Former York Naval Ordnance Plant (fYNOP) is first site in the nation to be cleaned up under joint federal and state program.

The federal Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (PADEP) confirmed that the fYNOP is the first in the nation to volunteer and enroll in the One Cleanup Program. Under this agreement, reached in July 2005, the state and federal governments will work closely to streamline and accelerate the cleanup of the affected soil and groundwater at the fYNOP.

The U.S. Navy and others under contract to the federal government are the historic owners and operators of the fYNOP. Therefore the federal government bears a portion of the cost for remediation of the site. The U.S. Army Corps of Engineers (USACE) is their representative.

Cleanup of contaminated sites across the nation is taking a long time. Conflicting requirements among federal and state agencies has contributed to inconsistent and duplicative cleanup approaches, often resulting in inefficiency and confusion. EPA is leading the One Cleanup Program initiative in response to these concerns. The goal of the One Cleanup Program is to improve the coordination, speed, and effectiveness of the cleanup activities. New legislation is not required.

The EPA, PADEP, Harley-Davidson, and USACE have established procedures for the coordinated review of reports for the fYNOP and responses from the two agencies. Paul Gotthold, Director of Operations for EPA, Region III said, "Harley-Davidson has taken their environmental responsibilities very seriously and has already made substantial progress in the investigation and cleanup of past contamination.......... Under the new One Cleanup Program, Harley, EPA, and PADEP will expedite the completion of the property investigation and reach a final solution that will permanently protect human health and the environment."

Pennsylvania's Land Recycling Program will serve as a 'one-stop shop' for state and federal standards guiding the cleanup of industrial sites. After signing the agreement, PADEP Secretary Kathleen A. McGinty said, "Harley-Davidson has been proactive in cleaning up groundwater and soil contamination at the facility. It is exactly this kind of environmentally conscious firm, which provides good paying jobs for Pennsylvania citizens, that we want to help by streamlining the environmental cleanup procedures through this agreement with the EPA."

Harley-Davidson believes that its enrollment in the One Cleanup Program demonstrates the company’s continued commitment to improve the Site since its acquisition in 1981. Extensive investigations and corrective measures had been performed under supervision of the PADEP and the USEPA prior to entering the One Cleanup Program. These measures included the installation and operation of a groundwater extraction and treatment system. Under the One Cleanup Program, Harley-Davidson is further committed to conducting additional work necessary to meet PADEP and USEPA requirements. Harley-Davidson will continue to carry out the pre-existing cleanup program that is being conducted under an agreement by which the U.S. Navy shares in the cost of the clean up. 

Soils

Soils have been extensively sampled.  The EPA and the PADEP approved the Supplemental Remedial Investigation (SRI) Report for Soils in March 2010.  A Site-wide Soil Risk Assessment (RA) Report was approved by EPA and PADEP in July 2012.  Both agencies have determined that no unacceptable risk to human health related to soil currently exists at the fYNOP. 

Groundwater

The findings of the Site-wide groundwater investigation and the groundwater human health RA were summarized in reports submitted to the PADEP and EPA during March 2018. 

The fYNOP Team has operated a groundwater capture and treatment system for more than 25 years.  The system is continuously maintained to operate efficiently and reliably.   A groundwater extraction system was also designed and installed for the fYNOP’s Southern Property Boundary Area (SPBA) during 2018. A final SRI report for the SPBA, along with details of the system design, construction, and startup of a groundwater extraction system, was submitted to PADEP and EPA in October 2019. Coincident with this report, EPA published updated Groundwater Environmental Indicator Determination reports, confirming that the migration of contaminated groundwater, and current human exposures are under control at fYNOP.

Chlorinated solvents are the primary constituents of concern at the fYNOP.  Large concentration reductions have occurred (over 90% reductions in groundwater samples from most wells) of the historically used chlorinated solvents.  The significant reduction in concentrations over time demonstrates that remediation to-date is successful. The fYNOP Team completed annual sampling of monitoring wells in October 2019; and the results will be presented in the 2019 Annual Groundwater Report.

Military Munitions Response Program (MMRP) Areas

Harley-Davidson, under an agreement with the U.S. Government, completed the investigation of the former munitions areas at fYNOP. The Final MMRP Remedial Investigation (RI) report was submitted to EPA and PADEP in April 2018.  The PADEP and EPA approved the MMRP RI in July 2018 and a Remedial Alternative Analysis was approved in March 2019. 

Although no hazard exists to the public, the fYNOP has implemented precautionary measures (such as signs, locks, barricades and fencing) to secure old building structures and potential ordnance hazard areas from contact with employees and contractors. 

Cleanup Plans

During 2019, the fYNOP Team worked with PADEP and EPA to select the Final Remedy for the site.  Cleanup Plans were submitted to PADEP and EPA in November 2019. A summary of the Cleanup Plans for soil and groundwater and the MMRP Areas is presented below.

Site-Wide Soil and Groundwater

Final remedy selection was guided by a Corrective Action Objectives table developed cooperatively by the fYNOP Team, EPA, and PADEP.  The final remedy is a combination of engineering controls, institutional controls, and other remedial actions and obligations; and includes:

• Continued operation of the existing groundwater treatment system to remove volatile organic compounds in groundwater extracted from the NP York property and the SPBA of fYNOP in accordance with existing permit requirements.
• Maintenance of permanent caps on the Site to eliminate the direct contact exposure pathway. 
• Maintenance of the existing environmental covenant for the North Point (NP) York property and off-Site industrial property (south of fYNOP) that prohibit future residential use and the use of groundwater except for environmental sampling and remediation; establish an environmental covenant for the Harley-Davidson property to prohibit future residential use and groundwater use except for environmental sampling and remediation.
• Environmental covenants on the Harley-Davidson property and NP York property will include a requirement to perform a vapor intrusion pathway evaluation and, if necessary, mitigation of the potential vapor intrusion pathway prior to the construction of any new inhabitable structure. 
• Environmental covenants on the Harley-Davidson property and NP York property (will include a requirement that a soil management plan be in place prior to digging, excavating, grading, pile driving, and/or removal of ground cover materials on these properties.
• Periodic assessment of land and groundwater uses in specified areas surrounding fYNOP to verify continued non-use of groundwater for potable purposes and non-residential land use west of the Site. 
• Monitored natural attenuation will be used to meet PADEP groundwater medium specific concentrations and EPA maximum contaminant levels in the aquifer at designated portions of the fYNOP.  Two Technical Impracticability waivers are approved for the Site.  The waivers specify where groundwater resource restoration is not practicable due to the site conditions and the nature of the contaminant, but where the environment and human health are nonetheless protected.
• Implementation of a post-remediation care plan that identifies long-term monitoring and other activities to be performed following Final Report approval, in accordance with PADEP Act 2 Regulations.

MMRP Areas

The Final Remedy includes complete surface and subsurface ordnance clearance to achieve unlimited use and unrestricted exposure (UU/UE) for a significant portion of the MMRP Areas. Surface Clearance and land use controls (LUCs) will be used in the remaining portion of the MMRP Areas. The Final Remedy also includes removal of process materials, munitions debris, and material potentially presenting an explosive hazard within the impacted areas of Building 14 along with demolition of Building 14 and Building 16 remnants (former firing ranges).

The LUCs of the MMRP remedy include continued maintenance of the site security force and fencing, construction support (i.e., on-call oversite/support by qualified ordnance personnel during excavation activities) for intrusive activities, and biennial ordnance awareness training for personnel entering and working in the area not remediated to UU/UE.  Additional LUC components, which are shared with the Site-Wide Cleanup Plan, include prevention of future residential site use and prevention of the consumption of groundwater.

For more information on the One Cleanup Program visit the EPA website, http://www.epa.gov/oswer/onecleanupprogram.