SENECA ARMY DEPOT
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PFAS (PFOS and PFOA) Recent and Future Investigations
The Army submitted a draft work plan for a Site Investigation (SI) presenting the groundwater investigation activities to be conducted for the investigation of the emerging contaminants per and polyfluroalkyl substances [PFAS] at the following sites where Aqueous Film Forming Foams (AFFF) (e.g., firefighting foams) may have been used: the Fire Training and Demonstration Pad (SEAD-25), Fire Training Pit (SEAD-26), and Airfield and Fuel Pads (SEAD-122E). The draft work plan was reviewed by EPA and NYSDEC, who submitted comments to the Army. The final work plan was approved by EPA and NYSDEC.
SEAD-25 is located in the east-central portion of SEDA. SEAD-25 was in use from the late 1960s to the late 1980s. The former pad was used for fire control training. During the 1980s, the pad was used twice for fire-fighting demonstrations, including one demonstration in 1982 or 1983, and one in 1987.
SEAD-26 is located in the southeastern portion of SEDA and was used one to four times a year for firefighting training during which time various flammable materials were floated on water, ignited, and extinguished. Prior to 1977, the fire training area may have also been used for fire demonstrations.
SEAD-122E, and the surrounding airfield, are located in the southwest corner of SEDA. SEAD-122E is associated with the deicing of planes at four separate aircraft refueling areas at the former SEDA Airfield.
The SI sampling took place in April 2017, and the draft SI report was submitted in October 2017. EPA and NYSDEC reviewed the report and submitted comments to the Army. A final report was issued in 2018 and approved by EPA and NYSDEC. The maximum detected PFAS total in groundwater at Seneca was 92,900 parts per trillion (ppt). The current criteria used is the EPA Health Advisory Level (HAL) for drinking water for PFAS of 70 ppt. This consists of the combined total of the 2 most prevalent PFAS compounds known as Perfluorooctanyl Sulfate (PFOS) and Perfluorooctanoic Acid (PFOA). Most of the groundwater wells at SEAD-25 and SEAD-26 were highly contaminated with PFAS above the HAL.
A draft work plan for an Expanded SI (ESI) was submitted by the Army in 2018. The purpose of the ESI was to further delineate the extent of PFAS contamination in groundwater at and near SEAD-25 and SEAD-26. EPA and NYSDEC reviewed the draft work plan and submitted comments to the Army. A final work plan was issued in December 2018. EPA and NYSDEC approved the final work plan with provisions. EPA requested that future investigations include soil at the sites as well as groundwater in the deeper bedrock aquifer. EPA also requested that the Army conduct a Preliminary Assessment (PA) of the entire former depot to determine whether AFFF may have been used or stored at other areas of the former depot. If other areas are identified in the PA, then they would be investigated by the Army as well. EPA also requested that the Army conduct an off-depot well survey to determine whether there are any drinking water wells in use within 1 mile of the former depot boundary. If any wells are identified, then these users would be contacted by the Army to get permission to sample the wells. The Army has agreed to conduct the PA and well survey. Fieldwork for the ESI began in May 2019.
Sampling of 22 off-depot drinking water wells was conducted by NYSDOH in 2018. None of the wells had PFAS above EPA’s HAL. The Army is currently coordinating with NYSDOH on its well survey.
To the west, and downgradient, of SEADs-25 and 26 is a section of the Depot that has been designated for future farming use. In 2018, NYSDEC sent a letter to the Seneca County Industrial Development Agency (IDA) advising them of the potential risk of any future groundwater use within the farming area. Additionally, in February 2019, EPA, NYSDEC, and NYSDOH held a conference call with the Army, the IDA, the owner of 7,000 acres of former depot property and other stakeholders, during which the regulatory agencies made all of these stakeholders aware of the potential for PFAS contamination in groundwater, and of the ongoing and planned PFAS studies.
Next StepsEPA, NYSDEC, and NYSDOH will review the draft ESI Report after it is submitted by the Army. Plans are already underway for the sampling of additional secondary wells should the initial results of the ESI show that the full extent of PFAS contamination at SEADs 25 and 26 has not yet been delineated. Additionally, the Army will conduct the above-mentioned PA and well survey.
Public Participation Opportunities
Public comment will be solicited by the Army when the Proposed Plan for the OD Grounds is released. A Proposed Plan may also be issued for PFAS, in which case public comment would also be solicited.