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Record of Decision Site 11- Ingot Storage Areas Naval Support Activity Mechanicsburg, Pennsylvania Naval Facilities Engineering Command Department of the Navy Naval Facilities Engineering Command Mid-Atlantic SEPTEMBER 2007

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Page 1: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

Record of Decision Site 11- Ingot Storage Areas

Naval Support Activity

Mechanicsburg, Pennsylvania

Naval Facilities Engineering Command

Department of the Navy Naval Facilities Engineering Command

Mid-Atlantic

SEPTEMBER 2007

Page 2: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

Contents

Declaration 1-1 1.1 Site Name and Location 1-1 1.2 Statement of Basis and Purpose 1-1 1.3 No Further Action Decision 1-1 1.4 Statutory Determinations 1-2 1.5 Authorizing Signatures 1-2

2 Decision Summary 2-1 2.1 Site Name, Location, and Background 2-1 2.2 Investigation and Removal Action History 2-1 2.3 Community Participation 2-4 2.4 Scope and Role of Response Actions 2-4 2.5 Site Characteristics 2-5 2.6 Current and Potential Future Site and Resource Uses 2-6 2.7 Site Risks 2-6 2.8 No Further Action Necessary 2-7 2.9 Documentation of Significant Changes 2-7

3 Responsiveness Summary 3-1

4 References 4-1

Tables

2-1 Confirmation Sampling Results, Site 11- Ingot Storage Area 414

2-2 Confirmation Sampling Results, Site 11 - Ingot Storage Areas 317, 413, and 606

Figures

1-1 Location of NSA Mechanicsburg 2-1 Site 11- Ingot Storage Area Locations

III

Page 3: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

Acronyms and Abbreviations

AOC

CERCLA

CFR

DDMP

DDRE

DDSP

DLA

EE/CA

EPTox

EPA

FFA

Ft

ICP

IRP

mg/kg

mg/L

MSL

NAVSUP

Navy

NCAP

NCP

NFA

NSA Mechanicsburg

NPL

NTCRA

Area of Concern

Comprehensive Environmental Response, Compensation and Liability Act

Code of Federal Regulations

Defense Depot Mechanicsburg, Pennsylvania

Defense Distribution Region East

Defense Distribution Depot Susquehanna, Pennsylvania

Defense Logistics Agency

Engineering Evaluation/Cost Analysis

Extraction Procedure Toxicity

United States Environmental Protection Agency

Federal Facilities Agreement

foot, feet

Inventory Control Point

Installation Restoration Program

milligrams per kilogram

milligrams per liter

mean sea level

Naval Supply Systems Command

United States Department of the Navy

New Cumberland Army Depot, Pennsylvania

National Oil and Hazardous Substances Pollution Contingency Plan

No further action

Naval Support Activity Mechanicsburg

National Priorities List

Non-time-critical removal action

v

Page 4: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

RECORD OF DECISION SITE 11: OPERABLE UNIT 1

au Operable Unit

PADEP Pennsylvania Department of Environmental Protection

PCB polychlorinated biphenyl

PRAP Proposed Remedial Action Plan

RAB Restoration Advisory Board

RAO Remedial action objective

RBC Risk based concentration

RCRA Resource Conservation and Recovery Act

ROD Record of Decision

SARA Superfund Amendments and Reauthorization Act

SMP Site Management Plan

SWMU Solid Waste Management Unit

TCLP Toxicity Characteristic Leaching Procedure

pg/kg micrograms per kilogram

VI

Page 5: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

SECTIONl

Declaration

1.1 Site Name and Location Site II, Ingot Storage Areas Naval Support Activity (formerly Navy Ship Parts Control Center) Mechanicsburg, Pennsylvania

The Naval Support Activity (NSA) Mechanicsburg (EPA ID# PA3170022104) was placed on the United States Environmental Protection Agency (EPA's) National Priorities List (NPL) in May 1994. NSA Mechanicsburg is located in Hampden Township and the Borough of Mechanicsburg, Cumberland County, Pennsylvania (Figure 1-1).

1.2 Statement of Basis and Purpose This Record of Decision (ROD) presents a final decision on remedial action for Site II, Ingot Storage Areas, at NSA Mechanicsburg. The determination has been made 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 Pollution Contingency Plan (NCP). This decision is based on information contained in the Administrative Record file for the site.

The United States Department of the Navy (Navy) is the lead agency and provides funding for site cleanups at NSA Mechanicsburg. The Navy and EPA Region III issue this ROD jointly. The Pennsylvania Department of Environmental Protection (PADEP) concurs with the decision.

1.3 No Further Action Decision Site II, Ingot Storage Areas, is one of several Installation Restoration Program (IRP) sites being addressed under CERCLA at NSA Mechanicsburg. Information about the other IRP sites at NSA Mechanicsburg can be found in the current version of the Site Management Plan (SMP), which is located in the Administrative Record.

The Navy and EPA, in consultation with PADEP, have determined that no remedial action under CERCLA is necessary to protect human health or the environment from releases of hazardous substances at Site II, the Ingot Storage Areas. A removal action was conducted at Site 11 in 2007 which eliminated potentially unacceptable risk associated with contaminated soil at the site. The remaining site soil concentrations meet the site-specific cleanup goals that were established for the removal.

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RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

1.4 Statutory Determinations No remedial action is necessary at the site. The removal action conducted at Site 11, Ingot Storage Areas has eliminated the need to conduct further remedial action. As there are no hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure, a 5-year review will not be required.

1.5 Authorizing Signatures

;;v.: Date

Commanding Officer Naval Support Activity

Date

1-2

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SECTION 2

Decision Summary

2.1 Site Name, Location, and Background Site 11, Ingot Storage Areas, is one of several IRP sites being addressed under CERCLA at NSA Mechanicsburg. The NSA Mechanicsburg (EPA ID# PA3170022104) was placed on the United States EPA's NPL in May 1994. NSA Mechanicsburg is located in Hampden Township and the Borough of Mechanicsburg, Cumberland County, Pennsylvania.

The NSA Mechanicsburg is a shore activity under the Commander in Chief, United States Atlantic Fleet. The mission of NSA Mechanicsburg is to coordinate and provide common base support services to tenant activities and other naval units located on the base in Mechanicsburg. Naval Supply Systems Command Headquarters is a major tenant of the base. Among the more than 30 other tenants that provide supply and logistics support to the Navy fleet and other military units are the NAVICP, Defense Logistics Agency (DLA), Naval Sea Logistics Center, and Navy Fleet Material Support Office.

As part of the activities at NSA Mechanicsburg, pure lead ingots were stored outdoors since the early 1950s in four storage areas (317,413,414, and 606), which have been designated as Site 11; zinc ingots were stored in the largest area (317). This practice left the ingots exposed to decades of weathering, resulting in surrounding soil in all storage areas being contaminated with lead and also zinc in Storage Area 317. Sale of the ingots in commercial markets began in 2004, and all ingots have been removed from Site 11. '

2.2 Investigation and Removal Action History The following subsections provide summaries of the investigations that have been conducted at Site 11. No enforcement activities have occurred at NSA Mechanicsburg.

Site Assessment (Tethys Consultants, 1989) A site assessment of Storage Areas 317, 413, and 414 conducted by Tethys Consultants, Inc. (Tethys, 1989) evaluated the total concentrations and Extraction Procedure Toxicity (EP Tox) concentrations of lead and zinc present in surface and near surface soil. The study concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations in the surficial soil; however zinc concentrations in surface soil were found to be well below the risk-based concentrations acceptable for residential land use. Concentrations of lead and zinc decreased dramatically with depth. It was estimated that background levels were reached at depths of 24 to 26 inches below ground surface.

Site Inspection (EA, 1990) The site inspection included sampling and analysis of subsurface soil and groundwater (EA, 1990). The EP Tox concentrations for all metals were significantly less than the criteria for classification as a Resource Conservation and Recovery Act (RCRA) hazardous waste or

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RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

PADEP residual waste. Also, the total lead and zinc concentrations within the subsurface soil samples were well within the ranges of United States and regional background levels. Migration vertically through the soil appeared to be minimal and had no effect on groundwater quality. The site inspection concluded that no further investigation of the site was warranted, but it was recommended that efforts to minimize soil erosion and migration away from Site 11 storage areas be considered.

Removal Action (EA, 1997) An Engineering Evaluation/Cost Analysis (EE/CA) for control of soil erosion at Site 11 was prepared and released for public comment (EA, 1997a). An Action Memorandum was signed after the end of the public comment period (EA, 1997b). This action was completed in late 1997 and included the placement of gravel blankets and curbing.

Groundwater Sampling (EA, 1999) Anomalous concentrations of inorganics were identified in samples from one Site 11 monitoring well during preparation of the Analysis of Historical Groundwater Data (EA, 1999a). Additional groundwater samples were collected as part of the Sites I, 2, 5, 10, and 11 Groundwater Investigation (EA, 1999b). Groundwater sample concentrations were lower using a low-flow groundwater sampling technique. The recommendation in the report was that no further groundwater sampling was necessary at Site 11.

Soil Stabilization Demonstration Project (Encapco, 2004) In August 2002, the Navy awarded Encapco a contract to perform a "Demonstration Project" to stabilize contaminated soil and place it back into the excavated area at Site 11. The process involves mixing the contaminated soil with an asphalt emulsion formulated to chemically bind with and stabilize the contaminants. Once cured, the emulsion fixes the metals in place, preventing them from leaching (or separating) from the mixture. The final product can be used as a subbase for roadways or fill material (NSA, 2002).

In October 2003, the Demonstration Project was implemented for approximately 1,000 tons of soil at Area 413. The first step included collecting soil samples at depth and around the perimeter of the site to delineate the vertical and horizontal extent of lead contamination. A screening-level risk assessment performed indicated that onsite soils were uniformly contaminated to a depth of approximately 10 inches.

In order to field test the Encapco process, a 10-ton batch of contaminated soil was treated and underwent proof-of-process laboratory testing. From the laboratory results, a 98 percent reduction of leachable lead in the contaminated soil was observed. These concentrations were below regulatory levels for land disposaL

Once these results were received, the remaining approximately 990 tons of soil were treated and placed back into the excavated area and compacted. Additional laboratory results on pre- and post-treatment soil samples indicated that the process successfully reduced the levels of leachable lead. The EPA, however, indicated that the treated soil would still be considered waste in place, and that institutional controls would be required unless it could be shown that bioavailable lead levels were below concentrations of concern.

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2-DECISION SUMMARY

The Navy subsequently performed a lead bioavailability study, which determined that bioavailable lead concentrations had not been reduced through the Encapco process. As a result, the Navy developed plans for the removal of the impacted/treated soils within Area 413.

Time-critical Removal Action (Sovereign Consulting, 2005) A time-critical removal action for the lead-contaminated soil at Storage Area 414 of Site 11 was completed in December 2005 (Sovereign Consulting, 2006). Based on previous investigations, soil contamination was identified to a depth of 18 inches (10 inches of stone and 8 inches of soil). Soil was removed and transported off site to an approved disposal facility. Soil sampling conducted following the removal action confirmed the removal of lead contaminated soil to levels acceptable for unrestricted land use (Table 2-1).

SoillWaste Characterization (Tt, 2006) In March 2006, Tetra Tech collected samples to determine whether the soil within Areas 317 and 606 would be classified as hazardous waste as defined by RCRA. Soil characterization at Area 413 had already been completed as part of the soil stabilization demonstration project. Four composite soil samples were collected from Area 317, and two composite soil samples were collected from Area 606. Each of the six composite samples was formed from four grab samples. The composite samples were analyzed for polychlorinated biphenyls (PCBs) and subjected to the Toxicity Characteristic Leaching Procedure (TCLP) and analyzed for TCLP metals. PCB concentrations in all samples were less than 250 micrograms per kilogram ().lg/kg). Based on this TCLP testing, the soil at Area 317 would be classified as a nonhazardous waste, and the soil at Area 606 could be classified as a hazardous waste because lead concentrations in the TCLP extract from the two samples collected from that area [9.1 milligrams per liter (mg/L) and 24.6 mg/L] are greater than the regulatory level for lead (5 mg/L).

In May 2006, Tetra Tech collected 58 pre-excavation confirmation soil samples from areas around the perimeter and immediately below the areas targeted for potential excavation to delineate the vertical and lateral limits of lead-contaminated soil at Areas 317, 413, and 606 that would be addressed by the non-time-critical removal action. All of the confirmation soil samples had lead concentrations well below the EPA 400 milligrams per kilogram (mg/kg) criteria for unrestricted land use (Table 2-2).

Engineering Evaluation/Cost Analysis and Action Memorandum (Tt, 2006 and 2007) Based on the findings of the previous investigations, an EE/CA was conducted to identify and evaluate removal actions to mitigate potential risk at Storage Areas 317, 413, and 606 at Site 11. Three alternatives were identified, evaluated, and ranked. Based on the comparative analyses of the removal alternatives, the selected Non Time-critical Removal Action (NTCRA) involved excavation of soil and off-site disposal

As required by 40 CFR Section 300.415(n)(4) of the NCP, a public notice of availability of the Draft EE/CA was published in The Patriot-News on July 18, 2006 and was made available to the public for comment from July 18 to August 17, 2006. No comments were received from the public during the comment period. The Navy signed an Action Memorandum on May 11, 2007 to implement the NTCRA as specified in the EE/CA.

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RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

Removal Action (Sovereign Consulting, 2007) The NTCRA activities at Storage Areas 317, 413, and 606 at Site 11 were completed in 2007. Approximately 13,325 tons of soil were removed. The limits of the soil excavation were determined based on pre-removal confirmatory sampling. The 2007 Removal Action Closeout Report summarizes the confirmation sample results from the NTCRA and demonstrates that the potential risk to human and ecological receptors posed by Site 11 has been mitigated.

2.3 Community Participation The Navy and EPA provide information regarding the cleanup of NSA Mechanicsburg to the public through the community relations program, which includes a Restoration Advisory Board (RAB), public meetings, the Administrative Record file for the site, the information repository, and announcements published in local newspapers.

In accordance with Sections 113(k) and 117(a) of CERCLA, the Navy provided a public comment period from July 16 through August IS, 2007, for the Proposed Remedial Action Plan (pRAP) for Site 11. A public meeting to present the PRAP was held on July 18, 2007, at the Hampden Township Municipal Building. Public notice of the meeting and availability of the document was published in the Patriot-News newspaper on July 16, 2007.

The PRAP and previous investigation reports for Site 11 are available to the public in the Administrative Record maintained at:

Naval Support Activity 5450 Carlisle Pike Mechanicsburg, Pennsylvania 17055

or, the information repository located at:

Joseph T. Simpson Public Library 16 North Walnut Street Mechanicsburg, Pennsylvania 17055

2.4 Scope and Role of Response Actions NSA Mechanicsburg was placed on EPA's NPL in May 1994. As a result of the NPL listing and pursuant to CERCLA, the Navy, EPA, and PaDEP entered into a Federal Facilities Agreement (FFA) to ensure that the environmental impacts associated with past and present activities at the NSA Mechanicsburg are thoroughly investigated and appropriate remedial action taken as necessary to protect the public health, welfare and the environment, and to establish a procedural framework and schedule for developing, implementing and monitoring appropriate response actions at the NSA Mechanicsburg in accordance with CERCLA, the SARA, and the NCP.

The NSA Mechanicsburg FFA identifies and categorizes every area that was previously identified as having, or suspected to have had, a release of a hazardous substance.

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2-DECISION SUMMARY

The following IRP sites are being investigated following the CERCLA process with ultimate closure performed pursuant to a ROD:

• Site 1 - Carter Road Landfill • Site 2 - Building 904 landfill • Site 3 - Ball Road Landfill and Bum Pits • Site 4 - Radioactive Waste Disposal Area • Site 5 - Golf Course Landfill • Site 6 - Building 306 Underground Fuel Tank Leak • Site 7 - Buildings 403 and 404 Solvent Disposal Area • Site 8 - Ore Storage Area • Site 9 - Stormwater Drainage ditch • Site 10 - Building 608 Underground Storage Tanks • Site 11 - Ingot Storage Areas • Site 12 - Building 608 Solid Waste Management Units and Environmental Photographic Interpretation

Center Signatures • Sitel3 - Open Pit Incinerator • Site 14 - Water Towers • Site 15 - Building 704 Area Filled Sinkhole

In addition to the IRP sites, 51 Areas of Concern (AOCs) have been identified at the facility. With Sites 3, 8, and 9 subdivided into two operable units (OUs) each, there is effectively documentation on 69 sites. Currently, only five IRP sites (3, 5, 8, 9, and 11) and two AOCs (9-A and 53-A) are active, with RODs or no further action Decision Documents completed for the others.

Based upon the complete removal of contaminated soil, there are no principal threats posed by Site 11 and no remedial action is necessary to protect human health or the environment. This ROD for Site 11 does not include or directly impact any other sites at NSA Mechanicsburg.

2.5 Site Characteristics Site 11 includes Ingot Storage Areas 317, 413, 414, and 606. These storage areas are located near the southeastern boundary of NSA Mechanicsburg near Perimeter Road (Figure 2-1). Area 317 is located east of Building 314. Area 413 is located east of Building 412 and west of Area 317. Storage Area 414 is located adjacent to Area 413. Area 606 is located southwest of Buildings 506 and 507.

As part of the activities at the facility, pure lead ingots were stored outdoors since the early 1950s in four storage areas (317, 413, 414, and 606), which have been designated as Site 11; zinc ingots were stored in the largest area (317), which extends westward from Q Street. This practice left the ingots exposed to decades of weathering, resulting in surrounding soil being contaminated with lead and also zinc at Storage Area 317. Sale of the ingots in commercial markets began in 2004, and all ingots have been removed from Site 11.

The Site 11 storage areas are generally flat parcels of land covered by gravel. Surface water runoff from the ingot storage areas flows largely over paved and gravel surfaces and collects and drains via topographical low points leaving the site via the stormwater management system to the north or along the railroad tracks to the south.

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Page 12: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

Soil types at the storage areas are classified as Urban Land Hagerstown Complex. The bedrock directly underlying the soil at these areas is limestone of the Rockdale Run Formation. The Camp Hill Fault passes near the western side of the westernmost site (Area 606).

The principal aquifer in the area is the Rockdale Run Formation. Mechanicsburg Water Company has an active supply welt which withdraws water from this aquifer, located approximately 3,500 feet west of the southwestern corner of NSA Mechanicsburg. Private wells in the area are located to the north and west of the facility. Due to the proximity of a local groundwater flow divide at the base, the direction(s) of groundwater flow beneath the storage areas is uncertain, however past investigations have shown that the Site 11 ingot storage areas have not had any impacts on groundwater.

The Site 11 storage areas are covered with gravel. The site is located within an industrial area that does not contain ecological habitat.

No surface water bodies are present at or near the site. Surface water runoff is collected by the stormwater drainage system; therefore, no streams or surface water ecosystems occur at Site 11.

Additionally, there are no known threatened or endangered species or species of concern at the NSA Mechanicsburg facility.

2.6 Current and Potential Future Site and Resource Uses Site 11 is currently for industrial purposes consistent with the mission of NSA Mechanicsburg. NSA Mechanicsburg is controlled by a chain link fence. There is currently no planned future land use at Site 11. Future residential development of the site is unlikely; however, residential land use would be acceptable given the lack of contamination present at Site 11.

Groundwater beneath and in the vicinity of Site 11 is not currently used, based on past groundwater studies performed. Investigations related to groundwater at Site 11 have indicated that the site has not impacted groundwater, thus there is no concern for potential site-related contaminant migration offsite through groundwater.

2.7 Site Risks A specific human health risk assessment was not conducted; however, lead concentrations in surface soil within the storage areas are less than 400 mg/kg. This value is the lesser of the EPA Interim Soil Lead Guidance (400 mg/kg) and the PADEP Statewide Health Standard for residential soil (450 mg/kg). EPA's guidance states that residential areas with soil lead concentrations below 400 mg/kg, on average, generally require no further action.

2-6

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2-DECISION SUMMARY

EPA's Interim Soil Lead Guidance screening level of 400 mg/kg is protective of young children (ages 0 to 6) in residential backyards, day care and school yards, playgrounds and public parks. Lead is less toxic to adults than it is to children therefore the lead screening level of 400 mg/kg is also considered to be protective of adult residents, industrial workers, and maintenance workers. Consequently if lead concentrations in soil are lower than the lead screening level of 400 mg/kg then the site is also considered to be suitable for recreational and industrial land use.

The highest zinc concentration found in soils at Site 11 was 3,720 mg/kg and the average concentration was 267 mg/kg. In comparison, the EPA Region III Residential RBC for zinc is 23,000 mg/kg and the PADEP Statewide Health Standard for residential soil is 66,000 mg/kg. The EPA Region III RBC is based on young children (ages 0 to 6) being exposed to soil 350 days a year while the PADEP Statewide Health Standard is based on young children being exposed to soil 250 days a year. The EPA Region III RBC and PADEP Statewide Health Standard are also considered protective of exposures to soil by adult residents, industrial workers, and maintenance workers.

No other contaminants of potential concern were identified at Site 11 during prior investigations. There are no threats to human health associated with exposure to groundwater.

At present, there is no on-site environmental threat. The site is located within an industrial area that does not contain ecological habitat. The purpose of the removal action was to prevent potential exposure to current off-site receptors via the migration of lead­contaminated soil and potential future on-site receptors, if land use changed.

2.8 No Further Action Necessary As demonstrated by the mitigation of potential site risks, Site 11 poses no unacceptable risk to human health or the environment. The Navy and EPA, in consultation with PADEP, have determined that no further action (NFA) under CERCLA is required for Site 11. There are no principal threat wastes at the site and an NFA determination for Site 11 meets the statutory requirements of CERCLA Section 121 and the regulatory requirements of the NCP for protection of human health and the environment. No remedial response action will be performed at Site 11, and no restrictions on land use or exposure are necessary.

2.9 Documentation of Significant Changes The PRAP for Site 11 identified NFA as the preferred alternative. No members of the public attended the public meeting for the Site 11 PRAP, and no comments were received during the public comment period. Therefore, no significant changes were made to the preferred remedial action alternative identified in the PRAP.

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SECTION 3

Responsiveness Summary

The participants in the public meeting held on July 18, 2007, included representatives of the Navy and the Commonwealth of Pennsylvania. No members of the public attended the public meeting for the Site 11 PRAP, and no comments were received during the public comment period.

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Pennsylvania Department of Environmental Protection 909 Elmerton Avenue

Harrisburg, PA 17110-8200 September 10, 2007

Southcentral Regional Office 717-705-4705 FAX - 717-705-4830

Mr. James J. Burke, Director 3HSOO Hazardous Sites Cleanup Division US EPA, Region III 1650 Arch Street Philadelphia, PA 19103-2029

and

Chris Vitt, CAPT, SC, USN Commanding Officer Naval Support Activity Building 306-C, 5450 Carlisle Pike Mechanicsburg, PA 17055

Re: Record of Decision Site II Ingot Storage Areas Naval Support Activities Mechanicsburg Borough, Cumberland County

Dear Mr. Burke:

The Department of Environmental Protection (DEP) has reviewed the Record of Decision (ROD) for Site II, Ingot Storage Areas at the Naval Support Activities in Mechanicsburg, Pennsylvania, received September 6, 2007.

The selected remedy consists of the following:

o The United States Department of the Navy and United States Environmental Protection Agency have determined that no remedial action under CERCLA is necessary to protect human health or the environment from releases of hazardous substances at Site II, the Ingot Storage Areas. A removal action was conducted at Site II in 2007, which eliminated potentially unacceptable risk associated with contaminated soil at the site. The remaining site soil concentrations meet the site­specific cleanup goals that were established for the removal.

DEP hereby concurs with this determination. Thank you for the opportunity to comment on this EPA ROD.

If you have any questions regarding this matter, please call Mr. Asuquo Effiong at 717-705-4853.

Sincerely,

Rachel S. Diamond Regional Director

cc: Yazmine Yap - Deffler, US EPA, 3HS50 Jeff Henning, NAVICPM0815

r::J0. An Equal Opportunity Employer www.dep.state.pa.us Printed on Recycled Paper 1:tJ<9

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SECTION 4

References

EA (EA Engineering, Science, and Technology, Inc.), 1990. Final Report:: Site Inspection Studies, Navy Ships Parts Control Center, Mechanicsburg, Pennsylvania. Northern Division, Naval Facilities Engineering Command, Philadelphia, Pennsylvania.

EA, 1997a. Engineering Evaluation/Cost Analysis for the Sediment Control Removal Action at the Naval Inventory Control Point, Mechanicsburg, Pennsylvania. Northern Division, Naval Facilities Engineering Command, Lester, Pennsylvania.

EA, 1997b. Action Memorandum for the Sediment Control Removal Action at the Naval Inventory Control Point, Mechanicsburg, Pennsylvania. Northern Division, Naval Facilities Engineering Command, Lester, Pennsylvania.

EA, 1999a. Analysis of Historical Ground-Water Data at NAVICP, Mechanicsburg, Pennsylvania. Northern Division, Naval Facilities Engineering Command, Lester, Pennsylvania.

EA, 1999b. Results of Sites I, 2, 5, 10, and 11 Ground-Water Investigation, Naval Support Station (Formerly Naval Inventory Control Point), Mechanicsburg, Pennsylvania. Northern Division, Naval Facilities Engineering Command, Lester, Pennsylvania.

Encapco, 2004. Draft Demonstration Summary, Storage Area 413, Naval Support Activity, 2002. Naval Support Activity, Mechanicsburg, PA, Installation Restoration Program Fact Sheet. Innovative Cleanup Technology at the Ingot Storage Areas.

Sovereign Consulting, Inc., 2006. Project Close-Out Report, Soil Removal at Site 11 (Area 414), Ingot Storage Area, NSA Mechanicsburg, PA. Naval Support Activity Mechanicsburg, Mechanicsburg, Pennsylvania.

Sovereign Consulting, Inc., 2007. Project Close-Out Report. Soil Removal at Site 11 (Areas 317, 413, &606), Ingot Storage Area, NSA Mechanicsburg, PA. NAVFAC Mid-Atlantic, Norfolk, Virginia.

Tethys Consultants, Inc, 1989. Site Assessment of Storage Areas 317, 413, and 414 Located Within Navy Ships Parts Control Center, Mechanicsburg, Pennsylvania. Defense Logistics Agency, Directorate of Stockpile Management.

Tetra Tech, 2005. Action Memorandum for the Time-Critical Removal Action of the Storage Area 414 Soil at Site 11 - Ingot Storage Area. Engineering Field Activity Northeast, Naval Facilities Engineering Command, Lester, Pennsylvania.

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RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

Tetra Tech, 2006. Confirmation Sampling Trip Report, Site 11, Naval Support Activity Mechanicsburg.

Tetra Tech, 2006. Engineering Evaluation/Cost Analysis for Site 11 - Ingot Storage Areas. Naval Facilities Engineering Command Mid-Atlantic, Norfolk, Virginia.

Tetra Tech, 2007. Action Memorandum for the Non-Time Critical Removal Action of the Soils at Site 11 Ingot Storage Areas 317, 413, and 606. Naval Facilities Engineering Command Mid-Atlantic, Norfolk, Virginia.

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TABLE 2-1

CONFIRMATION SAMPLING RESULTS

SITE 11- INGOT STORAGE AREA 414

NSA MECHANICSBURG, PA

Sample Date Sample Type Concentration,

mg/kg 414PE-1 12/1/2005 Sidewall 37.1 414PE-2 12/1/2005 Sidewall 99 414PE-3 12/1/2005 Sidewall 31.8 414PE-4 12/2/2005 Sidewall 305 414PE-5 12/2/2005 Bottom 99.9 414PE-6 12/5/2005 Bottom 78.1 414PE-7 12/5/2005 Bottom 55.3 414PE-8 12/5/2005 Bottom 36.7 414PE-9 12/5/2005 Sidewall 305 414PE-10 12/5/2005 Bottom 66.3

414PE-ll 12/5/2005 Bottom 403 414PE-12 12/7/2005 Bottom 41.3 414PE-13 12/7/2005 Vert. Confirmatory 57.2 414PE-14 12/7/2005 Hor. Confirmatory 26.8 414PE-15 12/7/2005 Hor. Confirmatory 34 414PE-16 12/7/2005 Hor. Confirmatory 73.9 414PE-X 12/1/2005 Duplicate 28.8

EPA Interim Soil Lead Guidance - 400 mg/kg

Note: Sample 414PE-ll slightly exceeded the EPA criteria for lead in soil. Additional excavation was performed and the location resampled

(414PE13), with the resampling result below EPA criteria.

Page 19: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

RECORD OF DECISION SITE 11: INGOT STORAGE AREAS

TABLE 2-2

CONFIRMATION SAMPLING RESULTS

SITE 11- INGOT STORAGE AREAS 317, 413, AND 606

NSA MECHANICSBURG, PA

SAMPLEID DATE LEAD (mg/kg)

115BB15 5/2/2006 36.1 115BB16 5/2/2006 26.9 115BB17 5/2/2006 31.9 115BB18 5/2/2006 27.9 115BB19 5/2/2006 34.2 115BB20 5/2/2006 21.1 115BB21 5/2/2006 26.5 115BB22 5/2/2006 29.8 115BB23 5/2/2006 27.2 115BB24 5/2/2006 29.6 115BB25 5/2/2006 30.4 115BB26 5/2/2006 30.7 115BB27 5/2/2006 28.4 115BB28 5/2/2006 30.2 115BB29 5/2/2006 38.6 115BB30 5/2/2006 21.5 115BB31 5/2/2006 43.7 115BB32 5/2/2006 32.6 115BB33 5/1/2006 35.8 115BB34 5/1/2006 34.8 115BB34 5/1/2006 39.2 115BB35 5/1/2006 81.4 115BB36 5/1/2006 39.4 115B520 5/2/2006 35.3 115B521 5/2/2006 29 115B522 5/2/2006 32.5 115B523 5/2/2006 34 115B524 5/2/2006 24.7 115B525 5/2/2006 21.2 115B526 5/2/2006 23.8 115B527 5/2/2006 42.4

SAMPLEID DATE LEAD (mg/kg)

115B528 5/2/2006 29 115B529 5/2/2006 48.5 115B530 5/2/2006 27.8 115B531 5/2/2006 47.8 115B532 5/2/2006 48.1 115BS33 5/2/2006 22.8 115BS34 5/2/2006 28 115BS35 5/2/2006 26.9 115BS36 5/2/2006 26.3 115BS37 5/2/2006 27.2 115BS38 5/1/2006 40.8 115BS39 5/1/2006 33.6 115BS40 5/1/2006 26 115BS41 5/1/2006 40.9 115BS42 5/1/2006 120 115BS43 5/1/2006 35.4 115BS44 5/1/2006 27.4 115BS44 5/1/2006 36.4 115BS45 5/1/2006 41.3 115BS46 5/3/2006 69.8 115BS47 5/3/2006 53.8 115BS48 5/3/2006 26.4 115BS48 5/3/2006 40.7 115BS49 5/3/2006 33.6 115B550 5/3/2006 28.9 115B551 5/3/2006 22.9 115B552 5/3/2006 59.4 115B553 5/3/2006 30.2 115B554 5/3/2006 53 115B555 5/3/2006 34.1

EPA Interim Soil Lead Guidance - 400 mg/kg

4-4

Page 20: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

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Page 21: RECORD OF DECISION (RODS)concluded that storage of lead and zinc ingots on the surface of the three storage areas had increased the levels of total and extractable lead and zinc concentrations

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