Record of Decision for Phase III Parcels

Letterkenny Army Depot

Chambersburg, Pennsylvania

U.S. Army Corps of Engineers

Baltimore District

Baltimore, MD

Prepared for

Weston Solutions, Inc.

1400 Weston Way

West Chester, PA 19380-1499

Prepared by

Contract Number: DACA31-94D-0063

August 2003

03P-0752

LETTERKENNY

PENNSYLVANIA

CHAMBERSBURG,

ARMY DEPOT

BALTIMORE DISTRICT

Proud Past

 Dynamic Future

Final

SM
Final 

Record of Decision 

for Phase III Parcels 

Letterkenny Army Depot 

Chambersburg, Pennsylvania 

Delivery Order 0008 

Contract Number DACA31-94D-0063 

Prepared for 

U.S. Army Corps of Engineers 

Baltimore District 

Baltimore, Maryland 

Prepared by 

Weston Solutions, Inc. 

1400 Weston Way 

West Chester, Pennsylvania 19380-1499 

August 2003 

W.O. No. 02281.016.008.1911/2911 
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ii 

TABLE OF CONTENTS 

 SECTION PAGE 

LIST OF ACRONYMNS ............................................................................ x

DECLARATION FOR THE RECORD OF DECISION......................... 1 

 Site Name and Location............................................................................................... 1 

 Statement of Basis and Purpose................................................................................... 1 

DECISION SUMMARY ............................................................................. 1 

SECTION 1 SITE NAME, LOCATION, AND 

DESCRIPTION....................................................1

1.1 INTRODUCTION ...................................................................................................1 

1.2 PHASE III PARCELS .............................................................................................2 

1.3 SMSR GROUNDWATER.......................................................................................3 

1.4 PARCEL 3-89..........................................................................................................3 

1.5 PARCEL 3-90..........................................................................................................5 

1.6 PARCEL 3-91..........................................................................................................5 

1.7 PARCELS 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, AND 2R-86L-3..............5 

1.8 GROUNDWATER ASSOCIATED WITH PHASE I PARCELS 24, 27, 

AND 28....................................................................................................................6 

SECTION 2 SITE HISTORY AND ENFORCEMENT 

ACTIVITIES........................................................6

2.1 HISTORY OF SITE ACTIVITIES..........................................................................6 

2.2 SUMMARY OF PREVIOUS SITE INVESTIGATIONS.......................................7 

2.3 HISTORY OF CERCLA COMPLIANCE ACTIVITIES .......................................7 

2.4 BASE REALIGNMENT AND CLOSURE (BRAC)..............................................9 

SECTION 3 COMMUNITY PARTICIPATION 

HIGHLIGHTS .....................................................9
TABLE OF CONTENTS 

(Continued) 

 SECTION PAGE 

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iii

SECTION 4 SCOPE AND ROLE OF RESPONSE 

ACTION..............................................................10

SECTION 5 SITE CHARACTERISTICS ............................10

5.1 ENVIRONMENTAL SETTING ...........................................................................10 

5.1.1 Topography and Surface Drainage .........................................................10 

5.1.2 Geology...................................................................................................11 

5.1.3 Hydrogeology .........................................................................................11 

5.1.4 Soils.........................................................................................................12 

5.1.5 Four BRAC Sites ....................................................................................12 

5.2 NATURE AND EXTENT OF CONTAMINATION............................................13 

5.2.1 Site Conceptual Model............................................................................13 

5.2.2 SMSR Groundwater................................................................................14 

5.2.3 OVSA......................................................................................................14 

5.2.4 Former Uncurbed AST North of Building 532 Site................................15 

5.2.5 Backwash Discharge Area from the Water Treatment Plant Site...........15 

5.2.6 Building 400 Series FTA Site.................................................................16 

SECTION 6 CURRENT AND POTENTIAL FUTURE 

LAND AND RESOURCE USES ......................16

6.1 LAND USE............................................................................................................16 

6.2 GROUNDWATER USE........................................................................................16 

6.3 SURFACE-WATER USE .....................................................................................17 

SECTION 7 SUMMARY OF SITE RISKS ..........................17

7.1 SUMMARY OF HUMAN HEALTH RISKS .......................................................17 

7.1.1 Introduction and Overview .....................................................................17 

7.1.2 Identification of Chemicals of Concern (COCs) ....................................19 

7.1.3 Site COPCs .............................................................................................20 

7.1.4 Exposure Assessment..............................................................................21 

7.1.5 Toxicity Assessment ...............................................................................21 

7.1.6 Risk Characterization..............................................................................22 

7.2 SUMMARY OF ECOLOGICAL RISKS..............................................................27 

7.2.1 OVSA Site ..............................................................................................27 

7.2.2 Backwash Discharge Area ......................................................................28 

7.2.3 Building 400 Series Fire Training Area..................................................28 

7.3 UNCERTAINTY ANALYSIS ..............................................................................29 
TABLE OF CONTENTS 

(Continued) 

 SECTION PAGE 

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7.4 CORRECTION OF MINOR ERROR IN PROPOSED PLAN RISK 

SUMMARY...........................................................................................................29 

SECTION 8 SELECTED REMEDY .....................................30

SECTION 9 DOCUMENTATION OF SIGNIFICANT

CHANGES..........................................................31

 TABLES.................................................................................................... T-1 

 FIGURES.................................................................................................. F-1 

 GLOSSARY OF TERMS........................................................................G-1 

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

 ATTACHMENTS 

ATTACHMENT 1 REFERENCES 
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LIST OF TABLES 

 TITLE PAGE 

Table 1 RAGS Part D, Table 1, Selection of Exposure Pathways, Open Vehicle 

Storage Area—DSERTS Site LEAD 114, SE OU 8 ........................................T-1 

Table 2 Site Conceptual Model, Ecological Exposure Pathways of Concern, Open 

Vehicle Storage Area........................................................................................T-2 

Table 3 RAGS Part D, Table 1, Selection of Exposure Pathways, Uncurbed AST 

North of Building 532, DSERTS Site LEAD-126, PDO OU 6........................T-3 

Table 4 RAGS Part D, Table 1, Selection of Exposure Pathways, Backwash 

Discharge Area (DSERTS Site LEAD-011).....................................................T-4 

Table 5 Site Conceptual Model, Ecological Exposure Pathways of Concern ...............T-5 

Table 6 RAGS Part D, Table 1, Selection of Exposure Pathways, Building 400 

Series Fire Training Area—DSERTS Site LEAD-118, SE OU 8 ....................T-6 

Table 7 Site Conceptual Model, Ecological Exposure Pathways of Concern, 

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, 

SE OU 8............................................................................................................T-7 

Table 8 RAGS Part D, Table 2.1, Occurrence, Distribution, and Selection of 

Chemicals of Potential Concern, Open Vehicle Storage Area, DSERTS Site 

LEAD-114, SE OU 8........................................................................................T-8 

Table 9 RAGS Part D, Table 3.1, Medium-Specific Exposure Point Concentration 

Summary, Open Vehicle Storage Area, DSERTS Site LEAD-114, 

SE OU 8..........................................................................................................T-11 

Table 10 RAGS Part D, Table 2.1, Occurrence, Distribution, and Selection of 

Chemicals of Potential Concern, Uncurbed AST North of Building 532, 

DSERTS Site LEAD-126, PDO OU 6 ...........................................................T-13 

Table 11 RAGS Part D, Table 3.1, Medium-Specific Exposure Point Concentration 

Summary, Uncurbed AST North of Building 532, DSERTS Site LEAD-126, 

PDO OU 6.......................................................................................................T-14 

Table 12 RAGS Part D, Table 2.1, Occurrence, Distribution, and Selection of 

Chemicals of Potential Concern, Backwash Discharge Area from the Water 

Treatment Plant—DSERTS Site LEAD-011, SE OU 8 .................................T-15 

Table 13 RAGS Part D, Table 3.1, Medium-Specific Exposure Point Concentration 

Summary, Backwash Discharge Area from the Water Treatment Plant—

DSERTS Site LEAD-011, SE OU 8...............................................................T-16 
LIST OF TABLES 

(Continued) 

 SECTION PAGE 

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Table 14 RAGS Part D, Table 2.1, Occurrence, Distribution, and Selection of 

Chemicals of Potential Concern, Building 400 Series Fire Training Area—

DSERTS Site LEAD-118, SE OU 8...............................................................T-17 

Table 15 RAGS Part D, Table 3.1, Medium-Specific Exposure Point Concentration 

Summary, Building 400 Series Fire Training Area—DSERTS Site LEAD118, SE OU 8..................................................................................................T-19 

Table 16 Summary of Chemicals Detected in Groundwater, Open Vehicle Storage 

Area.................................................................................................................T-20 

Table 17 RAGS Part D, Table 6.1, Cancer Toxicity Data—Oral/Dermal, Phase III 

Sites.................................................................................................................T-21 

Table 18 RAGS Part D, Table 6.2, Cancer Toxicity Data—Inhalation, Phase III SitesT-23 

Table 19 RAGS Part D, Table 5.1, Non-Cancer Toxicity Data—Oral/Dermal, Phase 

III Sites............................................................................................................T-25 

Table 20 RAGS Part D, Table 5.2, Non-Cancer Toxicity Data—Inhalation, Phase III 

Sites.................................................................................................................T-27 

Table 21 Models for Calculating Age-Adjusted Cancer Residential RBSCs for Soil 

Ingestion..........................................................................................................T-29 

Table 22 Model for Calculating Age-Adjusted Cancer Residential RBSCs for Dermal 

Contact with Soil ............................................................................................T-30 

Table 23 Model for Calculating Age-Adjusted Cancer Residential RBSCs for 

Inhalation of VOCs/Particulates .....................................................................T-31 

Table 24 Model for Calculating Noncancer Residential RBSCs for Soil Ingestion, 

Child and Adult...............................................................................................T-32 

Table 25 Integrated Risk-Based Screening Concentration Algorithm through All 

Relevant Exposure Pathways..........................................................................T-33 

Table 26 Model for Calculating Groundwater Ingestion Risk-Based Screening 

Concentrations for Child and Adult Resident and Industrial Worker ............T-34 

Table 27 Soil RBSCs Across All Direct Contact Pathways for Future Resident—

Child and Adult, Open Vehicle Storage Area (East), DSERTS Site LEAD114, SE OU 8..................................................................................................T-35 
LIST OF TABLES 

(Continued) 

 SECTION PAGE 

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Table 28 Soil RBSCs Across All Direct Contact Pathways for Future Resident—

Child and Adult, Backwash Discharge Area from Water Treatment Plant....T-38 

Table 29 Soil RBSCs Across All Direct Contact Pathways for Future Resident - Child 

and Adult, Building 400 Series Fire Training Area........................................T-39 

Table 30 Groundwater Health Risks, Open Vehicle Storage Area................................T-40 

Table 31 Comparison of Subsurface Levels of COPCs with SSLs for Groundwater 

Protection, Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE 

OU 8................................................................................................................T-41 

Table 32 Comparison of Subsurface Levels of COPCs with SSLs for Groundwater 

Protection, Uncurbed AST North of Building 532, DSERTS Site LEAD126, PDO OU 6...............................................................................................T-43 

Table 33 Comparison of Subsurface Levels of COPCs with SSLs for Groundwater 

Protection, Backwash Discharge Area from the Water Treatment Plant - 

DSERTS Site LEAD-011, SE OU 8...............................................................T-44 

Table 34 Building 400 Series Fire Training Area - Evaluation of Potential 

Groundwater Impacts of Chemicals in Subsurface Soils, Limestone Soils....T-45 

Table 35 Building 400 Series Fire Training Area - Evaluation of Potential 

Groundwater Impacts of Chemicals in Subsurface Soils, Shale Soils............T-46 

Table 36 Species of Special Concern, Phase III Sites....................................................T-47 

Table 37 Level 1 SLERA—Comparison of Maximum Detected Soil Concentrations 

(0-0.5 ft) with Ecological Benchmarks, Open Vehicle Storage Area.............T-48 

Table 38 Level 2 SLERA—Comparison of Exposure Point Concentrations of 

Chemicals of Concern in Soils with Ecological Benchmarks, Open Vehicle 

Storage Area ...................................................................................................T-50 

Table 39 Statistical Comparison of Site and Background Chemical Concentrations in 

Shale Surface Soils, Open Vehicle Storage Area ...........................................T-52 

Table 40 Level 1 SLERA—Comparison of Maximum Detected Soil Concentrations 

(0-0.5 ft) with Ecological Benchmarks, Backwash Discharge Area 

(DSERTS Site LEAD-011).............................................................................T-53 

Table 41 Level 2 SLERA—Comparison of Exposure Point Concentrations of 

Chemicals of Concern in Soils with Ecological Benchmarks, Backwash 

Discharge Area (DSERTS Site LEAD-011)...................................................T-54 
LIST OF TABLES 

(Continued) 

 SECTION PAGE 

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viii

Table 42 Statistical Comparison of Site and Reference Chemical Concentrations in 

Shale Surface Soil, Backwash Discharge Area (DSERTS Site LEAD-011)..T-55 

Table 43 Level 1 SLERA—Comparison of Maximum Detected Soil Concentrations 

(0-0.5 ft) with Ecological Benchmarks, Building 400 Series Fire Training 

Area, DSERTS Site LEAD-118C, SE OU 8 ..................................................T-56 

Table 44 Level 2 SLERA—Comparison of Exposure Point Concentrations of 

Chemicals of Concern in Soils with Ecological Benchmarks, Building 400 

Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8 .................T-58 

Table 45 Statistical Comparison of Site and Reference Chemical Concentrations in 

Shale Surface Soil, Building 400 Series Fire Training Area, DSERTS Site 

LEAD-118C, SE OU 8 ...................................................................................T-60 

Table 46 Statistical Comparison of Site and Reference Chemical Concentrations in 

Limestone Surface Soil, Building 400 Series Fire Training Area, DSERTS 

Site LEAD-118C, SE OU 8 ............................................................................T-61 
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LIST OF FIGURES 

 TITLE PAGE 

Figure 1 Property Location..............................................................................................F-1 

Figure 2 Location of SE and PDO Areas, Enclave Areas, Drainageways, and 

Drainage Divides at LEAD...............................................................................F-2 

Figure 3 Location of Phase III Parcels Within PDO and SE Areas ................................F-3 

Figure 4 Former Layout of Groundwater Operable Units (OUs)....................................F-4 

Figure 5 Current Layout of Groundwater Operable Units (OUs) ...................................F-5 

Figure 6 Site Layout of the OVSA..................................................................................F-6 

Figure 7 Soil Boring Sample Locations at Former Uncurbed AST Site North of 

Building 532 .....................................................................................................F-7 

Figure 8 Soil Boring, Drainageway, and Sediment Sampling Locations at the 

Backwash Discharge Area (DSERTS Site LEAD-011) ...................................F-8 

Figure 9 Test Trench Locations at the Building 400 Series Fire Training Area 

(DSERTS Site LEAD-118)...............................................................................F-9 

Figure 10 Conceptual Model of Groundwater Flow in Southern Martinsburg Shale 

Region at Letterkenny Army Depot................................................................F-10 

Figure 11 Monitoring Well Locations and Groundwater Contour Map of the Southern 

Martinsburg Shale Region—28 March 2000..................................................F-11 

Figure 12 Footprint of Non-Time-Critical-Removal-Action Excavations—Open 

Vehicle Storage Area......................................................................................F-12 
Acronyms

03P-0752
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LIST OF ACRONYMS 

AST aboveground storage tank 

BRAC Base Realignment and Closure 

BTAG Biological Technical Assistance Group 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

COC contaminant (chemical) of concern 

COPC contaminant (chemical) of potential concern 

DA Disposal Area 

DoD U.S. Department of Defense 

DSERTS Defense Site Environmental Restoration Tracking System 

EEQ ecological effects quotient 

EPA U.S. Environmental Protection Agency 

ESE Environmental Science and Engineering 

FS feasibility study 

FTA Fire Training Area 

ft bgs feet below ground surface 

HEAST Health Effects Assessment Summary Tables 

HI hazard index 

HQ hazard quotient 

IRIS Integrated Risk Information System 

LEAD Letterkenny Army Depot 

LIDA Letterkenny Industrial Development Authority 

μg/L micrograms per liter 

MCL maximum contaminant level 

mg/kg milligrams per kilogram 

MSC medium-specific concentration 

msl mean sea level 

NCP National Contingency Plan 

NOAEL no-observed-adverse-effect level 

NPL National Priorities List 

NSIA Northern Southeast Industrial Area 

ORNL Oak Ridge National Laboratory 

OSWER Office of Solid Waste and Emergency Response 

OU operable unit 
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LIST OF ACRONYMS 

(Continued) 

OVSA Open Vehicle Storage Area 

PADEP Pennsylvania Department of Environmental Protection 

PAH polycyclic aromatic hydrocarbon 

PCB polychlorinated biphenyl 

PCDD/PCDF polychlorinated dibenzo-p-dixon/polychlorinated dibenzofuran 

PDO Property Disposal Office 

ppm parts per million 

RBC risk-based concentration 

RBSC risk-based health screening concentration 

RME reasonable maximum exposure 

ROD Record of Decision 

SARA Superfund Amendments and Reauthorization Act 

SE Southeastern 

SIA Southeast Industrial Area 

SMSR Southern Martinsburg Shale Region 

SSIA Southern Southeast Industrial Area 

SSL soil screening level 

SVOC semivolatile organic compound 

THQ target hazard quotient 

UCL upper confidence limit 

USACE U.S. Army Corps of Engineers 

USAEC U.S. Army Environmental Center 

VOC volatile organic compound 
Declaration for the ROD

03P-0752
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LETTERKENNY ARMY DEPOT 

PHASE III PARCELS 

CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA 

DECLARATION FOR THE RECORD OF DECISION 

AUGUST 2003 

SITE NAME AND LOCATION 

Phase III BRAC Parcels/Southern Martinsburg Shale Region 

Letterkenny Army Depot, Southeastern (SE) Area and Property Disposal Office (PDO) Area 

Chambersburg, Franklin County, Pennsylvania 

U.S. Environmental Protection Agency (EPA) ID numbers PA6213820503 (SE) and PA2210090054 (PDO) 

STATEMENT OF BASIS AND PURPOSE 

The Base Realignment and Closure Act of 1988 (Public Law 100-526, 102 Statutes at Large 2623) (BRAC 88) and the Defense 

Base Realignment and Closure Act of 1990 (Public Law 101-510, 104 Statutes at Large 1808) (BRAC 91, 93, 95) designated more 

than 100 Department of the Army facilities for mission closure and/or realignment. In 1995, the United States Secretary of 

Defense (“1995 BRAC Commission”) submitted a recommendation to Congress and the President approved that Letterkenny 

Army Depot in Chambersburg, Pennsylvania, be selected for realignment. As a result of the recommendations of the 1995 

BRAC Commission, the U.S. Department of the Army (Army) must realign (i.e., change) the mission at Letterkenny Army 

Depot (LEAD or Site). As part of the realignment, approximately 1,450 acres at LEAD have been designated for release (i.e., 

to-be-excessed or transfer of ownership). 

The Army’s strategy has been to first identify parcels with little or no environmental contamination and prepare them for 

transfer to a local redevelopment authority known as the Letterkenny Industrial Development Authority (LIDA). Before each 

property transfer, the Army, in consultation with the U.S. Environmental Protection Agency (EPA) and the Commonwealth of 

Pennsylvania Department of Environmental Protection (PADEP), investigates the property for hazardous substances that may 

have been stored, disposed of, or released there. If necessary, the Army and EPA, in consultation with PADEP, will select a 

remedy designed to protect human health and the environment. The first two sets of parcels that the Army identified for 

transfer were the “Phase I parcels” and the “Phase II parcels,” which were transferred to LIDA in 1998 and 2001, respectively. 

This Record of Decision (also referred to as the “ROD”) presents the selected remedy for the third set of parcels, the “Phase III 

parcels.” The Phase III parcels, consist of three parcels, which consist of approximately 201 acres designated by the U.S. Army

and LIDA, located in both the part of LEAD referred to as the “Property Disposal Office” (PDO) Area and the part referred to 

as the “Southeastern” (SE) Area. The SE and PDO Areas at LEAD are two separate sites listed on the Federal facilities 

National Priorities List (NPL). The Phase III parcels also include 28 acres of subsurface property that is deeper than 8 feet 

below ground surface (ft bgs). This subsurface property is located underneath three entire parcels and underneath part of 

three road parcels previously transferred as part of Phase II. This ROD document addresses soils and groundwater in the 

Phase III parcels located in both the PDO and SE Areas in an area referred to as the Southern Martinsburg Shale Region 

(SMSR). In addition, this ROD addresses a final action for groundwater beneath the Phase I and Phase II parcels located in the 

SMSR. The RODs for the Phase I and Phase II parcels that are located in the SMSR originally documented an interim 

groundwater remedy of institutional controls to prohibit groundwater use and restrict excavation near or within the 

groundwater table. 

The remedy presented in this ROD was selected in accordance with the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 

1986 (SARA), and, to the extent practicable, the National Oil and Hazardous Substances Contingency Plan (NCP). This 

decision is based on the Administrative Record for this Site. 

This document is issued by the Army, the owner of the property and the lead agency under CERCLA, and EPA. The 

Pennsylvania Department of Environmental Protection (PADEP) (on behalf of the Commonwealth of Pennsylvania) concurs 

with the selected decision. 
LETTERKENNY ARMY DEPOT PHASE III PARCELs-DECLARAnON FOR THE ROD

Description of the Selected Remedy

The Army and EPA, in consultation with PADEP, have determined that no further CERCLA remedial action is necessary to

protect public health or welfare or the environment from the soil or groundwater at the Phase III parcels.

The Army has divided the Site into different "operable units" (OUs) to make environmental work more manageable. Some

operable units cover a specific geographic area, such as the Open Vehicle Storage Area (OYSA). Other operable units

encompass a specific environmental medium, such as groundwater.

Portions of the Phase III parcels are a subset of soil SE au 8, which is located in the part of LEAD referred to as the

"Southeastern Area," and portions are also a subset of soil POO OU 6, which is located in the "Property Disposal Office

Area." There are also two groundwater OUs located underneath the BRAC Phase III parcels, one in the POO Area and one in

the SE Area. The OUs that are the subject of this ROD are listed as follows:

SMSR groundwater (including groundwater below the Phase III parcels, as well as the Phase I and Phase II

parcels located in this area - OUs POO OU 7 and SE au 13").

Open Vehicle Storage Area (OYSA) site (part of BRAC waste sites OUs POO OU 6 and SE OU 8).

Former Uncurbed Aboveground Storage Tank (AST) North of Building 532 site (part of POO OU 6).

• Backwash Discharge Area from the Water Treatment Plant site (part of SE au 8).

Western portion of the Building 400 Series Fire Training Area (FTA) site (part of SE OU 8).

The specific areas affected by this no further action decision are referred to as Parcels 3-89, 3-90, 3-91, 2-53L, 2-54L, 2-70L, 2R80L-3, 2R-84L-3, and 2R-86L-3 (note that the "L" after the parcel number refers to the lower part of the Phase II parcel that

includes groundwater), as well as groundwater in the previously transferred Phase I parcels identified as Parcels 24, 27, and

28.

Statutory Determinations

The Army and EPA, in consultation with PADEP, have determined that no further action is necessary to protect public health

or welfare, or the environment from the soil and groundwater at the Phase III parcels and associated sites. The previous

response completed at the OYSA site in 2000 eliminated the need to conduct further remedial action. The response action at

the OYSA site was a non-time-critical-removal action for contaminated soils. A CERCLA 5-year review for the OVSA site is

not required because the contaminated soils were permanently removed from the site and the residual levels of chemicals in

soil allow for unlimited use and unrestricted exposure.

Authorizing Signatures

1\MES R. DAVIDSON

Director, National Capital Region Field Office

U.s. Army Installation Support Management Activity

ABRAHAM FERDAS

Director, Hazardous Sites Cleanup Division

EPA, Region III

"Please note that PDa au 7 and Sf au 13 are new aus created in December 2002 from portions of the following aus: PDa au 2

(groundwater), Sf au 3 (groundwater), Sf au 10 (groundwater), and Sf au 11 (groundwater).

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ROD Decision Summary

03P-0752
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 LETTERKENNY ARMY DEPOT 

PHASE III PARCELS 

CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA 

DECISION SUMMARY 

AUGUST 2003 FINAL 

SECTION 1 

SITE NAME, LOCATION, AND DESCRIPTION 

EPA ID numbers PA6213820503 (Southeastern Area) and PA2210090054 (Property Disposal Office Area) 

1.1 INTRODUCTION 

Letterkenny Army Depot (LEAD) is located in south-central 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 (16,614 acres). There are two areas within LEAD that are listed on the National Priorities List

(NPL). They are the Property Disposal Office (PDO) Area and the Southeastern (SE) Area. These two areas are 

separated by a major groundwater/surface-water drainage divide, as depicted in Figure 2. The industrial and 

maintenance areas, which are primarily located in the southeastern corner of LEAD, encompass approximately 

2,500 acres and include warehousing, vehicle storage, administration, industrial/maintenance, recreational 

activities, and housing. The infrastructure of this area includes roads; permanent, semipermanent, and temporary 

structures; and utilities. Approximately 1,450 acres at LEAD have been designated for “realignment” under the 

Base Realignment and Closure (BRAC) initiative. “Realignment” means that the mission at LEAD is to change 

and approximately 1,450 acres at LEAD have been designated for release (i.e., “to-be-excessed” or transfer of 

ownership). The BRAC area is concentrated in the southeastern portion of LEAD, but is located in both the PDO 

and SE Areas. The BRAC area is being transferred to the Letterkenny Industrial Development Authority (LIDA) 

in phases. The Phase I parcels were transferred in 1998. The Phase II parcels were transferred in 2002 and 

consisted of structures and property above the seasonal high groundwater table. 

What is BRAC? 

The Base Realignment and Closure Act of 1988 (Public Law 100-526, 102 Statutes at Large 2623) (BRAC 88) and the Defense 

Base Realignment and Closure Act of 1990 (Public Law 101-510, 104 Statutes at Large 1808) (BRAC 91, 93, 95) designated 

more than 100 Department of the Army facilities for closure and/or realignment. In 1995, the U.S. Secretary of Defense (“1995 

BRAC Commission”) submitted a recommendation to Congress that Letterkenny Army Depot (LEAD) in Chambersburg, 

Pennsylvania, be selected for “realignment.” As a result of the recommendations of the 1995 BRAC Commission, the U.S. 

Department of the Army (Army) must realign (i.e., change) the mission at LEAD and transfer ownership of property referred to as

the “BRAC parcels” or “BRAC area.” 

As part of the realignment of the LEAD mission, an environmental baseline survey was completed for the BRAC area. The 

environmental baseline survey process includes visual inspections of the property as well as record reviews and personnel 

interviews, used to document current and historical conditions with regard to use, storage, or release of hazardous substances 

and petroleum products. The environmental baseline survey process is used to identify areas within the BRAC parcels that need 

further investigation, normally referred to as site or remedial investigations. These are studies typically consisting of sampling and 

analysis (to see if chemicals are present) of soil, sediment, and/or groundwater and other techniques to identify releases to the 

environment and to provide data for evaluating potential risks to future users of the land. 

Also as part of the BRAC process, the Army prepares a “Finding of Suitability to Transfer” document that provides information to 

the U.S. Environmental Protection Agency (EPA), the Pennsylvania Department of Environmental Protection (PADEP), the public, 

and LIDA concerning the environmental condition of the buildings and land being transferred. 

There are nine parcels included in the Phase III BRAC property transfer. The Phase III parcels consist of 3 parcels 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION

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totaling approximately 201 acres designated by the U.S. Army and LIDA located in both the PDO and SE Areas. 

The Phase III parcels also include 28 acres of subsurface property that is deeper than 8 feet below ground surface 

(ft bgs), located underneath 3 parcels and part of 3 road parcels previously transferred as part of Phase II. 

This Record of Decision document, also referred to as a “ROD,” addresses soils and groundwater in the Phase III 

parcels located in both the PDO and SE Areas in an area referred to as the Southern Martinsburg Shale Region 

(SMSR). In addition, this ROD addresses a final action for groundwater beneath the Phase I and Phase II parcels 

located in the SMSR. The RODs for the Phase I and II parcels (WESTON, 1998a, 2001) located in the SMSR 

originally documented an interim groundwater remedy of institutional controls to prohibit groundwater use and 

restrict excavation near or within the groundwater table. 

This ROD: (1) addresses and provides the rationale for the selected remedy for groundwater beneath the Phase III 

parcels and the SMSR; (2) addresses and provides the rationale for the selected remedy for soils at the following 

four sites: the Open Vehicle Storage Area (OVSA), the Former Uncurbed Aboveground Storage Tank (AST) Site 

North of Building 532, the Building 400 Series Fire Training Area (FTA), and the Backwash Discharge Area; and 

(3) addresses public comments concerning the selected remedy. 

The future use of the Phase III parcels and Phase I and II parcels in the SMSR is currently planned as 

commercial/industrial use; however, the parcels were evaluated for residential (i.e., unrestricted) use so that the 

property could be transferred without land use restrictions. 

The U.S. Army is the owner of the property and the lead agency under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA). EPA is the lead regulatory agency, and PADEP has a 

concurrence role as a support regulatory agency. The Army and EPA are issuing this ROD. PADEP, on behalf of 

the Commonwealth of Pennsylvania, concurs with the selected remedy. 

1.2 PHASE III PARCELS 

LIDA developed a list of priority buildings and parcels based on their potential for reuse and redevelopment. The 

Phase III parcels represent those buildings and properties identified by LIDA that the Army deems 

environmentally suitable for transfer at this time. This decision is documented in the Finding of Suitability to

Transfer for the Phase III parcels (WESTON, 2003d). The rationale for putting all of these different sites and 

parcels together into one ROD is that most of the sites and parcels are contiguous and all are situated above a 

type of geological (subsurface rock) formation referred to as the Southern Martinsburg Shale formation, which 

does not contain contamination in the groundwater. These sites and parcels also require no action for soils and 

this was another reason for grouping them together. This grouping provides a large property that did not need 

land use restrictions, which will make it attractive for transfer and future development.

There are nine parcels included in the Phase III property transfer Proposed Plan identified by parcel numbers 

3-89, 3-90, 3-91, 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3. All of the parcels are in a large area 

referred to as the Southern Martinsburg Shale Region (SMSR), near the golf course in the southeastern corner of 

LEAD where the industrial, maintenance, and recreational areas are located, as shown in Figure 3. Of these 

parcels, six are located in the SE Area and three parcels are located partially in the SE Area and partially in the 

PDO Area. The property included in the Phase III parcels consists of industrial land, developed land, small 

stands of trees, open grassy areas, commercial recreational areas (golf course and community center), 

administration buildings, and former military housing. No wetlands are located within the Phase III parcels, and 

no Federal or state threatened or endangered species are known or suspected to exist within the Phase III parcels. 

Land located within an approximately 0.5-mile radius of the Phase III parcels includes industrial land to the 

north (including land to be retained by the Army), an industrial area to the east (other BRAC sites as well as land 

to be retained by the Army), agricultural land to the south, and industrial land to the west (other BRAC 

property). The Phase III parcels are accessible to the general public via Coffey Avenue, which was transferred to 

LIDA and is maintained by the local townships. 

In addition, the groundwater in several Phase I parcels (that were previously transferred to the local community), 

which are located within the boundaries of the SMSR (Parcels 24, 27, and 28 located in the SE Area), are included 

in this remedy. 

Four BRAC sites within the Phase III parcels, plus the SMSR groundwater, were investigated under CERCLA. 

The history of the sites indicated that industrial activities have occurred and that uncontrolled hazardous 
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substance releases, if they occurred, could present potential threats to human health and the environment. The 

Phase III parcels consist of the following sites (note that the operable unit [OU] numbers and the U.S. Army’s 

tracking number, which is referred to as the Defense Site Environmental Restoration Tracking System [DSERTS], 

assigned to these sites are also shown): 

 OVSA (part of PDO Area OU 6 and SE Area OU 8, DSERTS sites LEAD-110 and LEAD-114). 

 Former Uncurbed AST site North of Building 532 (part of PDO OU 6, DSERTS site LEAD-126). 

 Building 400 Series FTA site (SE OU 8, DSERTS site LEAD-118). 

 Backwash Discharge Area site (SE OU 8, DSERTS site LEAD-118). 

 SMSR groundwater (PDO OU 7 and SE OU 13). 

Please note that PDO OU 7 and SE OU 13 are new OUs created in December 2002 from portions of the following OUs: PDO OU 2 

(groundwater), SE OU 3 (groundwater), SE OU 10 (groundwater), and SE OU 11 (groundwater). PDO OU 7 and SE OU 13 

represent the SMSR, which is an area that is upgradient of, and not affected by, the sources of volatile organic compound (VOC)

groundwater contamination in the other OUs and also has a different geology than the other groundwater OUs. In addition, there is 

sufficient information from additional investigations to show that there are no contaminant sources within the SMSR. Therefore, it 

was decided to manage the SMSR area separately from the previously defined groundwater OUs. Figures 4 and 5 show both the 

former and new configuration of the groundwater OUs, respectively. 

Brief abstracts of the sites and the Phase III parcels are presented in the following subsections. 

1.3 SMSR GROUNDWATER 

The SMSR is a region at LEAD that contains an area of shale bedrock surrounded by limestone bedrock. This 

shale bedrock is generally more resistant to weathering than the surrounding limestone formations and therefore, 

forms the “highland” or elevated ridge areas in the area of the Phase III parcels. Several groundwater/surface 

water divides along this ridge in the SMSR cause groundwater to flow radially away from the SMSR. The 

boundary of the SMSR is shown in Figure 3. 

The SMSR was originally considered to be part of several other volatile organic compound (VOC)-contaminated 

groundwater OUs at LEAD. Based on the knowledge presented above, it was thought that the SMSR could be 

unaffected by the known and potential VOC sources located downgradient of the SMSR because groundwater 

flows from the SMSR into the lower lying valley areas underlain by limestone. In addition, there is no known 

groundwater contamination in the SMSR as documented in the remedial investigations performed for the BRAC 

sites. Therefore, the SMSR area was redefined as containing two groundwater OUs (one for the PDO Area and 

one for the SE Area). In addition, studies verified these theories. The four BRAC sites described in Subsections 1.4 

and 1.6 (Parcels 3-89 and 3-91) are industrial sites that were investigated to evaluate soil contamination; these 

four sites also lie within the SMSR. 

The Army has completed its investigation, data evaluations, and risk assessment at the SMSR (WESTON, 2003a, 

2003b) and there are no environmental concerns at the site. 

1.4 PARCEL 3-89 

Parcel 3-89 comprises the majority of the Phase III parcels/SMSR area; the parcel consists of approximately 191 

acres. This parcel is located on the northern side of Carbaugh Avenue and the western side of Coffey Avenue. 

The structures within Parcel 3-89 include the following 20 buildings, and a water tower: 

 Building 522 - Administration Office 

 Building 523 - Office 

 Building 527 - Emergency Generator 

Building 

 Building 528 - Swimming Pool 

 Building 536 - Locker Room 

 Building 539 - Guest/Temporary Housing 

 Buildings 540 – 545 Kenny Hill Housing Units 

 Building 546 - Storage Building 
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Building 

 Building 529 - Community Club

 Building 530 - Information Processing 

Center 

 Building 532 - Golf Cart Storage 

Maintenance Building 

 Building 554 - Water Treatment Plant

 Building 558, 559 - Emergency Pump and Chlorinator 

Buildings for Water Treatment Plant 

 Building 572 - Storage Building (Fire Dept.) 

The sites located in this parcel where industrial activities have occurred are described in the following 

paragraphs. 

OVSA site (part of soil OUs PDO OU 6 and SE OU 8): The OVSA comprises the majority of Parcel 3-89. From 

approximately 1947 and continuing until the spring of 1998, the OVSA site was used for the storage of military 

vehicles. While the most recent past practice of storage requires that the vehicles be drained of fluids (such as 

diesel fuel, oil, and other engine fluids) before they are stored, interviews with former employees have indicated 

that the vehicles were formerly stored “wet,” meaning that they were stored with the fluids still in the vehicle, 

and that the vehicles may have had their fluids drained onto the ground before they were refurbished. The layout 

of the site is shown in Figure 6. 

There were no vehicles stored or structures located at the OVSA site at the time of the remedial investigations 

(1998, 1999, and 2000), and at the time of the removal action that is described below (2000), with the exception of 

a small structure by the heliport used to store emergency equipment (such as fire extinguishers). Several piles of 

brush were found in the northwestern area of the site. 

The Army has completed its investigations, risk assessments, evaluation for a removal action, and completion of 

the removal action (excavation and off-site disposal of soils) at the OVSA site. Prior to the removal action, the 

investigations showed possible risks associated with elevated levels of a group of semivolatile organic 

compounds (SVOCs) referred to as polycyclic aromatic hydrocarbons (PAHs) in soil. Alternatives were 

developed and evaluated in the engineering evaluation/cost analysis document, which is a technical report that

evaluates the need for a removal action (WESTON, 2000a). In addition, alternatives were developed and 

evaluated that, if implemented, would reduce or eliminate risks to people and the environment. Soils 

contaminated with PAHs were excavated and disposed of at approved off-site waste disposal facilities. 

The cleanup levels used for the removal action were developed based on a future commercial/industrial postremoval reuse of the site, as discussed in the Engineering Evaluation/Cost Analysis (WESTON, 2000a). 

Confirmatory sampling conducted after the removal action showed that the remaining concentrations of PAHs 

were at or below risk-based standards. In some areas the limits of mechanical excavation were reached, 

preventing further removal of contaminants. A post-removal risk assessment was performed assuming a future 

commercial/industrial use as well as a potential future residential (unrestricted) use. The risk assessment 

completed after the removal action showed that there are no longer environmental concerns at the site, meaning 

that there are no longer unacceptable risks to people or the environment, assuming commercial/industrial or 

residential reuse of the property. 

Former Uncurbed AST North of Building 532 site (part of PDO OU 6): This is a small site that consists of a 

former aboveground storage tank (AST) area. Initially, there was an uncurbed single-walled AST (275 gallons) 

located north of Building 532 that stored gasoline used to fuel golf carts. This AST was replaced by a doublewalled AST; it is unknown how long the single-walled AST was in service. The soils near the uncurbed AST were 

not investigated prior to the change in ASTs. The layout of the site is shown in Figure 7. 

The double-walled AST was still in-place at the time of the remedial investigation (1999). The only structure in 

the area at the time was Building 532 (located near the site), which was used to store and maintain the golf carts 

(this building still exists). Since the field investigation was conducted, the double-walled AST has been removed 

because the golf course has converted to using electric golf carts. 

The Army has completed its investigation and risk assessment at the Former Uncurbed AST North of Building 

532 site and there are no environmental concerns at the site.

Backwash Discharge Area from the Water Treatment Plant site (part of SE OU 8): This site is located in the 

eastern part of the parcel along Coffey Avenue, near the water treatment plant for the potable water supply. In 
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the past, sediments that accumulated in the raw water line were flushed out in the western area of the site. The 

sediment discharge area is still used occasionally to flush out the sediments that have accumulated in the raw 

water supply line. In the past, fluffy material (referred to as “flocculant”), which primarily consists of suspended 

solids removed from the water during the treatment process, was discharged to the eastern area of the site for 

settling. The saturated flocculant was pumped into the area where a dam was set up, which allowed the 

flocculant to settle out. The flocculant was then discharged directly into the drainage area, which flows to the 

storm sewer system. The sediments and flocculant may contain suspended sediments, which may concentrate 

naturally occurring metals. The layout of the site is shown in Figure 8. 

There were no structures or material/waste storage on the site at the time of the remedial investigation (1998). 

The only structures in the vicinity of the site were the buildings associated with the water treatment plant, which 

still exists. 

The Army has completed its investigation and risk assessment at the Backwash Discharge Area from the water 

treatment plant site and there are no environmental concerns at the site. 

1.5 PARCEL 3-90 

Parcel 3-90 is approximately 8 acres in size and is located south of Carbaugh Avenue and west of Coffey Avenue. 

There are no structures on this parcel. This parcel is currently open land and has been an open area in the past 

with no apparent storage or industrial activities. 

1.6 PARCEL 3-91 

Parcel 3-91 is approximately 1.5 acres in size and is located east of Coffey Avenue and north of Texas/Innovation 

Avenue in the southeastern corner of the SMSR. There are no structures on Parcel 3-91. This parcel consists 

entirely of the western portion of the Building 400 Series Fire Training Area (FTA) site where industrial activities 

occurred as described in the following paragraphs. 

Building 400 Series FTA site (part of SE OU 8): The discussions presented here concerning site history, 

investigation, and findings are for the entire site. The Building 400 Series FTA area had been reportedly used in 

the past for a short period of time as a fire-fighting training area where a large metal pan was placed on the 

ground and filled with various flammable liquids, which were ignited. There was no record of the exact location 

of the pan, years of use, or when/if the pan was removed from the area when training activities ended. Historical 

aerial photographs from 1949 and 1957 show several disturbed places in this area. Based on knowledge of typical 

fire-training activities at LEAD, materials burned at the site may have included waste oils. The layout of the site 

is shown in Figure 9. 

There were no structures or material/waste storage on the site at the time of the remedial investigation (1998). 

The only structures in the vicinity of the site were several old barracks/office buildings, which are still located 

near the site. 

The Army has completed its investigation and risk assessment at the Building 400 Series FTA and there are no 

environmental concerns at the site. 

1.7 PARCELS 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, AND 2R-86L-3 

These parcels actually consist of land underneath the same parcels and roadways that were previouslytransferred as part of the Phase II BRAC property transfer at LEAD, as shown in Figure 3 (specifically, starting 

from 8 ft bgs to the center of the earth), located in the southern part of the SMSR/Phase III area. The entire land 

area was not originally transferred because it was thought the groundwater located underneath the land was 

potentially contaminated with VOCs. These parcels were investigated as part of the SMSR groundwater 

investigation described previously. The Army has completed its investigation and risk assessment for the SMSR 

groundwater and found no environmental concerns at the site. The top portions of these parcels were transferred 

with an interim remedy for groundwater (WESTON, 2001) consisting of soil excavation and groundwater use 

restrictions because at that time it was thought that the groundwater underneath the parcels was contaminated. 

The soil excavation and groundwater restrictions will now be removed as part of the no further action alternative. 
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1.8 GROUNDWATER ASSOCIATED WITH PHASE I PARCELS 24, 27, AND 28 

Parcels 24, 27, and 28 (Figure 3) are land (all of the land including groundwater) that was previously transferred 

as part of the Phase I BRAC property transfer at LEAD. These parcels were transferred with soil excavation and 

groundwater use restrictions because all of the Phase I parcels were categorized as having contaminated 

groundwater or potentially contaminated groundwater based on the data collected to that point in time. The 

groundwater underneath these parcels was evaluated as part of the SMSR groundwater investigations described 

previously, which showed that the groundwater was not contaminated. Therefore, these Phase I parcels are 

included in this ROD for no action for groundwater to remove the soil excavation and groundwater restrictions at 

Parcels 24, 27, and 28. 

SECTION 2

SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1 HISTORY OF SITE ACTIVITIES 

Prior to the establishment of LEAD in 1942, the area consisted of agricultural and forest lands. The area was 

predominantly single-family farms used for both subsistence and commercial purposes. 

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 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 U.S. Air Force 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 (such as sand from sandblasting operations), paints, chemicals, petroleum products, 

and metals. Storage, spills, releases, and disposal of these materials led to the current environmental concerns at 

LEAD. The histories of the four BRAC sites located in the Phase III area are as follows: 

OVSA site/SMSR: From approximately 1947 and continuing until the spring of 1998, the OVSA site was used for 

the storage of military vehicles. While the most recent past practice of storage requires that the vehicles be 

drained of fluids (such as diesel fuel, oil, and other engine fluids) before they are stored, interviews with former 

employees have indicated that the vehicles were formerly stored “wet,” meaning that they were stored with the 

fluids still in the vehicle, and that the vehicles may have had their fluids drained onto the ground before they 

were refurbished. In addition, in the past as part of grounds-keeping practices at LEAD, the soil in the OVSA site 

was scraped to the edges of the storage area to allow for removal of shale rock that lies beneath the site soil in the 

area to be used as fill in other areas at LEAD. The OVSA comprises the majority of the land in the SMSR area and 

therefore, represented the primary potential source of contamination for the SMSR groundwater. 
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Former Uncurbed AST North of Building 532 site: There was an uncurbed single-walled AST (275 gallons) 

located north of Building 532 that stored gasoline used to fuel golf carts. This AST was replaced by a doublewalled AST; it is unknown how long the single-walled AST was in service. 

Backwash Discharge Area from the Water Treatment Plant site: In the past, sediments that accumulated in the 

raw water line were flushed out in the western area of the site. In the past, fluffy material (referred to as 

“flocculant”), which primarily consists of suspended solids removed from the water during the treatment 

process, was discharged to the eastern area of the site for settling. The saturated flocculant was pumped into the 

area where a dam was set up, which allowed the flocculant to settle out. The flocculant was then discharged 

directly into the drainage area, which flows to the storm sewer system. At a later time the dam was dismantled 

and the area was backfilled with shale. The area was also used as a discharge area for backwashed water. 

Building 400 Series FTA site: The Building 400 Series FTA had been reportedly used in the past for a short 

period of time as a fire-fighting training area where a large metal pan was placed on the ground and filled with 

various flammable liquids (possibly including waste oils), which were ignited. There was no record of the exact 

location of the pan, years of use, or when/if the pan was removed from the area when training activities ended. 

Historical aerial photographs from 1949 and 1957 show several disturbed places in this area. 

2.2 SUMMARY OF PREVIOUS SITE INVESTIGATIONS 

Studies initiated since 1979 have concluded that toxic materials associated with operations at LEAD, along with 

uncertain past disposal practices and the nature of the complicated hydrogeological regime (e.g., “karst” as 

described in Subsection 5.1.3), offered significant potential for contamination by chlorinated hydrocarbons and 

subsequent contaminant migration. Between 1980 and the present, numerous environmental investigation 

programs were conducted at LEAD to evaluate potential contamination in the soil and groundwater at the Depot. 

In 1986, EPA ranked the LEAD 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 NPL. The SE Area was placed on the NPL in July 1987. The PDO Area was added 

to the NPL in March 1989. As reported in two documents (ESE, 1992, 1993), remedial investigations were conducted 

by Environmental Science and Engineering (ESE) at LEAD in the late 1980s/early 1990s in the PDO and SE Areas, 

which focused on the depot-wide sources of VOC contamination in groundwater outside the Phase III areas. 

Investigations and remedial actions are currently underway at both NPL sites. 

As part of the realignment of the LEAD mission, an environmental baseline survey was completed for all of the 

to-be-excessed (BRAC) property, including the Phase III parcels, discussed in more detail in Subsection 2.4. The 

environmental baseline survey is a comprehensive initial survey of site information. Based on the environmental 

baseline survey, the four BRAC sites and groundwater in the SMSR area underwent limited investigations to rule 

out the potential for contamination due to past operations. Remedial investigations/risk assessments were 

conducted for these four sites and additionally, for the groundwater in the entire Phase III/SMSR area. Previous 

investigations specific to the Phase III parcels are discussed in more detail in Section 5 and in Subsection 2.4. 

2.3 HISTORY OF CERCLA COMPLIANCE ACTIVITIES 

Since the listing of the two sites at LEAD on the NPL, all of the remedial activities at the site have been Army-led, 

in coordination with EPA Region III and the South-Central Region of PADEP. No other potentially responsible 

parties have been identified. 

As a result of the proposed NPL ranking, the U.S. Army Toxic and Hazardous Materials Agency, later renamed 

the U.S. Army Environmental Center (USAEC), took the initiative in conducting the response actions at LEAD in 

accordance with Executive Order 12316 and a Memorandum of Understanding of 12 August 1983. The Executive 

Order was signed on 14 August 1981 by President Reagan. It delegates to the Secretary of Defense the authority 

to take the lead on CERCLA activities at Federal facilities. The Memorandum of Understanding is between EPA 

and the U.S. Department of Defense (DoD). It 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 and remedial actions at Federal 

facilities to the secretaries of the applicable Federal agencies. 
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On 3 February 1989, a Federal Facilities Agreement was reached under CERCLA Section 120 among the DoD, 

EPA, and PADEP (EPA, Army, and PADEP, 1989). The 1989 Federal Facilities Agreement established the 

framework for the CERCLA response actions at LEAD and required the review of all documents concerning the 

investigation of environmental contamination at LEAD produced prior to the Federal Facilities Agreement. 

The PDO Area encompasses approximately 1,490 acres in the southern portion of the Depot. It extends 

approximately south from the southern end of the combat vehicle test track southwest to Rocky Spring Lake. The 

groundwater in the PDO Area becomes surface water discharge at Rocky Spring, which flows into the Rocky 

Spring Branch of Conococheague Creek, and eventually into the Potomac River. Seven OUs exist within the PDO 

Area. The following is a description of each OU in the PDO Area: 

 PDO OU 1: Source Area Soils (soil from the drum storage revetments). 

 PDO OU 2: PDO Area Groundwater and Surface Water. 

 PDO OU 3: Mercury Detections in Rocky Spring Lake. 

 PDO OU 4: Groundwater Associated with the Oil Burn Pit. 

 PDO OU 5: Polychlorinated Biphenyl (PCB) Investigation of the Rocky Spring System. 

 PDO OU 6: BRAC Waste Sites. 

 PDO OU 7: Southern Martinsburg Shale Region (SMSR). 

The response action in this ROD concerns areas in PDO OU 7 (groundwater in the PDO portion of the SMSR, 

below the Phase III parcels) and PDO OU 6 (Phase III BRAC waste sites). PDO OU 7 was originally part of PDO 

OU 2 but was separated into its own OU to investigate the theory that the groundwater in the SMSR area is not 

contaminated with VOCs because there are no known sources of VOCs in the SMSR area and the SMSR was 

thought to be unaffected by the known and potential VOC sources surrounding the area. 

The SE Area consists of the Southeast Industrial Area and the Disposal Area, and encompasses approximately 

1,136 acres. A total of 13 OUs exist within the SE Area. The following is a description of each OU in the SE Area: 

 SE OU 1: K Area Contaminated Soils. 

 SE OU 2: Industrial Wastewater Sewers and Contaminated Soils. 

 SE OU 3A: Disposal Area VOC-Contaminated Groundwater. 

 SE OU 3B: Area Upgradient of VOC Contamination Source in SE OU 3A. 

 SE OU 4: Stormwater Sewers and Contaminated Sediments. 

 SE OU 5: Areas A and B Contaminated Soils. 

 SE OU 6: VOC-Contaminated Groundwater North of Gate 6 and East of East Patrol Road (Rowe Run 

Drainage System). 

 SE OU 7: Truck Open Storage Area/Waste Oil Sump. 

 SE OU 8: BRAC Waste Sites. 

 SE OU 9: Landfill J; near Building 320. 

 SE OU 10: Southern Southeast Industrial Area (SSIA) VOC-Contaminated Groundwater South of Gate 6 

(Conococheague Drainage System). 

 SE OU 11: Northern Southeast Industrial Area (NSIA) VOC-Contaminated Groundwater North of Gate 6. 

 SE OU 12: Landfill G. 

 SE OU 13: Southern Martinsburg Shale Region (SMSR). 

The response action in this ROD concerns areas in SE OU 13 (groundwater in the SE portion of the SMSR, below 

the Phase III parcels) and SE OU 8 (Phase III BRAC waste sites). SE OU 13 was originally part of SE OU 3A/3B, 

SE OU 10, and SE OU 11 but was separated into its own OU to investigate the theory that the groundwater in the 

SMSR area is not contaminated with VOCs because there are no known sources of VOCs in the SMSR area and 

the SMSR was thought to be unaffected by the known and potential VOC sources surrounding the area. 
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2.4 BASE REALIGNMENT AND CLOSURE (BRAC) 

The majority of the administrative, industrial, and housing facilities at LEAD have been designated for “release” (“tobe-excessed” or transfer of ownership of property) from the U.S. Army based on the decision of the 1995 BRAC 

Commission to realign the LEAD mission. The land designated for release will be transferred to LIDA in a manner 

that follows BRAC program guidance. 

The Ammunition Area (Ammo Area), and selected portions of the industrial/administrative area, will be retained to 

support LEAD’s continuing mission. The retained area is also known as the “Enclave Area.” 

The LEAD BRAC Cleanup Team was established in 1995 to facilitate the environmental issues involved with the 

realignment at LEAD. The BRAC Cleanup Team is composed of the LEAD BRAC Environmental Coordinator and the 

Remedial Project Managers from EPA Region III and PADEP. The BRAC Cleanup Team meets on a monthly basis to 

discuss environmental issues related to the transfer of property at LEAD. The goal of the BRAC Cleanup Team is to 

streamline decisions, and to work together toward innovative and timely techniques to facilitate the timely transfer of 

property. 

As part of the realignment of the LEAD mission, an environmental baseline survey was completed for the BRAC 

parcels. This process includes visual inspections of the 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. The LEAD environmental baseline survey was finalized in 

August 1996 (WESTON, 1996). The final Community Environmental Response Facilitation Act letter report, 

which contains a map showing the environmental conditions at LEAD, was finalized in March 1997. An 

addendum, which updated environmental conditions, was finalized in April 1999 (WESTON, 1999). A follow-up 

document, Supplement 1 to the environmental baseline survey, was finalized in November 2000 (WESTON, 

2000b); this document included several buildings not covered in the environmental baseline survey or the 

addendum. The environmental baseline survey process identified certain BRAC sites that require further study 

prior to being transferred. Site investigations, remedial investigations, and screening level risk assessments have 

been completed or are currently underway for these BRAC sites. Of the Phase III parcels, only four sites (the 

OVSA, the Former Uncurbed AST near Building 532, the Building 400 Series FTA, and the Backwash Discharge 

Area) were identified as needing further study. 

Site investigations, remedial investigations, and screening level risk assessments have been completed for the 

four sites in the Phase III parcels and the SMSR groundwater. CERCLA site investigations and risk screenings 

were performed on the four sites in the Phase III parcels and the SMSR groundwater between 1998 and 2002 to 

determine if the existing site conditions are protective of human health and the environment, and if the sites 

could be cleared for transfer and reuse pursuant to the BRAC program. None of the parcels and buildings 

covered under this ROD were identified as having any environmental concerns, except for the OVSA. A removal 

action for contaminated soils was performed at the OVSA in 2000, thus, there are no longer environmental 

concerns with this site. 

The future use of the Phase III parcels is currently planned as commercial/industrial use. LIDA’s final reuse plan 

(as referenced by the Memorandum of Agreement between the Army and LIDA) specifies the intended future 

use of the parcels. In addition, Greene Township zoning restrictions preclude residential use of the BRAC parcels 

in that part of the township. However, risk assessments were also performed for potential future residential use 

to evaluate site conditions based on unrestricted use. 

SECTION 3

COMMUNITY PARTICIPATION HIGHLIGHTS

Pursuant to CERCLA Section 113(k)(2)(B)(i-v) and Section 117, the Proposed Plan for the Phase III parcels at 

LEAD was released to the public for comment on 14 April 2003. This document was made available to the public, 

in the Administrative Record, located in Building 14 at LEAD, and in the Coyle Free Library in Chambersburg. 

A public comment period was held from 14 April to 13 May 2003. On 23 April 2003, a public availability session 

was held at the Building 10 Letterkenny Great Room to present the Proposed Plan (in the form of a poster 

presentation) and to entertain questions and comments from the public. The notification for the Proposed Plan 

public meeting was published in the Shippensburg News Chronicle on April 15, the Waynesboro Record Herald on 
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April 10 and 11, and the Chambersburg Public Opinion on April 11 and 12, 2003. A summary of the community 

participation process is provided in the Responsiveness Summary, which is included as part of this ROD. There 

were no comments received during the public comment period, and there were no comments or questions during 

the public availability session. 

SECTION 4

SCOPE AND ROLE OF RESPONSE ACTION

The LEAD Site is complex as are many CERCLA sites and therefore, is split into many different OUs. The OUs 

that are the subject of this ROD are listed below. The response action selected in this ROD is a final action with 

regard to soils and groundwater at the Phase III parcels (no further action), including groundwater in the Phase I 

parcels within the SMSR area, which together address any environmental concerns at the Phase III parcels and 

SMSR. This ROD also provides the justification for deciding to take no further action under CERCLA. The no 

further action decision in this ROD applies to: 

 SMSR groundwater (including groundwater below the Phase III parcels as well as the Phase I and 

Phase II parcels located in this area – PDO OU 7 and SE OU 13). 

 OVSA site (part of BRAC waste sites in OUs PDO OU 6 and SE OU 8). 

 Former Uncurbed AST North of Building 532 site (part of PDO OU 6). 

 Backwash Discharge Area from the Water Treatment Plant site (part of SE OU 8). 

 Western portion of the Building 400 Series FTA site (part of SE OU 8). 

The specific areas affected by the selected remedy are referred to as Parcels 3-89, 3-90, 3-91, 2-53L, 2-54L, 2-70L, 

2R-80L-3, 2R-84L-3, and 2R-86L-3, as well as groundwater in the previously transferred Phase I parcels identified 

as Parcels 24, 27, and 28. This selected response action does not address other OUs at LEAD. The role of the 

response action selected for the Phase III parcels is to be protective of human health and the environment at the 

properties while making the parcels available for beneficial reuse in a timely manner. 

The description of the other past and current actions is too long to list here, but can be found in the Installation 

Action Plan for Letterkenny Army Depot, FY 2004 (LEAD, 2003). 

SECTION 5

SITE CHARACTERISTICS

The following information is presented to document the site characteristics of the Phase III BRAC parcels. Some 

of the environmental setting information is general to all of LEAD, with specific references to the Phase III parcels 

as appropriate. The Phase III parcels consist of approximately 201 acres, with an additional 28 acres of subsurface 

property that is deeper than 8 ft bgs, located underneath parcels previously transferred as part of Phase II. There 

are no wetlands or other ecologically sensitive areas located in the Phase III parcels. In addition, there are no 

areas of significant historical or archaeological importance in the Phase III parcels. The information pertaining to 

the site conceptual model and the nature and extent of contamination is presented in Subsection 5.2. 

5.1 ENVIRONMENTAL SETTING 

5.1.1 Topography and Surface Drainage 

LEAD is located in the Great Valley section of the Valley and Ridge Province of the eastern United States, and is 

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 southwest-trending limestone ridges and valleys. The valley floors 

are filled with rocks of the Martinsburg Formation. Weathering of the folded and faulted underlying geological 

formations imparts a gently rolling aspect to the local topography. The majority of LEAD is located within the 
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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 of LEAD are underlain by limestone. Figure 2 shows the general 

locations of the PDO and SE Areas. Surface elevations throughout LEAD range from approximately 600 to 750 ft 

above mean sea level (msl), except for the northwestern portion of LEAD, where the elevation increases abruptly 

to more than 2,300 ft 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. 

Surface water from the Phase III parcels located in the PDO Area flows to drainage ditches, and then ultimately 

flows to the Potomac River watershed via the Rocky Spring Branch system. 

Two major stormwater drainage systems serve the southeastern portion of LEAD and contribute to local surface 

drainage for the Phase III parcels in the SE Area. One system serves the area north of Coffey Avenue and 

discharges near the industrial wastewater treatment plant into the discharge ditch (located north of the industrial 

wastewater treatment plant), which discharges to Rowe Run; the northern part of the Phase III parcels/SMSR 

that are in the SE Area drains to this system. The other stormwater system serves the southeastern warehouse 

area; the southern part of the Phase III parcels/SMSR area located in the SE Area drains to this system. 

Stormwater in this area is discharged at the stormwater outfall into the southeastern drainageway, which 

discharges to the Conococheague Creek. Figure 2 illustrates the major drainage divides at LEAD. 

5.1.2 Geology 

LEAD straddles two major structural features—these are referred to as the “South Mountain anticlinorium” to 

the east and the “Massanutten synclinorium” to the west. An anticline refers to a configuration of folded, 

stratified rocks in which rocks dip in two directions away from a crest, as principal rafters of a common gable 

roof dip away from ridgepole. A syncline refers to a configuration of folded, stratified rocks in which rocks dip 

downward from opposite directions to come together in a trough. 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 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. 

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 (Phase III/SMSR area), 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 geological formations are fractured and deformed to varying degrees from past geological 

activity (ESE, 1993a). 

Two major faults, the Pinola fault and the Letterkenny fault, and several other unnamed faults, extend through 

the LEAD site boundary. Although an east-to-west cross fault was identified between these two faults, both the 

position and surface trace are open to question (Becher and Taylor, 1982). 

The Letterkenny fault is one of the few faults in the region that parallels the tectonic grain, yet is an early formed, 

eastward-dipping, thrust that moved material from within the syncline up onto the anticline to the west (EA, 

1991). 

The Pinola fault, located west of the Letterkenny fault, is considered to be an east-dipping, high-angle, thrust 

fault (because older beds are located 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 ridgeforming unit that extends through it (Becher and Taylor, 1982). 

5.1.3 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 
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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). This occurrence is demonstrated in the SMSR area as depicted in Figure 10; 

the SMSR is located in a high area along a ridge, where several groundwater/surface water divides cause 

groundwater to flow radially away from the SMSR. 

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 in low-lying 

areas 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 (Phase III/SMSR area) are generally small but are numerous 

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 more isolated fractures and solution cavities typical of what is referred to as a “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 

previously. The quantity and density of fractures and solution cavities within the limestone units are generally 

greatest in the upper 150 ft and generally decrease with depth. During three-quarters of the year (high and base 

flow conditions) groundwater levels are above the soil-bedrock interface. Leaching or resuspension of any 

materials or potential contaminants buried in the overburden soils may be enhanced during high water table 

conditions (ERM, 1995). 

Groundwater “recharge” occurs primarily through precipitation. “Recharge” refers to replenishing of supplies of 

groundwater. Recharge areas occur throughout the central part of LEAD, wherever fractured and jointed 

sandstone, siltstone, and shale bedrock are close to the surface. Actual points of recharge for the limestone 

aquifers have not been determined; however, the most likely routes are the many faults, joints, and sinkholes 

present at LEAD (ERM, 1995). 

Groundwater underlying LEAD generally occurs under unconfined conditions, with local areas of artesian 

conditions, which refers to when water flows upward under natural pressure, rather than having to be pumped 

to the surface. These artesian conditions occur along a moderately steep slope located near the northwestern edge 

of LEAD in the Ammunition Area. 

5.1.4 Soils 

Surface soils present at LEAD, including those in the Phase III/SMSR area, are predominantly shaley to very 

shaley silt loams that developed through weathering of the Martinsburg Shale and the interbedded siltstones and 

sandstones. According to the Soils Survey Bulletin of Franklin County, these soils have been classified as part of the 

Weikert-Berks-Bedington Association. Soils on the eastern edge of LEAD associated with the limestone (outside 

the Phase III/SMSR area) have been identified as part of the Hagerstown-Duffield Association. These soils are 

deep, level or sloping, somewhat poorly drained, and mostly rocky, silty, clay loams. Along the western side of 

LEAD, outside the BRAC area, are soils of both the Laidig-Very stony land-Buchanan Association (formed from 

sandstone) and the Morrill-Laidig Association (formed on the foot of mountain slopes). 

5.1.5 Four BRAC Sites 

The characteristics of the four sites investigated are discussed in the following paragraphs: 

OVSA site (part of soil OUs PDO OU 6 and SE OU 8): This site is situated in an open area with grass and 

weeds, with wooded areas to the north and east. The OVSA site is surrounded by Army-retained industrial land, 

commercial/industrial use land (other BRAC property, some of which is open land), parts of the golf course, the 

Backwash Discharge site, and Phase I Parcel 27 (parking lot). 

No known wetlands or sensitive species are present within or in the vicinity of the OVSA. Surface water drainage 

in the OVSA occurs as sheet flow to drainage ditches. There are several drainage ditches that run through and 
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around the OVSA. These drainage ditches, the same as described for the other three sites, are generally dry 

throughout most of the year and only have water flow during precipitation events. The OVSA is split by surface 

water and groundwater drainage divides. Surface water runoff in the western part of the site flows from the 

drainage ditches to upper Rocky Spring Branch (nearest downstream aquatic area/permanent flowing creek), 

which is approximately 2 miles downstream of the OVSA. Rocky Spring Branch flows through Rocky Spring 

Lake, and flows to Back Creek approximately 2.5 miles downstream of the lake, and ultimately discharges into 

the Potomac River via Conococheague Creek. Surface water in a small portion in the southeastern part of the site 

also eventually flows to the Potomac River via the flow pattern described for the Backwash Discharge Area. 

Surface water runoff in the northeastern part of the site flows to storm sewers, which flow to Rowe Run 

approximately 1⁄2 mile from the OVSA site, which eventually flows to the Susquehanna River. 

Former Uncurbed AST North of Building 532 site (part of PDO OU 6): This site is located at the northern end of 

a gravel parking area; the tank was surrounded on two sides by the parking area. Maintained grassy areas of the 

golf course surround the gravel parking area and slope down steeply to the north and west. Surface runoff from 

the site flows to drainage ditches to the north and west, which flow into Rocky Spring Lake, primarily via Rocky 

Spring Branch, which flows to Back Creek approximately 2.5 miles downstream, and ultimately discharges into

the Potomac River via Conococheague Creek. 

Backwash Discharge Area from the Water Treatment Plant site (part of SE OU 8): The site consists of grassy 

open fields, and portions of the site are periodically maintained by mowing. The site is surrounded by a parking 

lot (Phase I Parcel 27), parts of the golf course, the water treatment plant, and part of the OVSA site. Surface 

runoff from the site flows to drainage ditches along the site and along Coffey Avenue, which flow to the storm 

sewer system that eventually empties into the southeast drainageway in the far southeastern corner of LEAD. 

The southeast drainageway flows to Conococheague Creek, which eventually discharges into the Potomac River. 

Building 400 Series FTA site (part of SE OU 8): This site is currently lying fallow and is covered with grass. The 

site is surrounded by commercial/industrial use land (other BRAC property), agricultural land (off-site orchard), 

and part of the golf course. Drainage for a larger portion of the site flows to the west/southwest, while the 

remaining portion flows via somewhat steep slopes to the east/southeast. Surface runoff from the site flows to

roadside drainage ditches, which flow to the storm sewer system that eventually empties into the southeast 

drainageway in the far southeastern corner of LEAD. 

5.2 NATURE AND EXTENT OF CONTAMINATION 

Based on the environmental baseline survey, four sites within the Phase III parcel areas and the SMSR 

groundwater underwent limited investigations of the soils to rule out the potential for soil and groundwater 

contamination due to past operations. The remainder of the Phase III parcels were determined to be unaffected 

by activities at LEAD, and therefore, investigations and sampling were not warranted. 

To facilitate the transfer of the Phase III BRAC parcels where limited sampling was performed, a screening level 

risk assessment for human health effects was performed. The screening level risk assessment is a screening 

protocol (including comparison of the results to available risk-based criteria) that was developed by the Army, 

EPA, and PADEP, as discussed in more detail in Section 7 of this ROD. 

Remedial investigations/risk assessments were performed at the sites to provide information to support a

decision to investigate further, implement a removal action, or conduct no further action at the site. The 

objectives of the remedial investigation for each site were to: (1) identify the type, location, and levels of

contamination (and extent of contamination where necessary) at the study site; (2) identify the physical sitespecific characteristics that may influence contaminant distributions; (3) determine the potential for contaminant 

migration; and (4) determine if there are potentially unacceptable levels of risk to people or the environment at

the sites. The remedial investigation/risk assessment documents are available in the LEAD Administrative 

Record. 

5.2.1 Site Conceptual Model 

The site conceptual models for the OVSA/SMSR, Uncurbed AST North of Building 532 site, the Backwash 

Discharge Area, and the Building 400 Series FTA are described in Tables 1 though 7. These conceptual models list

possible exposure pathways for people, animals, and plants that could possibly be exposed to soil and 

groundwater at the sites. Investigations at these sites are discussed in more detail in the following subsections. 
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5.2.2 SMSR Groundwater 

An investigation was completed to determine if past industrial activities in the SMSR area or the known sources 

of groundwater contamination surrounding this area had impacted the groundwater quality in the area. Field 

activities were performed between October 1999 and November 2000, and then additionally in November 2002. 

Monitor wells were installed and surveyed; groundwater at numerous locations across the site was sampled and 

analyzed, and data validation was performed on four rounds of sampling; groundwater levels were taken; and 

risk assessments were conducted for the OVSA and the other areas of the SMSR (all Phase III parcels and Phase I 

Parcels 24, 27, and 28). The investigations and evaluations were done to verify that there was no groundwater 

contamination in the SMSR/Phase III area, and that known sources of VOC groundwater contamination 

downgradient of the SMSR had not migrated into the SMSR. The findings are reported in the OVSA remedial 

investigation/risk assessment (WESTON, 2003a) and the SMSR Summary Report (WESTON, 2003b). 

The locations of the monitor wells and the groundwater elevations are shown in Figure 11. The groundwater 

samples were analyzed for VOCs, SVOCs, polychlorinated biphenyls (PCBs), and metals, primarily based on the 

past activities at the OVSA site and the surrounding VOC contamination in the limestone aquifer. The SMSR is 

“upgradient” from known sources of groundwater contamination in the “downgradient” limestone aquifer. 

(“Upgradient” describes an area where groundwater is at a higher elevation than in other areas. Groundwater 

tends to flow away from upgradient locations toward downgradient locations, where groundwater is at a lower 

elevation.) The investigation results did not indicate any contaminants of concern (COCs). The sampling data 

collected indicate that there is no current VOC groundwater contamination present in the SMSR and the 

groundwater gradients show that the SMSR is upgradient of the contaminated limestone aquifer that surrounds 

the area. Four rounds of groundwater samples were taken from wells drilled into the shale. From these four 

rounds, only one chemical in one sample was found at a concentration greater than PADEP medium-specific 

concentrations (MSCs) and the EPA Federal maximum contaminant levels (MCLs). (Note that the MSCs for 

drinking water and the MCLs are the same values.) One well had a concentration of arsenic from one round of 

sampling that slightly exceeded the regulatory value, but was attributed to naturally occurring background 

levels, not contamination from industrial use or waste disposal. 

The screening level risk assessment showed that risks to people based on current and future 

commercial/industrial use are within acceptable limits. Risks to people based on a possible, but unlikely, 

residential use (including human consumption of site groundwater) are within acceptable limits or are due to 

widespread naturally occurring levels of background contamination, which CERCLA generally does not attempt 

to remedy. Note that the area is served by a piped public drinking water system, reducing the need to rely on 

groundwater for drinking water. This area has never been used by the Army as a drinking water supply. In 

addition, the land will be part of the Cumberland Valley Business Park, and in accordance with the business 

park’s Codes, Covenants, and Restrictions, one of the prohibited uses of the property is drilling for water.

5.2.3 OVSA 

An investigation was completed to determine if the former vehicle storage operation had caused a release of 

contaminants to site soil, sediments, surface water, and groundwater. Field activities were performed at various 

periods between October 1998 and November 2000, and then additionally in November 2002 (groundwater 

sampling). Geophysical surveys, soil borings, test trenching, soil sampling and analysis, drainage ditch soil 

sampling and analysis, surface water sampling and analysis, monitor well installation, water level 

measurements, groundwater sampling and analysis, data validation, and surveying were performed. Soil 

samples were collected based on the information obtained from the geophysical survey that identified disturbed 

areas and areas that could potentially be contaminated. Some of the test trenching and soil borings were 

completed as an additional round of investigation to further delineate the lateral extent of buried material 

(including roofing material) and/or contaminants detected in the first set of test trenches. The results of the 

groundwater sampling are the same as described for the SMSR. The results of the remedial investigation for soil 

indicated that polycyclic aromatic hydrocarbons (PAHs) were initially COCs in soil (see the following inset box). 

Concentrations of 17 types of PAHs were detected at high concentrations across the majority of the horizontal 

extent of the western part of the site; 5 of these compounds, including benzo(a)pyrene, were identified as COCs. 

Maximum concentrations of the various PAHs ranged from 53 milligrams per kilogram (mg/kg, which is 

equivalent to “parts per million” [ppm]) of acenaphthalene to 6,600 mg/kg of phenanthrene on the western side 

of the site. The maximum benzo(a)pyrene concentration detected was 2,300 mg/kg. PAH contamination was 
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found at depths from 1 ft to approximately 12 ft bgs. The OVSA site layout showing sample locations is shown in 

Figure 12. The text box presents information about the COCs present prior to the removal action at the OVSA. 

Therefore, in 2000, alternatives were developed and evaluated in an engineering evaluation/cost analysis 

document (similar to a feasibility study [FS]), which is a technical report that evaluates the need for a removal 

action (WESTON, 2000a). A non-time-critical-removal action was then implemented from July to November 2000 

to reduce or eliminate potential risks to people and the environment at the site (IT, 2001). The area where the 

removal action was completed is shown in Figure 12. This removal action consisted of excavating contaminated 

soils and disposing of them in regulated off-site disposal facilities. The total amount of contaminated soil and 

waste removed from the site was approximately 46,470 tons. 

Previous Contaminants of Concern at the OVSA Site (Present in Soils Prior to the 2000 Removal Action) 

PAHs: Polycyclic aromatic hydrocarbons are a group of over 100 different chemicals (e.g., benzo(a)pyrene) that are formed 

during incomplete burning of coal, oil and gas, garbage, or other organic substances such as tobacco or charbroiled meat. PAHs 

are found mostly in coal tar, crude oil, creosote, and roofing tar. Present in low concentrations virtually everywhere, PAHs 

occasionally reach elevated concentrations as the result of prolonged industrial activities involving burning, or by releases of 

materials such as creosote-based wood preservatives, that contain PAHs in high concentrations. PAHs are slow to degrade in 

the environment and can also accumulate in the tissues of marine animals. PAHs are a concern because some of them cause 

cancers in humans and are harmful to fish when concentrations are elevated. 

The analytical data from the remedial investigation and from the confirmation samples collected after the 

removal action were then evaluated and reported in the remedial investigation/risk assessment report 

(WESTON, 2003a). The investigation results for both the eastern and western sides based on post-removal-action 

conditions did not indicate any COCs in groundwater, soil, sediments, or surface water. Various VOCs, SVOCs, 

pesticides, PCBs, and metals were identified as chemicals of potential concern (COPCs) based on a comparison of 

maximum chemical concentrations to the lowest regulatory residential risk-based screening levels (also referred 

to as benchmarks). However, the remedial investigation/risk assessment showed that concentrations of 

chemicals found in site soils, sediments, surface water, and groundwater pose no unacceptable risks to people, 

plants, or animals based on current and future commercial/industrial reuse. Risks to people based on a 

theoretical future residential use are within acceptable limits or are due to widespread background 

contamination, which CERCLA generally does not attempt to remedy. 

5.2.4 Former Uncurbed AST North of Building 532 Site 

An investigation was completed to determine if the operation of the former AST at the site had caused a release of 

contaminants to site soil. Field activities were performed in April 1999. Soil borings, soil sampling and analysis, 

data validation, and surveying were performed. The site layout showing sample locations is shown in Figure 7. 

The investigation results did not indicate any COCs in soil and there were no potential sources of groundwater 

contamination found. Only two chemicals (acetone and lead) were identified as COPCs based on a comparison of 

maximum chemical concentrations to the lowest regulatory residential benchmarks. However, the remedial 

investigation/risk assessment (WESTON, 2002a) showed that concentrations of chemicals found in site soils pose 

no unacceptable risks to people based on current and likely future commercial/industrial use. Risks to people are 

also within acceptable limits based on a theoretical future residential use. There is minimal habitat available 

capable of sustaining plants and animals at this site; therefore, ecological risks were not evaluated. 

5.2.5 Backwash Discharge Area from the Water Treatment Plant Site 

An investigation was completed to determine if the former water treatment plant flocculant and backwash sediment 

disposal practices had caused a release of contaminants to site soil and sediments. Field activities were performed 

in October 1998. Soil borings, soil and drainage ditch soil sampling and analysis, sediment sampling and 

analysis, data validation, and surveying were performed. The site layout showing sample locations is shown in 

Figure 8. The investigation results did not indicate any COCs in soil and there were no potential sources of 

groundwater contamination found. Various metals were identified as COPCs based on a comparison of 

maximum chemical concentrations to the lowest regulatory residential benchmarks. However, the remedial 

investigation/risk assessment (WESTON, 2002c) showed that concentrations of chemicals found in site soils pose 

no unacceptable risks to people, plants, or animals based on current and likely future commercial/industrial 

uses. Risks to people are also within acceptable limits based on a theoretical future residential use. 
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5.2.6 Building 400 Series FTA Site 

An investigation was completed to determine if the former fire training activities had caused a release of 

contaminants to site soil. Field activities were performed in September 1998. A geophysical survey, test trenching, 

soil sampling and analysis, data validation, and surveying were performed. The site layout showing sample 

locations is shown in Figure 9. The investigation results did not indicate any COCs in soil and there were no 

potential sources of groundwater contamination found. One VOC (acetone), two SVOCs (PAHs), various metals, 

and polychlorinated dibenzo-p-dioxins/polychlorinated dibenzofurans (PCDDs/PCDFs) were identified as 

COPCs based on a comparison of maximum chemical concentrations to the lowest regulatory residential 

benchmarks. However, the remedial investigation/risk assessment (WESTON, 2002b) showed that 

concentrations of chemicals found in site soils pose no unacceptable risks to people, plants, or animals based on 

current and likely future commercial/industrial use. Risks to people are also within acceptable limits based on a 

theoretical future residential use. 

SECTION 6

CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES

6.1 LAND USE 

The majority of the land in the Phase III parcels in the SE Area and PDO Area is used for industrial operations 

(water treatment plant), supply storage, administration (office space and communications center), commercial 

recreational activities (golf course and community building), and former military housing. There are also areas of 

open land (including the OVSA and the golf course) interspersed in the Phase III parcels in the SE Area, which 

are characterized as maintained grassy areas, sparsely vegetated/grassy fields, pockets of wooded areas, 

vegetated natural and manmade drainageways, and small groves of trees. In accordance with the LIDA reuse 

plan as documented in the LEAD reuse strategy report (FCRC, 1997) and discussions between the Army and 

LIDA, the future use of the Phase III parcels being transferred to LIDA is planned for commercial/industrial use 

as part of the Cumberland Valley Business Park. The majority of the Phase III parcels in the SE and PDO Areas 

will continue to be used for commercial (office space and commercial recreational activities – golf 

course/industrial. LIDA currently has specified plans in-place for industrial development at several Phase III 

parcels. In addition, the Phase III parcels and associated sites are located in Greene Township, which prohibits 

residential use of the land in this area. Therefore, it is highly unlikely that the business park would close and that 

the land would convert to residential use in the future. 

6.2 GROUNDWATER USE 

When LEAD was first constructed, Rocky Spring served as the Depot’s water supply. In the 1950s a groundwater 

study prepared for the U.S. Army Corps of Engineers (USACE) concluded that there was not a viable source of 

groundwater available within LEAD boundaries to supply the Depot’s new industrial mission (Acker, 1995) due 

to insufficient well capacity to meet the Depot’s needs. LEAD subsequently built a 300-million-gallon reservoir in 

Roxbury that continues to serve as the Depot’s water supply. LIDA has extended the existing piped potable water 

supply system to the OVSA to service future development. The land will be part of the Cumberland Valley 

Business Park, and in accordance with Section 8.9,“Prohibited Uses,” of the business park’s Codes, Covenants, 

and Restrictions, one of the prohibited uses of the property is drilling for water. Also, under Section 85-52 of the 

Greene Township code entitled “Standards for Sewer and Water Systems,” Paragraph F, any new land 

development within 500 ft of an existing public water system is required to hook into the public water system. 

Currently, there are restrictions on the on-post groundwater at LEAD for the areas that are outside the Phase 

III/SMSR area (i.e., the groundwater is not used for drinking, irrigation, cooling, or any other purpose because of 

VOC contamination). 

The only use of groundwater in the area is off-post of LEAD, where some homes use individual water wells to 

supply their needs. Groundwater is also used off-post of LEAD as a water supply for livestock. Any homes on 

well water that exceeded the EPA regulatory value for VOCs, which is referred to as the maximum contaminant 

level (MCL), were initially supplied with bottled water, and later connected to public water. 
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No VOC contamination (that is, no concentrations higher than levels acceptable to EPA and PADEP) has been 

found in the groundwater at the Phase III properties. 

6.3 SURFACE-WATER USE 

There are no surface water bodies in the Phase III BRAC parcels; surface water is only present in drainage ditches 

during and after precipitation events. 

SECTION 7

SUMMARY OF SITE RISKS

The Army, EPA, and PADEP concluded that risks to people, plants, and animals from potential contact with soil 

and groundwater were acceptable for contaminants found in the SMSR groundwater (groundwater associated 

with the Phase III and Phase I parcels listed in this ROD) and in soils/sediments at the OVSA, Former Uncurbed 

AST North of Building 532, Backwash Discharge Area, or the Building 400 Series FTA sites and that no action is 

necessary to protect public health or welfare or the environment. For the OVSA site, this conclusion is based on 

the conditions of the site following the removal action that was performed in 2000 when PAH-contaminated soil 

was removed from the site. Remedial investigation/risk assessment reports for the sites (WESTON, 2002a, 2002b, 

2002c, 2003a), available in the Administrative Record, contain detailed descriptions of the risk assessments. Both 

ecological and human health risk assessments were included to address potential current and future risks to 

human health and the environment associated with environmental media (soil and groundwater) at the Phase III 

parcels. The text boxes in Subsection 7.1 explain the human health and ecological risk assessment process used 

for these sites. 

A screening level risk assessment process was used to evaluate risks to people, plants, and animals for the Phase 

III BRAC sites, including the SMSR groundwater. The screening level risk assessment process is a streamlined 

approach for identifying potential COCs and estimating potential risks at sites not known to or not expected to 

have widespread contamination. A human health screening level risk assessment compares the concentrations of 

hazardous substances in soil to chemical concentrations corresponding to fixed levels of risk, e.g., a lifetime 

cancer risk of one-in-one-million (1-in-1,000,000 or 1 x 10-6). Not as comprehensive as a baseline risk assessment, 

it nevertheless incorporates the principal technical elements of a baseline assessment. The Army, EPA Region III 

staff, and PADEP reviewed and agreed upon the screening level risk assessment methodology. The screening 

level approach is consistent with EPA policy, Land Use in the CERCLA Remedy Selection Process (Office of Solid 

Waste and Emergency Response [OSWER] Directive No. 9355.7-04, 25 May 1995) (EPA, 1995a). The CERCLA and 

screening level human health risk assessment approaches and summaries of the media-specific human health 

evaluations are described in the boxes in Subsection 7.1. 

The Phase III parcels and associated sites are all part of BRAC property with an intended future 

commercial/industrial reuse, as specified by the land reuse plan published by LIDA, the local development 

authority scheduled to receive the property. The BRAC property at LEAD is to be part of an already-established 

business park. In addition, the Phase III parcels and associated sites are located in Greene Township, which 

prohibits residential use of the land in this area. Therefore, it is highly unlikely that the business park would close 

and that the land would convert to residential use in the future. However, future residential land use was 

evaluated in the human health risk assessment. The following human health risk assessment summary focuses on 

the results of the residential scenario evaluation because this represented the highest risk for all sites relative to 

the other exposure scenarios evaluated. 
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7.1 SUMMARY OF HUMAN HEALTH RISKS 

7.1.1 Introduction and Overview 

A multi-step process was used in the screening level risk assessments that were performed for the SMSR 

groundwater (as reported in the OVSA remedial investigation/risk assessment) and soils for the four BRAC sites. 

The steps and the technical elements of each of those steps used in the baseline risk assessment and the screening 

level risk assessments are provided in the insets on the following pages. 

The human health risk assessment identified all chemicals found in concentrations that could cause cancer in 1 

out of 1,000,000 people (this means one additional chance in one million that a person will develop cancer if 

exposed to contaminated soil or groundwater). In addition, the risk assessment identifies whether or not these 

concentrations would result in harmful effects other than cancer by calculating hazard indices (HIs) for chemicals 

that do not cause cancer. A hazard index compares an existing amount of a chemical to an amount that might 

cause harmful noncancer health effects in people, again considering uncertainty in the risk assessment process 

and current and potential future land use. If the hazard index is greater than one, then there may be concern that 

harmful health effects (sickness) will occur in people. The assessment also considers uncertainty in the risk 

assessment process, which includes comparison to site background levels where available (e.g., for metals, which 

can be naturally occurring) as well as current and potential future land use. 

Human health risks were evaluated for exposures to contaminants (also referred to as chemicals of concern 

[COCs]). COCs are chemicals that are found in site media, such as soil, groundwater, or air, that are identified for 

further risk evaluation based on a number of factors. These factors include the chemical’s degree of toxicity, 

concentration, frequency of detection, and chemical properties important to the release, transport, and potential 

to come in contact with people. COCs are specific to each site and medium of concern (e.g., soil, air, 

groundwater). 

What Is a Human Health Risk Assessment and How is it Calculated? 

A CERCLA human health risk assessment estimates the “baseline risk.” This is an estimate of the likelihood of health problems 

occurring if no cleanup action were taken at a site. To estimate the baseline risk at a CERCLA site, the Army, EPA, and PADEP 

undertake a four-step process: 

Step 1: Analyze contamination 

Step 2: Estimate exposure 

Step 3: Assess potential health dangers 

Step 4: Characterize site risk 

In Step 1, the concentrations of contaminants found at a site, as well as past scientific studies on the effects these contaminants 

have had on people (or animals, when human studies are unavailable), are considered. Comparisons between site-specific 

concentrations and concentrations reported in past studies help determine which contaminants are most likely to pose the greatest 

threat to human health. 

In Step 2, the different ways that people might be exposed to the contaminants identified in Step 1, the concentrations that people 

might be exposed to, and the potential frequency and duration of exposure are considered. Using this information, a “reasonable

maximum exposure” (RME) scenario is calculated, which portrays the highest level of human exposure that could reasonably be 

expected to occur. 

In Step 3, the information from Step 2 is used in combination with information on the toxicity of each chemical to assess potential 

health risks. There are two types of risk: cancer risk and noncancer risk. The likelihood of any kind of cancer resulting from a 

CERCLA site is generally expressed as an upperbound probability; e.g., a “1-in-1,000,000 chance.” In other words, for every 

1,000,000 people that could be exposed, one extra cancer may occur as a result of exposure to site contaminants. An extra cancer 

case means that one more person could get cancer than would normally be expected to from all other causes. For noncancer health

effects, a hazard index is calculated. The key concept here is that a "threshold level” (measured usually as a hazard index of less 

than 1) exists below which noncancer health effects are no longer predicted. 

In Step 4, a determination is made on whether site risks are great enough to cause health problems for people at or near the 

CERCLA site. The results of the three previous steps are combined, evaluated, and summarized. The potential risks from the 

individual exposure pathways are added to provide the total risk.

The completion of the multi-step screening level risk assessment process and subsequent site-specific background 

(i.e., reference) data comparison is intended to provide the necessary information to facilitate a decision by the 

BRAC Cleanup Team to recommend site clearance or a more detailed investigation such as additional sampling 

or a baseline risk assessment. Acceptable levels of risk or exposure are explained in the inset on the following 

page. 
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What is a Screening Level Risk Assessment? 

The screening level risk assessment process is a streamlined approach for identifying potential contaminants of concern (COCs) and 

estimating health risks at sites not known or not expected to have widespread contamination. The first step (i.e., Level 1) determines 

the potential COCs by comparing maximum levels of chemicals found at the site to published (or calculated) risk-based screening

levels, also referred to as benchmarks or screening levels, developed for sites to be used for residential purposes. This method 

measures risks to human health by comparing concentrations of hazardous substances found at the site with theoretical 

concentrations developed by EPA and PADEP, which are considered to pose no unacceptable risk to human health. Chemicals that 

have maximum concentrations greater than the lowest benchmark are carried into the second step of the evaluation. Residentially

based benchmarks are more stringent and thus, more protective than those based on industrial use and, at the request of EPA 

Region III, are used to ensure that no potential COCs are overlooked. 

For sites that have chemicals exceeding the Level 1 screen, the assessment of potential health effects is refined in the second step 

(i.e., Level 2) by calculating estimates of the cancer and noncancer risks for those potentially exposed to contamination at the site. 

This is done by first determining the “exposure point concentration” for each chemical by statistically evaluating the site data. The 

exposure point concentration represents a concentration of chemicals(s) that a person at the site may be exposed to, in a worst

case. Then site-specific, risk-based health benchmarks are calculated based on specified risk level goals for each exposure 

scenario. This means that if a site user or worker were exposed to the chemical at levels greater than this calculated benchmark 

concentration, their health may be at risk at an unacceptable level. Exposure scenario refers to an evaluation of what types of people 

use the site, how people use the site now, and how they will use the site in the future, and ways in which they can be exposed to 

chemicals, such as ingestion of soil during lawn maintenance by a maintenance worker. The cancer and noncancer risks are then 

estimated with a calculation procedure that uses the exposure point concentration and the site-specific benchmarks. If the estimated 

risk is acceptable, then the parcel is deemed suitable for property transfer. 

If any chemicals exceed Level 2 benchmarks, the levels of those potential COCs at the site are compared statistically to levels of the 

chemicals found in areas not affected by past activities at the site (also referred to as site-specific “background”). If the values at the 

site are not statistically different from “background” concentrations, then it can be determined that detected levels of chemicals are 

not site-related. If the screening level risk assessment results determine that a parcel does not pose a threat to human health based 

on the present and intended future use or potential future use (i.e., commercial/industrial or residential), the parcel is deemed 

suitable for property transfer.

What are Acceptable Levels of Exposure ? 

Current Federal guidelines for acceptable exposures are: 

(1) an individual lifetime excess carcinogenic risk in the range of a one-in-ten-thousand (1-in-10,000 or 1 x 10-4) to onein-one-million (1-in-1,000,000 or 1 x 10-6); and (2) a maximum hazard index equal to 1.0 for noncancer (also referred to 

as noncarcinogenic) effects. A hazard index greater than 1.0 indicates a potential for noncancer effects.

7.1.2 Identification of Chemicals of Concern (COCs) 

Soil and drainageway samples collected at the OVSA, the Former Uncurbed AST North of Building 532, the 

Backwash Discharge Area, the Building 400 Series FTA sites, and groundwater samples from the SMSR (as 

reported in the OVSA remedial investigation/risk assessment) were included in the dataset used for the 

screening level risk assessment for each site. Sampling data were “validated,” which means subjected to a quality 

review, according to EPA Region III guidelines, which includes comparing to quality control samples such as 

blanks. Data that were rejected in the data validation were not used in the risk assessment. There were no COCs 

for any of the sites, based on current conditions. There were, however, chemicals of potential concern (COPCs) 

identified by comparing maximum soil/drainageway chemical concentrations to risk-based screening levels. 

These COPCs were then used for calculating estimated risk at the sites. Published screening values used for the 

screening level risk assessment follow; the assumptions for calculating these values are available in the citations 

listed. 

Adjusted EPA Region III Risk-Based Concentrations (U.S. Environmental Protection Agency, Risk-Based 

Concentration Tables, EPA Region III, Philadelphia, PA, April 2002): EPA Region III maintains a list of riskbased concentrations (RBCs) for chemicals in various media (e.g., soil, water, air) that correspond to a target 

cancer risk of 1 x 10-6 (1-in-1,000,000) or a target noncancer hazard quotient (HQ) (referred to as a hazard index 

when calculated for a site) of 1. For the purposes of identifying the COPCs, the residential soil ingestion riskbased concentrations were adjusted to reflect a risk-based screening concentration (i.e., RBSC). Risk-based 

screening concentrations for carcinogens were developed at a target risk of 1 x 10-6. For chemicals associated with 

noncancer health effects, the target hazard quotient was adjusted to 0.1, thus, lowering the noncancer risk-based 

concentration values presented in the risk-based table by an order of magnitude to address the additivity of 

noncancer effects when there is exposure to multiple chemicals. As noted in the EPA Region III risk-based 

concentration table, a concentration based on a 0.1 hazard quotient may be lower, and more protective, than a 
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concentration based on a target cancer risk of 1 x 10-6. In these cases, the lower and more protective concentration 

was used. 

EPA Site Screening Levels for VOCs and Particulate Inhalation (U.S. Environmental Protection Agency, 1996, Soil 

Screening Guidance: Technical Background Document, EPA/540/R-956/128, PB96-963502, Office of Solid Waste and 

Emergency Response, Washington, DC. May 1996; U.S. Environmental Protection Agency, Soil Screening Guidance: 

Technical Background Document and Soil Screening Guidance: User’s Guide, 9355-4.23, EPA/540/R-96/018, PB96-

963505, Office of Solid Waste and Emergency Response, Washington, DC, April 1996; and U.S. Environmental 

Protection Agency, Soil Screening Calculations, www.epa.gov/oerrpage/superfund/programs/risk/calc_sta.htm).: 

Soil screening levels (SSLs) for inhalation exposure to organic compounds (VOCs) and metals (particulates) from 

soil were calculated for all detected chemicals for each site using the EPA soil screening guidance calculations. 

The target risk and target hazard quotient are identical to those used in calculating risk-based screening 

concentrations. For the purposes of COPC screening, oral reference doses were extrapolated to the inhalation 

route when no inhalation toxicity criteria were available. 

Conventionally, inhalation soil screening levels were evaluated using the acceptabledaily intake approach, which uses the unitrisk 

factor or reference concentration values for an adult exposure. The inhalation soil screening level calculation method and input 

assumptions for cancer effects, as described in the EPA guidance, were modified at the request of EPA Region III to estimate values 

for the age-adjusted child and adult. EPA Region III requested that the Army estimate noncancer inhalation soil screening levels 

based on childhood exposure. Because the inhalation equations defined in the soil screening level guidance use unitrisk factoror 

reference concentration values, the calculation method was adjusted to reflect the child’s body weight and inhalation rate. 

The volatilization factors were estimated on a chemical-specific basis. The Harrisburg region was selected as the 

input value to the calculation for wind dispersion because this location is the one closest to Chambersburg, PA. 

EPA Soil Screening Levels for Protection of Groundwater (see EPA soil screening level citations listed 

previously): Soil screening levels for groundwater protection were calculated for all detected site chemicals. The 

conventional method of using the EPA maximum contaminant level (MCL), action level, or health-based limit in 

the EPA Soil Screening Guidance was modified by substituting these criteria with the EPA Region III tapwater riskbased concentrations at a target cancer risk of 1 x 10-6 or at an adjusted target hazard quotient of 0.1. A dilutionattenuation factor of 1 was used to achieve the most conservative soil screening level; this means that it is 

assumed that there is little dilution if a contaminant would migrate to groundwater. Default (or standard) inputs 

provided in the EPA guidance were used for all other values. Any chemical exceeding soil screening levels for 

groundwater protection were qualitatively evaluated in the screening level risk assessment for its potential 

impact on groundwater. 

PADEP Medium-Specific Concentrations (MSCs) (Commonwealth of Pennsylvania, Rules and Regulations, 

Title 25 – Environmental Protection, Environmental Quality Board [25 PA Code Chapter 250], Administration 

of the Land Recycling Program [Act 2], Pennsylvania Bulletin, Vol. 31, No. 47. 24 November 2001): If EPA 

Region III risk-based concentrations or soil screening levels were not available for a chemical, and a toxicity value 

for the chemical in question could not be obtained through the National Center for Environmental Assessment or 

other source provided by the EPA Region III toxicologist, then Pennsylvania Act 2 guidance was consulted for 

medium-specific concentrations for soil ingestion and inhalation of VOCs or particulates. Medium-specific 

concentrations are chemical-specific risk-based concentrations developed in a way similar to the EPA Region III 

risk-based concentrations. The medium-specific concentration tables are based on a target risk of 1 x 10-5 and a 

target hazard quotient of 1. For the purposes of the screening evaluation, the target risk was adjusted to 1 x 10-6, 

and the target hazard quotient adjusted to 0.1. The PADEP Act 2 guidance contains the calculation methods. 

Because EPA Region III does not recommend the use of PADEP benchmarks for COPC screening, any COPCs 

selected only as a result of medium-specific concentration comparisons are footnoted in the respective tables and 

discussed in the uncertainty analysis relative to their impacts on COPC selection. 

7.1.3 Site COPCs 

No COCs were identified for the OVSA site, based on post-removal-action confirmatory sampling data. Table 8

presents the COPCs (indicated by a “yes” in the COPC column), the minimum/maximum concentrations, and 

the frequency of detection for the COPCs for the OVSA based on the post-removal-action site conditions. Table 9

provides the exposure point concentrations for the OVSA COPCs. Exposure point concentrations are explained 

in more detail in Subsection 7.1.4. 
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Previously, before the soil removal action at the site, the OVSA investigations and screening level risk 

assessment showed possible risks (industrial exposure) associated with elevated levels of a group of SVOCs 

referred to as PAHs in soil. The COCs at that time were benz(a)anthracene, benzo(a)pyrene, 

benzo(b)fluoranthene, dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene. The screening level risk assessment 

conducted based on site conditions prior to the removal action are presented in the Engineering Evaluation/Cost 

Analysis for the Open Vehicle Storage Area Soils (WESTON, 2000a), which is available in the Administrative Record 

for LEAD. 

No COCs were identified for the Former Uncurbed AST North of Building 532, the Backwash Discharge Area, 

and the Building 400 Series FTA sites. Lists of the COPCs, the minimum/maximum concentrations, the frequency 

of detection for the COPCs, and EPCs for the COPCs are provided in Tables 10 through 15. 

For the SMSR, data from all of the wells drilled in the shale were used in the risk assessment. Therefore, all of the 

detected chemicals were considered COPCs for the purposes of calculation of risk and health effects. The 

summary of chemicals detected in the SMSR, frequency of detection, and EPCs are provided in Table 16. 

7.1.4 Exposure Assessment 

For the sites associated with the Phase III parcels, conceptual models of human exposure were developed that 

identified potential pathways by which exposure could occur and characterized the potentially exposed 

populations (e.g., workers and residents). These conceptual models are provided in Table 1 (OVSA/SMSR), Table 

3 (Uncurbed AST North of Building 532), Table 4 (Backwash Discharge Area), and Table 6 (Building 400 Series 

FTA). Under current conditions (present use scenario), potential exposure at the OVSA, Former Uncurbed AST 

North of Building 532, Backwash Discharge Area, or the Building 400 Series FTA sites is limited to workers 

engaged in property maintenance. Risks to current site workers were evaluated under the future 

commercial/industrial use scenario. 

The screening level risk assessments for the OVSA, the Former Uncurbed AST North of Building 532, the 

Backwash Discharge Area, the Building 400 Series FTA sites, and the SMSR study area (groundwater) included 

evaluating health effects for adult commercial/industrial workers and construction workers in a 

commercial/industrial setting, under the likely future use scenarios. In addition, other possible, but much less 

likely, scenarios were evaluated including an on-site resident. Under potential future site conditions, risks to 

workers and residents (children and adults) were quantitatively evaluated for exposures to surface soils, 

subsurface soils, and groundwater. The exposure routes evaluated were those that could result from current and 

future direct contact (incidental ingestion and dermal contact) with: (1) soil and sediment (e.g., children ingesting 

or having direct skin contact with soil or inhaling contaminated soil particles while playing in the area), and 

(2) groundwater (e.g., through ingestion and inhalation). In addition, the agricultural worker and off-site resident 

consuming beef and dairy products were evaluated for the Building 400 Series FTA site, and a recreational user 

(golfer) was evaluated for the OVSA site. 

For this assessment, it was assumed that commercial, industrial, and agricultural workers’ exposure to site soils 

would occur over a conservative period of 25 years, the assumed duration of employment at any one location. 

Construction workers’ exposures to soils were assumed to occur in a short-term (ranging from 3 months to 2 

years, depending on the size of the site) period of construction requiring excavation of soils. Exposure duration 

for residents was assumed to be 30 years (24 years adult, 6 years child). Exposure models and assumptions used 

to estimate exposure are provided in Subsection 5.2.4 of the remedial investigations/risk assessments. 

The exposure assessment uses exposure point concentrations, which are concentrations of a chemical in a given 

medium that a receptor may be exposed to at a specific location. The reasonable maximum exposure is the 

highest exposure that could reasonably be expected for a given pathway at a site and is intended to account for 

both uncertainty in the contaminant concentration and variability in the exposure parameters. To account for the 

uncertainty in the contaminant concentration, the 95% upper confidence limit (UCL) was calculated and used as 

the exposure point concentration. When the 95 % UCL exceeded the maximum value, the maximum chemical 

concentration was used. 

7.1.5 Toxicity Assessment 

In evaluating potential health risks, all exposure pathways were quantified for potential exposure and 

consequent risk by comparison to site-specific, risk-based health screening concentrations (RBSCs), also referred 

to as benchmarks, that were calculated based on specified risk level goals for each exposure scenario. The risk-
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based benchmarks were calculated using methods and toxicity data from EPA references similar to those used for 

a baseline risk assessment. Both cancer-causing and noncancer-causing effects from exposure to soil were 

considered in the risk assessment. 

The potential for producing cancer-causing effects is limited to those substances that have been shown to produce 

cancer in animals and/or humans. Excessive exposure to all substances, carcinogenic or not, can produce adverse 

noncancer health effects. Therefore, cancer slope factors were identified for those chemicals classified as 

carcinogens and reference doses, when available, were identified for every chemical selected regardless of its 

classification. Reference doses are used to evaluate the potential for adverse health effects from exposure to

COPCs exhibiting noncancer effects. 

7.1.5.1 Carcinogens 

EPA has developed cancer slope factors for estimating excess lifetime cancer risks associated with exposure to 

potentially carcinogenic COPCs. Cancer slope factors are derived from the results of human epidemiological 

studies or animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied. 

Cancer slope factors used in the screening level risk assessment were obtained from EPA’s Integrated Risk 

Information System (IRIS) database. Slope factors not available on IRIS were obtained from EPA’s second most 

current source of toxicity information, the Health Effects Assessment Summary Tables (HEAST). At this time, 

slope factors are not available for the dermal route of exposure. Dermal slope factors used in the assessment have 

been extrapolated from oral slope values used in this assessment. Cancer toxicity data used for the screening 

level risk assessments are provided in Table 17 (oral/dermal) and Table 18 (inhalation). 

7.1.5.2 Noncarcinogens 

EPA has developed media-specific reference doses for indicating the potential for adverse health effects from 

exposure to COPCs exhibiting noncancer effects. Reference doses are derived from human epidemiological 

studies or animal studies to which uncertainty factors have been applied. Reference doses used in the screening 

level risk assessments were obtained from EPA’s IRIS database. Reference doses not available on IRIS were 

obtained from EPA’s second most current source of toxicity information, HEAST. Noncancer toxicity data used 

for the screening level risk assessments are provided in Table 19 (oral/dermal) and Table 20 (inhalation). 

7.1.6 Risk Characterization 

The risk characterization presents the nature and the degree of the potential carcinogenic and noncarcinogenic 

(noncancer) risks posed to the current and future human health receptors presented previously in the exposure 

assessment. The cancer and noncancer toxicity data were used to calculate the risk-based screening 

concentrations. The algorithms and exposure inputs for the calculation of the risk-based screening concentrations 

for soil for residential use are presented in Tables 21 though 25, and for groundwater ingestion in Table 26. The 

cancer and noncancer risks are then estimated with a calculation procedure that uses the exposure point 

concentration and the site-specific benchmarks. 

Incremental lifetime cancer risks for soils and for groundwater were determined for each COPC by the following 

algorithm. Cancer risk for groundwater ingestion by the resident was determined individually for the child and 

the adult. 

Cancer risk = (EPC * 1 x 10-6) / (RBSC) 

Where: 

EPC = Exposure point concentration in soil (mg/kg) or groundwater (micrograms per liter 

[μg/L]). 

RBSC = Pathway-specific risk-based soil screening or groundwater benchmark (mg/kg or 

μg/L, respectively), target cancer risk of 1 x 10-6. 

The hazard quotients (HQs) for soils and for groundwater were determined for each COPC by the following 

algorithm. Systemic toxicity from groundwater ingestion by the resident was determined individually for the 

child and the adult. 
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HQ = (EPC * 0.1) / (RBSC)

Where: 

EPC = Exposure point concentration in soil (mg/kg) or groundwater (μg/L). 

RBSC = Pathway-specific risk-based soil screening or groundwater benchmark (mg/kg or 

μg/L, respectively), target hazard quotient (THQ) of 0.1. The term “THQ of 0.1” 

used here means that the RBSC is 1/10th of the number that would be considered a 

“safe dose” (below which no adverse health effects are likely to occur for a specific 

chemical). The lower “safe dose” value is used as a target “threshold value” to allow 

for the effects of multiple chemicals. Also note that the terms “hazard quotient” and 

“hazard index” are similar terms; the hazard index for a site is the sum of all hazard 

quotients. 

7.1.6.1 Estimated Risks and Health Effects 

The human health screening level risk assessment for the sites concluded that the lifetime excess cancer risks for 

the future adult/child resident from exposure to site-related chemicals evaluated in the risk assessment 

represented the highest risk for all sites relative to the other exposure scenarios evaluated (such as 

commercial/industrial worker, etc.). Therefore, the values for the resident are summarized in this ROD. The 

“residential” risks are age-adjusted to represent both the child and adult. The approximate lifetime excess cancer 

risks (rounded numbers) calculated for the resident for the study areas were as follows (media evaluated shown 

in parentheses): 3.37 x 10-5 for the OVSA site (soil/sediment); 2.4 x 10-5 for the Backwash Discharge Area 

(soil/sediment); 3.4 x 10-5 for the Building 400 Series FTA (soil); and 9.8 x 10-5 for the SMSR/OVSA 

(groundwater). 

Overall, these risks were primarily due to ingestion of soil or groundwater containing arsenic. Arsenic in soil and 

groundwater accounted for most of the total cancer risk for the future resident (as well as for the other potential

users of the sites at all of these study areas).The cancer risks and hazard index values for noncancer effects for the 

scenarios evaluated for each site are summarized in the inset tables provided on the following pages. The 

following discussion about “risk drivers” is based on the residential use scenario for each site. “Risk drivers” 

refers to chemicals that exceed the cancer point of departure (1 x 10-6) or the noncancer point of departure (hazard 

index of 1). 

For the OVSA site, the cancer risk drivers for soil/sediment were benzo(a)pyrene, dibenz(a,h)anthracene, and 

arsenic, with arsenic contributing the majority (68%) of the cancer risk. Arsenic was the only cancer risk driver for 

SMSA/OVSA groundwater. For the Backwash Discharge Area soil/sediment, the only cancer risk driver was 

arsenic. For the Building 400 Series FTA site, the cancer drivers for soil/sediment were benzo(a)pyrene and 

arsenic, with arsenic contributing the majority (94%) of the cancer risk. 

Tables with the summary of calculated cancer risks for these sites are provided as follows: Table 27 for 

soil/sediment for the OVSA site; Table 28 for the Backwash Discharge Area; Table 29 for the Building 400 Series 

FTA site; and Table 30 for SMSR/OVSA groundwater. Cancer risks were not calculated for the Former Uncurbed 

AST North of Building 532 because neither acetone nor lead has a verified cancer slope factor (meaning proven 

information does not currently exist to evaluate them as cancer-causing chemicals). In addition, acetone and lead 

were the only COPCs based on a comparison to health risk levels published by EPA and PADEP. A more 

detailed explanation of the evaluation of risk for the Former Uncurbed AST North of Building 532 site is available 

in Subsection 6.3.3.5 of the remedial investigation/risk assessment report (WESTON, 2002a). 

All of the calculated residential cancer risks are within EPA’s acceptable risk range for CERCLA, which is 10-6 to 

10-4, with one exception: the increased cancer risk for a future resident being exposed to both soils and 

groundwater at the SMSR/OVSA is approximately 1.31 x 10-4. This number is only slightly higher than the upper 

end of the CERCLA risk range. Arsenic is responsible for a significant portion of this increased cancer risk. 

However, the concentrations of arsenic in site soils were found to be statistically similar to concentrations of 

arsenic in background soil samples collected at LEAD. Therefore, the arsenic-related site risks for soil/sediment 

are reflective of a person being exposed to background levels that normally exist at LEAD. The CERCLA 

program generally does not attempt to clean up to levels below such background concentrations. Excluding 
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background arsenic concentrations, the sites/study areas do not pose unacceptable risks to people who are using 

the site or potentially may use the site in the future. Therefore, no further action is warranted under CERCLA. 

The calculated hazard index values for noncancer health effects for the future adult resident due to exposure to

chemicals in soil and groundwater at all of the study areas were either negligible (below the acceptable level of 1) 

or not at levels of concern. This indicates that adverse noncancer health effects are unlikely to develop as a result

of exposure through any of the pathways such as soil ingestion. The hazard index for the future child resident

were less than 1 (Former AST Uncurbed AST North of Building 532) or were approximately 3.8 to 5.9 (soil), 9.8 

(groundwater), or 13.98 (combined soil and groundwater value for OVSA/SMSR) for the various study areas. 

The following discussion about noncancer risk drivers is based on the residential use scenario. For the OVSA site, 

the noncancer risk driver for soil was iron (contributed a hazard quotient of 2 to the total hazard index number 

[HI]). For OVSA/SMSR groundwater, iron and manganese were the noncancer risk drivers (each have an HQ of 

4). Manganese and iron were also the noncancer risk drivers for the Backwash Discharge Area soil/sediment (HQ 

of 3 and 1.7, respectively) and the Building 400 Series FTA site (HQ of 1.02 and 1.7, respectively). 

Tables with the summary of calculated hazard indices for the residential scenario for these sites are provided as 

follows: Table 27 for soil/sediment for the OVSA site; Table 28 for the Backwash Discharge Area; Table 29 for the 

Building 400 Series FTA site; and Table 30 for SMSR/OVSA groundwater. Because the hazard index for the 

Former Uncurbed AST North of Building 532 site was so low for the construction worker and 

commercial/industrial worker (0.00000034 and 0.000000088, respectively), the hazard index for the resident was 

not calculated but rather was estimated at 0.0000023 based on a comparison of the exposure point concentration 

to the EPA Region III risk-based concentration (WESTON, 2002a). Although some of these values are greater than 

1, it was concluded in the screening level risk assessment, by way of the uncertainty analysis documented in the 

remedial investigation/risk assessments, that there are no significant health concerns at the Phase III sites. 

Examples of conclusions from the uncertainty analysis are that the concentrations of chemicals at the site were 

not statistically different from or were within the range of concentrations in background soil samples collected at

LEAD. The CERCLA program generally does not attempt to clean up to levels below such background 

concentrations. Also, in several cases, it was found that when segregating the hazard indices into the different

possible health effects and different parts of the body (referred to as a target endpoint analysis) that could be 

affected, there are no significant health concerns. The overall conclusion of the evaluation of noncancer risks 

showed that there are no significant health concerns expected at the sites for the potential future uses of

commercial/industrial or residential. 

Risks due to lead concentrations in soil were evaluated for the OVSA site where the maximum detected level in 

soil exceeded the CERCLA/Resource Conservation and Recovery Act corrective action level of 400 mg/kg, which 

was used to screen lead to determine if it was a COPC. The adult lead model, recommended by EPA, was used to 

calculate “preliminary remediation goals” to determine if concentrations of lead were at levels of concern. The 

soil lead preliminary remediation goals for the commercial/industrial and construction worker scenarios were 

1,338 and 343 mg/kg, respectively. Both the site soil average lead concentration (112 mg/kg) and the exposure 

point concentration (232 mg/kg) were below the calculated preliminary remediation goal. In addition, the site 

maximum lead concentration was less than the goal for the commercial/industrial worker. Therefore, from this 

evaluation it was concluded that lead in soil does not pose a significant health risk to the unborn child of a

commercial/industrial worker (woman of child-bearing age) through direct soil contact at the OVSA site. A leadin-soil evaluation model was not run for the future child resident because the average soil level and the site 

exposure point concentration were well below the CERCLA/Resource Conservation and Recovery Act corrective 

action level of 400 mg/kg. 

In addition to evaluating existing conditions, potentialfuture contamination of groundwater due to the chemicals in the 

subsurface soil possibly leaching out into the groundwater were evaluated. Various metals (i.e., iron, arsenic, manganese, 

chromium) and a few organic chemicals (i.e., carbazole, pentachlorophenol, and trichloroethylene, only at the OVSA) were the 

chemicals that had soil concentrations exceeding EPA groundwater protection “screening levels.” These screening levels are 

concentrations of chemicals in soil, above which there is the potentialfor a threatto groundwater atthe sites. Not all ofthese 

chemicals exceeded the screening values at every site. The screening levels were determined using EPA’s calculation 

procedure that incorporates possible cancer risks and noncancer health effects based on ingestion of drinking water. The results 

of the evaluation of soil screening levels (SSLs) for groundwater protection are provided as follows: Table 31 (OVSA); Table 32

(Former Uncurbed AST North of Building 532); Table 33 (Backwash Discharge Area); Table 34 (Building 400
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Summary of Risks and Hazards from Screening Level Risk Assessment 

Open Vehicle Storage Area and SMSR Groundwater 

Receptor Population/Exposure 

Medium Cancer Risk Noncancer Health Effects Risk

Resident: 

Soil/sediment 3.37 x 10-5 (age adjusted) 4.2a/0.59 (child/adult) 

Groundwaterb 9.76 x 10-5 (age adjusted) 9.8a (child) 

Cumulative risk (soil and 

groundwaterb) 

1.31 x 10-4 (age adjusted) 13.98a (child) 

Commercial/Industrial Worker: 

Soil/sediment 3.5 x 10-6 0.21 

Groundwater 2.7 x 10-5 1.4a

Cumulative risk (soil and 

groundwaterb)

3.05 x 10-5 1.61a

Construction Worker – Soil/sediment 1.1 x 10-6 0.89 

Golfer – Soil/sediment 1.4 x 10-7 0.0088 

a Note that the uncertainty analysis and the comparison of site data to LEAD reference (background soil) data reported were used to 

 formulate the conclusion that risks under this scenario are within acceptable levels. 

b Represents groundwater risk for entire SMSR/Phase III properties. 

Summary of Risks and Hazards from Screening Level Risk Assessment 

Backwash Discharge Area from the Water Treatment Plant Site 

Receptor Population/Exposure 

Medium Cancer Risk Noncancer Health Effects Risk

Resident - Soil/sediment 2.4 x 10-5 (age adjusted) 5.9*/0.9 (child/adult) 

Commercial/Industrial Worker—

Soil/sediment 

2.6 x 10-6 0.24 

Construction Worker – Soil/sediment 2.1 x 10-7 1 

*Note that the uncertainty analysis and the comparison of site data to LEAD reference (background soil) data reported were used

 to formulate the conclusion that risks under this scenario are within acceptable levels. 
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Summary of Risks and Hazards from Screening Level Risk Assessment 

Building 400 Series Fire Training Area 

Receptor Population/Exposure 

Medium Cancer Risk Noncancer Health Effects Risk

Resident – Soil/sediment 3.4 x 10-5 (age adjusted) 3.8*/0.5 (child/adult) 

Commercial/Industrial Worker - 

Soil/sediment 

3.7 x 10-6 0.15 

Construction Worker – Soil/sediment 3.0 x 10-7 0.62 

Agricultural Worker – Soil/sediment 1.2 x 10-5 1.7* 

Off-Site Beef/Milk Consumer - Soil 6.1 x 10-6 1.4* 

*Note that the uncertainty analysis and the comparison of site data to LEAD reference (background soil) data reported were used to 

 formulate the conclusion that risks under this scenario are within acceptable levels. 

Summary of Risks and Hazards from Screening Level Risk Assessment 

Former Underground Storage Tank North of Building 532 

Receptor Population/Exposure 

Medium Cancer Risk Noncancer Health Effects Risk

Resident - Soil Not calculateda 0.0000023b

Commercial/Industrial Worker - Soil Not calculateda 0.000000088 

Construction Worker - Soil Not calculateda 0.00000034 

a Cancer risks could were not calculated because proven information does not currently exist to evaluate acetone and lead (the only 

 COPCs) as cancer-causing chemicals. 

b Noncancer health effects for the residential scenario were estimated based on a comparison of the site exposure point concentration to 

 the EPA Region III risk-based concentration. 
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Series FTA, comparison to LEAD limestone background soils); and Table 35 (Building 400 Series FTA, 

comparison to LEAD shale background soils because the site contains soil types present both with shale and 

limestone bedrock conditions). The conclusion of this evaluation was that concentrations of chemicals in 

subsurface soil at the sites do not indicate a potential for significant impacts on groundwater. This conclusion 

was based on the uncertainty analysis documented in the remedial investigation/risk assessments. The 

uncertainty analysis concluded that many of the metals concentrations in site soil were not significantly different

from concentrations in background subsurface soil samples collected at LEAD, and that actual groundwater 

conditions indicated that these metals were not likely to migrate to the groundwater at levels of health concern. 

7.2 SUMMARY OF ECOLOGICAL RISKS 

For the sites with suitable wildlife habitat (the OVSA, Backwash Discharge Area, and the Building 400 Series 

FTA), an ecological risk assessment was performed to identify risks, if any, to plants and animals. Similar to the 

screening approach for the human health risk assessment, a screening level ecological risk assessment was 

completed, as described in the box on this page. Surface soil, surface drainageway soil, and sediment data were 

used in the ecological risk assessment. The data were reviewed for quality and used as described for the human 

health screening level risk assessment. The potential for plants and animals to be exposed to groundwater in the 

Phase III parcels is minimal. Groundwater does not come to the surface or discharge to surface streams, ponds, or 

wetlands in the Phase III parcels, and therefore, no pathway of exposure to plants and wildlife exists. Therefore, 

there is no ecological risk posed by contaminated groundwater to wildlife receptors that inhabit the Phase III 

parcels. 

The conceptual models showing the exposure pathways for the ecological exposure assessment are provided in 

Table 2 (OVSA), Table 5 (Backwash Discharge Area), and Table 7 (Building 400 Series FTA). The species of 

concern that were potentially applicable to all sites are listed in Table 36. The COPCs for the ecological risk 

assessment were identified, evaluated, and screened-out by comparison of the maximum detected concentrations 

and the exposure point concentrations to the published screening levels, and then by comparison to LEAD 

background samples, as shown for the OVSA, Backwash Discharge Area, and Building 400 Series FTA sites in 

Tables 37 through 46. Additional information pertaining to minimum concentrations, frequency of detection, 

mean, 95% UCL, and further evaluation of COPCs compared to expected levels of natural variation (defined as 

three times higher than background) are provided in the remedial investigation/risk assessment reports. Also, 

additional detailed evaluations pertaining to point-by-point evaluations of sediment samples and surface water 

samples are provided in the remedial investigations/risk assessments. 

The ecological risk assessments for the sites within the Phase III parcels determined that the potential risks to 

plants and animals at the sites that are within the Phase III parcels were within acceptable levels based on the 

intended future commercial/industrial use. 

7.2.1 OVSA Site 

The overall conclusion of the screening level ecological risk assessment is that the majority of chemicals in OVSA surface 

soils, sediments, and surface water do not pose a significant risk to terrestrial and aquatic ecological receptors at the site.

However, the screening level ecological risk assessment indicated that PAHs in surface soils pose a low level risk to 

mammals at the site. Given the historical use of the site as a vehicle storage area, levels of PAHs are likely to be 

attributable to historical use. The evaluation of PAHs was based on a single Region III BTAG benchmark (0.1 mg/kg) 

developed for mice for a single compound (benzo[a]pyrene) and this benchmark was applied to all PAHs. In addition, 

the screening level ecological risk assessment indicated that five metals (antimony, cadmium, lead, mercury, and silver) 

were present in concentrations in surface soils and two metals in sediments (aluminum and zinc) that were higher than 

expected levels of natural variation in the reference soils and sediments, respectively. An evaluation of the ecological 

significance of these metal concentrations was conducted that considered affected classifications of plants/animals and 

frequency of exceedances. This ecological significance evaluation concluded that only levels of cadmium and zinc pose a 

potentially ecologically significant level of risk at the site. Concentrations of antimony, lead, mercury, and silver above 

natural levels were spatially limited. Concentrations of cadmium above natural levels of variation were present 

throughout the site and are expected to pose a low-level risk to plants, birds, and mammals. Localized levels of zinc in the 

vicinity of sample 57SD04 located in the western OVSA may pose a risk to benthic organisms. Note that the site will be 

part of the Cumberland Valley Business Park, and future development of this site for commercial/industrial use will 
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What is a Screening Level Ecological Risk Assessment?

The screening level ecological risk assessment is based on the first steps of a full ecological risk assessment normally done for 

CERCLA sites. Ecological risk assessments provide an understanding of a site in terms of environmental setting, pathways of 

contaminant movement, and potential risks to plants and animals. This understanding can be used to help decide what actions, or lack 

of action, may be appropriate for managing ecological resources at a site.

The screening level ecological risk assessment evaluates the contaminants to determine if they are at levels that may cause potential 

harmful effects on the plants and animals at a site. In addition, the screening level ecological risk assessment is used to determine if 

additional ecological evaluation is needed to support a risk management decision or possibly a baseline ecological risk assessment. 

The first step is to describe the site, including plants and animals that live there, and how they may be exposed to contaminants from 

the site. Detected concentrations are compared to EPA’s Biological Technical Assistance Group (BTAG) screening levels as well as 

other published screening levels as agreed to between the Army and EPA from Oak Ridge National Laboratory (“Level 1”), to 

determine COPCs. Then, the exposure point concentration for contaminants carried from Level 1 is compared to the screening levels. 

If there are still COPCs at this point, then statistical and qualitative reference soil comparisons are performed. The screening level 

ecological risk assessment includes an uncertainty analysis discussion that describes any uncertainties pertaining to natural system 

variability, media sampling, data evaluation and reduction, target receptor selection, and exposure assumptions. After discussing

general uncertainties associated with the risk assessment process, uncertainties specific to the individual benchmarks and their 

derivation and applicability are presented. 

result in the removal of some or the entire limited habitat that currently supports the ecological resources that 

were evaluated in the screening level ecological risk assessment process. To the extent that the habitat changes, 

the effect of any chemical contamination in soils on plants and wildlife will also be altered due to changes in 

exposure potential.

7.2.2 Backwash Discharge Area 

Surface soils and drainageway sediments were evaluated as part of the screening level ecological risk assessment 

process for the Backwash Discharge Area site. The screening level ecological risk assessment for the Backwash 

Discharge Area site is limited to an evaluation of metals because metals are the only chemicals associated with 

the Backwash Discharge Area and originated from the potable water treatment plant. The weight of evidence, 

which includes a review of the soil and sediment data and ecological benchmarks, indicated that the potential 

impacts associated with exposure to elevated concentrations of the majority of metals in Backwash Discharge 

Area site drainageways are expected to be minor. Potential exposure to manganese and silver at some locations 

in the drainageways may pose a risk to benthic invertebrates inhabiting these areas. Lastly, the development of 

this site for commercial/industrial use will result in the removal of some or all of the habitat that currently 

supports the ecological resources that were evaluated in the screening level ecological risk assessment process. 

The intended future use plan for the Backwash Discharge Area site is development as part of the Cumberland 

Valley Business Park. To the extent that the habitat changes, the effect of any chemical contamination in soils on 

plants and wildlife will also be altered due to changes in exposure potential. The overall conclusion of the 

screening level ecological risk assessment is that Backwash Discharge Area site soils and sediment do not pose a 

significant risk to ecological receptors. 

7.2.3 Building 400 Series Fire Training Area 

The overall conclusion of the screening level ecological risk assessment is that the Building 400 Series FTA soils 

do not pose a significant risk to ecological receptors. Four organic compounds had exposure point concentrations 

that exceeded the lowest available ecological screening level value: bis(2-ethylhexyl)phthalate, fluoranthene, 

2,3,7,8-tetrachlorinated dibenzo-p-dioxin total equivalent concentration (2,3,7,8-TCDD TEQ — note: this number 

is used to represent a group of various chemical compounds known as polychlorinated dibenzo-p-dioxins/ 

polychlorinated dibenzofurans [PCDDs/PCDFs] also referred to as “dioxin/furan congeners”) for mammals, and 

2,3,7,8-TCDD TEQ for birds. Concentrations of bis(2-ethylhexyl)phthalate may pose low level risk to birds and 

mammals at the site. However, the absence of other phthalate chemical compounds at the site suggests that 

concentrations of bis(2-ethylhexyl)phthalate may not be site-related and may be due to common contamination at 

the laboratory where the samples were analyzed. Exposure to fluoranthene, a PAH, is not expected to pose a risk 

to organisms at the site because the exposure point concentration only slightly exceeded the benchmarks (at 1.2 

times higher) and concentrations of all other detected PAHs were less than benchmarks. 

Based on a comparison to no-observed-adverse-effect level (NOAEL)-based screening criteria, concentrations of 

dioxin/furan congeners are expected to pose a low level of risk to ground-foraging mammals and birds at the 

site. The ecological significance of the exposure to dioxins/furans is uncertain, although it is expected to be low. 

The isolation of this habitat from similar adjacent habitats may limit the amount of small mammals migrating to 

the local area required to replenish the mammals if the mammals already in the local area reproduce less. 
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Consequently, the structure and function of the small mammal community may exist below its biotic potential. 

However, the limited quality of this habitat suggests that the ecological significance of these results to a 

population of ground-foraging small mammals is low. 

Of the 22 inorganic chemicals evaluated, 16 metals had exposure point concentrations that exceeded their lowest 

respective ecological benchmarks. However, statistical and qualitative comparisons between Building 400 Series 

FTA surface soil concentrations and reference surface soil concentrations indicated that the site concentrations of 

all metals except copper were similar to reference soil levels. While the maximum soil concentration of copper at 

several locations was greater than 3x the limestone reference soil maximum (expected natural variation), all 

Building 400 Series FTA samples had copper concentrations less than 3 times the shale reference soil maximum 

value. Consequently, the risk associated with exposure to the majority of metals at the site may not be 

attributable to previous site activities. 

Based on a comparison of ecological benchmarks and statistical and qualitative comparisons to reference soils, 

copper may pose a low-level risk to ecological receptors at the site. The exposure point concentration of copper 

(33.9 mg/kg) exceeded a single benchmark, a Region III BTAG screening value of 15 mg/kg. The exposure point 

concentration of copper did not exceed Oak Ridge National Laboratory (ORNL)-derived benchmark values for 

plants, soil invertebrates, soil microbes, mammals, or birds. Given that the exposure point concentration of 

copper only had an ecological effects quotient (EEQ) of 2.05 (EPC is 2 times the lowest benchmark), and that 

copper concentrations only exceeded a single benchmark, the ecological risk associated with exposure copper is 

expected to be low. 

Lastly, note that the development of this site for commercial/industrial use will result in the removal of some or 

all of the habitat that currently supports the ecological resources that were evaluated in the screening level risk 

assessment process. The intended future use plan for the Building 400 Series FTA is development as part of the 

Cumberland Valley Business Park. To the extent that the habitat changes, the effect of any chemical 

contamination in soils on plants and wildlife will also be altered due to changes in exposure potential.

7.3 UNCERTAINTY ANALYSIS 

Virtually every step in the risk assessment process requires a number of assumptions, all of which contribute to 

uncertainty in the assessment of risk. In the absence of site-specific information, assumptions are developed 

based on “best estimates” of data quality (e.g., are there enough samples?), exposure parameters (e.g., how often 

would a worker contact the soil outside the building in which he works?), and toxicity information (how valid is 

the extrapolation of toxicity data taken from rat studies to humans?). To assist in the development of these 

estimates, EPA has developed and recommends the use of “standard” factors that are designed to promote 

consistency in risk assessments and provide a plausible estimate of the risk. In the absence of site-specific 

information (please note that much of this assessment was performed for workers who may use these sites in the 

future), the risk assessments conducted here used EPA’s “standard” (also known as “default”) assumptions. The 

extent to which these factors accurately predict risk depends on how close they are to site-specific conditions. 

In the presence of such uncertainty, 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 risk assessment for the Phase III parcels. 

7.4 CORRECTION OF MINOR ERROR IN PROPOSED PLAN RISK SUMMARY 

There was a minor change in the calculated soil risk numbers for the residential scenario for the OVSA when 

comparing the numbers published in the Proposed Plan to those listed in this ROD. The risk assessment 

conclusions for the OVSA did not change and the selected remedy did not change (i.e., no further action is 

necessary to protect public health or welfare or the environment). These number differences are described in 

more detail in the following paragraph/table. 

The soil risk numbers for the residential scenario for the OVSA were calculated for only the eastern part of the 

OVSA site and did not include the western area where the removal action was completed. Therefore, the soil risk 
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numbers for the residential scenario were published in error in the final remedial investigation/risk assessment 

and the Proposed Plan for the Phase III parcels. The correct entire dataset was used for the residential scenario 

evaluation in the draft remedial investigation/risk assessment, thus, EPA and PADEP did review the calculations 

and results based on the entire site dataset. The following table shows that the risk numbers with and without the 

western half of the site are very close and that the same conclusion would be reached for either set of numbers. 

This issue affected the cumulative risk numbers reported for the residential scenario. When the residential risk 

assessment for the OVSA was updated at the draft-final/final stage to incorporate the latest EPA Region III RBC 

update (as is normally done at that stage if a new version of the RBCs are published between the draft and draftfinal date) the calculation tables were mistakenly linked to the dataset for only the eastern side of the site instead 

of the entire site dataset (eastern and western side confirmation samples from the removal action). 

Summary of Minor Risk Error and Correction 

Item 

Final OVSA Remedial 

Investigation/Risk 

Assessment and Proposed 

Plan (April 2003) Revised Final Numbers

Dataset Eastern side only. Eastern and western sides of 

site including confirmation 

samples. 

What was done Revised per October 2002 

RBC update but linked 

calculation tables to 

eastern data only by 

mistake. 

Added back data from western 

side, updated per October 2002 

RBC update. 

Age-adjusted cancer risk* 3.13E-05 3.37E-05 

Noncancer risk, child* 5.26 4.2 

Noncancer risk, adult 0.76 0.59 

1.29E-04 (age adjusted 

cancer) 

1.31E-04 (age adjusted 

cancer) 

Cumulative risk (soil and 

groundwater)* 

15.04 (child noncancer) 13.98 (child noncancer)

* Note that the uncertainty analysis and the comparison of site data to LEAD reference (background soil) 

data reported in the remedial investigation/risk assessment were used to formulate the conclusion that 

risks under the residential scenario are within acceptable levels. 

SECTION 8 

SELECTED REMEDY 

 The Army and EPA, in consultation with PADEP, have determined that no further action is necessary under 

CERCLA for soils and groundwater at these sites in the Phase III parcels. No further action under CERCLA is 

necessary to protect human health or the environment at the Phase III parcels and associated sites under the 

current and reasonably anticipated future use of the property. The Phase III parcels and associated sites will be 

left as is and no costs will be associated with implementing a remedy there. 

This no further action decision applies to: 

 SMSR groundwater (PDO OU 7 and SE OU 13). 

 OVSA site (part of BRAC waste site OUs PDO OU 6 and SE OU 8). 
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 Former Uncurbed AST North of Building 532 site (part of PDO OU 6). 

 Backwash Discharge Area from the water treatment plant site (part of SE OU 8). 

 Western portion of the Building 400 Series FTA site (part of SE OU 8). 

The specific areas affected by the selected alternative are referred to as Parcels 3-89, 3-90, 3-91, 2-53L, 2-54L, 2-

70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3 (note that the “L” after the parcel number refers to the lower part of the 

Phase II parcel that includes groundwater), as well as groundwater associated with previously transferred Phase 

I parcels identified as Parcels 24, 27, and 28. 

SECTION 9 

DOCUMENTATION OF SIGNIFICANT CHANGES

There were no significant changes made in this ROD for the selected remedy identified in the Proposed Plan. 
Tables

03P-0752
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TABLES 
Table 1

RAGS Part D, Table 1,

Selection of Exposure Pathways,

Open Vehicle Storage Area- DSERTS Site LEAD 114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Medium Exposure Exposure Receptor Receptor Exposure On-Site/ Type of 

Timeframe Medium Point Population Age Route Off-Site Analysis 

Future Soil Soil Contaminants are in soil and exposure to soil is evaluated Commercial/Industrial Worker Adult Ingestion On-Site Quantitative W

Dermal Contact On-Site Quantitative WInhalation On-Site Quantitative WInhalation On-Site Quantitative W

Construction Worker Adult Ingestion On-Site Quantitative W

Dermal Contact On-Site Quantitative WInhalation On-Site Quantitative WInhalation On-Site Quantitative W

Golfera Adult Ingestion On-Site Qualitative G

Dermal Contact On-Site Qualitative GInhalation On-Site Qualitative GInhalation On-Site Qualitative G

Resident Child Ingestion On-Site Quantitative C

Dermal Contact On-Site Quantitative CInhalation On-Site Quantitative CInhalation On-Site Quantitative C

Adult Ingestion On-Site Quantitative A

Dermal Contact On-Site Quantitative AInhalation On-Site Quantitative AInhalation On-Site Quantitative A

Groundwater Groundwater Tap water Resident Child Ingestion On-Site Quantitative C

Inhalation On-Site Quantitative C

Adult Ingestion On-Site Quantitative A

Inhalation On-Site Quantitative A

a Assumed to be the commercial / industrial worker (see Subsection 6.3.5 of RI/RA)

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 1 T-1 
Table 2

Site Conceptual Model,

Ecological Exposure Pathways of Concern,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Source and Transport of 

Chemical Release Habitat Type/Name Exposure Medium

Sensitive 

Environment 

Flag

(Y or N)

Exposure Scenario Description Assessment Endpoints

Endangered 

Threatened 

Species Flag

(Y or N)

Exposure 

Routes

Soil Wooded Area Soil N Direct exposure to plants Survival, growth, and reproduction of plant community. N Direct contact with soils, up

from soils. 

and

Meadows

Direct exposure to soil Survival, reproduction, and N Ingestion and direct contac

invertebrates growth of soil invertebrate with soils. 

community. 

Direct exposure to small mammals Survival, reproduction, and N Ingestion and direct contac

growth of small mammal with soils.

community.

Direct exposure to birds Survival, reproduction, and N Ingestion and direct contac

growth of avian community with soils.

Indirect exposure to herbivorous Survival, reproduction, and N Ingestion of plants and gras

small mammals through plant uptake growth of small mammal

and consumption community.Indirect exposure to Survival, reproduction, and N Ingestion of worms, insects

insectivorous and carnivorous growth of insectivorous small mammals.

mammals through trophic transfer and carnivorous mammals.Indirect exposure to Survival, reproduction, and N Ingestion of worms, insects

insectivorous and carnivorous growth of insectivorous small mammals.

birds through trophic transfer and carnivorous birds.

Sediments Drainageway Sediment N

Direct exposure to plants. Survival, growth, and reproduction of aquatic plant community. N Direct contact with sedimen

uptake from sediments. 

Direct exposure to Survival, reproduction, and N Direct contact with sedimen

benthic invertebrates. growth of aquatic invertebrate uptake from sediments. 

community.

Surface Water Drainageway Surface water N Direct exposure to plants. Survival and growth of aquatic plant community. N Direct contact with surface 

uptake from surface water. 

Direct exposure to aquatic Ninvertebrates and benthic invertebrates.

Survival, reproduction, andgrowth of benthic invertebrates.

Ingestion and direct contacwith soils. 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 2 T-2 
Table 3

RAGS Part D, Table 1,

Selection of Exposure Pathways,

Uncurbed AST North of Building 532, DSERTS Site LEAD-126, PDO OU 6,

 Letterkenny Army Depot,

Chambersburg, PA

Scenario Exposure Exposure Receptor Receptor Exposure On-Site/ Type of 

Timeframe Medium Medium Point Population Age Route Off-Site Analysis 

Future Soil Soil Contaminants are in soil and exposure to soil is evaluated Commercial/Industrial Worker Adult Ingestion On-site Quantitative Wor

Dermal contact On-site Quantitative WorInhalation On-site Quantitative WorInhalation On-site Quantitative Wor

Construction Worker Adult Ingestion On-site Quantitative Wor

Dermal contact On-site Quantitative WorInhalation On-site Quantitative WorInhalation On-site Quantitative Wor

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 3 T-3 
Table 4

RAGS Part D, Table 1,

Selection of Exposure Pathways,

Backwash Discharge Area (DSERTS Site LEAD-011) - Letterkenny Army Depot - Chambersburg, PA

Scenario Medium Exposure Exposure Receptor Receptor Exposure On-Site/ Type of 

Timeframe Medium Point Population Age Route Off-Site Analysis 

Future Soil Soil Contaminants are in soil and exposure to soil is evaluated Commercial/Industrial Worker Adult Ingestion On-Site Quantitative Wo

Dermal Contact On-Site Quantitative WoInhalation On-Site Quantitative WoInhalation On-Site Quantitative Wo

Construction Worker Adult Ingestion On-Site Quantitative Wo

Dermal Contact On-Site Quantitative WoInhalation On-Site Quantitative WoInhalation On-Site Quantitative Wo

Resident Adult Ingestion On-Site Quantitative Res

Dermal Contact On-Site Quantitative ResInhalation On-Site Quantitative ResInhalation On-Site Quantitative Res

Child Ingestion On-Site Quantitative Res(1-6 years) Dermal Contact On-Site Quantitative Res

Inhalation On-Site Quantitative ResInhalation On-Site Quantitative Res

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 4 T-4 
Table 5

Site Conceptual Model,

Ecological Exposure Pathways of Concern,

Letterkenny Army Depot,

Chambersburg, PA

Source and Transport of 

Chemical Release Habitat Type/Name Exposure Medium

Sensitive 

Environment 

Flag 

(Y or N)

Exposure Scenario Description Assessment Endpoints

Endangered 

Threatened 

Species Flag 

(Y or N)

Exposure 

Routes

Soil Field Soil N Direct exposure to Survival, growth, and reproduction N Direct contact with soils, 

plants of plant community. from soils.

Direct exposure to Survival, reproduction, and N Ingestion and direct contasoil invertebrates growth of soil invertebrate with soils. 

community. 

Direct exposure to Survival, reproduction, and N Ingestion and direct contasmall mammals growth of small mammal with soils.

community.

Direct exposure to Survival, reproduction, and N Ingestion and direct contabirds growth of avian community. with soils.Indirect exposure to herbivorous Survival, reproduction, and N Ingestion of plants and grsmall mammals through plant uptake growth of small mammaland consumption community.Indirect exposure to Survival, reproduction, and N Ingestion of worms, insecinsectivorous and carnivorous growth of insectivorous small mammals.mammals through trophic transfer and carnivorous mammals.Indirect exposure to Survival, reproduction, and N Ingestion of worms, insecinsectivorous and carnivorous growth of insectivorous small mammals.birds through trophic transfer and carnivorous birds.

Sediments Drainageway Sediment N Direct exposure to plants. Survival, growth, and reproduction N Direct contact with sedim

of aquatic plant community. 

Direct exposure to Survival, reproduction, and N Direct contact with sedimbenthic invertebrates. growth of aquatic invertebrate uptake from sediments. 

community.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 5 T-5 
Table 6

RAGS Part D, Table 1,

Selection of Exposure Pathways,

Building 400 Series Fire Training Area - DSERTS Site LEAD-118, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Medium Exposure Exposure Receptor Receptor Exposure On-Site/ Type of 

Timeframe Medium Point Population Age Route Off-Site Analysis 

Future Soil Soil Contaminants are in soil and exposure to soil is evaluated Commercial/Industrial Groundskeeper Adult Ingestion On-Site Quantitative Wor

Dermal Contact On-Site Quantitative WorInhalation On-Site Quantitative WorInhalation On-Site Quantitative Wor

Construction Worker Adult Ingestion On-Site Quantitative Wor

Dermal Contact On-Site Quantitative WorInhalation On-Site Quantitative WorInhalation On-Site Quantitative Wor

Agricultural Worker (1) Adult Ingestion On-Site Quantitative Farm

Dermal Contact On-Site Quantitative FarmInhalation On-Site Quantitative FarmInhalation On-Site Quantitative Farm

Future Soil Beef and Dairy Milk Contaminants are in soil and ingestion of beef and dairy Beef/Milk Consumer (2) Child Ingestion Off-Site Quantitative Bee

milk is evaluated grow

Adult Ingestion Off-Site Quantitative Bee

grow

(1) Agricultural RBSCs for direct contact (As-RBSCs) will be compared to the maximum chemical concentrations in soil.

(2) Agricultural RBSCs for organic chemicals with bioaccumulation potential (ABM) will be compared to the maximum chemical concentration in soil. 

If these chemicals have bioaccumulation potential, they will be evaluated quantitatively based on future agricultural use.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 6 T-6 
Table 7

Site Conceptual Model,

Ecological Exposure Pathways of Concern,

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Source and Transport of 

Chemical Release Habitat Type/Name Exposure Medium

Sensitive 

Environment 

Flag 

(Y or N)

Exposure Scenario Description Assessment Endpoints

Endangered 

Threatened 

Species Flag 

(Y or N)

Exposure 

Routes

Soil Fallow field Soil N Direct exposure to Survival, growth, and reproduction N Direct contact with soils, 

plants of plant community. from soils.

Direct exposure to Survival, reproduction, and N Ingestion and direct contasoil invertebrates growth of soil invertebrate with soils. 

community. 

Direct exposure to Survival, reproduction, and N Ingestion and direct contasmall mammals growth of small mammal with soils.

community.

Direct exposure to Survival, reproduction, and N Ingestion and direct contabirds growth of avian community. with soils.Indirect exposure to herbivorous Survival, reproduction, and N Ingestion of plants and grsmall mammals through plant uptake growth of small mammaland consumption community.Indirect exposure to Survival, reproduction, and N Ingestion of worms and ininsectivorous and carnivorous growth of insectivorousmammals through trophic transfer and carnivorous mammals.Indirect exposure to Survival, reproduction, and N Ingestion of worms and ininsectivorous and carnivorous growth of insectivorousbirds through trophic transfer and carnivorous birds.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 1-7 concep models\Tab 7 T-7 
Table 8

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Open Vehicle Storage Area, DSERTS Site LEAD-114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Medium: Soil (All Depths)Exposure Medium: SoilExposure Point: Contaminants are in soil and exposure to soil is evaluated.

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)

Po

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value ARA

 Concentration Limits Screening V

540590 1,2-Dichloroethene, Total 0.003 J 0.003 J mg/kg 57TP58B002 1/99 0.01-0.027 0.003 N/A 5.70 N 

78933 2-Butanone 0.007 J 0.010 J mg/kg 57TP59B002 2/99 0.01-0.027 0.01 N/A 0.039 N 67641 Acetone 0.006 J 0.092 mg/kg 57TP59B002 10/99 0.01-0.027 0.092 N/A 0.012 N 

100414 Ethylbenzene 0.002 J 0.002 J mg/kg 57TP61B003 1/99 0.01-0.027 0.002 N/A 0.0021 C 

79016 Trichloroethene 0.003 J 0.003 J mg/kg 57TP61B102 1/99 0.01-0.027 0.003 N/A 0.000011 C 

1330207 Xylenes, Total 0.005 J 0.006 J mg/kg 57TP62B002 2/99 0.01-0.027 0.006 N/A 1.03 N 

120821 1,2,4-Trichlorobenzene 0.087 J 0.087 J mg/kg 57TP58B002 1/144 0.049-0.47 0.087 N/A 0.003 N 121142 2,4-Dinitrotoluene 0.082 J 0.19 J mg/kg 57TP58B001 2/144 0.19-1.1 0.19 N/A 0.00003 C 

95578 2-Chlorophenol 0.12 J 0.12 J mg/kg 57TP58B002 1/144 0.047-0.47 0.12 N/A 0.003 N 91576 2-Methylnaphthalene 0.013 J 5.6 mg/kg CD29A 24/249 0.029-1.8 5.6 N/A 156 N 59507 4-Chloro-3-Methylphenol 0.051 J 0.051 J mg/kg 57TP58B002 1/144 0.19-1.1 0.051 N/A 1,100 G 

100027 4-Nitrophenol 0.33 J 0.33 J mg/kg 57TP60B002 1/144 0.032-1.2 0.33 N/A 0.0084 N 

83329 Acenaphthene 0.034 27 mg/kg CD29A 39/249 0.029-1.8 27 N/A 0.37 N 

208968 Acenaphthylene 0.045 J 1.4 mg/kg CD29A 14/249 0.015-1.8 1.4 N/A 1,300 N 120127 Anthracene 0.025 70 mg/kg CD29A 67/249 0.026-1.1 70 N/A 8.61 N 

56553 Benz[a]anthracene 0.036 J 1.9 mg/kg 57TP67B001 49/144 0.036-0.47 1.9 N/A 0.048 C 50328 Benzo[a]pyrene 0.029 1.9 mg/kg 57TP67B001 45/144 0.024-0.47 1.9 N/A 0.018 C 

205992 Benzo[b]fluoranthene 0.029 J 2.8 mg/kg 57TP67B001 57/144 0.038-0.47 2.8 N/A 0.15 C 191242 Benzo[ghi]perylene 0.021 J 1.2 mg/kg 57TP67B001 42/144 0.049-0.47 1.2 N/A 235 N 207089 Benzo[k]fluoranthene 0.018 J 0.91 mg/kg 57TP03B005 38/144 0.034-0.47 0.91 N/A 1.53 C 117817 Bis(2-Ethylhexyl) Phthalate 0.022 J 0.7 mg/kg 57TP14B001 69/144 0.035-0.9 0.7 N/A 1.06 C 

86748 Carbazole 0.034 J 41 mg/kg CD29A 55/249 0.17-1.8 41 N/A 0.0082 C 

218019 Chrysene 0.024 J 99 mg/kg CD29A 127/249 0.037-1.1 99 N/A 5.45 C 

53703 Dibenz[a,h]anthracene 0.029 J 0.36 J mg/kg 57TP67B001 15/144 0.04-0.47 0.36 N/A 0.033 C 

132649 Dibenzofuran 0.043 J 0.63 mg/kg 57TP03B005 8/144 0.19-1.1 0.63 N/A 31.3 N 

84742 di-n-Butyl Phthalate 0.026 J 0.12 J mg/kg 57TP35B002 6/144 0.19-1.1 0.12 N/A 1.22 N 

206440 Fluoranthene 0.027 J 260 mg/kg CD29A 158/249 0.032-1.1 260 N/A 14.4 N 

86737 Fluorene 0.030 J 41 mg/kg CD29A 39/249 0.033-1.8 41 N/A 0.38 N 

193395 Indeno[1,2,3-cd]pyrene 0.022 J 1.4 mg/kg 57TP67B001 43/144 0.046-0.47 1.4 N/A 0.75 C 

91203 Naphthalene 0.042 J 26 mg/kg CD29A 28/249 0.048-1.8 26 N/A 0.0017 N 

621647 n-Nitrosodi-n-Propylamine 0.042 J 0.042 J mg/kg 57TP58B001 1/144 0.19-1.1 0.042 N/A 0.0000022 C 

87865 Pentachlorophenol 0.31 J 0.5 J mg/kg 57TP59B002 2/144 0.04-1.2 0.5 N/A 0.00068 C 85018 Phenanthrene 0.043 J 260 mg/kg CD29A 129/249 0.036-1.1 260 N/A 6,600 N 

108952 Phenol 0.082 J 0.14 J mg/kg 57TP58B002 2/144 0.035-0.47 0.14 N/A 0.27 N 129000 Pyrene 0.036 J 220 mg/kg CD29A 151/249 0.041-1.1 220 N/A 2.49 N 319846 alpha-BHC 0.0011 J 0.0011 J mg/kg 57DS04D001 1/3 0.00056-0.00063 0.0011 N/A 0.00004 C 

57749 alpha-Chlordane 0.0085 J 0.0085 J mg/kg 57DS04D001 1/3 0.00056-0.00063 0.0085 N/A 0.02 C 

Future Resident Screen

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 8 T-8 
Table 8

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Open Vehicle Storage Area, DSERTS Site LEAD-114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Medium: Soil (All Depths)Exposure Medium: SoilExposure Point: Contaminants are in soil and exposure to soil is evaluated.

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)

Po

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value ARA

 Concentration Limits Screening V

Future Resident Screen

60571 Dieldrin 0.0018 J 0.0018 J mg/kg 57DS04D001 1/3 0.0011-0.0013 0.0018 N/A 0.00021 C 72208 Endrin Ketone 0.0034 0.0034 mg/kg 57DS04D001 1/3 0.0011-0.0013 0.0034 N/A 2.35 N 57749 gamma-Chlordane 0.006 0.006 mg/kg 57DS04D001 1/3 0.00056-0.00063 0.006 N/A 0.02 C 

1024573 Heptachlor Epoxide 0.0024 J 0.0024 J mg/kg 57DS04D001 1/3 0.00056-0.00063 0.0024 N/A 0.00011 C 

53469219 Aroclor 1242 0.1 K 0.1 K mg/kg 57TP52B001 1/99 0.0071-0.044 0.1 N/A 0.0051 C 11097691 Aroclor 1254 0.013 J 0.095 J mg/kg 57TP03B002 3/99 0.0071-0.044 0.095 N/A 0.007 C 11096825 Aroclor 1260 0.0093 J 0.13 K mg/kg 57TP08B102 33/99 0.0071-0.044 0.13 N/A 0.16 N 

7429905 Aluminum 1720 32500 mg/kg 57SD04D001 100/100 - 32500 N/A 5,476 N 7440360 Antimony 0.4 L 9.8 L mg/kg 57TP03B002 39/93 0.28-4.8 9.8 N/A 0.066 N 7440382 Arsenic 0.99 J 32 J mg/kg 57TP48B002 99/100 1.1-1.1 32 N/A 0.0013 C 7440393 Barium 40.6 1300 mg/kg 57TP32B002 100/100 - 1300 N/A 10.5 N 7440417 Beryllium 0.13 3.8 mg/kg 57TP29B002 99/100 0.49-0.49 3.8 N/A 3.16 N 7440439 Cadmium 0.11 L 14.7 L mg/kg 57TP24B001 35/84 0.02-0.13 14.7 N/A 0.14 N 7440702 Calcium 121 198000 mg/kg 57TP17B001 100/100 - 198000 N/A NUT 

18540299 Chromium 5.5 285 mg/kg 57TP03B002 100/100 - 285 N/A 0.21 N 

7440484 Cobalt 2 61.4 mg/kg 57TP15B002 99/100 1.6-6.7 61.4 N/A 3.3 N 7440508 Copper 9.5 109 mg/kg 57TP03B002 100/100 - 109 N/A 52.6 N 7439896 Iron 1000 55800 J mg/kg 57TP58B002 100/100 - 55800 N/A 27.6 N 7439921 Lead 11.3 1170 mg/kg 57TP03B002 100/100 - 1170 N/A 13.5 N 7439954 Magnesium 414 15600 mg/kg 57TP52B002 100/100 - 15600 N/A NUT 7439965 Manganese 8.3 J 4840 mg/kg 57TP02B001 100/100 - 4840 N/A 4.76 N 7487947 Mercury 0.06 1.1 mg/kg 57DS04D001 13/100 0.01-0.31 1.1 N/A 1.1 N 7440020 Nickel 4.1 75.7 mg/kg 57TP03B002 100/100 - 75.7 N/A 4.76 N 7440097 Potassium 129 2420 mg/kg 57TP23B001 100/100 - 2420 N/A NUT 7782492 Selenium 0.32 L 2.7 J mg/kg 57SD01D001 42/100 0.23-2.5 2.7 N/A 0.095 N 7440224 Silver 0.08 0.66 mg/kg 57TP58B002 16/100 0.07-1.4 0.66 N/A 0.16 N 7440235 Sodium 14 L 800 mg/kg 57TP59B002 92/100 9-239 800 N/A NUT 7440280 Thallium 0.14 0.53 mg/kg 57TP48B002 18/100 0.11-0.68 0.53 N/A 0.018 N 7440622 Vanadium 5.8 43 mg/kg 57TP18B002 99/100 6.6-6.6 43 N/A 25.6 N 7440666 Zinc 6.9 J 2010 mg/kg 57SD04D001 100/100 - 2,010 N/A 68.1 N 

1,2,3,4,6,7,8-HPCDD 0.0000442 0.0000442 mg/kg 57SD04D001 1/1 - 0.0000442 N/A --- 1,2,3,4,6,7,8-HPCDF 0.0000173 0.0000173 mg/kg 57SD04D001 1/1 - 0.0000173 N/A --- 1,2,3,6,7,8-HXCDD 0.00000178 0.0000018 57SD04D001 1/1 - 0.00000178 --- 2,3,4,6,7,8-HXCDF 0.00000053 J 0.00000053 J 57SD04D001 1/1 - 0.000000525 --- 2,3,7,8-TCDF 0.00000084 0.00000084 57SD04D001 1/1 - 0.000000838 --- 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 8 T-9 
Table 8

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Open Vehicle Storage Area, DSERTS Site LEAD-114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Medium: Soil (All Depths)Exposure Medium: SoilExposure Point: Contaminants are in soil and exposure to soil is evaluated.

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)

Po

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value ARA

 Concentration Limits Screening V

Future Resident Screen

OCDD 0.000405 0.000405 57SD04D001 1/1 - 0.000405 --- OCDF 0.000157 0.000157 57SD04D001 1/1 - 0.00016 --- 

1746016 2,3,7,8-TCDD TEQ 0.00000099 0.0000010 57SD04D001 1/1 - 0.0000010 0.0000024 C 

(1) Minimum/maximum detected concentration. Definitions: ARAR/TBC = Applicable or Relevant and Appro

(2) Duplicates were averaged and considered one sample. C = Carcinogenic(3) Lower value of residential soil risk-based screening concentration (RBC), SSL for inhalation of volatiles/particulate, COPC = Chemical of Potential Concern

and SSL for migration to groundwater (1 DAF) (see Table 4-1). J = Estimated Value

(4) If an RBSC or SSL could not be calculated, PADEP residential soil MSCs were used as the screening toxicity value (see Table 4-1). K = Analyte present. Reported value may be bias(5) Rationale Codes Selection Reason: L = Analyte present. Reported value may be bias

Above Screening Levels (ASL) mg/kg = Milligrams per kilogramDeletion Reason: MSC = Medium-Specific ConcentrationEssential Nutrient (NUT) N = Non-CarcinogenicBelow Screening Level (BSL) N/A = Not Applicable

PADEP = Pennsylvania Department of Environm

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 8 T-10 
Table 9

RAGS Part D, Table 3.1,

Medium-Specific Exposure Point Concentration Summary,

Open Vehicle Storage Area, DSERTS Site LEAD-114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: Soil (All Depths)Exposure Medium: SoilExposure Point: 

(1) (1)

Chemical Units Arithmetic 95% UCL of Maximum Maximum EPC Reasonable Maximum Exposure Ce

of Mean Normal Detected Qualifier Units 

Potential Data Concentration Medium (1), (2) Medium Medium Medium M

Concern EPC EPC EPC EPC 

Value Statistic Rationale Value S

Acetone mg/kg 0.0099 0.012 0.092 mg/kg 0.00967 95% UCL-T W-Test (3) N/A Trichloroethene mg/kg 0.0061 0.0064 0.0030 J mg/kg 0.00300 Maximim W-Test (4) N/A 1,2,4-Trichlorobenzene mg/kg 0.15 0.16 0.087 J mg/kg 0.0870 Maximim W-Test (4) N/A 2,4-Dinitrotoluene mg/kg 0.20 0.21 0.19 J mg/kg 0.190 Maximim W-Test (4) N/A 2-Chlorophenol mg/kg 0.15 0.16 0.12 J mg/kg 0.120 Maximim W-Test (4) N/A 4-Nitrophenol mg/kg 0.35 0.38 0.33 J mg/kg 0.330 Maximim W-Test (4) N/A Acenaphthene mg/kg 0.36 0.56 27.0 mg/kg 0.238 95% UCL-T W-Test (3) N/A Anthracene mg/kg 0.78 1.32 70.0 mg/kg 0.338 95% UCL-T W-Test (3) N/A Benz[a]anthracene mg/kg 1.17 2.26 1.90 mg/kg 0.505 95% UCL-T W-Test (3) N/A Benzo[a]pyrene mg/kg 0.94 1.73 1.90 mg/kg 0.478 95% UCL-T W-Test (3) N/A Benzo[b]fluoranthene mg/kg 1.07 2.01 2.80 mg/kg 0.520 95% UCL-T W-Test (3) N/A Carbazole mg/kg 0.51 0.81 41.0 mg/kg 0.300 95% UCL-T W-Test (3) N/A Chrysene mg/kg 1.10 1.83 99.0 mg/kg 0.512 95% UCL-T W-Test (3) N/A Dibenz[a,h]anthracene mg/kg 0.17 0.20 0.36 J mg/kg 0.183 95% UCL-T W-Test (3) N/A Fluoranthene mg/kg 2.32 4.11 260 mg/kg 1.041 95% UCL-T W-Test (3) N/A Fluorene mg/kg 0.49 0.81 41.0 mg/kg 0.263 95% UCL-T W-Test (3) N/A Indeno[1,2,3-cd]pyrene mg/kg 0.60 1.07 1.40 mg/kg 0.337 95% UCL-T W-Test (3) N/A Naphthalene mg/kg 0.42 0.66 26.0 mg/kg 0.225 95% UCL-T W-Test (3) N/A n-Nitrosodi-n-Propylamine mg/kg 0.20 0.21 0.042 J mg/kg 0.0420 Maximim W-Test (4) N/A Pentachlorophenol mg/kg 0.35 0.38 0.50 J mg/kg 0.500 Maximim W-Test (4) N/A Pyrene mg/kg 1.94 3.44 220 mg/kg 0.877 95% UCL-T W-Test (3) N/A alpha-BHC mg/kg NC NC 0.0011 J mg/kg 0.00110 Maximim W-Test (4) N/A Dieldrin mg/kg NC NC 0.0018 J mg/kg 0.00180 Maximim W-Test (4) N/A Heptachlor Epoxide mg/kg NC NC 0.0024 J mg/kg 0.00240 Maximim W-Test (4) N/A Aroclor 1242 mg/kg 0.014 0.016 0.10 K mg/kg 0.0172 95% UCL-T W-Test (3) N/A Aroclor 1254 mg/kg 0.014 0.016 0.095 J mg/kg 0.0174 95% UCL-T W-Test (3) N/A Aluminum mg/kg 13,873 14,518 32,500 mg/kg 14,979 95% UCL-T W-Test (3) N/A Antimony mg/kg 0.98 1.2 9.8 L mg/kg 1.05 95% UCL-T W-Test (3) N/A Arsenic mg/kg 8.42 9.12 32.0 J mg/kg 9.43 95% UCL-T W-Test (3) N/A Barium mg/kg 192 223 1,300 mg/kg 203 95% UCL-T W-Test (3) N/A Beryllium mg/kg 1.04 1.11 3.80 mg/kg 1.14 95% UCL-T W-Test (3) N/A Cadmium mg/kg 1.06 1.50 14.7 L mg/kg 2.67 95% UCL-T W-Test (3) N/A 

Contaminants are in soil and exposure to soil is evaluated.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 9 T-11 
Table 9

RAGS Part D, Table 3.1,

Medium-Specific Exposure Point Concentration Summary,

Open Vehicle Storage Area, DSERTS Site LEAD-114, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: Soil (All Depths)Exposure Medium: SoilExposure Point: 

(1) (1)

Chemical Units Arithmetic 95% UCL of Maximum Maximum EPC Reasonable Maximum Exposure Ce

of Mean Normal Detected Qualifier Units 

Potential Data Concentration Medium (1), (2) Medium Medium Medium M

Concern EPC EPC EPC EPC 

Value Statistic Rationale Value S

Contaminants are in soil and exposure to soil is evaluated.

Chromium mg/kg 33.9 40.2 285 mg/kg 35.1 95% UCL-T W-Test (3) N/A Cobalt mg/kg 21.0 22.6 61.4 mg/kg 25.0 95% UCL-T W-Test (3) N/A Copper mg/kg 41.8 44.6 109 mg/kg 45.2 95% UCL-T W-Test (3) N/A Iron mg/kg 36,286 38,294 55,800 J mg/kg 47,045 95% UCL-T W-Test (3) N/A Lead mg/kg 87 117 1,170 mg/kg 81.6 95% UCL-T W-Test (3) N/A Manganese mg/kg 920 1,027 4,840 mg/kg 1,329 95% UCL-T W-Test (3) N/A Mercury mg/kg 0.068 0.087 1.10 mg/kg 0.0693 95% UCL-T W-Test (3) N/A Nickel mg/kg 31.8 33.8 75.7 mg/kg 34.6 95% UCL-T W-Test (3) N/A Selenium mg/kg 0.69 0.80 2.70 J mg/kg 0.861 95% UCL-T W-Test (3) N/A Silver mg/kg 0.17 0.20 0.66 mg/kg 0.195 95% UCL-T W-Test (3) N/A Thallium mg/kg 0.13 0.15 0.53 mg/kg 0.143 95% UCL-T W-Test (3) N/A Vanadium mg/kg 26.4 27.5 43.0 mg/kg 28.63 95% UCL-T W-Test (3) N/A Zinc mg/kg 131 166 2,010 mg/kg 134 95% UCL-T W-Test (3) N/A Statistics: Maximum Detected Value (Maximum); 95% UCL of Normal Data (95% UCL-N); 95% UCL of Log-transformed Data (95% UCL-T).

Definitions: J = Estimated Value

(1) Nondetects were included at half the sample quantitation limit. Values are representative of all depths combined. K = Analyte present. Reported value may be biased high. Actual value i(2) The EPC is based on the lower of the 95% UCL and the maximum detected concentration. L = Analyte present. Reported value may be biased low. Actual value is (3) Shapiro-Wilk W Test indicates data are neither normally nor lognormally distributed. They were assumed to be lognormally distributed. mg/kg = Milligrams per kilogram(4) 95% UCL exceeds maximum detected concentration. Therefore, maximum concentration used for EPC. N/A = Not Applicable(5) Shapiro-Wilk W Test indicates data are normally distributed. NC = Not calcualted due to insufficient sample size.(6) Shapiro-Wilk W Test indicates data are lognormally distributed.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 9 T-12 
Table 10

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Uncurbed AST North of Building 532, DSERTS Site LEAD-126, PDO OU 6 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: Soil (All Depths)Exposure Medium: Soil

Exposure Point: Contaminants are in soil and exposure to soil is evaluated.

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)(4)

Po

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value AR

 Concentration Limits Screening 

67641 Acetone 0.013 0.018 mg/kg 51SB01B001 4/6 0.01-0.011 0.018 N/A 0.012 N 98828 Isopropylbenzene 0.011 0.089 mg/kg 51SB01B003 3/6 0.01-0.011 0.089 N/A 0.14 N 

1330207 Xylenes, Total 0.004 J 0.004 J mg/kg 51SB02B003 1/6 0.01-0.011 0.004 N/A 1.03 N 

117817 Bis(2-ethylhexyl) phthalate 0.047 J 0.23 J mg/kg 51SB02B002 2/6 0.34-0.38 0.23 N/A 1.06 C 

7439921 Lead 13.4 J 26.4 J mg/kg 51SB02B101 6/6 - 26.4 N/A 13.5 

(1) Minimum/maximum detected concentration. Definitions: ARAR/TBC = Applicable or Relevant and Appropr

(2) Duplicates were averaged and considered one sample. C = Carcinogenic(3) Lower value of residential soil risk-based screening concentration (RBC), COPC = Chemical of Potential Concern

SSL for inhalation of volatiles/particulate, and SSL for migration to groundwater (1 DAF) (see Table 4-1 of RI/RA). J = Estimated Value

(4) If an RBSC could not be calculated, PADEP residential soil MSCs were used as the screening toxicity value (see Table 4-1). mg/kg = Milligrams per kilogram(5) Rationale Codes Selection Reason: MSC = Medium-specific concentration

Above Screening Levels (ASL) N = Noncancer

Deletion Reason: N/A = Not ApplicableBelow Screening Level (BSL) PADEP = Pennsylvania Department of Environmen

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 10 T-13 
Table 11

RAGS Part D, Table 3.1,

Medium-Specific Exposure Point Concentration Summary,

Uncurbed AST North of Building 532, DSERTS Site LEAD-126, PDO OU 6 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: Soil (All Depths)Exposure Medium: SoilExposure Point: 

(1) (1)

Chemical Units Arithmetic 95% UCL of Maximum Maximum EPC Reasonable Maximum Exposure 

of Mean Normal Detected Qualifier Units 

Potential Data Concentration Medium (1), (2), (3) Medium Medium Mediu

Concern EPC EPC EPC EPC 

Value Statistic Rationale Valu

Contaminants are in soil and exposure to soil is evaluated.

Acetone mg/kg 0.012 0.017 0.018 mg/kg 0.018 Maximum W-Test (5) N/A Lead mg/kg 18.1 22 26.4 J mg/kg 26.4 Maximum W-Test (5) N/A Statistics: Maximum detected value (Maximum); 95% UCL of normal data (95% UCL-N); 95% UCL of log-transformed data (95% UCL-T)(1) Nondetects were included at half the sample quantitation limit. Values are representative of all depths combined. Definitions: J = Estimated Value(2) Within each soil depth evaluated, the EPC is based on the lower of the 95% UCL and the maximum detected concentration. mg/kg = Milligrams per kilogram(3) The EPC shown represents the EPC of aggregate soils. N/A = Not Applicable(4) Shapiro-Wilk W Test indicates data are neither normally nor lognormally distributed. They were assumed to be lognormally distributed.(5) 95% UCL exceeds maximum detected concentration. Therefore, maximum concentration used for EPC.(6) Shapiro-Wilk W Test indicates data are normally distributed.(7) Shapiro-Wilk W Test indicates data are lognormally distributed.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 11 T-14 
Table 12

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Backwash Discharge Area from the Water Treatment Plant - DSERTS Site LEAD-011, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: SoilExposure Medium: Soil (All Depths)Exposure Point: Contaminants are in soil and exposure to soil is evaluated.

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)(4)

Po

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value ARA

 Concentration Limits Screening V

7429905 Aluminum 8,200 61,000 mg/kg 34SD01D001 18/18 - 61,000 N/A 5,476 N 7440360 Antimony 0.37 L 1.3 L mg/kg 34DS06D001 11/18 0.48-1.8 1.3 N/A 0.066 N 7440382 Arsenic 4.1 J 14.1 K mg/kg 34SB10B001 18/18 - 14.1 N/A 0.0013 C 7440393 Barium 66.3 L 1,110 mg/kg 34SB06B001 18/18 - 1,110 N/A 10.5 N 7440417 Beryllium 0.67 1.5 mg/kg 34SD01D001 18/18 - 1.5 N/A 3.16 N 7440439 Cadmium 0.05 L 0.1 L mg/kg 34DS03D001 2/18 0.02-1.8 0.1 N/A 0.27 N 7440702 Calcium 764 J 167,000 J mg/kg 34DS06D001 18/18 - 167,000 N/A NUT 

18540299 Chromium 14.9 L 34.3 mg/kg 34SB01B003 18/18 - 34.3 N/A 0.21 N 

7440484 Cobalt 11.6 39.4 mg/kg 34SD02D101 18/18 - 39.4 N/A 3.3 N 7440508 Copper 29.2 J 50.8 mg/kg 34SD01D001 18/18 - 50.8 N/A 52.6 N 7439896 Iron 21,100 59,300 mg/kg 34SD02D001 18/18 - 59,300 N/A 27.6 N 7439921 Lead 13.4 J 123 mg/kg 34DS06D001 18/18 - 123 N/A 13.5 N 7439954 Magnesium 3,110 8,690 mg/kg 34DS01D001 18/18 - 8,690 N/A NUT 7439965 Manganese 246 7,880 mg/kg 34SD01D001 18/18 - 7,880 N/A 4.76 N 7487947 Mercury 0.1 0.21 mg/kg 34DS04D001 4/18 0.05-0.16 0.21 N/A 1.1 N 7440020 Nickel 22.7 46.7 mg/kg 34DS01D001 18/18 - 46.7 N/A 4.76 N 7440097 Potassium 717 1,600 mg/kg 34DS01D001 18/18 - 1,600 N/A NUT 7782492 Selenium 1.9 J 2.7 J mg/kg 57SD01D001 2/18 0.44-4.1 2.7 N/A 0.095 N 7440224 Silver 0.26 2.1 mg/kg 34SD01D001 11/18 0.13-0.73 2.1 N/A 0.16 N 7440235 Sodium 71.6 L 486 mg/kg 34DS05D001 18/18 - 486 N/A NUT 7440280 Thallium 0.16 0.16 mg/kg 34SB01B001 1/18 0.17-0.92 0.16 N/A 0.018 N 7440622 Vanadium 15.6 43.3 mg/kg 34DS05D001 18/18 - 43.3 N/A 25.6 N 7440666 Zinc 67.1 J 2,300 mg/kg 34DS03D001 18/18 - 2,300 N/A 68.1 N 

Carbon, Total Organic 18,000 J 183,000 J mg/kg 34DS05D001 8/8 - 183,000 N/A NA 

(1) Minimum/maximum detected concentration. Definitions: ARAR/TBC = Applicable or Relevant and Appropriate 

(2) Duplicates were averaged and considered one sample. C = Carcinogenic(3) Lower value of residential soil risk-based screening concentration (RBC), SSL for inhalation of volatiles/particulate, COPC = Chemical of Potential Concern

and SSL for migration to groundwater (1 DAF) (see Table 4-1 of RI/RA). J = Estimated Value

(4) If an RBSC or SSL could not be calculated, PADEP residential soil MSCs were used as the screening toxicity value (see Table 4-1 of RI/RA). K = Analyte present. Reported value may be biased hig(5) Rationale Codes Selection Reason: L = Analyte present. Reported value may be biased low

Above Screening Levels (ASL) mg/kg = Milligrams per kilogramDeletion Reason: MSC = Medium-Specific ConcentrationEssential Nutrient (NUT) N = Non-CarcinogenicBelow Screening Level (BSL) N/A = Not Applicable

PADEP = Pennsylvania Department of Environmental SSL = Soil Screening Level

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 12 T-15 
Table 13

RAGS Part D, Table 3.1,

Medium-Specific Exposure Point Concentration Summary,

Backwash Discharge Area from the Water Treatment Plant - DSERTS Site LEAD-011, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: SoilExposure Medium: Soil (All Depths)Exposure Point: Contaminants are in soil and exposure to soil is evaluated.

(1) (1)

Chemical Units Arithmetic 95% UCL of Maximum Maximum EPC Reasonable Maximum Exposure 

of Mean Normal Detected Qualifier Units 

Potential Data Concentration Medium (1), (2), (3) Medium Medium Med

Concern EPC EPC EPC EP

Value Statistic Rationale Va

Aluminum mg/kg 17,972 22,780 61,000 mg/kg 21,704 95% UCL-T W-Test (4) N/Antimony mg/kg 0.68 0.83 1.3 L mg/kg 0.84 95% UCL-N W-Test (6) N/Arsenic mg/kg 8.32 9.57 14.1 K mg/kg 9.57 95% UCL-N W-Test (6) N/Barium mg/kg 231 326 1,110 mg/kg 353 95% UCL-T W-Test (4) N/Chromium mg/kg 26.8 28.9 34.3 mg/kg 28.9 95% UCL-N W-Test (6) N/Cobalt mg/kg 21.9 24.3 39.4 mg/kg 24.3 95% UCL-N W-Test (6) N/Iron mg/kg 36,469 40,477 59,300 mg/kg 40,477 95% UCL-N W-Test (6) N/Lead mg/kg 40.4 51 123 mg/kg 62.5 95% UCL-T W-Test (7) N/Manganese mg/kg 1,996 2,958 7,880 mg/kg 4,017 95% UCL-T W-Test (7) N/Nickel mg/kg 34.6 37.4 46.7 mg/kg 37.7 95% UCL-N W-Test (6) N/Selenium mg/kg 0.81 1.13 2.7 J mg/kg 1.28 95% UCL-T W-Test (4) N/Silver mg/kg 0.4 0.58 2.1 mg/kg 0.6 95% UCL-T W-Test (7) N/Thallium mg/kg 0.18 0.22 0.16 mg/kg 0.16 Maximum W-Test (5) N/Vanadium mg/kg 27.1 30.3 43.3 mg/kg 30.3 95% UCL-N W-Test (6) N/Zinc mg/kg 235 447 2,300 mg/kg 550 95% UCL-T W-Test (4) N/Statistics: Maximum Detected Value (Max); 95% UCL of Normal Data (95% UCL-N); 95% UCL of Log-transformed Data (95% UCL-T)(1) Nondetects were included at half the sample quantitation limit. Values are representative of all depths combined. Definitions: EPC = Exposure Point Concentration(2) Within each soil depth evaluated, the EPC is based on the lower of the 95% UCL and the maximum detected concentration. J = Estimated Value(3) The EPC shown represents the higher of the EPC of total soils or the surface soils. See Table 6-21 of RI/RA for surface soil statistics. K = Analyte present. Reported value may be biased high. A(4) Shapiro-Wilk W Test indicates data are neither normally nor lognormally distributed. It was assumed to be lognormally distributed. L = Analyte present. Reported value may be biased low. Ac(5) 95% UCL exceeds maximum detected concentration. Therefore, maximum concentration used for EPC. mg/kg = Milligrams per kilogram(6) Shapiro-Wilk W Test indicates data are normally distributed. N/A = Not Applicable(7) Shapiro-Wilk W Test indicates data are lognormally distributed. UCL = Upper Confidence Limit

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 13 T-16 
Table 14

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Building 400 Series Fire Training Area - DSERTS Site LEAD-118, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: SoilExposure Medium: Soil (All Depths)

Exposure Point: 

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)(4

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value 

 Concentration Limits Screening 

Contaminants are in soil and exposure to soil is evaluated.

67641 Acetone 0.039 J 0.054 J mg/kg 71TP07B102 2/12 0.01-0.014 0.054 N/A 0.012 N 

117817 Bis(2-Ethylhexyl) Phthalate 0.042 J 0.24 J mg/kg 71TP02B001 6/12 0.055-0.42 0.24 N/A 1.1 C 

56553 Benz(a)anthracene 0.13 0.13 mg/kg 71TP02B001 1/12 0.068-0.42 0.13 N/A 0.048 C 50328 Benzo(a)pyrene 0.093 0.093 mg/kg 71TP02B001 1/12 0.047-0.42 0.093 N/A 0.018 C 

205992 Benzo(b)fluoranthene 0.15 0.15 mg/kg 71TP02B001 1/12 0.073-0.42 0.15 N/A 0.15 C 218019 Chrysene 0.14 0.14 mg/kg 71TP02B001 1/12 0.072-0.42 0.14 N/A 5.45 C 206440 Fluoranthene 0.25 0.25 mg/kg 71TP02B001 1/12 0.062-0.42 0.25 N/A 14.4 N 

85018 Phenanthrene 0.13 0.13 mg/kg 71TP02B001 1/12 0.068-0.42 0.13 N/A 6,600 N 

129000 Pyrene 0.21 0.21 mg/kg 71TP02B001 1/12 0.078-0.42 0.21 N/A 2.49 N 

11096825 Aroclor 1260 0.011 0.032 mg/kg 71TP02B001 3/12 0.0071-0.042 0.032 N/A 0.32 C 

2,3,7,8-TCDD 0.000000077 0.00000077 mg/kg 71TP01B001 10/12 0.0000000782-0.000000474 0.00000077 N/A --- 1,2,3,7,8-PeCDD 0.00000061 0.0000011 mg/kg 71TP08B002 3/12 0.0000001254-0.0000005632 0.0000011 N/A --- 1,2,3,4,7,8-HxCDD 0.00000039 0.0000019 J mg/kg 71TP02B001 10/12 0.0000002149-0.00000032 0.0000019 N/A --- 1,2,3,6,7,8-HxCDD 0.00000054 J 0.0000024 mg/kg 71TP02B001 10/12 0.0000002249-0.0000002906 0.0000024 N/A --- 1,2,3,7,8,9-HxCDD 0.00000094 0.00001 mg/kg 71TP08B002 12/12 - 0.00001 N/A --- 1,2,3,4,6,7,8-HpCDD 0.000014 0.00015 mg/kg 71TP02B002 12/12 - 0.00015 N/A --- OCDD 0.0012 0.023 mg/kg 71TP01B002 12/12 - 0.023 N/A --- 2,3,7,8-TCDF 0.00000054 0.00000074 mg/kg 71TP02B001 3/12 0.0000000347-0.0000003806 0.00000074 N/A --- 1,2,3,7,8-PeCDF 0.00000061 0.00000061 mg/kg 71TP02B001 1/12 0.0000000113-0.0000004314 0.00000061 N/A --- 2,3,4,7,8-PeCDF 0.00000051 0.00000079 mg/kg 71TP02B001 2/12 0.0000000192-0.0000004038 0.00000079 N/A --- 1,2,3,4,7,8-HxCDF 0.00000057 0.0000012 mg/kg 71TP01B001 7/12 0.0000000449-0.000000494 0.0000012 N/A --- 1,2,3,6,7,8-HxCDF 0.00000039 J 0.00000047 J mg/kg 71TP06B001 3/12 0.0000000286-0.0000003108 0.00000047 N/A --- 2,3,4,6,7,8-HxCDF 0.000000032 J 0.00000071 mg/kg 71TP02B001 10/12 0.0000000181-0.000000064 0.00000071 N/A --- 1,2,3,4,6,7,8-HpCDF 0.00000082 0.0000047 mg/kg 71TP01B001 10/12 0.0000000237-0.0000004273 0.0000047 N/A --- OCDF 0.00000026 0.0000071 mg/kg 71TP01B001 10/12 0.00000002-0.0000002207 0.0000071 N/A --- Total TCDDs 0.000000077 J 0.0000024 J mg/kg 71TP01B001 11/12 0.0000000618-0.0000000618 0.0000024 N/A --- Total PeCDDs 0.00000012 J 0.0000047 J mg/kg 71TP02B001 12/12 - 0.0000047 N/A --- Total HxCDDs 0.0000052 J 0.000041 J mg/kg 71TP02B001 12/12 - 0.000041 N/A --- Total HpCDDs 0.000031 J 0.00034 J mg/kg 71TP02B002 12/12 - 0.00034 N/A --- Total TCDFs 0.00000006 J 0.0000085 J mg/kg 71TP01B001 12/12 - 0.0000085 N/A --- Total PeCDFs 0.00000030 J 0.000016 J mg/kg 71TP02B001 11/12 0.0000000192-0.0000000192 0.000016 N/A --- Total HxCDFs 0.00000002 J 0.000011 J mg/kg 71TP02B001 12/12 - 0.000011 N/A --- Total HpCDFs 0.00000028 J 0.00001 J mg/kg 71TP01B001 11/12 0.0000000237-0.0000000237 0.00001 N/A --- 

1746016 2,3,7,8-TCDD TEQ 0.0000011 0.000005 mg/kg 71TP02B001 12/12 - 0.000005 N/A 0.000002402 C 7429905 Aluminum 7,220 17,900 mg/kg 71TP05B001 12/12 - 17,900 N/A 5,476 N 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 14 T-17 
Table 14

RAGS Part D, Table 2.1,

Occurrence, Distribution, and Selection of Chemicals of Potential Concern,

Building 400 Series Fire Training Area - DSERTS Site LEAD-118, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: SoilExposure Medium: Soil (All Depths)

Exposure Point: 

CAS Chemical Minimum 

(1)

Minimum Maximum 

(1)

Maximum Units Location Detection (2) Range of Concentration Background Screening 

(3)(4

Number Concentration Qualifier Concentration Qualifier of Maximum Frequency Detection Used for Value Toxicity Value 

 Concentration Limits Screening 

Contaminants are in soil and exposure to soil is evaluated.

7440360 Antimony 0.69 L 0.96 L mg/kg 71TP01B002 3/12 0.43-0.9 0.96 N/A 0.066 N 7440382 Arsenic 3.1 L 29.4 mg/kg 71TP01B002 12/12 - 29.4 N/A 0.0013 C 7440393 Barium 132 692 L mg/kg 71TP01B002 12/12 - 692 N/A 10.5 N 7440417 Beryllium 0.7 2.3 mg/kg 71TP08B002 12/12 - 2.3 N/A 3.16 N 7440702 Calcium 1,050 9,770 J mg/kg 71TP02B001 12/12 - 9,770 N/A NUT 

18540299 Chromium 7.4 L 26.9 mg/kg 71TP05B001 12/12 6.2-6.2 26.9 N/A 0.21 N 

7440484 Cobalt 3.7 K 35.8 mg/kg 71TP08B002 12/12 - 35.8 N/A 3.3 N 7440508 Copper 8.1 L 45.7 mg/kg 71TP08B002 12/12 - 45.7 N/A 52.6 N 7439896 Iron 24,300 44,400 J mg/kg 71TP05B001 12/12 - 44,400 N/A 27.6 N 7439921 Lead 21.9 52.3 mg/kg 71TP02B001 12/12 - 52.3 N/A 13.5 N 7439954 Magnesium 1,220 5,590 mg/kg 71TP02B002 12/12 - 5,590 N/A NUT 7439965 Manganese 270 1,780 mg/kg 71TP08B002 12/12 - 1,780 N/A 4.76 N 7487947 Mercury 0.06 0.12 mg/kg 71TP01B002 4/12 0.05-0.07 0.12 N/A 1.1 N 7440020 Nickel 11.9 45.6 mg/kg 71TP08B002 12/12 - 45.6 N/A 4.76 N 7440097 Potassium 554 2,700 mg/kg 71TP07B102 12/12 - 2,700 N/A NUT 7440224 Silver 0.14 0.14 mg/kg 71TP01B001 1/12 0.11-0.24 0.14 N/A 0.16 N 7440235 Sodium 84.6 770 mg/kg 71TP02B002 3/12 79-124 770 N/A NUT 7440280 Thallium 0.13 1.0 mg/kg 71TP01B002 2/12 0.12-0.31 1.0 N/A 0.018 N 7440622 Vanadium 12.2 38.6 mg/kg 71TP02B002 12/12 - 38.6 N/A 25.6 N 7440666 Zinc 31.3 L 95.7 J mg/kg 71TP04B001 12/12 - 95.7 N/A 68.1 N 

57125 Cyanide, Total 0.24 0.24 mg/kg 71TP01B001 1/10 0.21-0.29 0.24 N/A 156.43 N 

(1) Minimum/maximum detected concentration. Definitions: ARAR/TBC = Applicable or Relevant and Appropriate Requirement/To Be Considered

(2) Duplicates were averaged and considered one sample. C = Carcinogenic

(3) Lower value of residential soil risk-based screening concentration (RBC), SSL for inhalation of volatiles/particulate, COPC = Chemical of Potential Concern

and SSL for migration to groundwater (1 DAF) (see Table 4-1 of RI/RA). J = Estimated Value

(4) If an RBSC or SSL could not be calculated, PADEP residential soil MSCs were used as the screening toxicity value (see Table 4-1). K = Analyte present. Reported value may be biased high. Actual value is expected to be lower.(5) Rationale Codes L = Analyte present. Reported value may be biased low. Actual value is expected to be higher.

Selection Reason: mg/kg = Milligrams per kilogramAbove Screening Levels (ASL) MSC = Medium-specific concentrationDeletion Reason: N = NoncancerEssential Nutrient (NUT) N/A = Not ApplicableBelow Screening Level (BSL) PADEP = Pennsylvania Department of Environmental Protection

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 14 T-18 
Table 15

RAGS Part D, Table 3.1,

Medium-Specific Exposure Point Concentration Summary,

Building 400 Series Fire Training Area - DSERTS Site LEAD-118, SE OU 8 - Letterkenny Army Depot - Chambersburg, PA

Scenario Timeframe: Future Resident ScreenMedium: SoilExposure Medium: Soil (All Depths)Exposure Point: Contaminants are in soil and exposure to soil is evaluated.

(1) (1)

Chemical Units Arithmetic 95% UCL of Maximum Maximum EPC Reasonable Maximum Exposure 

of Mean Normal Detected Qualifier Units 

Potential Data Concentration Medium (1), (2), (3) Medium Medium Medium 

Concern EPC EPC EPC EPC 

Value Statistic Rationale Value 

Acetone mg/kg 0.013 0.022 0.054 J mg/kg 0.023 95% UCL-T W-Test (4) N/A Benz(a)anthracene mg/kg 0.098 0.14 0.13 mg/kg 0.13 Maximum W-Test (5) N/A Benzo(a)pyrene mg/kg 0.089 0.13 0.093 mg/kg 0.093 Maximum W-Test (5) N/A 2,3,7,8-TCDD TEQ mg/kg 0.0000027 0.0000034 0.000005 mg/kg 0.0000034 95% UCL-N W-Test (6) N/A Aluminum mg/kg 11,728 13,462 17,900 mg/kg 13,756 95% UCL-N W-Test (6) N/A Antimony mg/kg 0.44 0.57 0.96 L mg/kg 0.61 95% UCL-T W-Test (4) N/A Arsenic mg/kg 8.62 12.3 29.4 mg/kg 12.9 95% UCL-T W-Test (7) N/A Barium mg/kg 250 335 692 L mg/kg 344 95% UCL-T W-Test (4) N/A Chromium mg/kg 17.5 20.4 26.9 mg/kg 21.4 95% UCL-N W-Test (6) N/A Cobalt mg/kg 18.9 23.4 35.8 mg/kg 23.4 95% UCL-N W-Test (6) N/A Iron mg/kg 35,904 38,965 44,400 J mg/kg 38,965 95% UCL-N W-Test (6) N/A Lead mg/kg 35 39.4 52.3 mg/kg 43.3 95% UCL-N W-Test (6) N/A Manganese mg/kg 1,082 1,324 1,780 mg/kg 1,372 95% UCL-N W-Test (6) N/A Nickel mg/kg 24.2 29.1 45.6 mg/kg 29.1 95% UCL-N W-Test (6) N/A Thallium mg/kg 0.17 0.31 1.0 mg/kg 0.27 95% UCL-T W-Test (4) N/A Vanadium mg/kg 25.2 28.5 38.6 mg/kg 28.5 95% UCL-N W-Test (6) N/A Zinc mg/kg 62.9 73.1 95.7 J mg/kg 78.9 95% UCL-N W-Test (6) N/A Statistics: Maximum detected value (Maximum); 95% UCL of normal data (95% UCL-N); 95% UCL of log-transformed data (95% UCL-T). Definitions:

J = Estimated Value

(1) Nondetects were included at half the sample quantitation limit. Values are representative of all depths combined. L = Analyte present. Reported value may be biased low. Actual (2) Within each soil depth evaluated, the EPC is based on the lower of the 95% UCL and the maximum detected concentration. mg/kg = Milligrams per kilogram(3) The EPC shown represents the higher of the EPC of total soils or the surface soils. See Table 6-28 of RI/RA for surface soil statistics. N/A = Not Applicable(4) Shapiro-Wilk W Test indicates data are neither normally nor lognormally distributed. They were assumed to be lognormally distributed.

(5) 95% UCL exceeds maximum detected concentration. Therefore, maximum concentration used for EPC.(6) Shapiro-Wilk W Test indicates data are normally distributed.

(7) Shapiro-Wilk W Test indicates data are lognormally distributed.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 15 T-19 
Table 16

Summary of Chemicals Detected in Groundwater,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Arithmetic Mean Standard 

Concentrationc Deviationc Data 

Chemical (μg/L) (μg/L) Distribution 

Volatiles

Carbon disulfide 1 / 52 4.00E-01 - 4.00E-01 1.00E+00 - 5.00E+00 1.04E+00 8.97E-01 default (lognormal) 

Semivolatiles

bis(2-Ethylhexyl)phthalate 3 / 52 1.60E+00 - 2.70E+00 8.20E-01 - 1.10E+01 4.28E+00 1.43E+00 default (lognormal) Phenol 1 / 52 9.00E-01 - 9.00E-01 9.40E+00 - 1.10E+01 4.88E+00 5.76E-01 default (lognormal) 

Inorganics

Aluminum 17 / 52 7.85E+01 - 3.88E+03 9.90E+00 - 6.47E+02 1.74E+02 5.27E+02 default (lognormal) Antimony 7 / 53 1.50E+00 - 5.00E+00 1.50E+00 - 1.00E+01 2.18E+00 1.90E+00 default (lognormal) Arsenic 12 / 53 1.30E+00 - 1.25E+01 1.20E+00 - 1.00E+01 2.99E+00 2.61E+00 default (lognormal) Barium 53 / 53 1.38E+01 - 1.35E+02 - 6.72E+01 3.14E+01 normal Beryllium 2 / 52 1.80E-01 - 7.10E-01 1.00E-01 - 4.00E+00 4.93E-01 7.94E-01 default (lognormal) Calcium 53 / 53 8.22E+03 - 1.48E+05 - 6.52E+04 3.52E+04 default (lognormal) Chromium 9 / 53 1.10E+00 - 3.60E+00 9.00E-01 - 5.70E+00 1.64E+00 1.03E+00 default (lognormal) Cobalt 10 / 53 1.40E+00 - 7.58E+01 5.00E-01 - 5.00E+01 9.80E+00 1.40E+01 default (lognormal) Copper 3 / 51 3.90E+00 - 7.00E+00 8.00E-01 - 2.50E+01 3.73E+00 4.82E+00 default (lognormal) Iron 47 / 53 1.08E+02 - 2.21E+04 1.43E+01 - 1.85E+02 4.17E+03 5.25E+03 default (lognormal) Lead 1 / 51 1.10E+00 - 1.10E+00 1.00E+00 - 3.00E+00 8.38E-01 4.31E-01 default (lognormal) Magnesium 53 / 53 7.39E+03 - 7.14E+04 - 2.53E+04 1.66E+04 default (lognormal) Manganese 53 / 53 4.74E+01 - 6.41E+03 - 8.42E+02 1.34E+03 lognormal Nickel 8 / 53 7.00E+00 - 1.30E+02 7.00E-01 - 4.00E+01 1.27E+01 2.03E+01 default (lognormal) Potassium 53 / 53 6.53E+02 - 4.41E+03 - 1.68E+03 7.57E+02 lognormal Silver 2 / 51 1.00E+00 - 1.20E+00 1.00E+00 - 5.00E+00 1.09E+00 8.90E-01 default (lognormal) Sodium 53 / 53 5.38E+03 - 1.28E+04 - 8.69E+03 1.81E+03 normal Vanadium 3 / 52 3.50E+00 - 7.60E+00 1.00E+00 - 5.00E+01 7.21E+00 1.04E+01 default (lognormal) Zinc 14 / 53 3.50E+00 - 1.06E+02 6.00E-01 - 2.00E+01 8.04E+00 1.53E+01 default (lognormal) 

a Number of sampling locations at which chemical was detected compared with total number of sampling locations; duplicates at a location were averaged and considered one sample.

b Based on nondetected samples.

c Nondetects were included at half the sample quantitation limit (EPA, 1989, 1992; see RI/RA for references).

d Based on the lower of the 95% UCL and the maximum detected concentration (EPA, 1989; see RI/RA for references).

μg/L = Micrograms per liter.UCL = Upper confidence limit.

Frequency 

of

Detectiona

Range of Detected

Concentrations Quantitation Limitsb

(μg/L) (μg/L)

Range of Sample

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 16 T-20 
Table 17

RAGS Part D, Table 6.1,

Cancer Toxicity Data -- Oral/Dermal,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Oral Cancer Slope Factor Oral to Dermal Adjusted Dermal Units Weight of Evidence/ Source Date

of Potential Adjustment Cancer Slope Factor (2) Cancer Guideline (MM/DD

Concern Factor (1) Description 

Acetone NA 1 NA (mg/kg-d)-1 D IRIS 02/27/Trichloroethene 0.40 1 0.40 (mg/kg-d)-1 NA NA 02/27/1,2,4-Trichlorobenzene NA 1 NA (mg/kg-d)-1 D IRIS 02/27/2,4-Dinitrotoluene 0.68 1 0.68 (mg/kg-d)-1 B2 IRIS 02/27/2-Chlorophenol NA 1 NA (mg/kg-d)-1 NA NA 02/27/4-Nitrophenol NA 1 NA (mg/kg-d)-1 NA NA 02/27/Acenaphthene NA 1 NA (mg/kg-d)-1 NA NA 02/27/Benz[a]anthracene 0.73 1 0.73 (mg/kg-d)-1 B2 IRIS 02/27/Benzo[a]pyrene 7.3 1 7.3 (mg/kg-d)-1 B2 IRIS 02/27/Benzo[b]fluoranthene 0.73 1 0.73 (mg/kg-d)-1 B2 IRIS 02/27/Carbazole 0.02 1 0.02 (mg/kg-d)-1 B2 HEAST 02/27/Dibenz[a,h]anthracene 7.3 1 7.3 (mg/kg-d)-1 B2 IRIS 02/27/Fluorene NA 1 NA (mg/kg-d)-1 D IRIS 02/27/Indeno[1,2,3-cd]pyrene 0.73 1 0.73 (mg/kg-d)-1 B2 IRIS 02/27/Naphthalene NA 1 NA (mg/kg-d)-1 C IRIS 02/27/n-Nitrosodi-n-Propylamine 7.0 1 7.0 (mg/kg-d)-1 B2 IRIS 02/27/Pentachlorophenol 0.12 1 0.12 (mg/kg-d)-1 B2 IRIS 02/27/Pyrene NA 1 NA (mg/kg-d)-1 D IRIS 02/27/alpha-BHC 6.3 1 6.3 (mg/kg-d)-1 B2 IRIS 02/27/Dieldrin 16 1 16 (mg/kg-d)-1 B2 IRIS 02/27/Heptachlor Epoxide 9.1 1 9.1 (mg/kg-d)-1 B2 IRIS 02/27/Aroclor 1242 2.0 1 2.0 (mg/kg-d)-1 B2 IRIS 02/27/Aroclor 1254 2.0 1.0 2.0 (mg/kg-d)-1 B2 IRIS 02/27/Aroclor 1260 2.00 1 2.00 (mg/kg-d)-1 B2 IRIS 02/27/2,3,7,8-TCDD TEQ 150000 1 150000 (mg/kg-d)-1 B2 HEAST 02/27/Aluminum NA 0.27 NA (mg/kg-d)-1 NA NA 02/27/Antimony NA 0.15 NA (mg/kg-d)-1 NA NA 02/27/Arsenic 1.50 1 1.5 (mg/kg-d)-1 A IRIS 02/27/Barium NA 0.07 NA (mg/kg-d)-1 D IRIS 02/27/Beryllium NA 0.007 NA (mg/kg-d)-1 B1 IRIS 02/27/Cadmium NA 0.025 NA (mg/kg-d)-1 B1 IRIS 02/27/Chromium NA 0.025 NA (mg/kg-d)-1 A IRIS 02/27/Cobalt NA 1 NA (mg/kg-d)-1 NA NA 02/27/Copper NA 0.57 NA (mg/kg-d)-1 D IRIS 02/27/Iron NA 1 NA (mg/kg-d)-1 NA NA 02/27/Lead NA 1 NA (mg/kg-d)-1 B2 IRIS 02/27/Manganese NA 0.04 NA (mg/kg-d)-1 D IRIS 02/27/Mercury NA 0.07 NA (mg/kg-d)-1 D IRIS 02/27/Nickel NA 0.04 NA (mg/kg-d)-1 A IRIS 02/27/

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 17 T-21 
Table 17

RAGS Part D, Table 6.1,

Cancer Toxicity Data -- Oral/Dermal,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Oral Cancer Slope Factor Oral to Dermal Adjusted Dermal Units Weight of Evidence/ Source Date

of Potential Adjustment Cancer Slope Factor (2) Cancer Guideline (MM/DD

Concern Factor (1) Description 

Selenium NA 1 NA (mg/kg-d)-1 D IRIS 02/27/Silver NA 0.04 NA (mg/kg-d)-1 D IRIS 02/27/Thallium NA 1 NA (mg/kg-d)-1 D IRIS 02/27/Vanadium NA 0.026 NA (mg/kg-d)-1 NA NA 02/27/Zinc NA 1 NA (mg/kg-d)-1 D IRIS 02/27/(1) Refer to RAGS, Part A. EPA Group:(2) Adjusted CSFd=CSFo divided by Oral to Dermal Adjustment Factor. A - Human carcinogenmg/kg-d = Milligrams per kilogram per day B1 - Probable human carcinogen - indicates that limited human data are availableIRIS = Integrated Risk Information System B2 - Probable human carcinogen - indicates sufficient evidence in animals and N/A = Not Applicable inadequate or no evidence in humans

 D - Not classifiable as a human carcinogen

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 17 T-22 
Table 18

RAGS Part D, Table 6.2,

Cancer Toxicity Data -- Inhalation,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Unit Risk Units Adjustment (1) Inhalation Cancer Units Weight of Evidence/ Source 

of Potential Slope Factor Cancer Guideline 

Concern Description

Acetone NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Trichloroethene 0.00011 (μg/m3)-1 3,500 0.4 (mg/kg-d)-1 NA NA 1,2,4-Trichlorobenzene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS 2,4-Dinitrotoluene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS 2-Chlorophenol NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA 4-Nitrophenol NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Acenaphthene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Benz[a]anthracene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Benzo[a]pyrene 0.00089 (μg/m3)-1 3,500 3.1 (mg/kg-d)-1 B2 IRIS Benzo[b]fluoranthene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Carbazole NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 HEAST Dibenz[a,h]anthracene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Fluorene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Indeno[1,2,3-cd]pyrene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Naphthalene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 C IRIS n-Nitrosodi-n-Propylamine NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Pentachlorophenol NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Pyrene NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS alpha-BHC 0.0018 (μg/m3)-1 3,500 6.3 (mg/kg-d)-1 B2 IRIS Dieldrin 0.0046 (μg/m3)-1 3,500 16 (mg/kg-d)-1 B2 IRIS Heptachlor Epoxide 0.0026 (μg/m3)-1 3,500 9.1 (mg/kg-d)-1 B2 IRIS Aroclor 1242 0.00057 (μg/m3)-1 3,500 2.0 (mg/kg-d)-1 B2 IRIS Aroclor 1254 0.00057 (μg/m3)-1 3,500 2.0 (mg/kg-d)-1 B2 IRIS Aroclor 1260 0.0006 (μg/m3)-1 3,500 2.00 (mg/kg-d)-1 B2 IRIS 2,3,7,8-TCDD TEQ 42.9 (μg/m3)-1 3,500 150,000 (mg/kg-d)-1 B2 HEAST Aluminum NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Antimony NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Arsenic 0.0043 (μg/m3)-1 3,500 15.1 (mg/kg-d)-1 A IRIS Barium NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Beryllium 0.0024 (μg/m3)-1 3,500 8.4 (mg/kg-d)-1 B1 IRIS Cadmium 0.0018 (μg/m3)-1 3,500 6.3 (mg/kg-d)-1 B1 IRIS Chromium 0.012 (μg/m3)-1 3,500 41 (mg/kg-d)-1 A IRIS Cobalt NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Copper NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Iron NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Lead NA (μg/m3)-1 3500 NA (mg/kg-d)-1 B2 IRIS Manganese NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Mercury NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Nickel NA (μg/m3)-1 3500 NA (mg/kg-d)-1 A IRIS 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 18 T-23 
Table 18

RAGS Part D, Table 6.2,

Cancer Toxicity Data -- Inhalation,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Unit Risk Units Adjustment (1) Inhalation Cancer Units Weight of Evidence/ Source 

of Potential Slope Factor Cancer Guideline 

Concern Description

Selenium NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Silver NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Thallium NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS Vanadium NA (μg/m3)-1 3500 NA (mg/kg-d)-1 NA NA Zinc NA (μg/m3)-1 3500 NA (mg/kg-d)-1 D IRIS (1) Adjustment Factor applied to Unit Risk to calculate Inhalation Slope Factor = EPA Group: 70 kg x 1/20 m3/day x 1,000 μg/mg. A - Human carcinogen

μg/m3 = Micrograms per cubic meter B1 - Probable human carcinogen - indicates that limited human data are available

mg/kg-d = Milligrams per kilogram per day B2 - Probable human carcinogen - indicates sufficient evidence in animals and IRIS = Integrated Risk Information System inadequate or no evidence in humansNA = Not Available C - Possible human carcinogen

D - Not classifiable as a human carcinogen

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 18 T-24 
Table 19

RAGS Part D, Table 5.1,

Non-Cancer Toxicity Data -- Oral/Dermal,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Chronic/ Oral RfD Oral RfD Oral to Dermal Adjusted Units Primary Combined Sourc

of Potential Subchronic Value Units Adjustment Factor (1) Dermal Target Uncertainty/Modifying Ta

Concern RfD (2) Organ Factors 

Acetone Chronic 0.1 mg/kg/d 1 0.1 mg/kg/d Liver/Kidney 1,000 Trichloroethene Chronic 0.0003 mg/kg/d 1 0.0003 mg/kg/d NA NA N1,2,4-Trichlorobenzene Chronic 0.01 mg/kg/d 1 0.01 mg/kg/d Adrenal 1,000 2,4-Dinitrotoluene Chronic --- mg/kg/d 1 --- mg/kg/d CNS/Liver 100 N2-Chlorophenol Chronic 0.005 mg/kg/d 1 0.005 mg/kg/d Reproductive system 1,000 4-Nitrophenol Chronic 0.008 mg/kg/d 1 0.008 mg/kg/d NA NA NAcenaphthene Chronic 0.06 mg/kg/d 1 0.06 mg/kg/d Liver 3,000 Benz[a]anthracene Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Benzo[a]pyrene Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Benzo[b]fluoranthene Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Carbazole Chronic --- mg/kg/d 1 --- mg/kg/d Liver NA NA Dibenz[a,h]anthracene Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Fluorene Chronic 0.04 mg/kg/d 1 0.04 mg/kg/d Blood 3,000 Indeno[1,2,3-cd]pyrene Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Naphthalene Chronic 0.02 mg/kg/d 1 0.02 mg/kg/d Whole body 3,000 n-Nitrosodi-n-Propylamine Chronic --- mg/kg/d 1 --- mg/kg/d NOAEL NA NPentachlorophenol Chronic 0.03 mg/kg/d 1 0.03 mg/kg/d Kidney/Liver 100 Pyrene Chronic 0.03 mg/kg/d 1 0.03 mg/kg/d Kidney 3,000 alpha-BHC Chronic --- mg/kg/d 1 --- mg/kg/d NA NA Dieldrin Chronic 0.00005 mg/kg/d 1 0.00005 mg/kg/d Liver 100 Heptachlor Epoxide Chronic 0.000013 mg/kg/d 1 0.000013 mg/kg/d Liver 1,000 Aroclor 1242 Chronic 0.00002 mg/kg/d 1 0.00002 mg/kg/d NA NA Aroclor 1254 Chronic 0.00002 mg/kg/d 1 0.00002 mg/kg/d Ocular/Immunological/Integument* 300 Aroclor 1260 Chronic --- 1 --- Ocular/Immunological/Integument* --- 2,3,7,8-TCDD TEQ Chronic --- 1 --- NA --- Aluminum Chronic 1.0 mg/kg/d 0.27 0.27 mg/kg/d CNS NA NCEA : ProAntimony Chronic 0.0004 mg/kg/d 0.15 0.00006 mg/kg/d Blood 1,000 Arsenic Chronic 0.0003 mg/kg/d 1 0.00030 mg/kg/d Integument * 3 Barium Chronic 0.07 mg/kg/d 0.07 0.0049 mg/kg/d NOEL/Kidney 3 Beryllium Chronic 0.002 mg/kg/d 0.007 0.000014 mg/kg/d Gastrointestinal 300 Cadmium Chronic 0.001 mg/kg/d 0.025 0.000025 mg/kg/d Kidney 10 Chromium Chronic 0.003 mg/kg/d 0.025 0.000075 mg/kg/d NOEL 300 Cobalt Chronic 0.02 mg/kg/d 1 0.02 mg/kg/d NA NA NCopper Chronic 0.04 mg/kg/d 0.57 0.023 mg/kg/d Gastrointestinal NA Iron Chronic 0.3 mg/kg/d 1 0.3 mg/kg/d Liver/Gastrointestinal/Body weight/Organ weight NA NCEA : ProLead Chronic --- mg/kg/d 1 --- mg/kg/d CNS NA NManganese Chronic 0.02 mg/kg/d 0.04 0.0008 mg/kg/d CNS 1 Mercury Chronic 0.0003 mg/kg/d 0.07 0.000021 mg/kg/d Immune System NA Nickel Chronic 0.02 mg/kg/d 0.04 0.0008 mg/kg/d Body weight/Organ weight 300 Selenium Chronic 0.005 mg/kg/d 1 0.005 mg/kg/d Integument * 3 Silver Chronic 0.005 mg/kg/d 0.04 0.0002 mg/kg/d Integument * 3 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 19 T-25 
Table 19

RAGS Part D, Table 5.1,

Non-Cancer Toxicity Data -- Oral/Dermal,

Phase III Sites - Letterkenny Army Depot - Chambersburg, PA

Chemical Chronic/ Oral RfD Oral RfD Oral to Dermal Adjusted Units Primary Combined Sourc

of Potential Subchronic Value Units Adjustment Factor (1) Dermal Target Uncertainty/Modifying Ta

Concern RfD (2) Organ Factors 

Thallium Chronic 0.00007 mg/kg/d 1 0.00007 mg/kg/d Liver/Blood 3,000 Vanadium Chronic 0.007 mg/kg/d 0.026 0.00018 mg/kg/d Integument * NA Zinc Chronic 0.30 mg/kg/d 1 0.3 mg/kg/d Blood 3 (1) Refer to RAGS, Part A.(2) Dermal reference doses were calculated by multiplying the oral reference dose and the oral to  dermal adjustment factor.(3) NCEA values were obtained from EPA Region III Risk-Based Concentration Table (10/9/2002).* Integument includes skin, hair, nails, sebaceous and sweat glands.CNS=Central Nervous SystemHEAST=Health Effects Assessment Summary TablesIRIS=Integrated Risk Information Systemmg/kg/d = Milligrams per kilogram per dayN/A= Not ApplicableNCEA=National Center for Environmental AssessmentNOEL=No Observed Effect Level

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 19 T-26 
Table 20

RAGS Part D, Table 5.2,

Non-Cancer Toxicity Data -- Inhalation,

Phase III Site - Letterkenny Army Depot - Chambersburg, PA

Chemical Chronic/ Value Units Adjusted Units Primary Combined Sources of (2) 

of Potential Subchronic Inhalation Inhalation Target Uncertainty/Modifying RfC,RfD, 

Concern RfC RfD (1) Organ Factors Target Organ

Acetone Chronic NA mg/m3 NA mg/m3 NA NA NA Trichloroethene Chronic 0.035 mg/m3 0.010 mg/m3 NA NA NCEA : NA 1,2,4-Trichlorobenzene Chronic 0.0035 mg/m3 0.0010 mg/m3 Liver NA NCEA : HEAST 2,4-Dinitrotoluene Chronic NA mg/m3 NA mg/m3 NA NA NA 2-Chlorophenol Chronic NA mg/m3 NA mg/m3 NA NA NA 4-Nitrophenol Chronic NA mg/m3 NA mg/m3 NA NA NA Acenaphthene Chronic NA mg/m3 NA mg/m3 NA NA NA Benz[a]anthracene Chronic NA mg/m3 NA mg/m3 NA NA NA Benzo[a]pyrene Chronic NA mg/m3 NA mg/m3 NA NA NA Benzo[b]fluoranthene Chronic NA mg/m3 NA mg/m3 NA NA NA Carbazole Chronic NA mg/m3 NA mg/m3 NA NA NA Dibenz[a,h]anthracene Chronic NA mg/m3 NA mg/m3 NA NA NA Fluorene Chronic NA mg/m3 NA mg/m3 NA NA NA Indeno[1,2,3-cd]pyrene Chronic NA mg/m3 NA mg/m3 NA NA NA Naphthalene Chronic 0.0032 mg/m3 0.0009 mg/m3 Respiratory system 3,000 IRIS n-Nitrosodi-n-Propylamine Chronic NA mg/m3 NA mg/m3 NA NA NA Pentachlorophenol Chronic NA mg/m3 NA mg/m3 NA NA NA Pyrene Chronic NA mg/m3 NA mg/m3 NA NA NA alpha-BHC Chronic NA mg/m3 NA mg/m3 NA NA NA Dieldrin Chronic NA mg/m3 NA mg/m3 NA NA NA Heptachlor Epoxide Chronic NA mg/m3 NA mg/m3 NA NA NA Aroclor 1242 Chronic NA mg/m3 NA mg/m3 NA NA NA Aroclor 1254 Chronic NA mg/m3 NA mg/m3 NA NA NA Aroclor 1260 Chronic --- --- --- --- NA --- NA2,3,7,8-TCDD TEQ Chronic --- --- --- --- NA --- NAAluminum Chronic 0.0035 mg/m3 0.0010 mg/m3 NA NA NCEA : NA Antimony Chronic NA mg/m3 NA mg/m3 Respiratory NA NA : IRIS Arsenic Chronic NA mg/m3 NA mg/m3 NA NA NA Barium Chronic 0.0005 mg/m3 0.00014 mg/m3 NA NA NA : IRIS Beryllium Chronic 0.000020 mg/m3 0.0000057 mg/m3 Lung 10 IRIS Cadmium Chronic 0.00020 mg/m3 0.000057 mg/m3 NA NA NCEA : NA Chromium Chronic 0.00011 mg/m3 0.00003 mg/m3 Lung 90 IRIS Cobalt Chronic 0.000020 mg/m3 0.000006 mg/m3 NA NA NCEA : NA Copper Chronic NA mg/m3 NA mg/m3 NA NA NA Iron Chronic NA mg/m3 NA mg/m3 NA NA NA Lead Chronic NA mg/m3 NA mg/m3 CNS NA NA : IRIS Manganese Chronic 0.00 mg/m3 0.000014 mg/m3 CNS 1,000 IRIS Mercury Chronic NA mg/m3 NA mg/m3 CNS 30 NA : IRIS 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 20 T-27 
Table 20

RAGS Part D, Table 5.2,

Non-Cancer Toxicity Data -- Inhalation,

Phase III Site - Letterkenny Army Depot - Chambersburg, PA

Chemical Chronic/ Value Units Adjusted Units Primary Combined Sources of (2) 

of Potential Subchronic Inhalation Inhalation Target Uncertainty/Modifying RfC,RfD, 

Concern RfC RfD (1) Organ Factors Target Organ

Nickel Chronic NA mg/m3 NA mg/m3 NA NA NA Selenium Chronic NA mg/m3 NA mg/m3 NA NA NA Silver Chronic NA mg/m3 NA mg/m3 NA NA NA Thallium Chronic NA mg/m3 NA mg/m3 NA NA IRIS : NA Vanadium Chronic NA mg/m3 NA mg/m3 NA NA NA Zinc Chronic NA mg/m3 NA mg/m3 NA NA NA (1) Adjusted inhalation RfD = RfC*20/70.(2) NCEA values were obtained from EPA Region III Risk-Based Concentration Table (10/9/2002).mg/m3= Milligrams per cubic meter

mg/kg/d = Milligrams per kilogram per dayN/A= Not ApplicableCNS=Central Nervous SystemNCEA=National Center for Environmental AssessmentIRIS=Integrated Risk Information System

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 20 T-28 
MK01|L:\RPT\02281016.008\PHASE III\ROD\TABLES 21 - 25.DOC 5/20/2003 T-29

Table 21 

Models for Calculating Age-Adjusted Cancer Residential RBSCs for Soil 

Ingestion, 

Letterkenny Army Depot, 

Chambersburg, PA 

a

a a

c

c c

adj BW

IR x ED

BW

IR x ED IFA (mg - year/kg - day) = +

For organics: 

adj o

c

EF x IFA x CSF

TR x AT RBSC (mg/kg) =

For inorganics: 

adj o

c

EF x IFA x CSF

TR x AT RBSC (mg/kg) =

Parameter Definition Value 

IFAadj Age-adjusted inhalation factor (mg-year/kg-day). * 

IRc Ingestion rate, child (mg/day). 200 

EDc Exposure duration, child (years). 6 

BWc Body weight, child (kg). 15 

IRa Ingestion rate, adult (mg/day). 100 

EDa Exposure duration, adult (years). 24 

BWa Body weight, adult (kg). 70 

TR Target cancer risk. 1.0E-06 

AT Cancer averaging time (days). 25,550 

EF Exposure frequency (days/year). 350 

CSFo Oral cancer inhalation slope factor (mg/kg-day)-1. Chemical-specific 

(Section 6 of 

RI/RA) 

* Calculated using formula shown above. 

mg/kg = Milligrams per kilogram. 

mg/kg-day = Milligram per kilogram per day. 

RBSC = Risk-based screening concentration. 
MK01|L:\RPT\02281016.008\PHASE III\ROD\TABLES 21 - 25.DOC 5/20/2003 T-30

Table 22 

Model for Calculating Age-Adjusted Cancer Residential RBSCs for 

Dermal Contact with Soil, 

Letterkenny Army Depot, 

Chambersburg, PA 

a

a a a

c

c c c

adj BW

SA x AF x ED

BW

SA x AF x ED IFA (mg - year/kg - day) = +

For organics: 

adj o

c

EF x IFA x CSF

TR x AT RBSC (mg/kg) =

For inorganics: 

adj o

c

EF x IFA x CSF

TR x AT RBSC (mg/kg) =

Parameter Definition Value 

IFAadj Age-adjusted inhalation factor (mg-year/kg-day). * 

SAc Exposed skin surface area, child (cm2/day). 2,983 

AFc Soil adherence factor, child (mg/cm2). 0.045 

EDc Exposure duration, child (years). 6 

BWc Body weight, child (kg). 15 

SAa Exposed skin surface area, adult (cm2/day). 5,651 

AFa Soil adherence factor, adult (mg/cm2). 0.065 

EDa Exposure duration, adult (years). 24 

BWa Body weight, adult (kg). 70 

TR Target cancer risk. 1.0E-06 

AT Cancer averaging time (days). 25,550 

EF Exposure frequency (days/year). 350 

CSFo Oral cancer inhalation slope factor (mg/kg-day)-1. Chemical-specific 

(Section 6 of 

RI/RA) 

* Calculated using formula shown above. 

mg/kg = Milligrams per kilogram. 

mg-year/kg-day = Milligram per year per kilogram per day. 

RBSC = Risk-based screening concentration. 
MK01|L:\RPT\02281016.008\PHASE III\ROD\TABLES 21 - 25.DOC 5/20/2003 T-31

Table 23 

Model for Calculating Age-Adjusted Cancer Residential RBSCs for 

Inhalation of VOCs/Particulates, 

Letterkenny Army Depot, 

Chambersburg, PA 

a

a tot c

c

3 c c

adj BW

IR x (ED - ED )

BW

IR x ED IFA (m - year/kg - day) = +

For organics: 

EF x IFA x CSF x 1/VF

TR x AT RBSC (mg/kg)

adj i

c =

For inorganics: 

EF x IFA x CSF x 1/PEF

TR x AT RBSC (mg/kg)

adj i

c =

Parameter Definition Value 

IFAadj Age-adjusted inhalation factor (m3-year/kg-day). * 

IRc Inhalation rate, child (m3/day). 8.4 

EDc Exposure duration, child (years). 6 

BWc Body weight, child (kg). 15 

IRa Inhalation rate, adult, average of male and female (m3/day). 13.3 

EDtot Exposure duration, total (years). 30 

BWa Body weight, adult (kg). 70 

TR Target cancer risk. 1.0E-06 

AT Cancer averaging time (days). 25,550 

EF Exposure frequency (days/year). 350 

CSFi Cancer inhalation slope factor (mg/kg-day)-1. Chemical-specific 

(Section 6) 

VF Volatilization factor (m3/kg). Chemical-specific 

(Section 6 of 

RI/RA) 

PEF Particulate emission factor (m3/kg). 6.79E+10 

* Calculated using formula shown above. 

m3

/kg = Cubic meters per kilogram. 

mg/kg-day = Milligrams per kilogram per day. 

RBSC = Risk-based screening concentration. 
MK01|L:\RPT\02281016.008\PHASE III\ROD\TABLES 21 - 25.DOC 5/20/2003 T-32

Table 24 

Model for Calculating Noncancer Residential RBSCs for Soil Ingestion, 

Child and Adult, 

Letterkenny Army Depot, 

Chambersburg, PA 

FI x EF x (ED or ED ) x IRS x (1/RfD ) x CF

THQ x AT x (BW or BW ) RBSC (mg/kg)

a c o

a c =

Parameter Definition Value 

THQ Target hazard quotient. 1.0 

ATa Noncancer averaging time, adult (days). 10,950 

ATc Noncancer averaging time, child (days). 2,190 

BWa Body weight, adult (kg). 70 

BWc Body weight, child (kg). 15 

FI Fraction of contaminated soil ingested (unitless). 1.0 

EF Exposure frequency (days/year). 350 

EDa Exposure duration, adult (years). 30 

EDc Exposure duration, child (years). 6 

IRSa Soil ingestion rate, adult (mg/day). 100 

IRSc Soil ingestion rate, child (mg/day). 200 

RfDo Oral reference dose (mg/kg-day). Chemical-specific 

(Section 6 of 

RI/RA) 

CF Conversion factor (kg/mg). 1.00E-06 

 

mg/kg = Milligrams per kilogram. 

mg/kg-day = Milligrams per kilogram per day.

RBSC = Risk-based screening concentration. 
MK01|L:\RPT\02281016.008\PHASE III\ROD\TABLES 21 - 25.DOC 5/20/2003 T-33

Table 25 

Integrated Risk-Based Screening Concentration Algorithma

through All Relevant Exposure Pathways, 

Letterkenny Army Depot, 

Chambersburg, PA 

RBSC int = [(RBSCing)

-1 + (RBSCder)-1 + (RBSCinh)-1] -1

Where: 

 RBSCint = Medium-specific integrated risk-based concentration for all pathways combined. b

 RBSCing = Medium-specific risk-based concentration for ingestion. 

 RBSCder = Medium-specific risk-based concentration for dermal contact. 

 RBSCinh = Medium-specific risk-based concentration for inhalation. 

a Rosenblatt et al., 1982. 

b This algorithm is used to estimate the integrated soil RBSC for the agricultural worker (direct contact) in 

 Level 1, and for the commercial/industrial and construction workers and resident in Level 2. 
Table 26

Model for Calculating Groundwater Ingestion Risk-Based Screening Concentrations

for Child and Adult Resident and Industrial Worker

Age-Adjusted Factor for Groundwater Ingestion:

Age-Adjusted Cancer Resident RBSC:

Cancer Industrial Worker RBSC:

Noncancer Child Resident and Industrial Worker RBSCs:

Parameter Definition Value

TR Target cancer risk. 1.00E-06

THQ Target hazard quotient. 0.1

ATc Averaging time carcinogens (days). 25,550

ATnc Averaging time noncarcinogens (days). 2,190

EF Exposure frequency (days/year). 350

EDtot Exposure duration, total (years). 30

EDa Exposure duration, adult (years). 24

EDc Exposure duration, child (years). 6

BWa Body weight, adult (kg). 70

BWc Body weight, child (kg). 15

IRWa Water ingestion rate, adult (L/day). 2

IRWc Water ingestion rate, child (L/day). 1

CF Conversion factor (mg/μg). 1.00E-03

CSFo Oral cancer slope factor ((mg/kg-day)-1). Chemical-specific

RfDo Oral reference dose (mg/kg-day). Chemical-specific

Letterkenny Army Depot,

Chambersburg, PA

a

a tot c

c

c c

adj

BW

IRW x (ED ED )

BW

IRW x ED

IFW (L year/kg day) − − − = +

adj o

c

EF x IFW x CF x CSF

TR x AT RBSC (μg / L) =

o

c

EF x ED x IRW x CF x CSF

TR x AT x BW RBSC (μg / L) =

o

c

RfD

1 EF x ED x IRW x CF x

THQ x AT x BW RBSC (μg / L) =

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 26 T-34 5/20/2003
Table 27

Soil RBSCs Across All Direct Contact Pathways for Future Resident—Child and Adult,

Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Exposure Integrated RBSCs

Point Carcinogenic a Noncarcinogenic b Cancer Primary 

Concentration Age-Adjusted Child Adult Risk Target 

Chemical (mg/kg) (mg/kg) (mg/kg) Age-Adjusted Organ 

1,2,4-Trichlorobenzene 8.70E-02 --- 8.45E+00 2.68E+01 --- Adrenal 2,4-Dinitrotoluene 1.90E-01 8.12E-01 --- --- 2.34E-07 CNS/Liver 2-Chlorophenol 1.20E-01 --- 3.83E+01 3.29E+02 --- Reproductive system 2-Methylnaphthalene 1.72E-01 --- 1.56E+02 1.46E+03 --- NA 4-Chloro-3-methylphenol 5.10E-02 --- --- --- --- Organ weight 4-Nitrophenol 3.30E-01 --- 5.86E+01 4.27E+02 --- NA Acenaphthene 2.38E-01 --- 4.69E+02 4.38E+03 --- Liver Acenaphthylene 1.58E-01 --- --- --- --- NA Anthracene 3.38E-01 --- 2.35E+03 2.19E+04 --- NOEL Benz(a)anthracene 5.05E-01 8.75E-01 --- --- 5.78E-07 NA Benzo(a)pyrene 4.78E-01 8.75E-02 --- --- 5.46E-06 NA Benzo(b)fluoranthene 5.20E-01 8.75E-01 --- --- 5.94E-07 NA Benzo(ghi)perylene 3.50E-01 --- 2.35E+02 2.19E+03 --- NA Benzo(k)fluoranthene 3.25E-01 8.75E+00 --- --- 3.71E-08 NA bis(2-Ethylhexyl)phthalate 1.66E-01 3.94E+01 1.47E+02 1.07E+03 4.21E-09 Liver Carbazole 3.00E-01 3.19E+01 --- --- 9.39E-09 Liver Chrysene 5.12E-01 8.75E+01 --- --- 5.85E-09 NA Dibenz(a,h)anthracene 1.83E-01 8.75E-02 --- --- 2.09E-06 NA Dibenzofuran 2.07E-01 --- 3.07E+01 2.63E+02 --- NA Di-n-butyl phthalate 1.20E-01 --- 7.33E+02 5.34E+03 --- Increased mortality Fluoranthene 1.04E+00 --- 3.13E+02 2.92E+03 --- Blood/Kidney/Liver Fluorene 2.63E-01 --- 3.13E+02 2.92E+03 --- Blood Indeno(1,2,3-cd)pyrene 3.37E-01 8.75E-01 --- --- 3.85E-07 NA Naphthalene 2.25E-01 --- 1.03E+01 3.19E+01 --- Whole body n-Nitrosodi-n-propylamine 4.20E-02 7.89E-02 --- --- 5.33E-07 NOAEL Pentachlorophenol 5.00E-01 3.85E+00 2.02E+02 1.15E+03 1.30E-07 Kidney/Liver Phenanthrene 8.55E-01 --- 2.35E+02 2.19E+03 --- NA Phenol 1.40E-01 --- 2.20E+03 1.60E+04 --- Fetus Pyrene 8.77E-01 --- 2.35E+02 2.19E+03 --- Kidney 1,2-Dichloroethene, total 3.00E-03 --- 7.04E+01 6.56E+02 --- Liver 2-Butanone 6.40E-03 --- 4.78E+02 1.52E+03 --- Reproductive system Acetone 9.67E-03 --- 7.82E+02 7.29E+03 --- Liver/Kidney Ethylbenzene 2.00E-03 1.51E+01 2.36E+02 8.70E+02 1.33E-10 Liver/Kidney Trichloroethene 3.00E-03 8.28E-02 1.74E+00 1.01E+01 3.62E-08 NA Xylenes, total 6.00E-03 --- 1.53E+04 1.32E+05 --- Body weight/CNS Aroclor 1242 1.72E-02 2.92E-01 1.50E-01 1.20E+00 5.88E-08 NA Aroclor 1254 1.74E-02 2.92E-01 1.50E-01 1.20E+00 5.96E-08 Ocular/Immunological/Integument* 

SemivolatilesVolatiles

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 27 T-35 
Table 27

Soil RBSCs Across All Direct Contact Pathways for Future Resident—Child and Adult,

Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Exposure Integrated RBSCs

Point Carcinogenic a Noncarcinogenic b Cancer Primary 

Concentration Age-Adjusted Child Adult Risk Target 

Chemical (mg/kg) (mg/kg) (mg/kg) Age-Adjusted Organ 

Aroclor 1260 2.96E-02 2.92E-01 1.50E-01 1.20E+00 1.01E-07 Ocular/Immunological/Integument* alpha-BHC 1.10E-03 8.76E-02 --- --- 1.26E-08 NA alpha-Chlordane 8.50E-03 1.58E+00 3.66E+00 2.67E+01 5.39E-09 Liver Dieldrin 1.80E-03 3.45E-02 3.66E-01 2.67E+00 5.22E-08 Liver Endrin ketone 3.40E-03 --- 2.20E+00 1.60E+01 --- Liver gamma-Chlordane 6.00E-03 1.58E+00 3.66E+00 2.67E+01 3.80E-09 Liver Heptachlor epoxide 2.40E-03 6.07E-02 9.53E-02 6.94E-01 3.96E-08 Liver Aluminum 1.50E+04 --- 7.63E+03 6.41E+04 --- CNS Antimony 1.05E+00 --- 2.99E+00 2.35E+01 --- Liver Arsenic 9.43E+00 4.05E-01 2.30E+00 1.96E+01 2.33E-05 Integument * Barium 2.03E+02 --- 4.99E+02 3.35E+03 --- NOEL/Kidney Beryllium 1.14E+00 7.45E+04 7.98E+00 2.34E+01 1.53E-11 Gastrointestinal Cadmium 2.67E+00 9.93E+04 6.17E+00 2.96E+01 2.68E-11 Kidney Calcium 1.33E+04 --- --- --- --- NA Chromium 3.51E+01 1.53E+04 1.85E+01 8.87E+01 2.30E-09 Lung Cobalt 2.50E+01 --- 1.55E+02 1.40E+03 --- NA Copper 4.52E+01 --- 3.09E+02 2.74E+03 --- Gastrointestinal Iron 4.70E+04 --- 2.33E+03 2.11E+04 --- Liver/Gastrointestinal/Body weight/Organ weight Leadc 8.16E+01 --- --- 4.00E+02 --- CNS Magnesium 6.15E+03 --- --- --- --- NA Manganese 1.33E+03 --- 1.34E+02 7.60E+02 --- CNS Mercury 6.93E-02 --- 2.14E+00 1.44E+01 --- Immune system/CNS Nickel 3.46E+01 --- 1.34E+02 7.61E+02 --- Body weight/Organ weight Potassium 1.14E+03 --- --- --- --- NA Selenium 8.61E-01 --- 3.88E+01 3.52E+02 --- Integument * Silver 1.95E-01 --- 3.35E+01 1.90E+02 --- Integument * Sodium 1.33E+02 --- --- --- --- NA Thallium 1.43E-01 --- 5.44E-01 4.93E+00 --- Liver/Blood Vanadium 2.86E+01 --- 4.35E+01 2.12E+02 --- Integument * Zinc 1.34E+02 --- 2.33E+03 2.11E+04 --- Blood Carbon, total organic 6.69E+04 --- --- --- --- --- 

Dioxins/Furans ---

1,2,3,4,6,7,8-HpCDD 4.42E-08 --- --- --- --- --- 1,2,3,4,6,7,8-HpCDF 1.73E-08 --- --- --- --- --- 1,2,3,6,7,8-HxCDD 1.78E-09 --- --- --- --- --- 2,3,4,6,7,8-HxCDF 5.25E-10 --- --- --- --- --- 2,3,7,8-TCDF 8.38E-10 --- --- --- --- --- 

Metals

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 27 T-36 
Table 27

Soil RBSCs Across All Direct Contact Pathways for Future Resident—Child and Adult,

Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Exposure Integrated RBSCs

Point Carcinogenic a Noncarcinogenic b Cancer Primary 

Concentration Age-Adjusted Child Adult Risk Target 

Chemical (mg/kg) (mg/kg) (mg/kg) Age-Adjusted Organ 

OCDD 4.05E-07 --- --- --- --- --- OCDF 1.57E-07 --- --- --- --- --- 2,3,7,8-TCDD TEQ 9.86E-10 4.07E-06 --- --- 2.42E-10 NA 

Total Risk 3.37E-05 

Note: Shading indicates hazard quotient is greater than 1 or cancer risk is greater than 1 x 10-6.

a Target cancer risk, 1E-06. Total Liver HI b Target hazard quotient, 0.1. Total Kidney HI c Based on CERCLA/RCRA Corrective Action Level (EPA, 1998). Total NA HI 

* Integument includes skin, hair, nails, sebaceous and sweat glands. Total CNS HI CNS = Central nervous system. Total Integument HI = 

mg/kg = Milligrams per kilogram. Total NOEL HI 

NA = Not available. Total Lung HI NOAEL = No-observed-adverse-effect level. Total Gastrointestinal HI 

NOEL = No-observed-effect level. Total Body Weight HI 

NUT = Essential nutrient. Total Organ Weight HI 

RBSC = Risk-Based Screening Concentration. Total Blood HI = 

Total Adrenal HI = 

Total Reproductive System HI = 

Total Immune System HI = 

Total Death HI 

Total Whole Body HI 

Total Fetus HI = 

Total Ocular HI = 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 27 T-37 
Table 28

Soil RBSCs Across All Direct Contact Pathways for Future Resident - Child and Adult

Backwash Discharge Area from Water Treatment Plant,

Letterkenny Army Depot,

Chambersburg, PA

Exposure Integrated RBSCs

Point Carcinogenica Noncarcinogenicb Cancer Primary 

Concentration (mg/kg) Risk Target 

Chemical (mg/kg) Age-Adjusted Child Adult Age-Adjusted Organ 

Aluminum 21,704 NA 7.63E+03 6.41E+04 NA CNS Antimony 0.84 NA 2.99E+00 2.35E+01 NA Liver Arsenic 9.57 4.05E-01 2.30E+00 1.96E+01 2.36E-05 Integument * Barium 353 NA 4.99E+02 3.35E+03 NA NOEL/Kidney Chromium 28.9 1.53E+04 1.85E+01 8.87E+01 1.89E-09 Lung Cobalt 24.3 NA 1.55E+02 1.40E+03 NA NA Iron 40,477 NA 2.33E+03 2.11E+04 NA Liver/Gastrointestinal/Body weiLeadc 62.5 NA NA NA NA CNS Manganese 4,017 NA 1.34E+02 7.60E+02 NA CNS Nickel 37.7 NA 1.34E+02 7.61E+02 NA Body weight/Organ wSelenium 1.28 NA 3.88E+01 3.52E+02 NA Integument * Silver 0.6 NA 3.35E+01 1.90E+02 NA Integument * Thallium 0.16 NA 5.44E-01 4.93E+00 NA Liver/Blood Vanadium 30.3 NA 4.35E+01 2.12E+02 NA Integument * Zinc 550 NA 2.33E+03 2.11E+04 NA Blood 

Total Risk 2.36E-05 

Note: Shading indicates hazard quotient is greater than 1 or cancer risk is greater than 1 x 10-6.

a Target cancer risk, 1E-06. b Target hazard quotient, 0.1. c Based on CERCLA/RCRA Corrective Action Level (EPA, 1998). 

mg/kg = Milligrams per kilogram 

RBSC = Risk-based screening concentration. Tot

METALS

(mg/kg)

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 28 T-38 
Table 29

Soil RBSCs Across All Direct Contact Pathways for Future Resident - Child and Adult,

Building 400 Series Fire Training Area,

Letterkenny Army Depot,

Chambersburg, PA

Exposure Integrated RBSCs

Point Carcinogenica Noncarcinogenicb Cancer Primary 

Concentration Age-Adjusted Child Adult Risk Target 

Chemical (mg/kg) (mg/kg) (mg/kg) Age-Adjusted Organ 

Acetone 0.023 NA 7.82E+02 7.29E+03 NA Liver/Kidney 

Benz[a]anthracene 0.13 8.75E-01 NA NA 1.49E-07 NA 

Benzo[a]pyrene 0.093 8.75E-02 NA NA 1.06E-06 NA 

Aluminum 13,756 NA 7.63E+03 6.41E+04 NA CNS 

Antimony 0.61 NA 2.99E+00 2.35E+01 NA Liver 

Arsenic 12.9 4.05E-01 2.30E+00 1.96E+01 3.18E-05 Integument * 

Barium 344 NA 4.99E+02 3.35E+03 NA NOEL/Kidney Chromium 21.4 1.53E+04 1.85E+01 8.87E+01 1.40E-09 Lung 

Cobalt 23.4 NA 1.55E+02 1.40E+03 NA NA 

Iron 38,965 NA 2.33E+03 2.11E+04 NA Liver/Gastrointestinal/Body weight/Organ w

Leadc 43.3 NA NA NA NA CNS 

Manganese 1,372 NA 1.34E+02 7.60E+02 NA CNS 

Nickel 29.1 NA 1.34E+02 7.61E+02 NA Body weight/Organ weight 

Thallium 0.27 NA 5.44E-01 4.93E+00 NA Liver/Blood Vanadium 28.5 NA 4.35E+01 2.12E+02 NA Integument * 

Zinc 78.9 NA 2.33E+03 2.11E+04 NA Blood 

DIOXINS/FURANS

2,3,7,8-TCDD TEQ 0.0000034 0.0000041 NA NA 8.42E-07 NA 

Total Risk 3.39E-05 

a Target cancer risk, 1E-06. Total Liveb Target hazard quotient, 0.1. Total Kidnec Based on CERCLA/RCRA Corrective Action Level (EPA, 1998). Total NA 

mg/kg = Milligrams per kilogram Total CN

RBSC = Risk-Based Screening Concentration. Total Integumen

Total NOE

Total Lun

Total Gastrointestin

Total Body Weigh

Total Bloo

VOLATILES

METALS

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 29 T-39 
Table 30

Groundwater Health Risks,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Commercial/ Industrialb Commercial/ Industrialb Age-Adjusted Residentb Child Residentb

Exposure Pointa Cancer-Based Estimatedc Non-Cancer-Based Estimatedd Cancer-Based Estimatedc Non-Cancer-Base

Concentration RBSL Cancer Risk RBSL Hazard Quotient RBSL Cancer Risk RBSL 

Chemical (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Organics

Carbon disulfide 4.00E-01 NA --- 1.02E+03 3.91E-05 NA --- 1.56.E+02 bis(2-Ethylhexyl) phthalate 2.70E+00 20.4 1.32E-07 2.04E+02 1.32E-03 4.8E+00 5.62E-07 3.13.E+01 Phenol 9.00E-01 NA --- 3.07E+03 2.94E-05 NA --- 4.69.E+02 

Inorganics

Aluminum 2.91E+02 NA --- 1.02E+04 2.85E-03 NA --- 1.56.E+03 Antimony 2.79E+00 NA --- 4.09E+00 6.83E-02 NA --- 6.26.E-01 Arsenic 4.35E+00 0.2 2.28E-05 3.07E+00 1.42E-01 4.5E-02 9.70E-05 4.69.E-01 Barium 7.44E+01 NA --- 7.15E+02 1.04E-02 NA --- 1.10.E+02 Beryllium 7.10E-01 NA --- 2.04E+01 3.47E-03 NA --- 3.13.E+00 Calcium 7.69E+04 NA --- NA --- NA --- NA Chromium 2.13E+00 NA --- 3.07E+01 6.93E-03 NA --- 4.69.E+00 Cobalt 3.14E+01 NA --- 2.04E+02 1.54E-02 NA --- 3.13.E+01 Copper 5.44E+00 NA --- 4.09E+02 1.33E-03 NA --- 6.26.E+01 Iron 1.87E+04 NA --- 3.07E+03 6.09E-01 NA --- 4.69.E+02

Lead 9.42E-01 NA --- 1.50E+01 --- NA --- NA Magnesium 2.99E+04 NA --- NA --- NA --- NA Manganese 1.25E+03 NA --- 2.04E+02 6.11E-01 NA --- 3.13.E+01 Nickel 2.25E+01 NA --- 2.04E+02 1.10E-02 NA --- 3.13.E+01 Potassium 1.85E+03 NA --- NA --- NA --- NA Silver 1.20E+00 NA --- 5.11E+01 2.35E-03 NA --- 7.82.E+00 Sodium 9.11E+03 NA --- NA --- NA --- NA Vanadium 7.60E+00 NA --- 7.15E+01 1.06E-02 NA --- 1.10.E+01 Zinc 1.45E+01 NA --- 3.07E+03 4.72E-04 NA --- 4.69.E+02 

Total Estimated Cancer Risk 2.29E-05 Total Estimated Cancer Risk 9.76E-05

Total Estimated Hazard Index 1.50E+00 Total Estimated Hazard Index 9.78E+00

a Refer to Table 6-9 of RI/RA. b Groundwater risks for each chemical were determined by "risk ratio" of the EPC with chemical-specific, 

commercial/ industrial and residential, risk-based screening levels. See text in Section 5 for details of methodology. 

c Target risk, 1E-06. d Target hazard quotient, 0.1. e Action level for lead (EPA, 2001) 

C = Target risk, 1E-06. N = Target hazard quotient, 0.1. Total RBSL = Risk-Based Screening Level. 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 30 T-40 
Table 31

Comparison of Subsurface Levels of COPCs with SSLs for Groundwater Protection,

Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Maximum 

Subsurface GW SSL Subsurface GW SSL 

Concentration (THQ, 0.1, DAF, 20) Exceedance EPC (THQ, 1, DAF, 20) Exceedance 

(mg/kg) (mg/kg) (Y or N) (mg/kg) (mg/kg) (Y or N) 

Acetone 0.092 0.25 N N 0.019 2.46 N N 0.015 ± 0.023 Trichloroethene 0.003 0.00023 C Y 0.003 0.00023 C Y 0.0059 ± 0.00068 1,2,4-Trichlorobenzene 0.087 0.05 N Y 0.087 0.5 N N 0.19 ± 0.024 2,4-Dinitrotoluene ND 0.00059 C --- ND 0.00059 C --- ND 2-Chlorophenol 0.12 0.059 N Y 0.12 0.59 N N 0.2 ± 0.019 4-Nitrophenol 0.33 0.17 N Y 0.33 1.68 N N 0.49 ± 0.045 Acenaphthene 0.67 7.3 N N 0.24 73 N N 0.2 ± 0.094 Benz[a]anthracene 1.5 0.95 C Y 0.25 0.95 C N 0.2 ± 0.24 Benzo[a]pyrene 1.5 0.36 C Y 0.25 0.36 C N 0.21 ± 0.24 Benzo[b]fluoranthene 2.4 3.07 C N 0.28 3.07 C N 0.24 ± 0.40 Carbazole 0.67 0.16 C Y 0.23 0.16 C Y 0.21 ± 0.08 Dibenz[a,h]anthracene 0.28 0.66 C N 0.21 0.66 C N 0.2 ± 0.032 Fluorene 0.87 7.6 N N 0.23 76 N N 0.22 ± 0.12 Indeno[1,2,3-cd]pyrene 1.0 15.1 C N 0.24 15.1 C N 0.19 ± 0.16 Naphthalene 0.35 0.034 N Y 0.21 0.34 N N 0.2 ± 0.027 n-Nitrosodi-n-Propylamine ND 0.000045 C --- ND 0.000045 C --- ND Pentachlorophenol 0.5 0.014 C Y 0.5 0.014 C Y 0.49 ± 0.047 Pyrene 4.2 49.7 N N 0.39 497 N N 0.35 ± 0.71 alpha-BHC ND 0.00079 C --- ND 0.00079 C --- ND Dieldrin ND 0.0043 C --- ND 0.0043 C --- ND Heptachlor Epoxide ND 0.0021 C --- ND 0.0021 C --- ND Aroclor 1242 ND 0.1 C --- ND 0.1 C --- ND Aroclor 1254 0.095 0.13 C N 0.025 0.13 C N 0.023 ± 0.014 Aluminum 17,500 109,515 N N 15,752 1,095,146 N N 12,918 ± 3,797 1Antimony 9.8 1.32 N Y 2.98 13.2 N N 1.75 ± 2.34 Arsenic 32 0.026 C Y 11.9 0.026 C Y 9.18 ± 6.67 Barium 1,300 211 N Y 366 2,105 N N 290 ± 295 Beryllium 3.8 63.2 N N 1.43 632 N N 1.08 ± 0.64 Cadmium 8.9 5.49 N Y 8.9 54.9 N N 1.46 ± 2.58 0Chromium 285 4.2 N Y 64.2 42 N Y 49.8 ± 64.9 Cobalt 44.1 66.0 N N 20 660 N N 16.9 ± 10.2 Copper 109 1,052 N N 55.4 10,518 N N 44.8 ± 25.3 Iron 55,800 552 N Y 55,800 5,519 N Y 38,253 ± 12,474 3Lead 1,170 270 Y 308 270 Y 174 ± 307 Manganese 2,270 95.2 N Y 1,994 952 N Y 665 ± 531 Mercury 0.19 21.9 N N 0.076 219 N N 0.061 ± 0.041 0Nickel 75.7 95.2 N N 36.1 952 N N 31.3 ± 15.8 Selenium 2.1 1.9 N Y 1.07 19 N N 0.77 ± 0.58 Silver 0.66 3.1 N N 0.26 31 N N 0.21 ± 0.2 0Thallium 0.53 0.36 N Y 0.17 3.64 N N 0.15 ± 0.086 Vanadium 37.4 511 N N 30.1 5,111 N N 25.8 ± 6.83 Zinc 654 1,362 N N 186 13,622 N N 139 ± 153 Level 1 COPC Selectiona

Subsurface Arithmetic 

Meanb ± Standard 

Deviation OVSA (mg/kg)

Subsurf

± S

Ba

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 31 T-41 
Table 31

Comparison of Subsurface Levels of COPCs with SSLs for Groundwater Protection,

Open Vehicle Storage Area (East), DSERTS Site LEAD-114, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Note: Shading indicates there is an exceedance. 

a COPCs for groundwater impact were selected by comparing the maximum detected concentration in aggregate soils to groundwater SSLs at a DAF of 1, and a THQ of 0.1 or a TR of 1E-06 in the 

 (see Table 6-2 of RI/RA, RAGS Part D, Table 2.1).

b Nondetects were included at half the sample quantitation limit.c Shale-derived horizons B (0.5-1.0 ft bgs) and C (3-4.5 ft bgs) combined; see Table 5-30 of RI/RA.d Right-tailed Mann-Whitney U-Test at 95% confidence level was performed for those chemicals that exceeded the GW SSL (DAF, 20; THQ,1). 

 See Subsection 5.2.10 of RI/RA for explanation of methods and Appendix G of RI/RA for documentation.

e The GW SSL for lead cannot be adjusted based on noncancer effects because the drinking water action level was used in the calculation.

C = Carcinogenic.COPC = Chemical of potential concern.DAF = Dillution attenuation factor.EPC = Exposure point concentration. mg/kg = Milligrams per kilogram.N = Non-carcinogenic.ND = Not detected. With respect to the site data, these chemicals had GW SSL exceedances in surface soils only.NS = Not significantly different (p > 0.05).S = Significantly different (p < 0.05).SSL = Soil screening level. 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 31 T-42 
Table 32

Comparison of Subsurface Levels of COPCs with SSLs for Groundwater Protection

Uncurbed AST North of Building 532, DSERTS Site LEAD-126, PDO OU 6, 

Letterkenny Army Depot - Chambersburg, PA

Maximum

Subsurface GW SSL Subsurface GW SSL 

Concentration (THQ, 0.1, DAF, 20) Exceedance EPC (THQ, 1, DAF, 20) Exceedance 

Level 1 COPC Selection (mg/kg) (mg/kg) (Y or N) (mg/kg) (mg/kg) (Y or N) 

a

Subsurface Arithmetic Meanb 

± Standard Deviation AST at 

Building 532 (mg/kg)

S

Acetone 0.016 0.25 N N 0.016 2.46 N N 0.01 ± 0.0055 Leade 17.6 270 N N 17.1 270 N N 14.9 ± 1.88 

a COPCs for groundwater impact were selected by comparing the maximum detected concentration in aggregate soils to groundwater SSLs at a DAF of 1, and a THQ of 0.1 or a TR of 1E-06 in the original 

(see Table 6-2 of RI/RA, RAGS Part D, Table 2.1).

b Nondetects were included at half the sample quantitation limit.c Shale-derived horizons B (0.5-1 ft bgs) and C (3-4.5 ft bgs) combined; see Table 5-23 of RI/RA.d Right-tailed Mann-Whitney U-Test at 95% confidence level was performed for those chemicals that exceeded the GW SSL (DAF, 20; THQ,1). 

 See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix E of RI/RA for documentation

e The GW SSL for lead cannot be adjusted because the action level, not the tapwater RBC, was used in the calculation.

COPC = Chemical of potential concern.

EPC = Exposure point concentration. mg/kg = Milligrams per kilogramN = Noncancer value.ND = Not detected.SSL = Soil screening level. 

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 32 T-43 
Table 33

Comparison of Subsurface Levels of COPCs with SSLs for Groundwater Protection

Backwash Discharge Area from the Water Treatment Plant - DSERTS Site LEAD-011, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Maximum 

Subsurface GW SSL Subsurface GW SSL 

Concentration (THQ, 0.1, DAF, 20) Exceedance EPC (THQ, 1, DAF, 20) Exceedance 

Level 1 COPC Selection (mg/kg) (mg/kg) (Y or N) (mg/kg) (mg/kg) (Y or N) 

a

Subsurface Arithmetic Meanb 

± Standard Deviation BDA 

(mg/kg)

Sub

Aluminum 19,300 109,515 N N 19,300 1,095,146 N N 16,333 ± 2,122 

Antimony ND 1.32 N --- ND 13.2 N --- ND 

Arsenic 11.5 0.026 C Y 11.5 0.026 C Y 9.6 ± 1.85 

Barium 228 211 N Y 228 2,105 N N 176 ± 58.4 

Chromium 34.3 4.2 N Y 34.3 42 N N 28.6 ± 4.92 

Cobalt 27.6 66 N N 27.6 660 N N 24.6 ± 2.17 Iron 42,400 552 N Y 42,400 5,519 N Y 41,083 ± 1,154 Leade 31.3 270 N N 31.3 270 N N 24.2 ± 6.91 Manganese 1,250 95.2 N Y 1,250 952 N Y 759 ± 493 Nickel 46.6 95.2 N N 46.6 952 N N 37.9 ± 8.44 Selenium ND 1.9 N --- ND 19 N --- ND 

Silver 0.49 3.1 N N 0.49 31 N N 0.42 ± 0.068 

Thallium ND 0.36 N --- ND 3.64 N --- ND 

Vanadium 33.8 511 N N 33.8 5,111 N N 32.2 ± 2.18 

Zinc 104 1,362 N N 104 13,622 N N 94.8 ± 8.3 

Note: Shading indicates there is an exceedance. 

a COPCs for groundwater impact were selected by comparing the maximum detected concentration in aggregate soils to groundwater SSLs at a DAF of 1, and a THQ of 0.1 or a TR of 1E-06 in the origin

 (see Table 6-2 of RI/RA, RAGS Part D, Table 2.1).

b Non-detects were included at half the sample quantitation limit.c Shale-derived Horizons B (0.4-1.8 ft bgs) and C (3-4.5 ft bgs) combined. See Table 5-23 of RI/RA.d Right-tailed Mann-Whitney U-Test at 95% confidence level was performed for those chemicals that exceeded the GW SSL (DAF, 20; THQ,1). 

 See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix E of RI/RA for documentation

e The GW SSL for lead cannot be adjusted based on noncancer effects because the drinking water Action Level was used in the calculation.

C = Carcinogenic.COPC = Chemical of potential concern.

EPC = Exposure point concentration. mg/kg = Milligrams per kilogramN = Non-carcinogenic.ND = Not detected. With respect to the site data, these chemicals had GW SSL exceedances in surface soils only.NP = Mann Whitney test could not be performed due to insufficient sample size (n=3)SSL = Soil screening level.

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 33 T-44 
Table 34

Building 400 Series Fire Training Area - Evaluation of Potential Groundwater Impacts of Chemicals in Subsurface Soils,

Limestone Soils, 

Maximum

Subsurface GW SSL Subsurface GW SSL 

Concentration (THQ, 0.1, DAF, 20) Exceedance EPC (THQ, 1, DAF, 20) Exceedance 

(mg/kg) (mg/kg) (Y or N) (mg/kg) (mg/kg) (Y or N) 

Level 1 COPC Selectiona

Subsurface Arithmetic Meanb 

± Standard Deviation FTA 

(mg/kg)

Subsurface Arith

± Standard D

Background 

Letterkenny Army Depot - Chambersburg, PA

Acetone 0.054 0.25 N N 0.023 2.46 N N 0.028 ± 0.025 ND Benz[a]anthracene 0 0.95 C N 0.130 0.95 C N NA ND Benzo[a]pyrene 0 0.36 C N 0.093 0.36 C N NA ND 2,3,7,8-TCDD TEQ 0.0000049 0.00004804 C N 0.0000034 0.00004804 C N 0.0000033 ± 0.0000014 NA Aluminum 17,900 109,515 N N 13,756 1,095,146 N N 12,068 ± 3,962 10,681 ± Antimony 0.96 1.32 N N 0.61 13.2 N N 0.603 ± 0.373 0.073 ± Arsenic 29.4 0.026 C Y 12.9 0.026 C Y 12.66 ± 11.92 5.72 ± Barium 692 211 N Y 344 2,105 N N 388 ± 234 31.8 ± Chromium 26.9 4.2 N Y 21.4 42 N N 16.0 ± 7.87 9.67 ± Cobalt 35.8 66.0 N N 23.4 660 N N 18.5 ± 14.92 19.4 ± Iron 44,400 552 N Y 38,965 5,519 N Y 38,813 ± 7,878 52,955 ± Leade 52.3 270 N 43.3 270 N 29.2 ± 7.11 17.9 ± 

Manganese 1,780 95.2 N Y 1,372 952 N Y 978 ± 696 354 ± Nickel 45.6 95.2 N N 29.1 952 N N 25.6 ± 14.89 16.9 ± Thallium 1.0 0.36 N Y 0.3 3.64 N N 0.359 ± 0.428 0.091 ± Vanadium 38.6 511 N N 28.5 5,111 N N 24.9 ± 10.59 8.22 ± Zinc 95.7 1,362 N N 78.9 13,622 N N 56.1 ± 22.4 37.6 ± Note: Shading indicates there is an exceedance. 

a COPCs for groundwater impact were selected by comparing the maximum detected concentration in aggregate soils to groundwater SSLs at a DAF of 1, and a THQ of 0.1 or a TR of 1b Nondetects were included at half the sample quantitation limit.c Limestone-derived horizons B (2.0-3.5 ft bgs) and C (4-8 ft bgs) combined; see Table 5-31 of RI/RA.d Right-tailed Mann-Whitney U-Test at 95% confidence level was performed for those chemicals that exceeded the GW SSL (DAF, 20; THQ,1). 

 See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix F.2 of RI/RA for documentation.

e The GW SSL for lead cannot be adjusted based on noncancer effects because the drinking water action level was used in the calculation.

C = CarcinogenicCOPC = Chemical of potential concernmg/kg = Milligrams per kilogramN = Non-carcinogenicND = Not detected. With respect to the site data, these chemicals had GW SSL exceedances in surface soils only.NS = Not significantly different (p > 0.05)S = Significantly different (p < 0.05)

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 34

T-45
Table 35

Building 400 Series Fire Training Area - Evaluation of Potential Groundwater Impacts of Chemicals in Subsurface Soils,

Shale Soils, 

Letterkenny Army Depot - Chambersburg, PA

Maximum

Subsurface GW SSL Subsurface GW SSL 

Concentration (THQ, 0.1, DAF, 20) Exceedance EPC (THQ, 1, DAF, 20) Exceedance 

(mg/kg) (mg/kg) (Y or N) (mg/kg) (mg/kg) (Y or N) 

Level 1 COPC Selectiona

Subsurface Arithmetic 

Meanb ± Standard 

Deviation FTA (mg/kg)

Subsurfa

Meanb,c 

Deviation 

(m

Acetone 0.054 0.25 N N 0.023 2.46 N N 0.028 ± 0.025 Benz[a]anthracene 0.130 0.95 C N 0.130 0.95 C N NA Benzo[a]pyrene 0.093 0.36 C N 0.093 0.36 C N NA 2,3,7,8-TCDD TEQ 0.0000049 0.00004804 C N 0.0000034 0.00004804 C N 0.0000033 ± 0.0000014 Aluminum 17,900 109,515 N N 13,756 1,095,146 N N 12,068 ± 3,962 15,833 Antimony 0.96 1.32 N N 0.61 13.2 N N 0.603 ± 0.373 0.213 Arsenic 29.4 0.026 C Y 12.9 0.026 C Y 12.66 ± 11.92 7.38 Barium 692 211 N Y 344 2,105 N N 388 ± 234 102 Chromium 26.9 4.2 N Y 21.4 42 N N 16.0 ± 7.87 24.0 Cobalt 35.8 66.0 N N 23.4 660 N N 18.5 ± 14.92 31.6 Iron 44,400 552 N Y 38,965 5,519 N Y 38,813 ± 7,878 35,056 Leade 52.3 270 N 43.3 270 N 29.2 ± 7.11 19.0 

Manganese 1,780 95.2 N Y 1,372 952 N Y 978 ± 696 739.0 Nickel 45.6 95.2 N N 29.1 952 N N 25.6 ± 14.89 27.4 Thallium 1.0 0.36 N Y 0.3 3.64 N N 0.359 ± 0.428 0.186 Vanadium 38.6 511 N N 28.5 5,111 N N 24.9 ± 10.59 23.2 Zinc 95.7 1,362 N N 78.9 13,622 N N 56.1 ± 22.4 55.8 Note: Shading indicates there is an exceedance. 

a COPCs for groundwater impact were selected by comparing the maximum detected concentration in aggregate soils to groundwater SSLs at a DAF of 20, and a THQ of 0.1 or a TR of 1Eb Nondetects were included at half the sample quantitation limit.c Shale-derived horizons B (0.5-1.0 ft bgs) and C (3.0-4.5 ft bgs) combined; see Table 5-31 of RI/RA.d Right-tailed Mann-Whitney U-Test at 95% confidence level was performed for those chemicals that exceeded the GW SSL (DAF, 20; THQ,1). 

 See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix F.2 of RI/RA for documentation.

e The GW SSL for lead cannot be adjusted based on noncancer effects because the drinking water action level was used in the calculation.

C = CarcinogenicCOPC = Chemical of potential concernmg/kg = Milligrams per kilogramN = Non-carcinogenicND = Not detected. With respect to the site data, these chemicals had GW SSL exceedances in surface soils only.NS = Not significantly different (p > 0.05)S = Significantly different (p < 0.05)

MK01\O:\02281016.008\PhaseIII\ROD\Tables 8 -20, 26 - 35 risk tables.xls\Tab 35 T-46 
Table 36

Species of Special Concern,a

Phase III Sites,

Letterkenny Army Depot,

Chambersburg, PA

Federal State Last Seen in

Scientific Name Common Name Statusb Statusb Franklin Co. c

Known to occur at LEAD

Canis latrans Coyote N U 1987

May occur at LEAD

Cryptotis parva Least shrew N E 1949

Clemmys muhlenbergii Bog turtle T E --

Crotalus horridus Timber rattlesnake N C 1985

Ruellia humilis Fringed-leaved petunia N E 1984

Opuntia humifusa Prickley-pear cactus N R 1987

Spiia americana Dickcissel sparrow N U 1986

Senecio antennariifolius Cat's paw ragwort N E 1986

a Source: Environmental Science and Engineering (ESE), Inc. 1992. Risk Assessment of 

the Property Disposal Area at Letterkenny Army Depot; Operable Units 1 and 2. 

Final Report. Prepared for the Army Environmental Center. ENAEC-IR-CR-93090.

b Species status as of June 2000.

c Status as of October 1992, as listed in ESE (1992).

N = Not a Federal species of concern.

E = Endangered species.

T = Threatened species.

R =

native wild plants classified as Disjunct, Endemic, Limit of Range, and Restricted 

are included within the Pennsylvania Rare classification.

U = Unknown status.

C = Animal considered at risk. Animal that could become endangered or threatened

in the future; uncommon or has restricted habitat distribution.

Plant species that are uncommon within the Commonwealth. All species of the

MK01\O:\02281016.008\Tables 36-46.xls(Table 36) T-47 5/20/2003
Table 37

Level 1 SLERA —

Comparison of Maximum Detected Soil Concentrations (0-0.5 ft) with Ecological Benchmarks,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Maximum Microorganisms/ NOAEL-Based Wildlife Region III Lo

Detected Earthworm Microbial Processes Benchmarks BTAG Ecol

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmarks Benc

Chemical (mg/kg) Sample ID (mg/kg)a (mg/kg)b (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg

Volatiles

Acetone 0.04 57TP04B001 NBA NBA NBA NBA NBA NBA N

Semivolatiles

bis(2-Ethylhexyl)phthalate 0.70 57TP14B001 NBA NBA NBA 0.09 e 4.1E-04 e NBA 0.0

Carbazole 0.35 57TP67B001 NBA NBA NBA NBA NBA NBA NDibenzofuran 0.16 57TP67B001 NBA NBA NBA NBA NBA NBA NDi-n-Butylphthalate 0.09 57DS05D001 200 NBA NBA NBA NBA NBA 22,4-Dinitrotoluene 0.19 57TP58B001 NBA NBA NBA NBA NBA NBA N2-Methylnaphthalene 0.16 57TP75B001 NBA NBA NBA NBA NBA NBA Nn-Nitrosodipropylamine 0.04 57TP58B001 NBA NBA NBA NBA NBA NBA N

Polycyclic Aromatic Hydrocarbons

Acenaphthene 0.46 57TP67B001 20.0 NBA NBA NBA NBA 0.10 f 0

Anthracene 0.46 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Benz(a)anthracene 1.90 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Benzo(a)pyrene 1.90 57TP67B001 NBA NBA NBA NBA NBA 0.10 h 0Benzo(b)fluoranthene 2.80 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Benzo(ghi)perylene 1.20 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Benzo(k)fluoranthene 0.90 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Chrysene 2.20 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Dibenz(a,h)anthracene 0.36 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Fluoranthene 4.10 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Fluorene 0.28 57TP67B001 NBA 30.0 NBA NBA NBA 0.10 f 0Indeno(1,2,3-cd)pyrene 1.40 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Napthalene 0.12 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Phenanthrene 2.60 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0Pyrene 3.70 57TP67B001 NBA NBA NBA NBA NBA 0.10 f 0

Polychlorinated Biphenyls

Aroclor 1242 0.10 57TP52B001 40.0 i NBA NBA 0.04 i 0.07 i 0.10 g 0

Aroclor 1260 0.08 57TP07B001 40.0 i NBA NBA 0.04 i 0.07 i 0.10 g 0

Pesticides

alpha-BHC 0.001 57DS04D001 NBA NBA NBA NBA NBA 100 h 1

alpha-Chlordane 0.01 57DS04D001 NBA NBA NBA NBA NBA 0.10 f 0

Dieldrin 0.002 57DS04D001 NBA NBA NBA NBA NBA 0.10 f 0Endrin ketone 0.003 57DS04D001 NBA NBA NBA NBA NBA 0.10 f 0gamma-Chlordane 0.01 57DS04D001 NBA NBA NBA NBA NBA 0.10 f 0Heptachlor epoxide 0.002 57DS04D001 NBA NBA NBA NBA NBA 0.10 f 0

MK01\O:\02281016.008\Tables 36-46.xls(Table 37) T-48 
Table 37

Level 1 SLERA —

Comparison of Maximum Detected Soil Concentrations (0-0.5 ft) with Ecological Benchmarks,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Maximum Microorganisms/ NOAEL-Based Wildlife Region III Lo

Detected Earthworm Microbial Processes Benchmarks BTAG Ecol

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmarks Benc

Chemical (mg/kg) Sample ID (mg/kg)a (mg/kg)b (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg

Inorganics

Aluminum 19,100 57TP03B001 50.0 NBA 600 NBA NBA 1.0 g 1

Antimony 3.70 57TP21B001 5.00 NBA NBA NBA NBA 0.48 g 0Arsenic 13.6 57SD05D001 10.0 60.0 100 0.99 10.2 328 g 0Barium 364 57TP26B001 500 NBA 3,000 32.9 28.3 440 g 2Beryllium 1.40 57TP02B001 10.0 NBA NBA NBA NBA 0.02 g 0Cadmium 14.7 57SB06B001 4.00 20.0 20.0 0.60 0.42 2.50 g 0Calcium j 198,000 57TP17B001 NBA NBA NBA NBA NBA NBA N

Chromium 72.1 57DS07D001 1.00 0.40 10.0 11.0 1.61 0.01 h 0

Cobalt 41.9 57TP29B001 20.0 NBA 1,000 NBA NBA 100 g 2Copper 59.9 57TP12B001 100 50.0 100 37.0 51.5 15.0 g 1Iron 52,100 57TP24B001 NBA NBA 200 NBA NBA 12.0 h 1Lead 212 57TP60B001 50.0 500 900 74.0 4.05 0.01 h 0Magnesium 11,400 57TP17B001 NBA NBA NBA NBA NBA 4,400 f 4,

Manganese 4,840 57DS05D001 500 NBA 100 NBA NBA 330 g 1

Mercury 1.10 57DS04D001 0.30 0.10 30.0 0.01 0.00005 0.06 f 0.0

Nickel 50.2 57SD05D001 30.0 200 90.0 24.6 12.1 2.00 g 2

Potassium j 2,420 57TP23B001 NBA NBA NBA NBA NBA NBA N

Selenium 2.30 57SD05D001 1.00 70.0 100 0.02 42.0 1.80 f 0

Silver 0.46 57TP62B001 2.00 NBA 50.0 NBA NBA 0.00001 g 0.0

Sodium j 345 57DS06D001 NBA NBA NBA NBA NBA NBA N

Thallium 0.34 57TP31B001 1.00 NBA NBA 0.21 NBA 0.001 g 0.

Vanadium 34.6 57TP61B001 2.00 NBA 20.0 5.50 NBA 0.50 g 0

Zinc 220 57DS05D001 50.0 200 100 160 0.85 10.0 g 0

Note: Shading indicates the maximum detection exceeds the benchmark.

mg/kg = Milligrams per kilogram.NBA = No benchmark available.NOAEL = No-observed-adverse-effect level. 

a ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.b ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 1997 Revision. 

c ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints.

d EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

e

f Region III BTAG soil screening level for flora and fauna.

g Region III BTAG soil screening level for flora.h Region III BTAG soil screening level for fauna.

i Benchmark for total PCBs was used as surrogate value.j Chemical is an essential nutrient, and concentrations at the site are not expected to pose a significant ecological risk to organisms at this site. 

Derived with information provided in U.S. EPA. 1999. Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities. EPA530-D-99-001C.

MK01\O:\02281016.008\Tables 36-46.xls(Table 37) T-49 
Table 38

Level 2 SLERA —

Comparison of Exposure Point Concentrations of Chemicals of Concern in Soils with Ecological Benchmarks,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Exposure Microorganisms/ NOAEL-Based Wildlife Region III Lowest 

Point Earthworm Microbial Processes Benchmarks BTAG Ecologica

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmarks Benchmar

Chemical (mg/kg)a (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg/kg)d (mg/kg)e (mg/kg) 

Volatiles

Acetone 0.04 NBA NBA NBA NBA NBA NBA NBA 

Semivolatile Organic Chemicals

bis(2-Ethylhexyl)phthalate 0.13 NBA NBA NBA 0.01 f 0.00004 f NBA 0.00004 

Carbazole 0.20 NBA NBA NBA NBA NBA NBA NBA Dibenzofuran 0.16 NBA NBA NBA NBA NBA NBA NBA 2,4-Dinitrotoluene 0.19 NBA NBA NBA NBA NBA NBA NBA 2-Methylnaphthalene 0.16 NBA NBA NBA NBA NBA NBA NBA n-Nitrosodipropylamine 0.04 NBA NBA NBA NBA NBA NBA NBA 

Polycyclic Aromatic Hydrocarbons

Acenaphthene 0.28 20.0 NBA NBA NBA NBA 0.10 g 0.10 

Anthracene 0.26 NBA NBA NBA NBA NBA 0.10 g 0.10 Benz(a)anthracene 0.50 NBA NBA NBA NBA NBA 0.10 g 0.10 Benzo(a)pyrene 0.52 NBA NBA NBA NBA NBA 0.10 i 0.10 Benzo(b)fluoranthene 0.59 NBA NBA NBA NBA NBA 0.10 g 0.10 Benzo(ghi)perylene 0.35 NBA NBA NBA NBA NBA 0.10 g 0.10 Benzo(k)fluoranthene 0.30 NBA NBA NBA NBA NBA 0.10 g 0.10 Chrysene 0.57 NBA NBA NBA NBA NBA 0.10 g 0.10 Dibenz(a,h)anthracene 0.23 NBA NBA NBA NBA NBA 0.10 g 0.10 Fluoranthene 0.82 NBA NBA NBA NBA NBA 0.10 g 0.10 Fluorene 0.28 NBA 30.0 NBA NBA NBA 0.10 g 0.10 Indeno(1,2,3-cd)pyrene 0.37 NBA NBA NBA NBA NBA 0.10 g 0.10 Napthalene 0.1200000 NBA NBA NBA NBA NBA 0.10 g 0.10 Phenanthrene 0.71 NBA NBA NBA NBA NBA 0.10 g 0.10 Pyrene 0.81 NBA NBA NBA NBA NBA 0.10 g 0.10 

Polychlorinated Biphenyls

Aroclor 1242 0.10 40.0 j NBA NBA 0.04 j 0.07 j 0.10 h 0.04 

Aroclor 1260 0.08 40.0 j NBA NBA 0.04 j 0.07 j 0.10 h 0.04 

Inorganics

Aluminum 14,843 50 NBA 600 NBA NBA 1.00 h 1.00 

Antimony 0.78 5.0 NBA NBA NBA NBA 0.48 h 0.48 Arsenic 8.75 10.0 60.0 100 0.99 10.2 328 h 0.99 Barium 163 500 NBA 3,000 32.9 28.3 440 g 28.3 

MK01\O:\02281016.008\Tables 36-46.xls(Table 38) T-50 
Table 38

Level 2 SLERA —

Comparison of Exposure Point Concentrations of Chemicals of Concern in Soils with Ecological Benchmarks,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Exposure Microorganisms/ NOAEL-Based Wildlife Region III Lowest 

Point Earthworm Microbial Processes Benchmarks BTAG Ecologica

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmarks Benchmar

Chemical (mg/kg)a (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg/kg)d (mg/kg)e (mg/kg) 

Beryllium 1.06 10.0 NBA NBA NBA NBA 0.02 h 0.02 

Cadmium 5.10 4.0 20.0 20.0 0.60 0.42 2.50 h 0.42 Chromium 29.5 1.0 0.40 10.0 11.0 1.61 0.01 i 0.01 Cobalt 24.4 20 NBA 1,000 NBA NBA 100 h 20.0 Copper 42.1 100 50.0 100 37.0 51.5 15.0 h 15.0 Iron 43,001 NBA NBA 200 NBA NBA 12.0 i 12.0 Lead 56 50 500 900 74.0 4.05 0.01 i 0.01 Magnesium 6,123 NBA NBA NBA NBA NBA 4,400 g 4,400 

Manganese 1,137 500 NBA 100 NBA NBA 330 g 100 

Mercury 0.07 0.30 0.10 30.0 0.01 0.00005 0.06 g 0.00005 

Nickel 33.3 30.0 200 90.0 24.6 12.1 2.00 h 2.00 

Selenium 1.11 1.0 70.0 100 0.02 42.0 1.80 g 0.02 Silver 0.13 2.0 NBA 50.0 NBA NBA 0.00001 h 0.00001 

Thallium 0.13 1.0 NBA NBA 0.21 NBA 0.001 h 0.001 

Vanadium 27.5 2.0 NBA 20.0 5.50 NBA 0.50 h 0.50 

Zinc 106 50 200 100 160 0.85 10.0 h 0.85 

Note: Shading indicates the maximum detection exceeds the benchmark.

mg/kg = Milligrams per kilogram.NBA = No benchmark available.NOAEL = No-observed-adverse-effect level. 

a See Table 6-24 of RI/RA.

b ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.

c ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 1997 Revision. 

d ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints.

e EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

f

g Region III BTAG soil screening level for flora and fauna.

h Region III BTAG soil screening level for flora.

i Region III BTAG soil screening level for fauna.j Benchmark for total PCBs were used as surrogate value.

Derived with information provided in U.S. EPA. 1999. Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities. EPA530-D-99-001C.

MK01\O:\02281016.008\Tables 36-46.xls(Table 38) T-51 
Table 39

Statistical Comparison of Site and Background Chemical Concentrations in Shale Surface Soils,

Open Vehicle Storage Area,

Letterkenny Army Depot,

Chambersburg, PA

Chemical 

Data Distribution 

OVSA

Data Distributio

Shale Referenc

Inorganics

Aluminum 13,747 ± 3,282 default (lognormal) 13,515 ± 1,157 normal 

Antimony 0.67 ± 0.66 lognormal 0.36 ± 0.11 normal Arsenic 8.21 ± 2.36 normal 8.05 ± 0.58 normal Barium 148 ± 61.6 default (lognormal) 134 ± 28.0 default (lognorm

Beryllium 1.00 ± 0.18 default (lognormal) 0.83 ± 0.05 normal Cadmium 1.10 ± 2.66 default (lognormal) ND --- 

Chromium 27.1 ± 11.0 default (lognormal) 22.6 ± 1.51 normal Cobalt 22.7 ± 7.24 normal 14.2 ± 3.29 lognormal Copper 39.6 ± 10.6 normal 24.4 ± 2.06 normal Iron 36,384 ± 9,389 default (lognormal) 39,060 ± 2,427 normal Lead 49.9 ± 38.9 default (lognormal) 24.9 ± 1.41 normal Magnesium 5,684 ± 1,886 normal 4,075 ± 427 normal Manganese 1,010 ± 648 lognormal 837 ± 415 default (lognormMercury 0.07 ± 0.16 default (lognormal) ND --- Nickel 31.3 ± 8.67 normal 20.3 ± 2.26 normal Selenium 0.69 ± 0.62 default (lognormal) 1.40 ± 0.19 normal Silver 0.11 ± 0.10 default (lognormal) 0.04 ± 0.01 default (lognormThallium 0.12 ± 0.06 default (lognormal) 0.11 ± 0.05 default (lognormVanadium 26.2 ± 5.53 normal 26.5 ± 1.08 normal Zinc 97.5 ± 32.2 lognormal 57.7 ± 4.93 normal 

Note: Shading indicates significantly different (p < 0.05).

a Non-detects were included at half the sample quantitation limit.

b Surface soils (0-0.5 ft bgs). Data are untransformed as shown in Table 6-1 of RI/RA.

c Horizon A (0-0.5 ft bgs). Data are transformed as shown in Table 5-28 of RI/RA.

d Right-tailed Mann-Whitney U-Test at 95% confidence level. See Subsection 5.2.8 of RI/RA for explanation of methods.

e Reporting limits for the reference soils were used to perform the Mann-Whitney U-Test.

mg/kg = Milligrams per kilogram.ND = Not detected in background.NS = Not significantly different (p > 0.05).

Arithmetic Mean ± Standard 

Deviation OVSAa,b (mg/kg)

Arithmetic Mean ± Standard 

Deviation Shale Referencea,c 

(mg/kg)

MK01\O:\02281016.008\Tables 36-46.xls(Table 39) T-52 
Table 40

Level 1 SLERA —

Comparison of Maximum Detected Soil Concentrations (0-0.5 ft) with Ecological Benchmarks,

Backwash Discharge Area (DSERTS Site LEAD-011),

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Maximum Microorganisms/ NOAEL-Based Wildlife Region III 

Detected Earthworm Microbial Processes Benchmarks BTAG 

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmark

Chemical (mg/kg) Sample ID (mg/kg)a (mg/kg)b (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d 

Inorganics

Aluminum 30,500 34DS03D001 50 NBA 600 NBA NBA 1.00 Antimony 1.30 34DS06D001 5.0 NBA NBA NBA NBA 0.48 Arsenic 14.1 34SB10B001 10 60 100 0.99 10.2 328 Barium 1,110 34SB06B001 500 NBA 3,000 32.9 28.3 440 Beryllium 1.10 34SB03B001 10 NBA NBA NBA NBA 0.02 Cadmium 1.20 34DS06D001 4.0 20 20.0 0.60 0.42 2.50 Calciumh 167,000 34DS06D001 NBA NBA NBA NBA NBA NBA 

Chromium 32.8 34DS03D001 1.00 0.40 10.0 11.0 1.61 0.008 

Cobalt 26.3 34DS01D001 20.0 NBA 1,000 NBA NBA 100 

Copper 48.2 34DS01D001 100 50 100 37.0 51.5 15.0 Iron 46,700 34SB10B001 NBA NBA 200 NBA NBA 12.0 Lead 123 34DS06D001 50.0 500 900 74.0 4.05 0.01 Magnesium 8,690 34DS01D001 NBA NBA NBA NBA NBA 4,400 

Manganese 2,270 34DS03D001 500 NBA 100 NBA NBA 330 

Mercury 0.21 34DS04D001 0.30 0.10 30.0 0.015 0.000051 0.058 

Nickel 46.7 34DS01D001 30.0 200 90.0 24.6 12.1 2.00 

Potassiumh 1,600 34DS01D001 NBA NBA NBA NBA NBA NBA 

Selenium 1.90 57DS01D001 1.0 70 100 0.021 42.0 1.80 

Silver 0.48 34SB10B001 2.0 NBA 50.0 NBA NBA 0.00001 

Sodiumh 217 34DS06D001 NBA NBA NBA NBA NBA NBA 

Thallium 0.16 34SB01B001 1.0 NBA NBA 0.21 NBA 0.001 

Vanadium 28.7 34DS01D001 2.0 NBA 20.0 5.50 NBA 0.50 

Zinc 2,300 34DS03D001 50 200 100 160 0.85 10.0 

Note: Shading indicates the maximum detected concentration exceeds the benchmark.

a ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.

b ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 1997 Revision . 

c ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints. PRGs were adjusted to NOAEL-based criteria using a factor of 10.

d EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

e Region III BTAG soil screening level for flora and fauna.

f Region III BTAG soil screening level for flora.

g Region III BTAG soil screening level for fauna.h Chemical is an essential nutrient, and concentrations at the site are not expected to pose a significant ecological risk to organisms at this site. 

MK01\O:\02281016.008\Tables 36-46.xls(Table 40)

T-53
Table 41

Level 2 SLERA—

Comparison of Exposure Point Concentrations of Chemicals of Concern in Soils with Ecological Benchmarks

Backwash Discharge Area (DSERTS Site LEAD-011),

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Exposure Microorganisms/ NOAEL-Based Wildlife Region III Lo

Point Earthworm Microbial Processes Benchmarks BTAG Eco

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmarks Benc

Chemical (mg/kg)a (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg/kg)d (mg/kg)e (m

Inorganics

Aluminum 19,834 50 NBA 600 NBA NBA 1.00 g 

Antimony 0.84 5.0 NBA NBA NBA NBA 0.480 g 0

Arsenic 9.37 10 60.0 100 0.99 10.2 328 g 0Barium 353 500 NBA 3,000 32.9 28.3 440 f 2Beryllium 0.98 10 NBA NBA NBA NBA 0.020 g 0Cadmium 0.37 4.0 20.0 20.0 0.60 0.42 2.500 g 0Chromium 28.4 1.00 0.40 10.0 11.0 1.61 0.008 h 0Cobalt 22.5 20.0 NBA 1,000 NBA NBA 100 g 2Copper 44.2 100 50.0 100 37.0 51.5 15.0 g 1Iron 37,594 NBA NBA 200 NBA NBA 12.0 h 1Lead 62.5 50 500 900 74.0 4.05 0.010 h 0Magnesium 7,659 NBA NBA NBA NBA NBA 4,400 f 4

Manganese 1,262 500 NBA 100 NBA NBA 330 f 

Mercury 0.11 0.30 0.10 30.0 0.015 0.00005 0.058 f 0.

Nickel 37.7 30 200 90 24.6 12.1 2.0 g 2Selenium 0.88 1.0 70 100 0.02 42.0 1.80 f 0Silver 0.32 2.00 NBA 50.0 NBA NBA 0.0000098 g 0.0

Thallium 0.16 1.0 NBA NBA 0.21 NBA 0.001 g 0Vanadium 25.6 2.0 NBA 20.0 5.50 NBA 0.50 g 0

Zinc 550 50.0 200 100 160 0.85 10.0 g 0

Note: Shading indicates the EPC exceeds the benchmark.

a See Table 6-24 of RI/RA.

b ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.

c ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 

d ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints. PRGs were adjusted to NOAEL-based criteria using a factor of 10.

e EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

f Region III BTAG soil screening level for flora and fauna.

g Region III BTAG soil screening level for flora.h Region III BTAG soil screening level for fauna.

MK01\O:\02281016.008\Tables 36-46.xls(Table 41) T-54 
Table 42

Statistical Comparison of Site and Reference Chemical Concentrations in Shale Surface Soil,

Backwash Discharge Area (DSERTS Site LEAD-011),

Letterkenny Army Depot,

Chambersburg, PA

Data Data

Distribution Distribution Statistical

BDA Shale Reference Analysisd

Chemical Result

Inorganics

Aluminum 15,836 ± 5,865 lognormal 13,515 ± 1,157 normal NSAntimony 0.67 ± 0.32 normal 0.36 ± 0.11 normal SArsenic 7.80 ± 2.87 normal 8.05 ± 0.58 normal NSBarium 220 ± 297 default (lognormal) 134 ± 28.0 default (lognormal) NSBeryllium 0.90 ± 0.13 normal 0.83 ± 0.047 normal NSChromium 25.4 ± 5.47 normal 22.6 ± 1.51 normal SCobalt 19.7 ± 5.17 normal 14.2 ± 3.29 lognormal SCopper 40.7 ± 6.41 normal 24.4 ± 2.06 normal SIron 33,355 ± 7,759 normal 39,060 ± 2,427 normal NSLead 40.0 ± 30.8 lognormal 24.9 ± 1.41 normal NSMagnesium 6,784 ± 1,603 normal 4,075 ± 427 normal SManganese 956 ± 560 normal 837 ± 415 default (lognormal) NSMercury 0.06 ± 0.06 default (lognormal) ND default (lognormal) NSNickel 33.9 ± 6.86 normal 20.3 ± 2.26 normal SSelenium 0.55 ± 0.49 default (lognormal) 1.40 ± 0.19 normal NSSilver 0.24 ± 0.14 normal 0.044 ± 0.013 default (lognormal) SThallium 0.14 ± 0.03 default (lognormal) 0.11 ± 0.053 default (lognormal) NSVanadium 23.1 ± 4.68 normal 26.5 ± 1.08 normal NSZinc 310 ± 661 default (lognormal) 57.7 ± 4.93 normal S

a Nondetects were included at half the sample quantitation limit.

b Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 6-21 of RI/RA.

c Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 5-20 of RI/RA.

d Right-tailed Mann-Whitney U-test at 95% confidence level unless otherwise noted. See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix F of RI/RA f

mg/kg = Milligrams per kilogram.ND = Not detected in reference soils. Statistical comparison based on quanitation limits.NS = Not significantly different (p > 0.05).S = Significantly different (p < 0.05).

Note: Shaded values indicate exceedances.

BDA = Backwash Discharge Area.

Arithmetic Mean ±

 Standard Deviation

Shale Referencea,c 

(mg/kg)

Arithmetic Mean ±

 Standard Deviation

BDA a,b

(mg/kg)

MK01\O:\02281016.008\Tables 36-46.xls(Table 42) T-55 
Table 43

Level 1 SLERA—

Comparison of Maximum Detected Soil Concentrations (0-0.5 ft) with Ecological Benchmarks,

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Maximum Microorganisms/ NOAEL-Based Wildlife Region III 

Detected Earthworm Microbial Processes Benchmarks BTAG 

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmark

Chemical (mg/kg) Sample ID (mg/kg)a (mg/kg)b (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d 

Semivolatiles

bis(2-Ethylhexyl)phthalate 0.240 71TP02B001 NBA NBA NBA 0.090 e 0.00041 e NBA 

Polycyclic Aromatic Hydrocarbons

Benz(a)anthracene 0.130 71TP02B001 NBA NBA NBA NBA NBA 0.10 

Benzo(a)pyrene 0.093 71TP02B001 NBA NBA NBA NBA NBA 0.10 Benzo(b)fluoranthene 0.150 71TP02B001 NBA NBA NBA NBA NBA 0.10 Chrysene 0.140 71TP02B001 NBA NBA NBA NBA NBA 0.10 Fluoranthene 0.250 71TP02B001 NBA NBA NBA NBA NBA 0.10 Phenanthrene 0.130 71TP02B001 NBA NBA NBA NBA NBA 0.10 Pyrene 0.210 71TP02B001 NBA NBA NBA NBA NBA 0.10 

Polychlorinated Biphenyls

Aroclor 1260 0.032 71TP02B001 40.0 i NBA NBA 0.037 i 0.066 i 0.100 

Dioxins/Furans

2,3,7,8-TCDD TEQ (Humans/Mammals) 4.96E-06 71TP02B001 NBA NBA NBA 3.2E-07 NBA 0.010 

2,3,7,8-TCDD TEQ (Birds) 4.02E-06 71TP02B001 NBA NBA NBA NBA 1.6E-06 0.010 

Inorganics

Aluminum 17,900 71TP05B001 50.0 NBA 600 NBA NBA 1.00 

Antimony 0.69 71TP08B001 5.00 NBA NBA NBA NBA 0.480 Arsenic 10.0 71TP08B001 10.0 60.0 100 0.990 10.2 328 Barium 282 71TP04B001 500 NBA 3,000 32.9 28.3 440 Beryllium 1.40 71TP02B001 10.0 NBA NBA NBA NBA 0.020 Calciumj 9,770 71TP02B001 NBA NBA NBA NBA NBA NBA 

Chromium 26.9 71TP05B001 1.00 0.400 10.0 11.0 1.61 0.008 

Cobalt 26.0 71TP05B001 20.0 NBA 1,000 NBA NBA 100 Copper 33.9 71TP02B001 100 50.0 100 37.0 51.5 15.0 Iron 44,400 71TP05B001 NBA NBA 200 NBA NBA 12.0 Lead 52.3 71TP02B001 50.0 500 900 74.0 4.05 0.010 Magnesium 5,040 71TP05B001 NBA NBA NBA NBA NBA 4,400 

MK01\O:\02281016.008\Tables 36-46.xls(Table 43)

T-56
Table 43

Level 1 SLERA—

Comparison of Maximum Detected Soil Concentrations (0-0.5 ft) with Ecological Benchmarks,

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Maximum Microorganisms/ NOAEL-Based Wildlife Region III 

Detected Earthworm Microbial Processes Benchmarks BTAG 

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchmark

Chemical (mg/kg) Sample ID (mg/kg)a (mg/kg)b (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d 

Manganese 1,570 71TP01B001 500 NBA 100 NBA NBA 330 

Mercury 0.060 71TP08B001 0.30 0.10 30.0 0.015 0.000051 0.058 

Nickel 32.5 71TP04B001 30.0 200 90.0 24.6 12.1 2.00 Potassiumj 1,390 71TP07B001 NBA NBA NBA NBA NBA NBA 

Silver 0.140 71TP01B001 2.00 NBA 50.0 NBA NBA 0.00001 

Sodiumj 93.8 71TP07B001 NBA NBA NBA NBA NBA NBA 

Thallium 0.130 71TP08B001 1.00 NBA NBA 0.210 NBA 0.001 

Vanadium 32.8 71TP05B001 2.00 NBA 20.0 5.50 NBA 0.500 Zinc 95.7 71TP04B001 50.0 200 100 160 0.850 10.0 Cyanide (Total) 0.24 71TP01B001 NBA NBA NBA NBA NBA 0.005 

Note: Shading indicates the maximum detection exceeds the benchmark.

mg/kg = Milligrams per kilogram.NBA = No benchmark available.PRG = Preliminary remediation goal.NOAEL = No-observed-adverse-effect level. 

a ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.

b ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 1997 Revision . 

c ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints. PRGs were adjusted to NOAEL-based criteria using a factor of 10.

d EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

e

f Region III BTAG soil screening level for flora and fauna.

g Region III BTAG soil screening level for flora.h Region III BTAG soil screening level for fauna.

i Benchmark for total PCBs was used as surrogate value.j Chemical is an essential nutrient, and concentrations at the site are not expected to pose a significant ecological risk to organisms at this site. 

Derived with information provided in U.S.EPA. 1999. Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities. EPA530-D-99-001C.

MK01\O:\02281016.008\Tables 36-46.xls(Table 43)

T-57
Table 44

Level 2 SLERA—

Comparison of Exposure Point Concentrations of Chemicals of Concern in Soils with Ecological Benchmarks

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Exposure Microorganisms/ NOAEL-Based Wildlife Region I

Point Earthworm Microbial Processes Benchmarks BTAG 

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchma

Chemical (mg/kg)a (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg/kg)d (mg/kg)

Semivolatiles

bis(2-Ethylhexyl)phthalate 0.190 NBA NBA NBA 0.090 f 4.1E-04 f NBA 

Polycyclic Aromatic Hydrocarbons

Benz(a)anthracene 0.070 NBA NBA NBA NBA NBA 0.10 

Benzo(b)fluoranthene 0.078 NBA NBA NBA NBA NBA 0.10 Chrysene 0.074 NBA NBA NBA NBA NBA 0.10 Fluoranthene 0.117 NBA NBA NBA NBA NBA 0.10 Phenanthrene 0.070 NBA NBA NBA NBA NBA 0.10 Pyrene 0.103 NBA NBA NBA NBA NBA 0.10 

Dioxins/Furans

2,3,7,8-TCDD TEQ (Humans/Mammals) 0.000003 NBA NBA NBA 3.2E-07 NBA 0.01 

2,3,7,8-TCDD TEQ (Birds) 0.000003 NBA NBA NBA NBA 1.6E-06 0.01 

Inorganics

Aluminum 13,756 50.0 NBA 600 NBA NBA 1.00 

Antimony 0.477 5.0 NBA NBA NBA NBA 0.480 

Arsenic 8.06 10.0 60.0 100 0.99 10.2 328 Barium 215 500 NBA 3,000 32.9 28.3 440 

Beryllium 1.33 10 NBA NBA NBA NBA 0.020 

Chromium 21.4 1.0 0.40 10 11.0 1.61 0.008 

Cobalt 22.5 20 NBA 1,000 NBA NBA 100 Copper 30.7 100 50.0 100 37.0 51.5 15.0 

MK01\O:\02281016.008\Tables 36-46.xls(Table 44) T-58 
Table 44

Level 2 SLERA—

Comparison of Exposure Point Concentrations of Chemicals of Concern in Soils with Ecological Benchmarks

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Oak Ridge National Laboratory Benchmarks 

Exposure Microorganisms/ NOAEL-Based Wildlife Region I

Point Earthworm Microbial Processes Benchmarks BTAG 

Concentration Phytotoxicity Toxicity Toxicity Mammals Birds Benchma

Chemical (mg/kg)a (mg/kg)b (mg/kg)c (mg/kg)c (mg/kg)d (mg/kg)d (mg/kg)

Iron 37,516 NBA NBA 200 NBA NBA 12.0 

Lead 43.3 50 500 900 74.0 4.05 0.010 

Magnesium 3,630 NBA NBA NBA NBA NBA 4,400 Manganese 1,372 500 NBA 100 NBA NBA 330 

Mercury 0.040 0.30 0.100 30 0.015 0.00005 0.058 

Nickel 28.0 30 200 90 24.6 12.1 2.00 Silver 0.089 2.0 NBA 50 NBA NBA 0.0000098 

Thallium 0.093 1.0 NBA NBA 0.21 NBA 0.001 

Vanadium 28.0 2.0 NBA 20 5.5 NBA 0.50 Zinc 78.9 50 200 100 160 0.850 10.0 Cyanide (Total) 0.177 NBA NBA NBA NBA NBA 0.005 

Note: Shading indicates the maximum detection exceeds the benchmark.

mg/kg = Milligrams per kilogram.NBA = No benchmark available.PRG = Preliminary remediation goal.NOAEL = No-observed-adverse-effect level. 

a See Table 6-34 of RI/RA.

b ORNL, 1997a. Oak Ridge National Laboratories. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants: 1997 Revision.

c ORNL, 1997b. Oak Ridge National Laboratories. Toxicological Benchmarks for Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process: 1997 Revis

d ORNL, 1997c. Oak Ridge National Laboratories. Preliminary Remediation Goals (PRGs) for Ecological Endpoints. PRGs were adjusted to NOAEL-based criteria using a factor of 10.

e EPA, 1995b. Region III Biological Technical Assistance Group Screening Levels - Draft. September, 1995. 

f

g Region III BTAG soil screening level for flora and fauna.

h Region III BTAG soil screening level for flora.

i Region III BTAG soil screening level for fauna.

Derived with information provided in U.S. EPA. 1999. Screening Level Ecological Risk Assessment Protocol for Hazardous Waste Combustion Facilities. EPA530-D-99-001C.

MK01\O:\02281016.008\Tables 36-46.xls(Table 44) T-59 
Table 45

Statistical Comparison of Site and Reference Chemical Concentrations in Shale Surface Soil,

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Data Data

Distribution Distribut

B400 FTA Referen

Chemical 

Inorganics

Aluminum 11,558 ± 3,282 normal 13,515 ± 1,157 normaArsenic 6.6 ± 2.2 normal 8.1 ± 0.6 normaBarium 182 ± 50.0 normal 134 ± 28.0 default (lognBeryllium 1.238 ± 0.141 normal 0.830 ± 0.047 normaChromium 18.2 ± 4.74 normal 22.6 ± 1.51 normaCobalt 19.1 ± 5.09 normal 14.2 ± 3.29 lognormCopper 26.063 ± 6.97 normal 24.4 ± 2.06 normaIron 34,450 ± 4,576 normal 39,060 ± 2,427 norma

Lead 37.8 ± 8.15 normal 24.9 ± 1.41 normaManganese 1,134 ± 355 normal 837 ± 415 default (lognMercury 0.032 ± 0.012 default (lognormal) ND default (lognNickel 23.5 ± 6.70 normal 20.3 ± 2.26 normaSilver 0.069 ± 0.029 default (lognormal) 0.044 ± 0.013 default (lognThallium 0.077 ± 0.023 default (lognormal) 0.106 ± 0.053 default (lognVanadium 25.4 ± 3.963 normal 26.5 ± 1.08 normaZinc 66.3 ± 18.7 normal 57.7 ± 4.93 normaCyanide, Total 0.140 ± 0.046 default (lognormal) NA --- 

Note: Shaded metals indicate which chemicals have site concentrations that are significantly greater than background concentrations.

a Nondetects were included at half the sample quantitation limit.

b Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 6-34 of RI/RA.

c Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 5-37 of RI/RA.

d Right-tailed Mann-Whitney U-test at 95% confidence level unless otherwise noted. See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix F of R

e Right-tailed T-test at 95% confidence level. Assumption of equal variances confirmed in data set using the Equal Variance Test.

FTA = Fire Training Area.mg/kg = Milligrams per kilogram.NA = Not analyzed in background.ND = Not detected in reference soils.NS = Not significantly different (p < 0.05).S = Significantly different (p > 0.05).

Arithmetic Mean ±

 Standard Deviation

Referencea,c 

(mg/kg)

Arithmetic Mean ±

 Standard Deviation

B400 FTA a,b 

(mg/kg)

MK01\O:\02281016.008\Tables 36-46.xls(Table 45) T-60 
Table 46

Statistical Comparison of Site and Reference Chemical Concentrations in Limestone Surface Soil,

Building 400 Series Fire Training Area, DSERTS Site LEAD-118C, SE OU 8,

Letterkenny Army Depot,

Chambersburg, PA

Data Data

Distribution Distribut

B400 FTA Referen

Chemical 

Inorganics

Aluminum 11,558 ± 3,282 normal 4,479 ± 767 normaArsenic 6.6 ± 2.2 normal 6.2 ± 0.8 normaBarium 182 ± 50.0 normal 77.8 ± 12.6 normaBeryllium 1.238 ± 0.141 normal 1.96 ± 0.206 default (lognChromium 18.2 ± 4.74 normal 11.7 ± 4.60 lognormCobalt 19.1 ± 5.09 normal 20.5 ± 3.31 default (logn

Copper 26.063 ± 6.97 normal 5.88 ± 1.55 normaIron 34,450 ± 4,576 normal 17,430 ± 3,506 normaLead 37.8 ± 8.15 normal 23.0 ± 2.76 normaManganese 1,134 ± 355 normal 1,705 ± 454 default (lognMercury 0.032 ± 0.012 default (lognormal) 0.075 ± 0.132 default (lognNickel 23.5 ± 6.70 normal 7.86 ± 1.83 normaSilver 0.069 ± 0.029 default (lognormal) ND default (lognThallium 0.077 ± 0.023 default (lognormal) 0.065 ± 0.020 default (lognVanadium 25.4 ± 3.963 normal 10.8 ± 1.67 normaZinc 66.3 ± 18.7 normal 22.2 ± 4.73 normaCyanide, Total 0.140 ± 0.046 default (lognormal) NA --- 

Note: Shaded metals indicate which chemicals have site concentrations that are significantly greater than background concentrations.

a Nondetects were included at half the sample quantitation limit.

b Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 6-34 of RI/RA.

c Horizon A (0-0.5 ft bgs). Data are untransformed as shown in Table 5-37 of RI/RA.

d Right-tailed Mann-Whitney U-test at 95% confidence level unless otherwise noted. See Subsection 5.2.8 of RI/RA for explanation of methods and Appendix F of R

e Right-tailed T-test at 95% confidence level. Assumption of equal variances confirmed in data set using the Equal Variance Test.

FTA = Fire Training Area.mg/kg = Milligrams per kilogram.NA = Not analyzed in background.ND = Not detected in reference soils.NS = Not significantly different (p < 0.05).S = Significantly different (p > 0.05).

Arithmetic Mean ±

 Standard Deviation

B400 FTA a,b 

(mg/kg)

Arithmetic Mean ±

 Standard Deviation

Referencea,c 

(mg/kg)

MK01\O:\02281016.008\Tables 36-46.xls(Table 46) T-61 
Figures

03P-0752
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION

MK01\O:\02281016.008\PHASE III\ROD\ROD_TABLES_FIGURES.DOC FINAL

FIGURES 
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

1

3

2

4

PDO Area SE Area

Letterkenny 

Township

Greene

Township

2-74A

2-36

2-74B

2-76

2-48

2-69

2-63

2-71

2-64

2-52

2-49

2-40

2-38

2-39

2-42

2-68

2-44 2-43

2-45 2-46

2-37

2-67

2-51

2-58 2-59

2-50

2-47

2-53 and 

2-53-L 2-41

2-65

2-61

2-35

2-62

2-60

2-66

2-77

2-55

2R-84L-3 

(Texas)

2R-80L-3 

(Coffey)

2-72

2-54 and 

2-54-L 2-56

2-57

2-70 and 

2-70-L

29

2

7

1

5 4

6

24

8

9 3

23

22

(Railroad)

27

31

(Railroad)

25

21

18

20

16

17

19

13

11

34

33

12

10

26

28

Parcel 3-89

3-90

3-91 Parcel

Parcel

2R-86L-3

(Carbaugh)

Buildings

Roads

N

W E

S

Letterkenny Army Depot

Chambersburg, PA

U.S. Army Corps of Engineers

Baltimore District

Date:

03-07-03

Figure 3

Location of Phase III

Parcels With PDO and SE Areas

Legend:

SM

1250 0 1250 Feet

| Q:\LEAD\aprs\phase3.apr | Layout- phase3 rev0 | q:\lead\pdfs\phase_3\in\phase3_rev0.eps | 9:18 AM, 4/30/2003 |

Drainage Divides 

Enclave

1 Phase I Parcels

1 Phase II Parcels

(Does not show all roads) 2-48

2-48

Phase III Parcel That is

Lower Portion of Phase II 

Parcel (8ft. below ground 

surface to center of the earth)

2-70-L

3-90 248 Phase III Parcels

Shale/Limestone Boundary

BRAC Sites

Open Vehicle Storage 

Area (OVSA)

Backwash Discharge Area from 

the Water Treatment Plant

Former Uncurbed AST at

Building 532

Building 400 Series

Fire Training Area

1

2

3

4

Township Line

Note: Parcel 3-92 (Letterkenny Reservoir) is located off-depot and is not shown here.
N W

E

S

Letterkenny Army Depot

Chambersburg, PA

U.S. Army Corps of Engineers

Baltimore District

Date:

02-03-03

Figure 4

Former Layout of Groundwater

Operable Units (OUs)

Legend:

SM

1400 0 1400 Feet

| Q:\LEAD\aprs\gw_ous.apr | Layout- gw ous | q:\lead\pdfs\gw_ous\in\gw_ous.eps | 10:31 AM, 4/22/2003 |

Shale/Limestone Boundary

PDO OU 4: Groundwater Associated with the PDO Oil Burn Pit

PDO OU 2: PDO Area Groundwater and Surface Water

SE OU 3: Disposal Area VOC- Contaminated Groundwater

Subbasin Drainage Divide

Major Watershed Divide

Enclave Area

Drainage

SE OU 10: Southern Southeast Industrial Area VOC-Contaminated Groundwater South of Gate 6 (Conococheague Drainage System)

SE OU 11: Northern Southeast Industrial Area VOC-Contaminated Groundwater North of Gate 6

Note: SE OU 6 (not shown) is SE Area Off-Post VOC-Contaminated Groundwater (beyond boundaries of SE OU 3 and SE OU 11)

Base Features

SE OU 3 Drains to the Susquehanna River Watershed via Rowe Run

SE OU 11 Drains to the Susquehanna River Watershed via Rowe Run Rowe Run

PDO OU 4 Drains to the Susquehanna River Watershed via Meghan Mackenzie Run and Muddy Run

Ammo Area

PDO OU 2 Drains to the Potomac River Watershed via the Rocky Spring Branch System

Gate 1

Outfall of Storm Sewers from SE Area to the Southeast Drainageway to Conococheague Creek

SE OU 10 Drains to the Potomac River Watershed via the SE Drainageway to the Conococheague Creek (includes Off-Post)

Gate 6
N

W E

S

Letterkenny Army Depot

Chambersburg, PA

U.S. Army Corps of Engineers

Baltimore District

Date:

02-03-03

Figure 5

Current Layout of Groundwater

Operable Units (OUs)

Legend:

SM

1400 0 1400 Feet

| Q:\LEAD\aprs\gw_ous.apr | Layout- gw ous rev1 | q:\lead\pdfs\gw_ous\in\gw_ous_rev1.eps | 10:39 AM, 4/22/2003 |

Shale/Limestone Boundary

PDO OU 7

SE OU 13

Southern Martinsburg

Shale Region (SMSR)

Groundwater

PDO OU 4: Groundwater Associated with the PDO Oil Burn Pit

PDO OU 2: PDO Area Groundwater and Surface Water

SE OU 6: Off-Post VOC-Contaminated Groundwater North of Gate 6

SE OU 3A: Disposal Area VOC- Contaminated Groundwater

SE OU 3B: Area Upgradient of VOC Contamination Source in SE OU 3A

Subbasin Drainage Divide

Major Watershed Divide

Enclave Area

Drainage

SE OU 10: Southern Southeast Industrial Area VOC-Contaminated Groundwater South of Gate 6 (Conococheague Drainage System)

SE OU 11: Northern Southeast Industrial Area VOC-Contaminated Groundwater North of Gate 6

SE OU 10 (Off-Post)

Note: SE OU 6 (entire area shown) is SE Area Off-Post VOC-Contaminated Groundwater (beyond boundaries of SE OU 3 and SE OU 11)

Base Features

SE OU 6 Drains to the Susquehanna River Watershed

SE OU 11 Drains to the Susquehanna River Watershed via Rowe Run

Rowe Run

SE OU 3A Drains to the Susquehanna River Watershed via Rowe Run

SE OU 3B Drains to the Susquehanna River Watershed via Rowe Run

PDO OU 4 Drains to the Susquehanna River Watershed via Meghan Mackenzie Run and Muddy Run

Ammo Area

PDO OU 2 Drains to the Potomac River Watershed via the Rocky Spring Branch System

Gate 1

Outfall of Storm Sewers from SE Area to the Southeast Drainageway to Conococheague Creek

SE OU 10 Drains to the Potomac River Watershed via the SE Drainageway to the Conococheague Creek (includes Off-Post)

Gate 6

PDO OU 7 Drains to the Potomac River Watershed via the Rocky Spring Branch System

SE OU 13 Drains to the Potomac River Watershed via the Conococheague Creek
q:/lead/dgn/n27/site57a_3.dgn May. 16, 2003 11:24:58



GROUNDWATER FLOW IN SOUTHERN MARTINSBURG SHALE REGION AT LETTERKENNY ARMY DEPOT

FIGURE 10

610620630640650660670680690700710720730740750760770780

Overburden Silty Clay 

Heliport

Road

Road

Coffey

Avenue

Approximate Formation 

Shale/Limestone 

Contact

oximate Formation 

mestone/Shale 

Contact

ESE Elevation

(Feet/MSL)

NE

MARTINSBURG SHALE

Overburden Silty Clay

NE

MARTINSBURG SHALE

Formation Contact (Approximate) Formation Contact (Approximate)

Approximate

Water Table

Dark Brown

Clayey Silt

NOTE:68° Dip Corrected to 80° Dipfor Vertical ExaggerationNOTE:68° Dip Corrected to 80° Dip

for Vertical Exaggeration

Formation Contact (Approximate) Formation Contact (Approximate) Formation Contact (Approximate)CHAMBERSBURG LIMESTONE

SM

Horizontal Scale In Feet

Vertical

 Scale In 

Feet

Vertical Exaggeration 10:1

0 100 200 300 400

0

10

andy silt

wn silty clay

rk gray, argillacious, hard,

nal solution cavities present

e-gray, fissile, friable-occ hard, 

one and siltstone interbeds

Generalized groundwater flow directionApproximate depth to water

WNW Elevation: Elevation on the west northwest side of the SMSRESE Elevation: Elevation on the east southeast side of the SMSR


Glossary of Terms

03P-0752
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION

MK01|O:\02281016.008\PHASE III\ROD\ROD_GLOSSARY FINAL 

GLOSSARY OF TERMS 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION

MK01|O:\02281016.008\PHASE III\ROD\ROD_GLOSSARY FINAL 

G-1

GLOSSARY OF TERMS 

Administrative Record A collection of documents containing all the information and reports 

generated during the entire phase of investigation and cleanup at a site, which 

are used to make a decision on the selection of a response action under 

CERCLA. This file is to be available for public review and a copy maintained 

at or near the site, usually at one of the information repositories (Coyle Free 

Library). 

Baseline Ecological Risk 

Assessment (BERA) 

An assessment performed to characterize and evaluate potential risks to plants 

and animals if remedial activities are not performed at a site. 

Base Realignment and 

Closure (BRAC) 

The process by which the U.S. Department of Defense (DoD) is rightsizing. As 

part of this procedure, excess infrastructure and property that are no longer 

needed to support the defense mission are being closed and/or realigned. 

Cancer Risk Cancer risks are expressed as numbers reflecting the increased chance that a 

person will develop cancer if exposed to chemicals or substances. For 

example, EPA’s acceptable risk range for CERCLA sites is 1 x 10-4 to 1 x 10-6. 

This means that the probability of cancer should not be greater than a 1-in10,000 chance to a 1-in-1,000,000 chance above background. 

Chemicals of Potential 

Concern (COPCs) 

Chemicals, either present at the site as a result of historical activities or of 

likely concern to human health and the environment, which are evaluated in 

the risk assessment. 

Contaminants of Concern 

(COCs) 

Chemicals identified through the risk assessment process as the primary 

chemicals that may cause unacceptable human health and/or ecological risk. 

Commercial/Industrial Use As referenced in this document means the use as administrative/office space, 

manufacturing, warehousing, restaurants, hotels/motels, and retail activities. 

Under this definition residential and daycare uses are prohibited. 

Comprehensive 

Environmental Response, 

Compensation, and Liability 

Act (CERCLA) 

A Federal law passed in 1980 and modified in 1986 by the Superfund 

Amendments and Reauthorization Act (SARA) to investigate and clean up 

abandoned and uncontrolled hazardous waste sites. DoD cleanups are 

funded by the defense budget or individual service funds (e.g., LEAD cleanup 

is paid for with U.S. Army funds). 

Engineering Evaluation/Cost 

Analysis (EE/CA) 

Analysis of the practicability of a proposal; e.g., a description and technical 

evaluation/cost analysis of the need for a removal action and potential 

cleanup alternatives for a CERCLA site, where the technologies or alternatives 

evaluated have already been narrowed-down to a small number of 

alternatives that can be readily implemented. The EE/CA usually 

recommends selection of the most cost-effective viable alternative. 

Environmental Baseline 

Survey 

A detailed search and review of available information (Army, Federal, state, 

and local), analysis of aerial photographs, interviews with current and/or 

former employees, review of ongoing response actions, visual inspections, and 

identification of sources of contamination to determine the environmental 

condition of a property. 

Exposure Pathways Describes the course a chemical or physical agent takes from the source to the 

exposed receptor. Elements of the exposure pathway are: (1) the source of the 

released chemical; (2) the contaminated medium (e.g., soil); (3) a point of 

contact with the contaminated medium; and (4) an exposure route (e.g., 

ingestion, inhalation) at a contact point. 
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G-2

GLOSSARY OF TERMS 

(Continued)

Groundwater Underground water that fills pores in soil or openings in rocks to the point of 

saturation. Groundwater is often used as a source of drinking water via 

municipal or domestic wells. 

Hazard Index (HI) A number indicative of noncarcinogenic health effects, which is the ratio of the 

existing level of exposure to an acceptable level of exposure. A value equal to 

or less than one indicates that the human population is not likely to experience 

adverse effects from exposure. 

Human Health Risk 

Assessment 

An evaluation of the risk posed to human health should remedial activities not 

be implemented. 

Information Repository A file containing current information, technical reports, reference documents, 

and other information on a CERCLA site. The information repository includes 

the Administrative Record file. This is maintained by LEAD and EPA. 

National Oil and Hazardous 

Substances Pollution 

Contingency Plan (NCP) 

The Federal regulation that guides the CERCLA program. The NCP was 

revised in February 1990. The purpose of the NCP is to provide the 

organizational structure and procedures for preparing for and responding to 

discharges of oils and releases of hazardous substances, pollutants, or 

contaminants. 

National Priorities List (NPL) A list developed by the U.S. Environmental Protection Agency (EPA) of 

uncontrolled hazardous substance release sites or abandoned hazardous waste 

sites in the United States that are considered priorities for long-term 

environmental investigation, remedial evaluation, and response. LEAD is on 

the Federal facilities NPL. 

Operable Unit (OU) Term for each of a number of separate activities or actions that each comprises 

an incremental step toward comprehensively addressing environmental 

problems at a CERCLA site. The cleanup of a site can be divided into a 

number of operable units, depending on the complexity of the problems 

associated with the site. Operable units may, for example, address 

geographical portions of a site or specific site problems, such as groundwater 

contamination. 

Organic Compound Chemicals that are carbon-based compounds, such as solvents, oils, and 

pesticides. Most are not readily dissolved in water. Exposure to some organic 

compounds may increase the risk of developing cancer. 

Polycyclic Aromatic 

Hydrocarbons (PAHs) 

A group of over 100 different chemicals (for example, benzo(a)pyrene) that are 

formed during incomplete burning of coal, oil and gas, garbage, or other 

organic substances such as tobacco or charbroiled meat. PAHs are found 

mostly in coal tar, crude oil, creosote, and roofing tar. Present in low 

concentrations virtually everywhere, PAHs occasionally reach elevated 

concentrations as the result of prolonged industrial activities involving 

burning, or by releases of materials such as creosote-based wood 

preservatives, that contain PAHs in high concentrations. PAHs are slow to 

degrade in the environment and can also accumulate in the tissues of marine 

animals. PAHs are a concern because some of them cause cancers in humans 

and are harmful to fish when concentrations are elevated. 

Proposed Plan A document that presents a proposed cleanup alternative, rationale for the 

preference, and requests public input regarding the proposed alternative. 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION

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G-3

GLOSSARY OF TERMS 

(Continued)

Property Disposal Office 

(PDO) Area 

The PDO Area is located in the southeastern part of Letterkenny Army Depot 

and contains industrial and maintenance operations, offices, and recreational 

areas. The PDO Area is located on the western side of a drainage divide, west 

of the SE Area. This part of LEAD was added to the NPL in 1989 due to the 

presence of VOC-contaminated groundwater located in the area (see Figure 2). 

Record of Decision (ROD) A legal public document that describes the cleanup action or remedy selected 

for a CERCLA site, the basis for the choice of that remedy, and public 

comments on alternative remedies. The ROD is based on information and 

technical analysis generated during the RI/FS process. 

Remedial Action Implementation of plans and specifications, developed as part of the design, to 

remediate a site. 

Remedial Investigation (RI) A study of a facility or site that provides information supporting the 

evaluation for the need for a remedy and/or selection of a remedy for a site 

where hazardous substances have been disposed of. The RI identifies the 

nature and extent of contamination at the facility. 

Removal Action Short-term immediate actions taken to address releases of hazardous 

substances that may require expedited response. 

Residential Use As referenced in this ROD means use as housing, daycare facilities, schools 

(excluding education and training programs for persons over 18 years of age), 

assisted living facilities, and outdoor recreational activities. Unrestricted use 

(community and commercial/industrial included) is permitted under this 

definition. 

Risk Assessment Qualitative and quantitative evaluation of the risk posed to human health 

and/or the environment by the actual or potential presence and/or use of 

specific pollutants. 

Risk-Based Screening Level Risk-based concentrations established by EPA associated with specific levels 

of risk. These concentrations have been developed for a variety of exposure 

scenarios, including ingestion and inhalation. They are used to screen 

chemicals for inclusion in the risk assessment. 

Semivolatile Organic 

Compounds 

Organic compounds that volatilize slowly at standard room temperature (20 

degrees C and 1 atmosphere pressure). 

Site The facility or part of the facility and any other areas in close proximity to the 

facility where a hazardous substance, hazardous waste, hazardous 

constituent, pollutant, or contaminant from the facility has been deposited, 

stored, disposed of, or placed, or has migrated or otherwise come to be 

located.

Southeastern (SE) Area The farthest southeastern part of Letterkenny Army Depot that contains 

mostly industrial and maintenance operations and offices, as well as some 

recreational areas, and is located on the eastern side of a drainage divide. This 

part of the Depot was added to the NPL in 1987 due to the presence of VOCcontaminated groundwater located in the northern half (referred to as the 

Disposal Area) and in the southern half (referred to as the Southeast Industrial 

Area) (see Figure 2). 

Superfund Amendments and 

Reauthorization Act (SARA) 

A modification (amendment) to CERCLA enacted on 17 October 1986. 
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GLOSSARY OF TERMS 

(Continued)

Volatile Organic Compound 

(VOC) 

An organic (carbon-containing) compound that evaporates (volatilizes) readily 

at room temperature. Examples of VOCs are trichloroethene (TCE) and 

dichloroethene (DCE). 
Responsiveness Summary

03P-0752
O:\02281016.008\PHASE III\ROD\ROD_RESPONSESUM.DOC FINAL 1 

LETTERKENNY ARMY DEPOT 

PHASE III PARCELS 

CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA 

RESPONSIVENESS SUMMARY 

AUGUST 2003 

SECTION 1

OVERVIEW 

Based on an assessment of the removal action completed and site conditions, the U.S. Department of the Army 

(Army) and the U.S. Environmental Protection Agency (EPA) selected a remedy for the Phase III parcels at 

Letterkenny Army Depot (LEAD), Chambersburg, PA. The Commonwealth of Pennsylvania Department of 

Environmental Protection (PADEP) concurs with the selected remedy. The selected remedy applies to the soil 

and groundwater associated with the Open Vehicle Storage Area (OVSA), the Uncurbed Aboveground Storage 

Tank (AST) North of Building 532 Site, the Backwash Discharge Area at the Water Treatment Plant, and the 

Building 400 Series Fire Training Area (FTA), and the Southern Martinsburg Shale Region (SMSR) soils for the 

current and intended future commercial/industrial use as well as in the event of a possible but unlikely future 

nonindustrial land use. As specified in this Record of Decision (ROD), the selected remedy is no further action, 

which will be protective of human health and the environment. 

Based on the fact that no comments were received during the public comment period, the residents and 

Letterkenny Industrial Development Authority (LIDA) appear not to object to the no further action alternative for 

the Phase III parcels. No written or verbal comments were received during the public comment period on the 

Proposed Plan.

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. Interviews were conducted in 1997 as part of the revised Community Relations Plan (WESTON, 

1997). 

LEAD has a Restoration Advisory Board (RAB), which began meeting in 1996 and focuses primarily on the 

restoration activities related to the Defense Environmental Restoration Account and Base Realignment and 

Closure (BRAC) actions. The Restoration Advisory Board replaced the Technical Review Committee, formed in 

1988, which was the previous means by which the community could provide comments and review progress on 

the environmental programs at LEAD. LEAD representatives attend Restoration Advisory Board meetings and 

Letterkenny Industrial Development Authority (LIDA) meetings (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 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RESPONSIVENESS SUMMARY

O:\02281016.008\PHASE III\ROD\ROD_RESPONSESUM.DOC FINAL 2 

from LEAD, the U.S. Army Corps of Engineers (USACE), the Pennsylvania Department of Environmental 

Protection (PADEP), EPA Region III, Department of the Army, and the U.S. Army Aviation and Missile 

Command (which is a subordinate Command of the U.S. Army Materiel Command). 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 Restoration Advisory Board, USACE, PADEP, EPA 

Region III, and contractors. Numerous site visits by the regulatory agency representatives have promoted 

communication among 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 the property. 

The residents in the vicinity of LEAD have generally reacted favorably to the efforts made by 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 connections 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 CERCLA sites and LEAD over the long term. 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. A total of 19 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 people 

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 wastes 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 conduct 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 economic impact of having fewer civilian jobs with the realignment of LEAD, the majority of the 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RESPONSIVENESS SUMMARY

O:\02281016.008\PHASE III\ROD\ROD_RESPONSESUM.DOC FINAL 3 

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 about the 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 re-contaminating 

the site and creating noise or traffic problems. Some were concerned with how the Army will provide access to 

the reuse areas, grant public use of the reservoir, and share the Depot’s infrastructure (electricity, water, sewer, 

etc.). One person suggested that the state establish 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:

 Apartment complex (Kenny Gardens housing). 

 Old quarry (Fagan’s Quarry). 

 Rocky Spring Lake. 

 Mercury in the lake. 

 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 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 PADEP 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 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RESPONSIVENESS SUMMARY

O:\02281016.008\PHASE III\ROD\ROD_RESPONSESUM.DOC FINAL 4 

following:

 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). 

Of the 19 interviewees, 18 said they had an understanding of the BRAC activities at LEAD. The majority of the 

interviewees were favorable toward the cleanup activities related to the BRAC parcels. In addition, the majority 

of the interviewees were supportive of LIDA’s reuse plan. Most individuals also were favorable toward the 

cooperation and interaction between the Army and LIDA in freeing the to-be-excessed parcels as soon as 

possible. 

SECTION 3

SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT 

PERIOD AND AGENCY RESPONSES 

The public comment period on the Proposed Plan for the Phase III parcels was held from 14 April to 13 May 2003. 

No comments were received during this time. On 23 April 2003, a public availability session was held at the 

Building 10, Letterkenny Great Room to present the Proposed Plan (in the form of a poster presentation) and to 

entertain questions and comments from the public. There were no questions, and no comments were made 

during the public availability session. 
Attachment 1 References

03P-0752
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION 

MK01\O:\02281016.008\PHASE III\ROD\ROD_ATT1REF.DOC FINAL 

ATTACHMENT 1 

REFERENCES 
LETTERKENNY ARMY DEPOT PHASE III PARCELS—RECORD OF DECISION 

MK01\O:\02281016.008\PHASE III\ROD\ROD_ATT1REF.DOC FINAL 1-1

ATTACHMENT 1 

REFERENCES

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

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

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, PA. 

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

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