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PUBLIC HEALTH ASSESSMENT ADDENDUM

LETTERKENNY ARMY DEPOT
USA LETTERKENNY SOUTHEAST AREA
CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA
AND
USA LETTERKENNY - PROPERTY DISPOSAL OFFICE AREA
CHAMBERSBURG, FRANKLIN COUNTY, PENNSYLVANIA


CONCLUSIONS

  1. ATSDR considers the Property Disposal Office Area and the Southeastern Area at Letterkenny to be Indeterminate Public Health Hazards. This determination was made because there are data gaps in on-and off-site environmental data and in site-specific health outcome data. Those data gaps are further discussed below.
  2. Potential exposure pathways both on and off site have been identified. On-site environmental characterization at Letterkenny is underway and will be reviewed when complete.
  3. Off-site potential exposure pathways include ingesting food products irrigated and farm animals (and associated products) watered with VOC-containing springs and wells. During 1993, a farm animal products study will be conducted. In addition, a hydrogeological study off-site of the SE and PDO Areas and sampling of off-site private wells with prior lead detections near the PDO Area will be conducted during 1993. Those studies will help identify the potential source of lead contamination. Those potential pathways cannot be evaluated until the results from those sampling data are available.
  4. In the past, off-site residents east of the SE Area were exposed to private well water containing VOCs at concentrations exceeding Maximum Contaminant Levels (MCLs). Those people were potentially exposed to contaminant levels which may result in adverse health effects. However, the actual concentration ranges and duration of exposure are unknown. Exposures stopped when residences with detected contamination in their wells were supplied bottled water in 1982. Possible health effects associated with past use of VOC-contaminated drinking water are unknown because of both lack of environmental exposure information and published data on health effects stemming from low-level, chronic exposure to multiple contaminants.
  5. Evaluation of two sets of health outcome data, from 1959 to 1979 and 1979 to 1981, found no elevated cancer mortality rates for either men or women of Franklin County. The knowledge of the duration of exposures together with site-specific health outcome data are necessary to determine possible adverse health effects from site-related exposures. At this time, those data are not available.
  6. This site is not being considered for dose reconstruction because of the hydrogeological conditions at Letterkenny; the underlying limestone aquifer is characterized by fracture and solution cavity-controlled permeability. Thus, intensive data collection would be necessary to accurately model the behavior of the aquifer underlying Letterkenny and beyond the boundary. Hydrogeological studies are planned for areas off-site of the SE and PDO Areas. Once those data become available, it may be feasible to conduct dose reconstruction analysis at Letterkenny.
  7. Persons associated with past exposure pathways via private wells are not being considered for inclusion in a registry because criteria for conducting such actions are not met. Persons at Letterkenny were exposed to more than one VOC, and at this time, ATSDR does not have a multiple-VOC exposure registry. Because there were a relatively small number of persons using those wells and the exposure duration is unknown, it is not feasible to include those persons in a registry at this time. If new hydrogeological data allow dose reconstruction analysis, inclusion in a registry may be reconsidered.
  8. Other off-site wells near the SE and PDO Areas were detected with carbon tetrachloride, aluminum, and lead in 1991. Those data are based on one sampling event. The maximum concentration of carbon tetrachloride has been evaluated and is not expected to result in adverse health effects. Exposure to aluminum and lead occurred for an unknown period of time, and the source of aluminum and lead may be associated with the residential piping. Lead is bioaccumulated, and any lead exposure to children may potentially add to their lead body burden.
  9. It is not possible to separate the surface water and groundwater pathway because surface waters at and near Letterkenny may either emerge at springs or submerge at sinkholes. The geologic variability of the site has precluded the definition of a contaminant plume in the unconfined, fractured limestone aquifer.
  10. Intermittent or incidental exposure may occur via dermal contact with and ingestion and inhalation of contaminants which have volatilized from surface waters in the SE and PDO Areas as well as in off-site creeks and springs. Human exposure to the previously detected concentrations of VOCs in those open areas is not likely to result in adverse health effects because of the limited duration of exposure and low levels previously detected.
  11. There are contaminated soils on site at Letterkenny. Those soils are in areas where remediation is occurring or where only limited numbers of installation and maintenance personnel would have access. Site restriction to personnel and use of appropriate protective gear during sampling, remediation, or maintenance activities would diminish the possibility of exposure.
  12. Additional environmental characterization of the SWMUs has begun. Most of the SWMUs are in the AD/AS Area, but two of them are in the SE Area. That information will determine if deer that inhabit and are hunted in the AD/AS Area are exposed to soil contaminants that may bioaccumulate in deer tissue. Until those data are collected and analyzed, potential exposure pathways cannot be delineated.
  13. As noted in the Toxicologic Evaluation section of this public health assessment, health guidelines needed to address all exposure routes (ingestion, inhalation, and dermal contact) are not available for all contaminants to which people were potentially exposed through the use of contaminated private well water. More information is needed about adverse health effects that may result from exposure to multiple chemicals, i.e., VOCs and metals.

RECOMMENDATIONS

  1. Continue to assess the hydrogeological conditions off-site of the SE, PDO, and AD/AS Areas. If environmental sampling or hydrogeological studies indicate that substances from Letterkenny may be migrating toward off-site private wells that were not supplied with municipal water, identify and periodically monitor those wells.
  2. Resample the six private wells that remain in service with lead detected at concentrations greater than the EPA action level of 15 µg/L. Current data are based on one sampling event. Samples should be collected from the wellhead and at the tap prior to and after "flushing" the piping system. The detection limit for lead should be set below the EPA action level of 15 µg/L.
  3. Educate persons with lead in their drinking water at concentrations greater than the EPA action level about corrective measures, such as flushing the water system prior to use, that can be taken to reduce lead levels in their well water.
  4. Continue to characterize Rowe Run Spring for addition of a groundwater treatment plant. Also, identify how surface waters are used in order to further evaluate potential and/or completed exposures.
  5. Continue to periodically sample fish tissue in the PDO Area in Rocky Spring Lake.
  6. Farm animals and associated products should be analyzed for the VOCs and metals previously detected in off-site private wells. Those potential food chain pathways cannot be evaluated until those data become available.
  7. Continue to characterize the SWMUs in the AD/AS and SE Areas. Monitoring should be conducted for site-related contaminants. The results from those ongoing studies will be evaluated by ATSDR upon their completion.
  8. Develop health guidelines, such as Minimal Risk Levels, for contaminants for all exposure routes (ingestion, inhalation, and dermal contact). Health guidelines are needed for 1,1,1-TCA, 1,1,2,2-PCA, 1,2-DCA, TCE, Chloroform, T-1,2-DCE, Aluminum, and Lead. Additional discussion on guidelines lacking for specific contaminants in this public health assessment are discussed in the Toxicologic Evaluation section. Validated studies should also be conducted or funded by ATSDR, EPA, or other appropriate agencies to determine possible health effects that may be associated with simultaneous exposure to multiple VOCs and to mixtures of VOCs and metals (i.e., TCE, 1,2-DCA, and lead).
  9. The data and information in the Public Health Assessment for the two NPL sites at the Letterkenny Army Depot, USA Letterkenny Southeastern Area and USA Letterkenny - PDO, have been evaluated for follow-up health activities by the ATSDR Health Activities Recommendations Panel (HARP). Community health education has been conducted by the Army through established technical review committee meetings, public meetings, and individual meetings with concerned citizens. Letterkenny continues to distribute environmental fact sheets to the public and communicate private well sampling results to homeowners whose wells have been sampled. The Army has also provided an alternate water supply to residences with wells containing concentrations of VOCs greater than MCLs. Currently, there are no indications that adverse health conditions are occurring or have occurred from past exposures to Letterkenny contaminants. Past exposures were for an unknown duration. However, if during the site-characterization and remediation process, environmental or health outcome data become available that indicate human exposure to hazardous substances is occurring at levels of public health concern, ATSDR will reevaluate the sites to determine necessary followup.

PUBLIC HEALTH ACTION PLAN

The public health action plan for the Letterkenny Army Depot sites contains a description of actions to be taken by ATSDR and/or other governmental agencies at and in the vicinity of the sites after completing this public health assessment. The purpose of the public health action plan is to ensure that the public health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. Included is ATSDR's commitment to follow up on the plan and ensure that it is implemented. Public health actions to be implemented are as follows:

A. Actions Undertaken

  1. Letterkenny Army Depot has provided the community with alternate water supplies (bottled water and connections to municipal water supplies) for potable use when VOCs greater than MCLs were detected in residential wells, off-site and adjacent to the SE Area.
  2. Community health activities undertaken by Letterkenny Army Depot include the preparation and distribution of quarterly, environmental fact sheets, communication of sampling results to private well owners, and meeting with community members to discuss remediation and environmental sampling planned for Letterkenny or the surrounding area. The environmental fact sheets discuss the developments under the Installation Restoration Program at Letterkenny to enable the community to become more involved with the environmental cleanup program. The fact sheets are entitled "Environmental Issues" and began in 1991. There are approximately 475 readers currently on the fact sheet mailing list. Estimated distribution dates are January, April, July, and October for 1993 (106).
  3. The Groundwater Treatment Plant near the IWTP lagoon in the SE Area has been in operation at Letterkenny since 1989. Remediation of the IWTP lagoon is completed, and closure certification is expected in 1993.

Actions Planned

  1. Letterkenny Army Depot, various Army agencies, EPA, PADH, PADER, and ATSDR will continue to provide current health information to the community to assess any possible adverse health outcomes associated with exposure to hazardous substances.
  2. In 1993, low temperature treatment of the K Area soils in the SE Area will be conducted. Further investigation at the Solid Waste Management Units primarily in the AD/AS Area will be conducted during 1993 (106). A groundwater treatment plant will be considered for Rowe Run Spring near the SE Area, if indicated by environmental sampling results and hydrogeological studies being conducted in 1993 (118).
  3. Letterkenny Army Depot in conjunction with various Army agencies will continue to perform field studies to evaluate the potential for uptake of contaminants into farm animals and their by products from Rowe Run Spring, off-site near the SE Area. Also, fish tissue in the Rocky Spring Lake system will also be analyzed for potential contaminant uptake. Those studies will be conducted during 1993.
  4. ATSDR will reevaluate and expand the public health action plan when needed. New environmental, toxicologic, or health outcome data, or the results of implementing the above proposed actions may determine the need for additional actions at the Letterkenny Army Depot NPL sites.

PREPARERS OF REPORT

Linda K. West, M.S.P.H.
Environmental Health Scientist

W. Mark Weber, Ph.D.
Geologist

Mark W. Evans, Ph.D.
Environmental Geologist

ATSDR Regional Representative:
Jack Kelly
Field Operations Branch
EPA Region III


REVIEWERS OF REPORT:

C. Virginia Lee, M.D., M.P.H.
Medical Officer
Federal Programs Branch
Division of Health Assessment and Consultation

Gary H. Campbell, Ph.D.
Environmental Health Scientist
Chief, Army Unit, Defense Facilities Assessment Section
Federal Programs Branch
Division of Health Assessment and Consultation

John E. Abraham, Ph.D., M.P.H.
Chief, Defense Facilities Assessment Section
Federal Programs Branch
Division of Health Assessment and Consultation


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  5. Jo, W.K., Weisel, C.P., and Lioy, P.J. 1990. Routes of Chloroform Exposure and Body Burden From Showering With Chlorinated Tap Water. Risk Analysis 10(4):575-580.

  6. Jo, W.K., Weisel, C.P., and Lioy, P.J. 1990. Chloroform Exposure and the Health Risk Associated With Multiple Uses of Chlorinated Tap Water. Risk Analysis 10(4)581-585.

  7. Letterkenny Army Depot. 1993. Progress Report for the First Quarter of Calendar Year 1993. April 9, 1993.

  8. U.S. Army Environmental Hygiene Agency. Public Release Comments; Letterkenny Army Depot Public Health Assessment. February 15, 1993.

  9. Letterkenny Army Depot. Draft Remedial Investigation of the Southeastern Area. 1992.

  10. Letterkenny Army Depot. Draft Remedial Investigation of the Property Disposal Area. 1992.

  11. Maxwell, N.I., Burnmaster, D.E., and Ozonoff, D. 1991. Trihalomethanes and Maximum Contaminant Levels: The Significance of Inhalation and Dermal Exposures to Chloroform in Household Water. Regulatory Toxicology and Pharmacology 14:297-312.

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