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Letterkenny Army Depot, Southeast

EPA Region 3 (Mid-Atlantic)

Pennsylvania
Franklin County
5 miles north of Chambersburg

EPA ID# PA6213820503

3rd Congressional District

Last Update: January 2015

Other Names


Letterkenny Army Depot (LEAD)

Current Site Status

The following paragraphs include highlights of the progress made at Letterkenny SE over the last fiscal year.

Building 37/47 (SE OU 8)
A Record of Decision (ROD) was completed in 2014. The selected remedy is subslab depressurization and Land Use Controls (LUCs) to prevent exposure to vapor intrusion from the underlying groundwater contamination. Remedy implementation is expected in 2015. The groundwater contamination is being addressed under SE OU 10.

Building 349 Soil Staging Area (SSA) and the Former Test Track (FTT) (SE OU 14)
A combined Proposed Plan (PRAP) for these two sites was completed in 2014. The ROD for these two sites will also include Areas A and B (SE OU 5) and is expected to be completed in 2015. The recommended remedy for the SSA and FTT is Land Use Controls (LUCs) to restrict land use to commercial/industrial use.

Areas A and B and Spill Area at Area A (SE OU 5)
A PRAP for these sites was completed in 2014. The ROD will also include the Building 349 Soil Staging Area and the Former Test Track (SE OU 14) and is expected to be complete in 2015. The recommended remedy for Areas A and B and the Spill Area at Area is LUCs to restrict land use to commercial/industrial use and to enhance the existing soil cover at Area A so that the cover is at least 2 feet thick over the entire site. This ROD was delayed because additional sampling for dioxin had to be completed before the draft ROD could be submitted.

SE OU 9
A draft PRAP and Feasibility Study (FS) Addendum are currently in review. Both are expected to be completed in 2015.

SE OUs 3A, 6 and 11
The PRAP was completed in 2014 and the ROD is expected to be complete in 2015. The recommended remedy is in-situ chemical oxidation with a Technical Impracticability Waiver for the dense non-aqueous phase liquid (DNAPL) portion of the plume.

Site Description

The Letterkenny Army Depot (LEAD) was originally a 19,243 acre Army facility, located 5 miles north of Chambersburg, Franklin County, Pennsylvania. Approximately 17,000 people live within 5 miles of the Letterkenny Army Depot. There are two NPL sites associated with the Letterkenny Army Depot. The first is referred to as the Letterkenny Army Depot Property Disposal Office (LEAD PDO) NPL site. The second is referred to as the Letterkenny Army Depot Southeast (LEAD SE) Area NPL site. This narrative will concentrate on the Letterkenny Army Depot SE Area NPL site.

LEAD was established in 1942 for ammunition storage. Since 1947, however, activities at LEAD expanded to include (a) the testing, maintenance and overhaul of wheeled and tracked vehicles and missiles; (b) the storage and transportation of industrial chemicals and petroleum; and (c) storage, maintenance, demilitarization, and modification of ammunition. The LEAD SE NPL site includes areas associated with the overhauling, rebuilding, and testing of wheeled and tracked vehicles, as well as warehousing operations.

LEAD was included in the 1995 Base Closure and Realignment Act (BRAC), with 1,235 acres designated for transfer to the private sector for local redevelopment, while the remaining land will remain Army property.

Contamination from both NPL sites includes chlorinated organic solvents, blast media, paints, petroleum products, metals, and cleaning agents stored or disposed of in landfills, trenches, burn pits, or spilled from storage.

The Army also formed a Restoration Advisory Board (RAB) with the regulators, citizens and local government members to give input to final cleanup decisions. Funding for cleanups comes from both Army BRAC and Installation Restoration Programs accounts.

Site Responsibility

This site is being addressed by the U.S. Department of Defense under the Installation Restoration Program and Base Closure (BRAC 1995).

NPL Listing History
The Letterkenny Army Depot SE Area was proposed to the National Priorities List of the most serious uncontrolled or abandoned hazardous waste sites requiring long term remedial action on October 15, 1984. The site was formally added to the list on July 22, 1987.

Threats and Contaminants

Groundwater both on- and off-post at LEAD SE is contaminated with chlorinated organic chemicals. Soil has been found to be contaminated with chlorinated organic chemicals, including VOCs. Individuals may be at risk if they accidentally ingest or inhale vapors, or come in direct contact with contaminated groundwater or soil.

Cleanup Progress

Environmental Studies began in 1978 and continue. Portions of the two NPL sites were identified in 1995 as excess to be returned to the community for local reuse. The Army, EPA, and Pennsylvania signed a Federal Facilities Agreement in 1989. The Army, state and EPA formed a BRAC Cleanup Team (BCT) in 1996 which is working closely to streamline the cleanup process, to expedite the cleanup, transfer and reuse of excess property to facilitate local redevelopment. Franklin County has formed a Local Reuse Authority (LRA) referred to as the Letterkenny Industrial Development Authority (LIDA) to support reuse and cleanup priorities.

LEAD SE has been divided into Operable Units (OU) to aid in the cleanup process. The following are brief descriptions of the OUs.

SE OU 1 - K Area Contaminated Soils
The ROD is complete and the remedy was implemented. VOC-contaminated soils were excavated, treated with Low Temperature Thermal Desorption, returned to the site, and capped. VOC-contaminated groundwater at this site is being addressed under SE OU 3.

SE OU 2 – Industrial Wastewater Sewer System and Contaminated Soils
The ROD is complete and the remedy was implemented. The selected remedy for SE OU 2 was cleaning followed by abandonment of the sewer and drain lines at Building 37 and 57 to prevent future use of the existing sewers.

SE OU 3 – Disposal Area VOC-Contaminated Groundwater
SE OU 3A addresses on-post groundwater contamination associated with the K areas (SE OU 1). Groundwater in SE OU 3A is contaminated with chlorinated solvents. Dye studies have shown that water from areas within SE OU 3A is discharging off-post (see SE OU 6). Although the many of the sources of contamination have been addressed, VOCs are still being detected. This is most likely due to the presence of Dense Non-Aqueous Phase Liquids (DNAPL) within the bedrock matrix and associated groundwater, which is continuing to act as a secondary source.

A draft Focused Feasibility Study (FFS) including an upfront Technical Impracticability waiver was finalized in 2010. Many studies have been completed to date, including a recirculation well Pilot Study and an in-situ H2O2 Pilot Study that was completed in April 2000. Additionally, investigations to verify the vertical extent of groundwater contamination were conducted from 2005 to 2006. A Proposed Plan for groundwater was completed in 2014.

SE OU 3B is a BRAC OU that addresses the area upgradient of the VOC-contaminated groundwater.  Groundwater sampling was initiated in August 2003 and a final SI Report was finalized in May 2005. A Proposed Plan was issued for public review in May 2005. A no action ROD and a FOST were completed and signed in June 2006. The ROD specifies no action for SE OU 3B groundwater and for soil associated with four parcels that consist of a portion of SE OU 8.

SE OU 4 – Stormwater Sewer Lines and Associated Drainageways
A Record of Decision was completed and the selected remedy was no further remedial action.

SE OU 5 – Areas A and B Contaminated Soils

SE OU 5 is comprised of two areas of contaminated soil, which are designated Areas A and B. They were initially investigated in the 1980s. Area A is primarily contaminated with total petroleum hydrocarbons (TPH) and metals, with a small amount of VOCs. In 1995 a localized spill area of elevated VOC concentrations was identified. An EE/CA was prepared and an emergency removal action was conducted in summer 1997 to excavate and dispose of the VOC-contaminated soil in the spill area. The remainder of Area A was evaluated during the Remedial Investigation (RI).

Area B was a former Oil Burn Pit (OBP). The soil in this area was found to contain TPH, metals, and a small amount of VOCs; groundwater was also found to contain VOCs. Area B was further evaluated as part of an RI.

A Final RI/RA was completed in October 2004; these were published separately as an RI and an RA. A worm bio-uptake study was conducted in accordance with comments from EPA Biological Technical Assistance Group (BTAG), and as a result, a draft addendum to the ecological RA was submitted in September 2006. The PRAP was completed in 2014 and the recommended remedy will be LUCs to restrict use to commercial/industrial and additional soil for the existing soil cover at Area A so that the entire cover is 2 feet thick. Additional dioxin sampling was conducted in 2014. A ROD is expected to be signed in 2015.

SE OU 6 – VOC-Contaminated Groundwater North of Gate 6 and East of East Patrol Road (Rowe Run Drainage System)
SE OU 6 includes off-post groundwater and surface water that have been contaminated from VOC-contaminated groundwater migrating from OUs 3A and 11.

After residential well sampling disclosed the presence of VOC-contaminated groundwater, the Army initially supplied affected residences with bottled potable water. By 1987, 38 residences and businesses were connected to the Guilford Water Authority water supply. In 1992, three additional residences were added to the water supply line.

Impacts to animals and animal products located on farms near SE OU 6 were also evaluated. Samples of eggs, milk, and meat were collected from numerous farms. VOCs and metals were detected at concentrations within the literature values or regional background levels for the media sampled.

A final RI/RA Report for SE OU 6 was submitted in November 2004. Additional investigations to verify the vertical extent of groundwater contamination were conducted from 2005 to 2006. A vapor intrusion pilot study was conducted from July 2004 to January 2006 and results showed no unacceptable risk, however, toxicity values for TCE have recently changed and a new VI study will be initiated in 2015.
 
The Proposed Plan for SE OUs 3, 6 and 11 was completed in 2014 and a ROD for groundwater is expected in 2015.

SE OU 7 – Truck Open Storage Area
SE OU 7 was included in the Phase V BRAC Parcels ROD that was completed in 2012.

SE OU 8 – BRAC Waste Sites
SE OU 8 consists of BRAC parcels and has been addressed under the several RODs: Phases I, II, III, IV and V.

SE OU 9 – Landfill J
SE OU 9 consists of Landfill J, which is located west of Building 320. The extent of the landfill was determined using geophysical techniques and trenching. The characteristics of the soils and groundwater were evaluated through several sampling efforts. An emergency removal action was conducted in June 2001. A finalized Removal Action Summary Report, which included the RI/RA data, was completed in October 2004. A draft PRAP is currently under review and expected to be complete in 2015. A ROD is expected to be complete in 2016.

SE OU 10 – VOC-Contaminated Groundwater South of Gate 6 (Conococheague Drainage System)
SE OU 10 consists of contaminated groundwater south of Gate 6. SE OU 10 was created when SE OU 3 was divided at the groundwater/surface water divide near Gate 6. The sources of the groundwater contamination for SE OU 10 are the formerly leaking IWWS lines in the vicinity of Building 37 (VOC-contaminants) and a release from a diesel tank fuel line in the vicinity of Building 37. A ROD was completed. The selected remedy for SE OU 10 is Enhanced Biodegradation with Monitored Natural Attenuation and Land Use Controls (to prevent contact with contaminated groundwater until the time the groundwater is safe for use).

SE OU 11 – VOC-Contaminated Groundwater North of Gate 6
SE OU 11 consists of the VOC-contaminated groundwater associated with the IWTP lagoons and IWWS gravity lines. The groundwater discharges off-post (see SE OU 6). A pilot study was initiated in September 2001 to evaluate the feasibility of treating DNAPL sources and reducing off-site contaminant migration concentrations at the property line. This study was completed by January 2003. Additional investigations to verify the vertical extent of groundwater contamination were conducted from 2005 to 2006. A vapor intrusion pilot study was conducted from July 2004 to January 2006. SE OU 11 will be addressed with SE OUs 3A and 6. A Proposed Plan was completed in 2014 and a ROD is expected in 2015.

SE OU 13 – Southern Martinsburg Shale Region Groundwater
A ROD was completed and the remedy was No Further Action.

SE OU 14 – Former Test Track Area

SE OU 14 was created in 2007 to track sites in Army-retained land that were formerly administered under the BRAC program and are now in the ER,A program as a result of the revised BRAC boundary. SE OU 14 consists of the Former Test Track and the Building 349 Soil Staging Area. The RI/RA for the Former Test Track was finalized in 2004. This RI/RA showed that risks are within acceptable levels for commercial/industrial use. A RI was completed for the Building 349 Soil Staging Area in 2010 and a PRAP was completed in 2014. A ROD is expected in 2015.

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