................................3

Ammunition Detonation.................................................................................................3

Government ......................................................................................................................3

Army ..................................................................................................................................3

SECTION 3 SUMMARY OF COMMENTS RECEIVED DURING THE

PUBLIC COMMENT PERIOD AND AGENCY RESPONSES ........3

RESULTS OF THE SCREENING INVESTIGATIONS.......................................................3

PARCEL-SPECIFIC COMMENTS........................................................................................4

RISK ASSESSMENTS .............................................................................................................4

ENFORCEMENT OF THE INSTITUTIONAL CONTROLS.............................................4

ATTACHMENTS

ATTACHMENT 1 REFERENCES

ATTACHMENT 2 RISK ASSESSMENT TABLES

ATTACHMENT 3 TRANSCRIPT OF THE PUBLIC MEETING ON

THE PROPOSED PLAN
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LIST OF FIGURES

TITLE PAGE

Figure 1 Property Location ...................................................................................................2

Figure 2 Location of SE, PDO, and Enclaved Areas at LEAD..........................................3

Figure 3 Location of Drainageways and Major Drainage Divides at LEAD .................4

Figure 4 Location of Phase I Parcels at LEAD....................................................................8

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LETTERKENNY ARMY DEPOT

PHASE I PARCELS

CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA

RECORD OF DECISION

SEPTEMBER 28, 1998

SECTION 1

SITE NAME, LOCATION,

AND DESCRIPTION

INFORMATION

Letterkenny Army Depot (LEAD) is located in

Southcentral Pennsylvania in Franklin County, 5 miles

north of the Borough of Chambersburg (see Figure 1).

The Depot covers 19,243 acres, most of which is

devoted to ammunition storage (16,895 acres). The

industrial and maintenance areas, which are primarily

located in the southeast corner 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

portion of LEAD, which includes warehousing, vehicle

storage, industrial/maintenance, administration and

recreational activities, and housing. This entire area,

with the exception of selected retained areas, has been

designated for realignment (see Figure 2). The

infrastructure of this area includes roads; permanent,

semipermanent, and temporary structures; and

utilities.

TOPOGRAPHY AND SURFACE DRAINAGE

LEAD is located in the Great Valley section of the

Valley Ridge Province of the eastern United States, and

referred to locally as the Cumberland Valley. The

Cumberland Valley trends northeast to southwest

through central Pennsylvania and is bordered to the

west by the Appalachian Mountain Province. The

South Mountain section of the Blue Ridge Province is

situated east of Chambersburg and marks the eastern

edge of the Cumberland Valley.

The Cumberland Valley is characterized by southwesttrending limestone ridges and valleys. The valley

floors are filled with rocks of the Martinsburg

Formation. Weathering of the folded and faulted

underlying geologic formations imparts a gently

rolling aspect to the local topography. The majority of

LEAD is located within the Martinsburg Shale terrain,

except for bands of carbonate rocks along the eastern

and western edges of LEAD. The PDO Area and the

Southeast Industrial Area (SIA) of LEAD are underlain

by limestone. Surface elevations throughout LEAD

range from approximately 600 to 750 feet above mean

sea level (msl), except for the northwest portion of

LEAD, where the elevation increases abruptly to more

than 2,300 feet (ft) above msl in the vicinity of Broad

Mountain (EA, 1991).

Streams cutting through the limestone terrain flow

through broad, open valleys and are usually

intermittent. In contrast to this, streams cutting

through the upper shale units of the Martinsburg

Formation usually meander in small, steep-walled

valleys and are perennial. Surface drainage at LEAD is

divided into two watersheds—the Susquehanna River

to the northeast and the Potomac River to the

southwest. Both the Susquehanna and Potomac Rivers

eventually drain into the Chesapeake Bay.

Two major stormwater drainage systems serve the

southeast portion of LEAD and contribute to local

surface drainage. One system serves the area north of

Coffey Avenue and discharges near the Industrial

Wastewater Treatment Plant (IWTP) into the industrial

plant outfall ditch (located north 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 storm drain

outfall, and joins other surface runoff flowing

southward to Conococheague 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

Massanutten synclinorium to the west. The eastern

portion of the Depot (underlain by carbonate rocks) is

part of the anticlinorium, whereas the western portion

of the Depot (underlain by shale) is part of the

synclinorium. These structures resulted from folding
Property location shown in black. Base map image adapted

from the U.S. Geological Survey 30x60 minute quadrangle maps,

Carlisle, PA (photo inspected 1985) and Hagerstown, MD, PA, WV (1983).

Scale

1:100,000

0 4

0 Kilometers 5

Miles N

WV

MD

PENNSYLVANIA

98P-0629

Letterkenny Army Depot

Philadelphia

Pittsburgh Harrisburg

LETTERKENNY

ARMY DEPOT

U.S. Army Corps of Engineers

Baltimore District

Letterkenny Army Depot

Chambersburg, Pennsylvania

FIGURE 1

PROPERTY LOCATION


LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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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, which 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

Formation. The five formations occurring 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

Rockdale Run Formation, and the dolomites of the

Pinesburg Station 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 Letterkenny Faults. Although an east-towest 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 Letterkenny

Fault, indicating that the latter fault is older.

The Letterkenny Fault is one of the few faults in the

region that parallels the tectonic grain, yet is an early

formed, westward-dipping thrust that moved material

from within the syncline to the west up onto the

anticline to the east (EA, 1991).

The Pinola Fault, located 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 Formation

on the basis of a ridge-forming unit that extends

through it (Becher and Taylor, 1982).

HYDROGEOLOGY

The regional surface water flow system of Franklin

County controls the general groundwater flow patterns

within LEAD. The surface water drainage divide,

discussed previously, also divides the groundwater

flow system into two basins. Groundwater elevation

contours within LEAD generally reflect surface

topography. The water table is located at moderate

depth in areas of topographic highs and is shallow near

stream valleys and other topographic lows (ERM,

1995).

The shale and carbonate rock that underlie LEAD have

been disturbed and faulted during deformational

events that ultimately formed the Great Valley. The

two major faults located within the confines of LEAD

(the Pinola Fault and the Letterkenny Fault) influence

groundwater flow. Where faulting is present and

dissimilar rocks have been brought into contact, the

fault tends to act as a barrier to groundwater

movement, occasionally forcing water within the

formation to discharge as a fault spring. Where similar

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 to generally follow a regional flow path.

Groundwater flow within the limestone of the

Chambersburg Formation and St. Paul Group is more

complex because it occurs predominantly through

individual fractures and solution cavities typical 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 flow 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/surface material contact. Leaching or

resuspension of any materials or potential

contaminants buried in the surficial sediments may be

enhanced during high water table conditions (ERM,

1995).

Groundwater recharge occurs primarily through

precipitation. Recharge areas occur throughout the

central part 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 present

at LEAD are the most likely routes (ERM, 1995).

Groundwater underlying LEAD generally occurs

under unconfined conditions, with local areas of

artesian conditions. These artesian conditions occur

along a moderately steep slope located near the

northwest edge of LEAD in the Ammo Area.

A groundwater study completed for the U.S. Army

Corps of Engineers (USACE) in the 1950s concluded

that there was not a viable source of groundwater

available within LEAD boundaries to supply the
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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Depot’s industrial 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 others are connected to the

Guilford Water Authority waterline. Groundwater is

also used outside LEAD as a water supply for

livestock. Any homes on well water that exceeded an

applicable ARAR were initially supplied with bottled

water, and later connected to public water.

NATURAL RESOURCES

The property included in the Phase I Parcels consists of

primarily industrial and developed land, small stands

of trees and open grassy areas, and agricultural areas.

No wetlands are located within the Phase I Parcels,

and no Federal or state threatened or endangered

species are known or suspected to have habitats within

the Phase I Parcels.

SECTION 2

SITE HISTORY AND

ENFORCEMENT ACTIONS

PROPERTY HISTORY

The Letterkenny Ordnance Depot was established in

January 1942 as an ammunition storage facility. In

subsequent years, the following missions were added:

♦ Reserve storage and export advance storage of parts,

tools, supplies, and equipment for combat vehicles,

artillery, small munitions, and vehicle fire control

equipment (1943).

♦ Receipt and storage of hardware, heavy-duty trucks,

and parts (1944).

♦ Establishment of transport and combat vehicle shops

and expansion of the maintenance program (1947).

♦ Establishment of a rebuild system for guided missile

ground control, launching, and handling equipment;

missile propellant systems; and internal guidance

systems (1954).

♦ Assignment of the special weapons mission (1958).

♦ Designation of the Depot as the Eastern Equipment

Assembly Area (1959). This mission gave the Depot

responsibility for the handling and shipment of

equipment for guided missile and special weapons

units to overseas locations.

♦ Acceptance and destruction of contaminated U.S.

Air Force (USAF) missile fuel (1961).

♦ Letterkenny Ordnance Depot renamed as

Letterkenny Army Depot (1962).

♦ Disposal of explosive ordnance generated from the

Army as well as state and local police (1964).

♦ Maintenance and storage of USAF missiles (1966).

♦ Receipt, storage, and dispersal of batteries and tires

to Army units (1972).

♦ Operation of a washout facility to reclaim explosives

from munitions (1973).

These operations consisted of cleaning, stripping,

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.

Prior to the establishment of LEAD, the area consisted

of agricultural and forest lands. 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 the

Defense Base Closure and Realignment Act of 1990

(Public Law 101-510, 104 Stat. 1808) (BRAC 91, 93, 95)

designated more than 100 Department of the Army

facilities for closure and/or realignment. On 28

February 1995, the United States Secretary of Defense

submitted a recommendation to Congress that LEAD

be selected for realignment.

The BRAC Commission recommended “transferring

the towed and self-propelled combat vehicle mission to

Anniston Army Depot, Alabama; retain[ing] an

enclave for conventional ammunition storage and

tactical missile disassembly and storage; and

change[ing] the 1993 [BRAC] Commission’s decision

regarding the consolidation of tactical missile

maintenance at Letterkenny by transferring missile

guidance system workload to Tobyhanna Army Depot

(TYAD), Pennsylvania, or private sector commercial

activities.”

In anticipation of the realignment of the LEAD mission,

an Environmental Baseline Survey (EBS) was

conducted for the to-be-excessed property (Phase I,

August 1996; Phase II, Draft, July 1997). The EBS

process includes visual inspections of each property as

well as record reviews and personnel interviews,

which are used to document current and historical

conditions with 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
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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environmental concerns, aside from the documented

VOC groundwater contamination.

The Letterkenny Industrial Development Authority

(LIDA) developed a list of priority buildings and

parcels based on the potential for reuse and

redevelopment planning. The Phase I Parcels represent

those buildings and properties identified by LIDA that

the Army deemed suitable to transfer at this time, as

will be documented in the FOST for Phase I Parcels.

The Phase I Parcels consist of the following:

♦ Parcels 1 and 2 (Open land near Gate 6)

♦ Parcels 3 and 4 (Buildings 6 and 9)

♦ Parcel 5 (Buildings S20-1 through S20-5)

♦ Parcel 6 (Open storage south of Parcel 7)

♦ Parcel 7 (Building 238)

♦ Parcel 8 (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,

and 54)

♦ 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 581)

♦ 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

Reutilization 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 the 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 [SIA])

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 the 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 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.

PDO 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.

LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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Analysis of soil, surface water, and groundwater

samples collected during the investigatory programs

conducted in the 1980s indicated concentrations of

chlorinated solvents, such as trichloroethene (TCE),

1,1,1-trichloroethane (TCA), and their associated

breakdown products. These constituents are consistent

with those used at LEAD for degreasing and cleaning

operations. Concentrations of total volatile organic

compounds (VOCs) detected in Rocky Spring have

averaged 50 to 80 parts per billion (ppb) during the

period 1981 to 1995.

Based on the information collected to date for the PDO

Area, six OUs have been created. These six OUs are:

♦ OU 1: Source Area Soils (soils from the Oil Burn Pit

[OBP] and drum storage revetments).

♦ OU 2: PDO Area Groundwater and Surface Water.

♦ OU 3: Mercury Detections in Rocky Spring Lake.

♦ OU 4: Groundwater Divide at 81-5 and Off-PDO

Groundwater (Ammunition Area and OffPost Residential Wells).

♦ OU 5: PCB Investigation of the Rocky Spring

System.

♦ OU 6: BRAC Waste Sites.

OUs 1 and 2 were originally established when 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. The creation of

these two OUs permitted the continued remedial

action at OUs 1 and 2, while further investigation was

conducted at OUs 3 and 4. OU 5 was created in

September 1995, with EPA and PADEP consent, based

on the detection of PCBs in the sediments of Rocky

Spring. OU 6 is composed of waste sites, located in the

to-be-excessed part of the PDO Area, that were

identified as part 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 PDO Area are the drum storage revetments (part of

PDO OU 1), the PDO Oil Burn Pit (part of PDO OU 4),

the Open Trench Landfill, and the DRMO Scrap Yard

(PDO OU 5). None of these source areas are located

within the Phase I Parcels.

SOUTHEASTERN AREA

The SE Area consists of the SIA and the DA and

encompasses approximately 1,136 acres. Eight

individual OUs have been created in the SE Area at

LEAD:

♦ OU 1: K Area Contaminated Soils.

♦ OU 2: Industrial Wastewater Sewers and

Contaminated Soils.

♦ OU 3: SE Area On-Post Contaminated

Groundwater.

♦ OU 4: Storm Sewers and Contaminated Soils and

Sediments.

♦ OU 5: Area A and Area B Contaminated Soils.

♦ OU 6: SE Area Off-Post Contaminated

Groundwater.

♦ OU 7: Truck Open Storage Area (north of

Buildings 32/33)/Waste Oil Sump.

♦ OU 8: BRAC Waste Sites.

SE OUs 2 and 3 underlie the following Phase I Parcels:

1-13, 16-21, and 23-27. Portions of SE OUs 2 and 4 are

included in the Phase I Parcels.

The main sources of contamination in the SE Area are

the K Areas (SE OU 1), the former industrial

wastewater lagoons (addressed under the Resource

Conservation and Recovery Act [RCRA]), and the

leaking industrial wastewater sewers (IWWS)

(SE OU 2). None of these source areas are located

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 associated with

leakage of the IWWS.

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 coordination with the EPA Region III and PADEP

Southcentral Region. No other potentially responsible

parties (PRPs) have been identified.

SECTION 3

COMMUNITY PARTICIPATION

HIGHLIGHTS

Pursuant to CERCLA §113(k)(2)(B)(i-v) and §117, the

Proposed Plan for the Phase I Parcels at LEAD was

released to the public for comment on 30 March 1998.

This document was made available to the public in the

Administrative Record, located at the Coyle Free
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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Library in Chambersburg and at Building 618 at

LEAD.

The notice of availability of notification of the

Proposed Plan Public Meeting was published in The

News Chronicle, The Record Herald, and The Public

Opinion on 30 March 1998. A public comment period

was held from 30 March 1998 to 29 April 1998. On

7 April 1998, 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

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 Attachment 3 to this ROD.

SECTION 4

SCOPE AND ROLE OF

RESPONSE ACTION

The response action selected for this site is a final

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 final

measure to address the VOC-contaminated on-post

groundwater operable units (PDO OUs 2 and 4, and SE

OU 3). Final remedial actions for these OUs are being

developed separately. A Draft Final ROD for PDO OU

2 is currently under regulatory review. Draft Remedial

Investigation (RI) reports have been prepared for PDO

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 parcels available for

beneficial reuse in a timely fashion.

SECTION 5

SUMMARY OF SITE

CHARACTERISTICS

NATURE AND EXTENT OF CONTAMINATION

Soil

Numerous studies have been conducted in both the

PDO 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 onsite treatment, or excavation and off-site disposal, to

the extent practicable.

Based on the Environmental Baseline Survey (EBS),

several of the Phase I Parcel areas underwent limited

investigations of the soils to 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

Army, 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:

♦ EPA Region III Risk-Based Concentrations (RBCs)

for Industrial Use (October 1997).

♦ 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).

Parcel 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 parcel, and

one sample was analyzed for Target Analyte 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 Army, as part of

the 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 metal in

Pennsylvania (Shacklette and Boerngen, 1984).

Residential and child-intense use scenarios were not

evaluated.

Parcels 1 and 2

Parcels 1 and 2 are open land located south of Coffey

Avenue near Gate 6. Historic vehicle storage and

temporary coal storage were observed in aerial
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photographs, which prompted the screening

investigation. Eight test trenches were completed in

these parcels, 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 Army

agreed that the detected concentrations did not

warrant 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 two metals in Pennsylvania.

Residential and child-intense use was not

characterized.

Parcel 29

Parcel 29 is a large undeveloped parcel that is leased to

a private farmer for agricultural use. Evidence from

historic aerial photography indicated 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 III RBCs.

EPA, PADEP, and the Army agreed that these

concentrations did not warrant further remedial action

for continued commercial/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 two metals in Pennsylvania.

Residential and child-intense use was not

characterized.

Soil borings were advanced within the perimeter of

Parcel 29 as part of the investigations for PDO OU 5.

(Parcel 29, although initially included as part of PDO

OU 5, is being addressed as part of the Phase I Parcels.)

Only scattered 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.

Parcels 10 through 13

An Installation Assessment Report (1980) indicated

that a spill of pesticides had occurred near Dock 45 and

that damaged pesticide containers had been stored at

this dock. However, a figure in the report showed a

much larger area as the site for the spill. To determine

whether residual levels of pesticides were present from

these incidents, a sampling program was conducted

that 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 45

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 confirm

these results, 20% of the samples were randomly

selected and submitted to the laboratory for

confirmatory analysis. No pesticides were detected in

the laboratory analyzed samples.

Railroad Tracks Within the Phase I Parcels

Information from interviews with former employees

indicated that heavy doses of herbicides were routinely

used along the railroad tracks, and that oils may have

been applied to suppress vegetation. Composited soil

samples were collected along the railroad tracks in the

SE Area warehouse district. The only constituents that

were detected above the screening criteria were arsenic

and beryllium, which exceeded the EPA RBCs. EPA,

PADEP, and the Army agreed that these

concentrations did not warrant further remedial action

for continued 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 two

metals in Pennsylvania. Residential and child-intense

use was not evaluated.

Groundwater

VOC-contaminated groundwater exists beneath all of

the PDO and SE Areas, which include all of the Phase I

Parcels. The primary contaminants of concern detected

are trichloroethene (TCE), 1,1,1-trichloroethane (TCA),

1,1-dichlorethane (DCA), 1,2-dichlorethene (DCE), and

tetrachloroethene (PCE), all of which have been

detected at concentrations exceeding their respective

Maximum Contaminant Levels (MCLs).

Routes 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 I Parcels. In the PDO 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 flow into the groundwater

system. Groundwater then surfaces downgradient at

the Rocky Spring House, where it flows into Rocky

Spring Lake, and then across a man-made dam to an
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off-Depot stream, which eventually discharges into the

Conodoguinet watershed.

Potential routes of exposure include:

♦ Dermal contact with soil and groundwater.

♦ Inhalation of soil dust and vapors.

♦ Ingestion of soil and or groundwater.

For the risk assessments conducted previously for the

SE and PDO Areas, all of the above exposure pathways

were considered for on-Depot workers, since that was

the current and anticipated future use of the property.

The probable exposure pathways under the future uses

proposed by LIDA are consistent with those for current

on-Depot workers.

SECTION 6

SUMMARY OF SITE RISKS

Risk Assessments (RAs) were conducted for specific

areas within the PDO and SE Areas at 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 that could exist if no action is taken at the

Phase I Parcels. This section of the ROD summarizes

the results of the RAs conducted for this Site.

CONTAMINANTS OF CONCERN

Soil and groundwater data collected during the RIs

were reviewed and evaluated to determine the

contaminants of concern at the Site that are most likely

to pose risks to public health. None of the soil samples

collected during the RIs 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 1 (Tables are

presented in Attachment 2).

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

industrial and potential future (industrial) land use.

Currently, there are workers on-site. The exposure

pathways for the current worker scenario group

included dermal contact with, and incidental ingestion

of, contaminants in surface soils along with the

inhalation of soil gases from the volatilization of

groundwater VOCs.

Future 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 construction 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 dermal contact with,

groundwater.

At the time that the PDO and SE Area risk assessments

were conducted, the anticipated future use of the

property was industrial. Therefore, no other use

scenarios were considered.

The exposure scenarios, mathematical models, and the

assumptions that were used to calculate the intakes

(i.e., doses) of the chemicals of concern for each

receptor through the applicable exposure route are

presented in Tables 2 and 3.

TOXICITY ASSESSMENT

In evaluating potential health risks, both carcinogenic

and noncarcinogenic effects were considered. The

potential for producing carcinogenic effects is limited

to substances that have been shown to be carcinogenic

in animals and/or humans. Excessive exposure to all

substances, carcinogenic or noncarcinogenic, can

produce noncarcinogenic effects. Therefore, reference

doses, when available, are identified for every chemical

selected regardless of its classification, and cancer

slopes are identified for those chemicals classified as

carcinogenic.

Carcinogens

Slope factors (SFs) have been developed by EPA for

estimating excess lifetime cancer risks associated with

exposure to potentially carcinogenic contaminants of

concern. SFs, which are expressed in units of (mg/kgday)-1, are multiplied by the estimated intake of a

potential carcinogen in mg/kg-day to provide an

upper bound estimate of the excess lifetime cancer risk

associated with the exposure at the intake level. The

term “upper bound” reflects the conservative estimate

of the risk calculated from the SFs. Use of these

approaches makes underestimation of the actual cancer

risk highly unlikely. SFs are derived from the results of

human epidemiological studies of chronic animal

bioassays to which animal-to-human extrapolation and

uncertainty factors have been applied (e.g., to account
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for the use of animal data to predict effects on

humans).

The EPA weight-of-evidence classification systems for

carcinogenicity is presented in Table 4, and the

carcinogenicity classification for the contaminants of

concern is presented in Table 5.

Noncarcinogens

Reference doses (RfDs) 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 mg/kg-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 RfDs. RfDs are

derived from 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 RfDs used in this evaluation

and the references used for each contaminant are listed

in Table 5.

RISK CHARACTERIZATION

This risk characterization is an evaluation of the nature

and degree of potential carcinogenic and

noncarcinogenic health risks posed to the current

worker and future construction workers receptors at

LEAD. In this section, human health risks are

discussed independently for potential carcinogenic and

noncarcinogenic effects for contaminants because of

the different toxicological endpoints, relevant exposure

duration, and methods employed in characterizing

risk.

Carcinogenic Risks

For carcinogens, risks are estimated as the incremental

probability of an individual developing cancer over a

lifetime as a result of exposure to the carcinogen.

Excess life-time cancer risk is calculated from the

following equation:

Risk = CDI x SF

where:

risk = a unit less probability (e.g., 2 x 10-5) of

an individual developing cancer;

CDI = chronic daily intake averaged over an

estimated exposure period (mg/kgday); and

SF = slope factor, expressed as

(mg/kg-day)-1

These risks are probabilities that are generally

expressed in scientific notation. An excess lifetime

cancer risk of 1 x 10-6 indicates that, as a reasonable

maximum estimate, an individual has a 1 in 1,000,000

chance of developing cancer as a result of LEADrelated exposure to a carcinogen over a working

lifetime under the specific exposure conditions at the

Site.

For the current on-site worker scenario, the lifetime

excess cancer risk was estimated to range from

9.6 x 10-11 to 7.5 x 10-8 in the SE Area, and 4.2 x 10-8 to

1 x 10-6 in the PDO Area. For the future construction

worker scenario, the lifetime excess cancer risk were

estimated to range from 2.4 x 10-9 to 6 x 10-3 in the SE

Area and from 1.5 x 10-4 to 4.1 x 10-4 in the PDO. The

primary difference between the current and future

worker scenarios was the consumption and use of

VOC-contaminated groundwater.

Noncarcinogenic Risks

The potential for noncarcinogenic effects is evaluated

by comparing an exposure level over a specific time

period (e.g., lifetime) with a reference 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 contaminants of concern that affect the

same target organ (e.g., liver) within a medium or

across all media to which a given population may

reasonably be exposed, the Hazard Index (HI) can be

generated.

The HQ is calculated as follows:

Noncancer HQ = CDI/RFD

where:

CDI = Chronic Daily Intake

RfD = Reference dose; and

CDI and RfD are expressed in the same units and

represent the same exposure period (i.e., chronic,

subchronic, or short-term).

The results of the risk calculations indicated that the HI

for the current work scenario ranged between 3.6 x 10-6

and 2.5 x 10-2 for the SE Area, and well below 1 for the

PDO Area. For future worker scenarios, however, the
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HIs ranged from 3.3 to 3.5, attributable mainly to the

assumed use and consumption of groundwater.

ECOLOGICAL CONSIDERATIONS

The Phase I Parcels include several commercial and

industrial buildings, paved roads and paved parking

areas, an agricultural parcel, and areas of mowed

grassy fields and small stands of trees. This

configuration inhibits the formation of habitat areas, as

it is completely developed. Given the nature and future

use of the Phase I Parcels, it is unlikely that the site

would constitute a significant habitat or affect

threatened or endangered species identified as being

potentially present at LEAD.

RISK UNCERTAINTY

There is a generally recognized uncertainty in human

risk values developed from experimental data. This is

primarily due to the uncertainty of data extrapolation

in the areas of (1) high to low dose exposure, (2)

modeling of dose response effects observed, (3) route

to route extrapolation, and (4) animal data to human

data extrapolation. The site-specific uncertainty is

mainly due to the degree of accuracy of the exposure

assumptions.

In the presence of such uncertainty, the EPA and the

risk assessor have the obligation to make conservative

assumptions such that the chance is very small for the

actual health risk to be greater than that determined

through the risk process. On the other 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 the interpretation of

data and guidance for the baseline risk assessment for

this Site. The environmental condition of these parcels

is expected to improve based on actions planned or in

progress at the other OUs.

REMEDIAL ACTION OBJECTIVES (RAO)

Remedial action objectives for the contaminants of

concern in the Phase I Parcels were developed to

prevent direct contact 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 to levels of

contaminants that produce unacceptable risk levels.

Selection of final remedial measures regarding

groundwater will be presented in separate RODs.

SECTION 7

DESCRIPTION OF REMEDIAL

ALTERNATIVES

CERCLA requires that each selected final site remedy

be protective of human health 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 of toxicity,

mobility, or volume (TMV) of the hazardous

substances.

Based on the available information, the Army has

evaluated the following two alternatives:

Alternative 1: 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: $0

5-Year Review Cost: $25,000/review

Present Worth Cost: $35,000

CERCLA guidance requires that the no-action

alternative be considered as a baseline for comparison

of other alternatives. No remedial actions would be

implemented under this technology. The present worth

cost is based on two 5-year performance evaluation

reviews/reports.

ALTERNATIVE 2: INSTITUTIONAL CONTROLS

Capital Cost: $7,500

5-Year Review Cost: $25,000/review

Present Worth: $42,500

Annual Recurring Cost: $1,000

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 the property transfer, the institutional controls will

take the form of environmental deed restrictions. The

environmental deed restrictions shall be protective of
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human health and the environment by:

♦ Restricting the property for commercial and

industrial use only.

♦ Not permitting soil excavation activities below a

depth of 3 feet above the water table without prior

approval of the Army.

♦ Not permitting construction of any subsurface

structure for human occupation, without the prior

approval of the Army, PADEP, and the EPA.

♦ Restricting access or use of the groundwater

underlying the property without the prior written

approval of the Army, 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 transferred, the

restrictions will be implemented through the use of

appropriate deed restrictions, which will be recorded

at the time of transfer. In addition, upon transfer of the

property, the Army, in consultation with EPA and

PADEP, will establish periodic inspection procedures

to ensure adherence to the institutional controls. The

present worth cost includes two 5-year performance

evaluation 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 evaluation criteria: overall protection of

human health and the environment; compliance with

applicable or relevant and appropriate level

requirements (ARARs); long-term effectiveness and

permanence; reduction of toxicity, mobility, and/or

volume; short-term effectiveness; implementability;

cost; regulatory acceptance; and community

acceptance.

A comparative analysis of the two alternatives based

on these evaluation criteria is presented in the

following sections.

THRESHOLD CRITERIA

Overall Protection of Human Health and the

Environment

Alternative 1: No Action

No remedial action would be implemented under this

alternative. The current site conditions and property

use present no risk to human health because the

groundwater is not used and constituents in the soils

do not exceed industrial RBCs. This alternative,

however, is not protective of an unrestricted use

scenario. Furthermore, since soils were evaluated only

for industrial use scenarios, there may be potential risk

under different types of use scenarios. The potential for

exposure and associated risk for exposure to VOCcontaminated groundwater to future land users is high

considering activities such as construction.

During periods of high groundwater table elevations,

the risk of exposure to VOC-contaminated

groundwater would increase.

No permanent habitats for aquatic life exist within the

BRAC Parcels. Therefore, no evaluation of aquatic risk

was necessary. No significant risk to terrestrial

receptors was identified for the Phase I Parcels due to

both a lack of sustainable habitat and insignificant

levels of bioaccumulating contaminants.

Alternative 2: Institutional Controls

Institutional controls would be implemented under this

alternative. The enforcement 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

to future users. The institutional controls would

mitigate both the carcinogenic and noncarcinogenic

risks described in Section 6 above.

No permanent habitats for aquatic life exist within the

BRAC Parcels. Therefore, no evaluation of aquatic risk

was necessary. No significant risk to terrestrial

receptors was identified for the Phase I Parcels due to

both a lack of sustainable habitat and insignificant

levels of bioaccumulating contaminants.

Compliance with ARARs

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 both alternatives

would be in compliance with all ARARs.

Chemical-Specific ARARs

♦ PADEP Act 2 Medium-Specific Concentrations,

Appendix A, Tables 3A and 4A, Nonresidential

Surface Soil 0-2 Feet; and Tables 3B and 4B, Used

Aquifers, TDS <2,500, Nonresidential, Generic

Value.
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Action-Specific ARARs

Neither alternative would be subject to action-specific

ARARs.

Location-Specific ARARs

No location-specific ARARs are required.

PRIMARY BALANCING CRITERIA

Long-Term Effectiveness and Permanence

Alternative 1: No Action

Implementation of the no-action alternative could be

effective and permanent in the long-term if considering

the soil alone because no significant contamination is

present, assuming continued industrial use. However,

in the long term, 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 1 does not meet the requirements for longterm effectiveness and permanence.

Alternative 2: Institutional Controls

The long-term effectiveness of the institutional controls

will be contingent upon enforcement of use restrictions

initially by the Army through the LEAD Master Plan,

and after transfer, through enforcement of the

environmental deed restrictions. The enforcement of

these restrictions will be the responsibility of LIDA, the

Army, EPA, and PADEP.

Implementation of this alternative would maintain the

industrial 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 permanent

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-term and permanent remedial action.

Reduction in Toxicity, Mobility, or Volume

Neither alternative results in a change in toxicity,

mobility, or volume, since the alternatives do not

involve physical remedial actions. The soils do not

contain levels of constituents above the EPA Region III

industrial 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

treatment that reduces the toxicity, mobility, and/or

volume as a principal element will be addressed by the

final groundwater response.

Short-Term Effectiveness

Alternative 1: No Action

Alternative 1 would not meet the requirements for

short-term effectiveness. Currently, LEAD prohibits

use or contact with groundwater, and there is only

industrial use of the property on the Phase I Parcels.

Once the 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.

Alternative 2: Institutional Controls

Under this alternative, institutional controls would be

implemented to mitigate risk due to exposure to

groundwater. This alternative would have short-term

effectiveness because the Army will formally

document the requirements of the institutional controls

by amending the LEAD Master Plan. This will provide

effectiveness from the finalization of the ROD until the

date of transfer. The environmental deed restrictions

would be in place from the date of transfer, which will

provide for long-term effectiveness (see above).

Implementability

Alternative 1: No Action

Under the no-action alternative, there are no measures

to implement.

Alternative 2: Institutional Controls

Alternative 2 can be easily implemented. The shortterm implementation of the preferred alternative

would involve amending the LEAD Master Plan to

include the institutional controls that are already in

place informally at the Depot. Once the amendment is

added, appropriate directorates at LEAD (the

environmental division, Public Works, security) will be

provided with a copy and with the enforcement action

chain-of-command for infractions.

Concurrent with this activity, the Department of the

Army would be developing deed restrictions for the

Phase I Parcels. The BCT has already discussed the

property transfer environmental restrictions, and the

deed restrictions will be presented to the regulatory

representatives for concurrence.
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Cost

Alternative 1 solely has the estimated costs of the two

5-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 received on the

Proposed Plan during the Public Comment Period.

These comments and responses to these comments are

provided in the Responsiveness Summary of this ROD.

SECTION 9

THE SELECTED REMEDY

Based on consideration of the CERCLA requirements,

the NCP, the detailed analysis of the alternatives using

the nine criteria, and public and state comments, the

Army 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 recurring cost of $1,000/year.

The selected remedy, Institutional Controls, shall

include the following components:

♦ Restricting the property for commercial and

industrial use only.

♦ Not permitting soil excavation activities below a

depth of 3 feet above the water table without prior

approval of the Army.

♦ Not permitting construction of any subsurface

structure for human occupation without the prior

approval of the Army, PADEP, and the EPA.

♦ Restricting access or use of the groundwater

underlying the property without the prior written

approval of the Army, 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 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 property, the

Army, in consultation with EPA and PADEP, will

establish periodic inspection procedures to ensure

adherence to the institutional controls.

SECTION 10

STATUTORY DETERMINATIONS

Under CERCLA 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 permanent

solutions and alternative treatment technologies or

resource recovery technologies to the maximum extent

practicable. In addition, CERCLA includes a preference

for remedies that employ treatment that permanently

and significantly reduce the volume, toxicity, or

mobility of hazardous waste as their principal element.

The following sections discuss the remedy in light of

these statutory requirements.

PROTECTION OF HUMAN HEALTH AND THE

ENVIRONMENT

The remedy shall be protective of human health and

the environment. The institutional controls will

mitigate both the carcinogenic and noncarcinogenic

risks described in Section 6 above.

COMPLIANCE WITH APPLICABLE OR

RELEVANT AND APPROPRIATE

REQUIREMENTS

The selected final remedy with regard to soils will be in

full compliance with all applicable or relevant and

appropriate requirements (ARARs). Since the remedy

regarding groundwater is an interim measure, final

cleanup objectives and ARARs will be addressed in

subsequent OU RODs.

COST EFFECTIVENESS

The selected remedy, Institutional Controls, was

chosen because it provides the best balance among

criteria used to evaluate the alternatives considered in

the Detailed Analysis. The alternative was found to

achieve both adequate protection of human health and

the environment and to meet the statutory

requirements of Section 121 of CERCLA. The selected

remedy was found to be cost-effective. The cost of

Alternative 2 has been established to be $7,500.
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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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 and treatment technologies can be

utilized in a cost-effective and timely manner for the

Phase I Parcels. The groundwater portion of this action,

however, is interim and is not intended to utilize

permanent solutions and alternative 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 satisfy the statutory

preference for treatment as a principal element of

the remedy. With respect to the soils, as long as the

property is not used for non-industrial purposes, a

treatment remedy is not required. As for the

groundwater, since the selected action does not

constitute a final remedy, the statutory preference

for remedies that employ treatment that reduces

toxicity, mobility, or volume as a principal element

will be addressed by the final groundwater response

action.
O:\02281016.005\FNL_RSUM.DOC(9/29/98) FINAL 1

LETTERKENNY ARMY DEPOT

PHASE I PARCELS

CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA

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 Letterkenny 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 alternative 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

LIDA.

SECTION 2

BACKGROUND ON COMMUNITY

INVOLVEMENT

CHRONOLOGY OF COMMUNITY

INVOLVEMENT

Community relations activities at LEAD to date have

included public meetings; review and coordination

meetings with Federal and state regulatory personnel;

site visits; meetings with elected Federal, state, and

local officials and with community groups; news

releases to the local media; and direct contact with

nearby property owners.

Community interviews were conducted in 1988 as part

of the process of developing the Public Involvement

and Response Plan, which was published in 1990. At

the time of the 1988 community interviews, the

primary 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

restoration activities related to DERA and BRAC

actions. The RAB replaced the Technical Review

Committee (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

(LIDA) (formerly the Franklin County Reuse

Committee) and provide status updates on

environmental activities at LEAD.

Meetings with regulatory agency personnel have been

conducted regularly and are held with representatives

from LEAD, U.S. Army Corps of Engineers (USACE),

PADEP, EPA Region III, Department of the Army, and

U.S. Army Materiel Command (AMC). Topics of

discussion at these meetings generally include review

of project status, review of new technical information,

resolution of problem areas, and direction and

schedule of further studies. In addition to the formal

meetings, 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

of the 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 1982, when the groundwater

contamination problem was first identified, formal

news releases have been issued by LEAD concerning

the groundwater issue and other sources of

contamination. These news releases typically contain

information on the initial phases of investigation

and/or remedial work. Recently, much of the news

coverage has concerned cleanup with regard to the

BRAC parcels and the status of lease and transfer of
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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the property.

The residents in the vicinity of LEAD have generally

reacted favorably to the efforts made by the

Department of the Army with regard to the

identification and cleanup programs underway and

proposed. The off-post sampling of wells for potential

groundwater contamination during the 1980s 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 source for residents whose wells

had potential or known contamination) was received

favorably.

KEY COMMUNITY CONCERNS

The community is greatly concerned about the

Superfund sites and LEAD in the long-term 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 Activities

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 status of specific

cleanup activities (e.g., data, results, costs, and

schedule). One mentioned that some of the

environmental reports 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 Army’s environmental standards may

not be as stringent as the public’s standards in the level

of cleanup activities.

Several expressed a concern to return areas to

farmland use and to coordinate efforts to preserve

existing farmland. A few residents noted that farmers

do not seem to be concerned about contamination

because farming activities continue on property

adjacent to LEAD.

Some were concerned that cleanup activities would

continue after areas were open for public reuse. One

resident said that $350 million was too much to pay for

groundwater contamination cleanup on-site and that

documentation of the historic value of a warehouse

before tearing it down was “foolish.”

Reuse

Noting the economical impact of having fewer civilian

jobs with the realignment of LEAD, the majority of the

interviewees have accepted LIDA’s reuse plan.

Some thought the reuse of areas of LEAD was 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 concerned about

the feasibility of taking care of the reuse areas of

LEAD. Many were concerned with potential liability if

additional Army-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 recontaminating the site and creating noise or traffic

problems. Some were concerned how the Army will

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 be discovered. One said that the

Army brought materials from across the country for

disposal at the Depot. 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 quarry (Fagan’s Quarry).

♦ Rocky Spring Lake.

♦ Mercury in the lake.
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

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♦ Fire practice training areas.

♦ Lead contamination at the ammunition detonation

area.

♦ Discharge from LEAD (below Gate 6) into streams

after a heavy rain.

Air Quality

A few residents said that 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 crack in

homes adjacent to and about a mile from LEAD. One

resident said that the impact of the detonations is

worse for homes a greater distance from 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

regarding the detonation activities.

Government

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 that the

government does not think an individual is important

to consider.” However, the majority of the interviewees

believe that the Pennsylvania Department of

Environmental Protection is the most credible

government agency regarding environmental issues.

Army

The majority of the interviewees believe that the Army

is committed to cleaning up the contamination at

LEAD. One resident was pleased that LEAD is a

government site because the Army 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 Army 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 not be getting all of the information.

One individual participated in two tours of the

facility and questioned the use and contents of a

building with concertina wire. The question was not

answered to the individual’s satisfaction; therefore,

this person believes the Army is hiding something.

♦ There was a lack of response from the LEAD Public

Affairs Officer when residents complained about the

blasting and poor quality of the office’s answering

machine (very short tape).

Eighteen of the 19 interviewees said they had an

understanding of the Base Realignment and Closure

activities at LEAD. The majority of the interviewees

were favorable towards the cleanup activities related to

the Base Realignment and Closure parcels. In addition,

the majority of the interviewees were supportive of

LIDA’s reuse plan. Most individuals also were

favorable towards the cooperation and interaction

between the Army and LIDA in freeing the to-beexcessed 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 are

summarized below.

RESULTS OF THE SCREENING

INVESTIGATIONS

Comment 1: The results of the soil sampling conducted on

several of the parcels indicated concentrations of

arsenic and beryllium that exceeded EPA

Region III Risk Based Concentrations

(RBCs) for the industrial ingestion scenario.

LIDA expressed a concern that the reuse plan

calls for a mix of commercial and industrial

uses in the Phase I Parcels area, and requested

that confirmation be made as to whether the

“no further action” decision is consistent with

the proposed reuse. LIDA also requested that

DEP provide concurrence on the “no further

action” decision.
LETTERKENNY ARMY DEPOT PHASE I PARCELS—RECORD OF DECISION

O:\02281016.005\FNL_RSUM.DOC(9/29/98) FINAL 4

Response 1: The levels of arsenic and beryllium that

were found on the Phase I Parcels are believed to be

naturally occurring, and not a result of operations

and/or disposal practices. The BRAC Cleanup Team

(BCT), comprised of representatives from LEAD, EPA

Region III, and PADEP, reviewed these results with

consideration 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

controls remedy to maintain continued like use of the

property. The arsenic and beryllium results obtained at

LEAD are not inconsistent with the published

background concentrations for these two metals in

Pennsylvania. The BCT believes that the

commercial/industrial uses outlined in the reuse plan

are consistent with the current use of these parcels. In

addition, the Army and EPA are signatories on the

decision documents for each of the parcels where

screening sampling was conducted and PADEP

concurs with the decision.

PARCEL-SPECIFIC COMMENTS

Comment 2: LIDA expressed concerns about two fuel spills

reported to have occurred on the Building 43

parcel, and the sufficiency of the cleanup.

Response 2: The two spills are documented in the

Phase I Environmental Baseline Survey (WESTON,

August 1996). The first spill occurred on the paved

road adjacent to Building 43 and consisted of leakage

of approximately 10 gallons of fuel onto the road. At

the time of the spill, the fuel was soaked up with

absorbent materials. The second release occurred

during tank tightness testing. Contaminated soils were

excavated and removed.

RISK ASSESSMENTS

Comment 3: The Proposed Plan cites risk assessments that

were performed at a time when the future use

of LEAD was continued industrial. LIDA

requested confirmation that these risk

assessments are consistent with their reuse

plans.

Response 3: 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 PDO and SE Areas) can be found in the

Administrative Record for LEAD, either at Building

618 or at the Coyle Free Library in Chambersburg.

ENFORCEMENT OF THE INSTITUTIONAL

CONTROLS

Comment 4: The enforcement of the deed restrictions is cited

as being the responsibility of LIDA, the

Army, EPA, and PADEP. LIDA

commented that since these restrictions will be

bound by deed, adjoining property owners have

jurisdiction to enforce the actions via a private

action.

Response 4: The Army and EPA concur.
LETTERKENNY ARMY DEPOT

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ATTACHMENT 1

REFERENCES
LETTERKENNY ARMY DEPOT

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 1-1

ATTACHMENT 1

REFERENCES

Acker, R.C. 1955. Water Supply from Wells for Letterkenny Ordnance. Letter Report to

District Engineer, U.S. Army Corps of Engineers, Baltimore District.

Archaeological & Historical Consultants, Inc. December 1996. Phase I Archaeological

Survey, Letterkenny Army Depot. Franklin County, Pennsylvania.

Battelle. June 1983. Geophysical Survey of the Southeast Area of LEAD.

Battelle. September 1983. Environmental Contamination Survey of LEAD: Southeast

Industrial Area.

Battelle. October 1983. Environmental Contamination Survey of LEAD: Property Disposal

Office Drainage System.

Battelle. December 1983. Environmental Contamination Survey of LEAD: Exploratory and

Confirmatory Phases.

Battelle. May 1984. Environmental Contamination Survey of LEAD: Multi-Phase Investigation

Summary.

Becher, A.E. and L.E. Taylor. 1982. Groundwater Resources in the Cumberland and

Contiguous Valleys of Franklin County, Pennsylvania. Pennsylvania Geological Survey

Water Resources Report 53. Harrisburg, Pennsylvania.

Berger Associates. 1981. Army Pollution Abatement Program Studies.

Building Technology Incorporated. July 1984. Historic Properties Report, Letterkenny Army

Depot.

Dames and Moore, Inc. 1993. Asbestos Survey - Letterkenny Army Depot.

Dames and Moore, Inc. 1996. Lead-Based Paint Survey—Letterkenny Army Depot.

Dragun, J. and A. Chiasson. 1991. Elements in North American Soils. Hazardous Materials

Control Resources Institute, Greenbelt, MD.

EA (EA Engineering, Science, and Technology). 1991. Site Investigation, LEAD.

EMC (Environmental Management Consultants). July 1988. Asbestos Survey, Building 663,

Letterkenny Army Depot.

EMC (Environmental Management Consultants). 1988. Asbestos Survey - Building 1,

Letterkenny Army Depot.

EMS (Environmental Management Systems). 1989. Asbestos Assessment Survey for

Letterkenny Army Depot.

EQM (Environmental Quality Management). August 1995. Dock 35 Closure Report,

Letterkenny Army Depot.

ERM (Environmental Resources Management, Inc.). January 1995. Letterkenny Army

Depot - SWMU Site Investigation Follow-on Report, ELIN A009.

ESE (Environmental Science & Engineering, Inc.). August 1986. Remedial Investigation of

the Disposal Area at LEAD.
LETTERKENNY ARMY DEPOT ATTACHMENT 1—REFERENCES

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 1-2

ESE (Environmental Science & Engineering, Inc.). September 1987. Remedial Investigation

of the Property Disposal Office Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). December 1987. Remedial Investigation

of the Southeastern Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). 1988a. Feasibility Study of the Property

Disposal Office Area at Letterkenny Army Depot. Gainesville, Florida.

ESE (Environmental Science & Engineering, Inc.). 1988b. Feasibility Study of the

Southeastern Area of Letterkenny Army Dept, First Operable Unit. Gainesville Florida.

ESE (Environmental Science & Engineering, Inc.). 1989. Feasibility Study of the Southeastern

Area of Letterkenny Army Depot, Second Operable Unit. Gainesville Florida.

ESE (Environmental Science & Engineering, Inc.). August 1993. Draft Addendum to the

Remedial Investigation of the Southeastern Area at Letterkenny Army Depot Contamination

Assessment of K Area Soils.

ESE (Environmental Science & Engineering, Inc.). September 1995. PDO New OU #5 Site

Investigation, PCBs in Rocky Spring Lake, Draft Report.

FCADC (Franklin County Area Development Corporation). 1993. 1993 Franklin County

Data Book.

Franklin County Reuse Committee (now know as the Letterkenny Industrial

Development Authority [LIDA]). May 1997. Letterkenny Army Depot Reuse Strategy

Summary Report.

Geonex Corporation. August 1995. Draft Wetlands Mapping Report for United States Army,

Letterkenny Army Depot.

John Milner Associates. 1981. An Archaeological Reconnaissance of Proposed Development

Sites at the Letterkenny Army Depot.

Kearney, A.T. and The Earth Technology Corporation. February 1988. RCRA Facility

Assessment Phase I Preliminary Review of Solid Waste Management Units.

Nature Conservancy, Pennsylvania Science Office. December 1992. An Inventory of

Significant Ecological Features of the Letterkenny Army Depot, Franklin County, Pennsylvania.

Pennsylvania State University and Envirosphere Company. January 1985. An

Archaeological Overview and Management Plan for the Letterkenny Army Depot.

R.E. Wright Environmental, Inc. July 1994. Draft Report for Building Investigations for

Radon Recommendations.

R.E. Wright Environmental, Inc. July 1995. Radon Testing Plan, Letterkenny Army Depot.

R.E. Wright Environmental, Inc. March 1997. Draft Report for Building Investigations for

Radon Recommendations, Letterkenny Army Depot.

Root, S.I. 1971 (Reprinted 1974). Geology and Mineral Resources of Northeastern Franklin

County, Pennsylvania. Pennsylvania Department of Environmental Resources, Atlas

119ab. Harrisburg, Pennsylvania.
LETTERKENNY ARMY DEPOT ATTACHMENT 1—REFERENCES

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 1-3

Shacklette, H.J. and J.G. Boerngen, 1984. “Element Concentrations in Soils and Other

Surficial Materials of the Conterminous United States.” U.S. Geological Survey Professional

Paper 1270. U.S. Department of the Interior.

SS&M (Spots, Stevens and McCoy). December 1991. Letter to PADEP on Closure of

Storage Pad at Building S26-5, Letterkenny Army Depot.

USATHAMA (U.S. Army Toxic and Hazardous Materials Agency). 1980. Installation

Assessment of Letterkenny Army Depot, Report No. 161., Aberdeen Proving Ground, Maryland.

U.S. Department of Defense. Fall 1995. BRAC Cleanup Plan (BCP) Guidebook.

U.S. Department of Defense. 1995. DoD Base Reuse Implementation Manual.

U.S. Department of the Army. February 1987. Evaluation of Solid Waste Management Units.

U.S. Department of the Interior, National Park Service. 1992. Standards for Rehabilitation

and Illustrated Guidelines for Rehabilitating Historic Buildings.

Versar, Inc. May 1994. Remedial Investigation/Feasibility Study Letterkenny Army Depot

Property Disposal Office Area, Operable Units 3 and 4, Work Plan.

WESTON (Roy F. Weston, Inc.). 1984. LEAD Remedial Investigation and Feasibility Study.

WESTON (Roy F. Weston, Inc.). 1996. Phase I Environmental Baseline Survey, Letterkenny

Army Depot, BRAC 95 Action.

WESTON (Roy F. Weston, Inc.). 1997. CERFA Letter Report (Final) Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1997. Technical Plan for Investigation of PCBs in the Rocky

Spring System Property Disposal Office (PDO) Area, Operable Unit 5 (OU 5), Letterkenny

Army Depot.

WESTON (Roy F. Weston, Inc.). 1997. Finding of Suitability to Lease (FOSL) for Buildings 6,

9, 19, 412, 416, 500, 522, and 2291 (Final) Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998a. Decision Document for BRAC Parcels 1 and 2,

Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998b. Decision Document for BRAC Parcels 8 through 13,

Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998c. Decision Document for BRAC Parcel 24, Letterkenny

Army Depot.

WESTON (Roy F. Weston, Inc.). 1998d. Decision Document for BRAC Parcel 29, Letterkenny

Army Depot.

WESTON (Roy F. Weston, Inc.). 1998e. Decision Document for BRAC Railroad Parcels,

Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998f. Decision Document for BRAC Buildings 6 and 9,

Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998g. Phase II Environmental Baseline Survey (Draft)

Letterkenny Army Depot, BRAC 95 Action.

Weston Services, Inc. 1989. EPRDA Soil Gas Investigation Report.
LETTERKENNY ARMY DEPOT

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ATTACHMENT 2

RISK ASSESSMENT TABLES
LETTERKENNY ARMY DEPOT

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Table 1—Contaminants of Concern (COC) in the SE and PDO Areas at LEAD

Organic COCs Inorganic COCs

Acetone (ACET) Arsenic (AS)

Benzene (C6H6) Beryllium (BE)

Bromodichloromethane (BRDCLM) Cadmium (CD)

Carbon tetrachloride (CCL4) Chromium (CR)

Chloroform (CHCL3) Copper (CU)

1,1-Dichloroethane (11DCLE) Lead (PB)

1,2-Dichloroethane (12DCLE) Manganese (MN)

1,2-Dichloroethene (12DCE) Nickel (NI)

1,1-Dichloroethene (11DCE) Thallium (TL)

Methylene chloride (CH2CL2) Zinc (ZN)

Tetrachloroethene (TCLEE)

Trichloroethene (TRCLE)

1,1,1- Trichloroethane (111TCE)

1,1,2- Trichloroethane (112TCE)

Trichlorofluoromethane (CCL3F)

Toluene (MEC6H5)

Trans-1,2-dichloroethylene (T12DCE)

Vinyl chloride (C2H3CL)

Chlordane (CLDAN)

Heptachlor (HPCL)

Diethylphthalate (DEP)

Bis (2-ethylhexyl) phthalate (B2EHP)

Pentachlorophenol (PCP)
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

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Table 2—Exposure Scenarios with Applicable Sites and Exposure Pathways

Applicable AA FS GW SE SO SW

Scenario Sites inh oral inh oral der oral der inh oral der inh oral

Current

Worker

-S X X X

Future

Worker

-S 2 2 X X X

Note: AA = ambient air (vapors).

FS = fish.

GW = groundwater.

SE = sediment.

SO = soil.

SW = surface water.

der = dermal.

inh = inhalation.

X = This receptor/pathway is evaluated based on measured chemical concentrations at the

(sub)

contamination area.

2 = This receptor/pathway is evaluated to estimate the risks associated with future worker

use

of site groundwater should it ever be used as a water supply.

-S = This receptor/pathway is evaluated based on modeled chemical concentrations in air at

the

source (over the contamination area).

Source: ESE (Environmental Science & Engineering, Inc.). 1994. Risk Assessment of the Southeastern Area at

Letterkenny Army Depot, Operable Units One and Three-Final Report.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

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Table 3—Formulas/Assumptions for Intake Calculations

Ambient Air, Inhalation Exposure (Volatilization from Soil and Surface Water to Outdoor Air)

Intake mg/kg/day CAa x IRaa x EFaa x ED

BW x AT

( ) =

Where:

CAa = chemical concentration in ambient air (mg/m3).

IRaa = intake rate for ambient air (m3/day).

EFaa = exposure frequency for ambient air (days/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = period of time over which exposure is averaged (days).

Groundwater, Inhalation Exposure (Theoretical Worker Exposure to Vapors While Showering)

Intake mg/kg/day CAs x IRas x EFas x ED

BW x AT

( ) =

Where:

CAs = chemical concentration in shower air (mg/m3).

IRas = intake rate for shower air (m3/day).

EFas = exposure frequency for shower air (days/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = period of time over which exposure is averaged (days).

Groundwater, Oral Exposure

Intake mg/kg/day CGW x IRgw x EFgw x ED

BW x AT

( ) =

Where:

CGW = chemical concentration in groundwater (mg/L).

IRgw = intake rate for groundwater (L/day).

EFgw = exposure frequency for contaminated groundwater (days/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = period of time over which exposure is averaged (days).
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-4

Soil, Dermal Exposure

Intake mg/kg/day CSo x FCs x SAso x AF x ABS x EFso x ED

BW x AT

( ) =

Where:

CSo = chemical concentration in soil (mg/kg).

FCs = conversion factor for soil/sediment (kg/mg).

SAso = skin surface area available for soil contact (cm2/event).

AF = soil/sediment to skin adherence factor (mg/cm2).

ABS = chemical-specific absorption factor (unitless).

EFso = exposure frequency for soil (events/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = period of time over which exposure is averaged (days).

Soil, Inhalation Exposure (Suspended Particulates in Ambient Air)

Intake mg/kg/day CSo x /PEF x IRaa x EFaa x ED

BW x AT

( )

( )

=

1

Where:

CSo = chemical concentration in soil (mg/kg).

PEF = particulate emission factor (m3/kg).

IRaa = intake rate for ambient air (m3/day).

EFaa = exposure frequency for ambient air (days/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = period of time over which exposure is averaged (days).

Soil, Oral Exposure

Intake mg/kg/day CSo x IRso x FCs x FIso x EFso x ED

BW x AT

( ) =

Where:

CSo = chemical concentration in soil (mg/kg).

IRso = soil ingestion rate (mg/day).

FCs = conversion factor for soil/sediment (kg/mg).

FIso = fraction of soil ingested from contaminated source (unitless).

EFso = exposure frequency for soil (days/year).

ED = exposure duration (years).

BW = body weight (kg).

AT = averaging time (days).
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-5

What Exposure Parameters Were Used for LEAD SE?

ABS

Chromium VI 0.15 Hawley, 1985

Inorganic chemicals (other than Cr VI) 0.01 Ryan et al., 1987

Polychlorinated biphenyls 0.05 Ryan et al., 1987

Semivolatile organic chemicals 0.10 Ryan et al., 1987

Volatile organic chemicals 0.25 Ryan et al., 1987

AF

1.0 mg/cm2 kaolin clay on hands EPA, 1992a

Site soils consist predominantly of silty loam (ESE, 1992). Since clay has a higher AF than sand or

potting soil, the AF for clay is used as a conservative RME.

AT

carcinogenic effects 70 years x 365 days/year EPA, 1989c

noncarcinogenic effects ED (years) x 365 days/year EPA, 1989c

BW

Adult (Residential, Worker)

70 kg average (male and female) of 50th percentile EPA, 1991a

values for age = 18 to 75 years

CAa

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 parameters (i.e., soil

concentration, Henry’s Law constant, Koc, etc.) and site-specific parameters (i.e., soil depth, soil

porosity, wind velocity, etc.).
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-6

CAs

The concentration of VOCs 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.

1) CGW measured value.

2) Ratio of chemical concentration in shower air

to chemical concentration in water (mg/L). 18 L/m3

CAs (mg/m ) x CGW (mg/L) x (L/m )

3 3

18

CGW / CSe / CSo / CSW

The upper 95 percent confidence limit (UCL95) of the mean chemical concentration was used to

represent the RME exposure concentration. If the UCL95 exceeded the maximum detected chemical

concentration, the maximum concentration was used to represent the RME.

ED

Adult (Worker)

25 years national 95th percentile time at one workplace EPA, 1991b

EFaa

Worker (Adult)—Current

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 cutting

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

EFgw

250 days/year number of days spent at work EPA, 1991b

Site groundwater is not currently 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.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-7

EFso

Worker (Adult)—Current

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 cutting

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

FCs

1 x 10-6 kg/mg

FCw

0.001 L/cm3

IRaa

Worker (Adult)—Current

5 m3/day based on a reasonable upper-bound occupational inhalation rate for an 8-hour

workday [20 m3/day (EPA, 1991b)] and assumes that maintenance personnel may

work in the area 2 hours/day.

Worker (Adult)—Future

20 m3/day reasonable upper-bound occupational inhalation

rate for an 8-hour workday. EPA 1991b

IRgw

1.0 L/day reasonable occupational ingestion rate EPA, 1991b

Site groundwater is not currently 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.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-8

IRso

Worker (Adult)—Current

12.5 mg/day based on the typical adult workplace ingestion rate for an 8-hour workday [50

mg/day (EPA, 1991b)] and assumes that a person works in the area 2 hours/day.

Worker (Adult)—Future

50 mg/day typical adult workplace ingestion rate for an

8-hour workday. EPA 1991b

SAso

Values are based on the average adult (male and female) 50th percentile body part surface areas (m2)

in EPA, 1985 multiplied by a conversion factor of 10,000 cm2/m2. 50th percentile values are used

because surface area is related to body weight, and average body weights over the ED were used in

the exposure calculations. It is assumed that workers at LEAD will wear long pants, a long-sleeved

shirt, and gloves while at the facility. 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 904

1⁄2 head 602

1,506 cm2

References

Environmental Science & Engineering, Inc. (ESE). 1998. Endangerment Assessment of the Southeastern Area at

Letterkenny Army Depot. Final Report. U.S. Army Toxic and Hazardous Materials Agency, Installation

Restoration Division. Contract No. DAAA15-85-D-0017. Gainesville, FL.

Environmental Science & Engineering, Inc. (ESE). 1992. Remedial Investigation of the Southeastern Area at

Letterkenny Army Depot (LEAD). Preliminary Draft Report. U.S. Army Toxic and Hazardous Materials

Agency, Installation Restoration Division. Contract No. DAAA15-85-D-0017. Gainesville, FL.

Hawley, J.D. 1985. “Assessment of Health Risks from Exposure to Contaminated Soil.“ Risk Analysis,

5(4):289-302.

Hazardous Substance Data Bank (HSDB). 1993. National Library of Medicine (NLM). Micromedex TOMES

PLUS® System CD/ROM, Version 16, Expires 4/30/93. Managed by Micromedex, Inc., Denver, CO.

Integrated Risk Information System (IRIS). 1993. U.S. Environmental Protection Agency (EPA). Micromedex

TOMES PLUS® System CD/ROM, Version 18, Expires 10/31/93. Managed by Micromedex, Inc.,

Denver, CO.

McKone, T.E. 1987. “Human Exposure to Volatile Organic Compounds in Household Tap Water: The Indoor

Envir. Sci. and Tech, 21(12):1194-1201.

National Oceanic and Atmospheric Administration (NOAA), Naval Oceanography Command Detachment

Asheville, and USAFETAC. 1990. International Station Meteorological Climate Summary for Glenview,

Illinois. Version 1.0. National Climatic Data Center, Federal Climate Complex, Asheville, NC.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 3—Formulas/Assumptions for Intake Calculations

(Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-9

Ryan, E.A., Hawkins, E.T., Magee, B., and Santos, S.L. 1987. “Assessing Risk from Dermal Exposure at

In: Proceedings of the 8th National Superfund Conference. Hazardous Materials

Control Research Institute. Silver Spring, MD.

U.S. Environmental Protection Agency (EPA). 1985. Development of Statistical Distributions or Ranges of

Standard Factors Used in Exposure Assessments. Office of Health and Environmental Assessment, Office

of Research and Development, Washington, DC. EPA/600/8-85/010.

U.S. Environmental Protection Agency (EPA). 1989a. Exposure Factors Handbook. Final Report. Office of Health

and Environmental Assessment, Washington, DC. EPA/600/8-89/043.

U.S. Environmental Protection Agency (EPA). 1989b. Interim Final Guidance for Soil Ingestion Rates. Office of

Solid Waste and Emergency Response, Washington, DC. OSWER Directive 9850.4.

U.S. Environmental Protection Agency (EPA). 1989c. Risk Assessment Guidance for Superfund (RAGS). Volume

1: Human Health Evaluation Manual, Part A. Office of Emergency and Remedial Response, Washington,

DC. EPA/540/1-89/002.

U.S. Environmental Protection Agency (EPA). 1991a. Risk Assessment Guidance for Superfund (RAGS). Volume

1: Human Health Evaluation Manual, Part B (Development of Risk-Based Preliminary Remediation Goals).

Office of Emergency and Remedial Response, Washington, DC. OERR 9285.7-01B.

U.S. Environmental Protection Agency (EPA). 1991b. Risk Assessment Guidance for Superfund (RAGS). Volume

1: Human Health Evaluation Manual, Supplemental Guidance (Standard Default Exposure Factors). Interim

Final. Office of Emergency and Remedial Response, Washington, DC. OSWER Directive 9285.6-03.

U.S. Environmental Protection Agency (EPA). 1992a. Dermal Exposure Assessment: Principles and Applications.

Interim Report. Office of Research and Development, Washington, DC. EPA/600/ 8-91/011B. NTIS No.

PB92-205665.

U.S. Environmental Protection Agency (EPA). 1992b. Health Effects Assessment Summary Tables (HEAST).

Annual FY 1992. Office of Research and Development and Office of Emergency and Remedial

Response, Washington, DC. OEHA ECAO-CIN-821. NTIS No. PB92-921199.

U.S. Environmental Protection Agency (EPA). 1992c. Health Effects Assessment Summary Tables (HEAST).

Annual FY 1992; Supplement No. 1. Office of Research and Development and Office of Emergency and

Remedial Response, Washington, DC. OEHA ECAO-CIN-821A. NTIS No. PB92-921199A.

U.S. Environmental Protection Agency (EPA). 1992d. Health Effects Assessment Summary Tables (HEAST).

Annual FY 1992; Supplemental No. 2. Office of Research and Development and Office of Emergency and

Remedial Response, Washington, DC. OEHA ECAO-CIN-821B. NTIS No. PB92-921102.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

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2-10

Table 4—Weight of Evidence Classification System for Potential Carcinogens

EPA

Category

Description

of Group Description of Evidence

Group A Human carcinogen Sufficient evidence from epidemiologic studies to

support a casual association between exposure and

cancer.

Group B1 Probable human carcinogen Limited evidence of carcinogenicity in humans from

epidemiologic studies.

Group B2 Probable human carcinogen Sufficient evidence of carcinogenicity in animals, but

inadequate data in humans.

Group C Possible human carcinogen Limited evidence of carcinogenicity in animals and no

data in humans.

Group D Not classified Inadequate evidence of carcinogenicity in animals.

Group E No evidence of carcinogenicity

in humans

No evidence of carcinogenicity in at least two adequate

animal tests or in both epidemiologic and animal

studies.

Source: U.S. Environmental Protection Agency (EPA). 1989. Risk Assessment Guidance for Superfund (RAGS).

Volume I: Human Health Evaluation Manual, Part A. Office of Emergency and Remedial Response,

Washington DC. EPA/540/1-89/002.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL

2-11

Table 5—Chronic Dose-Response Toxicity Constants for the COCs in the SE and PDO

Areas at LEAD

Chemical

Oral RfD

(UF)*

Inhal RfD

(UF)*

Oral

CSF*

Oral

WoE*

Inhal

CSF*

Inhal

WoE*

Inorganic Chemicals (IOC)

Arsenic 3.0E-04 (3) — 1.8E+00I1 A 5.0E+01 A

Beryllium 5.0E-03 (100) — 4.3E+00 B2 8.4E+00# B2

Cadmium (aqueous matrix) 5.0E-04 (10) — — —

Cadmium (solid matrix) 1.0E-03 (10) — — 6.1E+00# B1

Chromium, totalI2 5.0E-03 (500) ndI3 — 4.1E+01# A

Copper 3.7E-02#, I4 (2) — — —

Lead —I5 — ndI6 B2 ndI6 B2

Manganese

(aqueous matrix) 5.0E-03 (1) — — —

Manganese

(solid matrix) 1.4E-01 (1) 1.1E-04 (900) — —

Nickel 2.0E-02 (300) — — 8.4E-01#, I7 A

Thallium 7.0E-05#,I10 (3,000) — — —

Zinc 3.0E-01 (10) — — —

Pesticides/Polychlorinated Biphenyls (PCBs)

Chlordane, total 6.0E-05 (1,000) — 1.3E+00 B2 1.3E+00# B2

Heptachlor 5.0E-04 (100) — 4.5E+00 B2 4.5E+00# B2

Semivolatile Organic Chemicals (SOC)

Bis(2-ethylhexyl)phthalate 2.0E-02 (1,000) — 1.4E-02 B2 ndS1 B2

Diethyl phthalate 8.0E-01 (1,000) — — —

Pentachlorophenol 3.0E-02 (100) — 1.2E-01 B2 ndS1 B2

Volatile Organic Chemicals (VOC)

Acetone 1.0E-01 (1,000) — — —

Benzene 2.0E-02V1 (na) 5.7E-05V2 (na) 2.9E-02 A 2.9E-02# A

Bromodichloromethane 2.0E-02 (1,000) — 1.3E-01 B2 ndV3 B2

Carbon tetrachloride 7.0E-04 (1,000) — 1.3E-01 B2 5.3E-02# B2

Chloroform 1.0E-02 (1,000) — 6.1E-03 B2 8.1E-02# B2

Dichloroethane, 1, 1- 1.0E-01# (1,000) 1.0E-01 (1,000) ndV3 C ndV4 C

Dichloroethane, 1, 2- 7.0E-02V5 (100) 2.9E-03V2 (na) 9.1E-02 B2 9.1E-02# B2

Dichloroethene, 1, 1- 9.0E-03 (1,000) — 6.0E-01 C 1.8E-01 C

Dichloroethene, 1, 2-,

total 9.0E-03 (1,000) — — —

Methylene chloride 6.0E-02 (100) 8.6E-01# (100) 7.5E-03 B2 1.6E-03 B2
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 5—Chronic Dose-Response Toxicity Constants for the COCs in the SE and PDO

Areas at LEAD (Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-12

Chemical

Oral RfD

(UF)*

Inhal RfD

(UF)*

Oral

CSF*

Oral

WoE*

Inhal

CSF*

Inhal

WoE*

Tetrachloroethene 1.0E-02 (1,000) — 5.1E-02V6 B2V6 1.8E-03V6 B2V6

Toluene 2.0E-01 (1,000) 1.1E-01# (100) — —

Trichloroethane, 1, 1, 1- 9.0E-02 (1,000) 3.0E-01# (1,000) — —

Trichloroethane, 1, 1, 2- 4.0E-03 (1,000) — 5.7E-02 C 5.7E-02# C

Trichloroethene 6.0E-03V2 — 1.1E-02V6 B2V6 6.0E-03V2 B2V6

Trichlorofluoromethane 3.0E-01 (1,000) 2.0E-01# (10,000) — —

Vinyl chloride — — 1.9E+00# A 3.0E-01# A

Note: RfD = Reference dose [mg/kg/day].

UF = Uncertainty factor (includes any applicable modifying factor).

CSF = Cancer slope factor [(mg/kg/day)-1].

WoE = Weight of evidence for ranking as a human carcinogen (see Table 4).

inhal = Inhalation.

na = Not available.

nd = Not determined.

(I1) CSF for arsenic based on unit cancer risk of 5 x 10-5 (μg/L)-1 proposed by Risk Assessment Forum (EPA,

1991a).

(I2) All values are for hexavalent chromium; a less conservative oral RfD of 1E+00 mg/kg/day for trivalent

chromium is also available.

(I3) Inhalation RfD for chromium has been withdrawn from IRIS pending further EPA review.

(I4) RfD for copper based on the MCL of 1.3 mg/L (56 FR 26460) and assumes that a healthy 70-kg adult

consumes 2 L/day water.

(I5) EPA prefers to use a biokinetic uptake model to evaluate lead exposure rather than the reference dose

method.

(I6) Although EPA has classified lead as a Group B2 suspect human carcinogen via ingestion and

inhalation, no CSF has been developed for either of these exposure pathways.

(I7) Inhalation of CSF for nickel refinery dust.

(I10) This value (for soluble thallium salts) has been withdrawn from IRIS pending further review.

(S1) Although EPA has classified this SOC as a Group B2 suspect human carcinogen via inhalation, no CSF

has been developed for this exposure pathway.

(V1) RfD for benzene based on the EPA 10-day Health Advisory of 0.235 mg/L (EPA, 1987) and assumes

that a healthy 10-kg child consumes 1 L/day water.

(V2) Interim value obtained from EPA Environmental Criteria and Assessment Office (ECAO), as

recommended by EPA Region III.

(V3) Although EPA has classified this chemical as a Group C possible human carcinogen via ingestion, no

CSF has been developed for this exposure pathway.

(V4) Although EPA has classified this chemical as a Group C possible human carcinogen via inhalation, no

CSF has been developed for this exposure pathway.
LETTERKENNY ARMY DEPOT ATTACHMENT 2—RISK ASSESSMENT TABLES

Table 5—Chronic Dose-Response Toxicity Constants for the COCs in the SE and PDO

Areas at LEAD (Continued)

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL 2-13

(V5) RfD for 1,2-dichloroethane based on a chronic oral NOAEL for rats of 7 mg/kg/day (ATSDR, 1988)

and an uncertainty factor of 100 (10X for sensitive human subpopulations and 10X for animal-tohuman extrapolation).

(V6) CSFs and WoEs for this VOC have been withdrawn from IRIS pending further review; the listed value

is from EPA/HEAST (1991).

*All RfDs, CSFs, and WoEs are available in IRIS (1993), unless otherwise noted.

#This value is available in EPA/HEAST (1992).

Sources: U.S. Environmental Protection Agency (EPA). 1987. Health Advisories for 25 Organics. Office of

Drinking Water, Washington, DC. NTIS No. PB87-235578.

Agency for Toxic Substance and Disease Registry (ATSDR). 1988. Toxicological Profile for 1,2-

Dichloroethane. Prepared by Clement Associates. U.S. Public Health Service, Atlanta, GA. NTIS No.

PB90-171422.

U.S. Environmental Protection Agency (EPA). 1991. Health Effects Assessment Summary Tables

(HEAST). Annual FY 1991. Office of Research and Development and Office of Emergency and

Remedial Response, Washington, DC. OERR 92006-303(91-1).
LETTERKENNY ARMY DEPOT

O:\02281016.005\FNL_RTBL.DOC(9/29/98) FINAL

ATTACHMENT 3

TRANSCRIPT OF THE PUBLIC MEETING ON THE PROPOSED PLAN