Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

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FINAL

FINDING OF SUITABILITY TO TRANSFER (FOST) FOR THE 

PHASE III BRAC PARCELS 

LETTERKENNY ARMY DEPOT 

Delivery Order: 0008 

Contract No.: DACA31-94-D-0063 

Prepared for

U.S. ARMY CORPS OF ENGINEERS 

Baltimore District 

10 South Howard Street 

Baltimore, Maryland 21010 

and 

LETTERKENNY ARMY DEPOT 

1 Overcash Avenue 

Chambersburg, Pennsylvania 17201

Prepared by 

Weston Solutions, Inc. 

1400 Weston Way 

P.O. Box 2653 

West Chester, Pennsylvania 19380 

August 2003 

W.O. No. 02281.016.008.3102 
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TABLE OF CONTENTS 

Section Page 

1. PURPOSE...........................................................................................................................1 

2. PROPERTY DESCRIPTION...........................................................................................2 

3. ENVIRONMENTAL CONDITION OF THE PROPERTY..........................................3 

3.1 ENVIRONMENTAL CONDITION OF PROPERTY CATEGORY......................3 

3.2 STORAGE, RELEASE, OR DISPOSAL OF HAZARDOUS SUBSTANCES......4 

3.3 PETROLEUM AND PETROLEUM PRODUCTS .................................................4 

3.3.1 Underground and Aboveground Storage Tanks (USTs/ASTs) ...................4 

3.3.2 Non-UST/AST Storage, Release, or Disposal of Petroleum Products ........5 

3.4 POLYCHLORINATED BIPHENYLS (PCB) EQUIPMENT ................................5 

3.5 ASBESTOS..............................................................................................................5 

3.6 LEAD-BASED PAINT............................................................................................6 

3.7 RADIOLOGICAL SOURCES OR CONTAMINATION.......................................7 

3.8 RADON ...................................................................................................................7 

3.9 UNEXPLODED ORDNANCE (UXO) ...................................................................7 

4. ADJACENT HAZARDOUS CONDITIONS...................................................................8 

5. REMEDIATION................................................................................................................9

6. REGULATORY AND PUBLIC COORDINATION....................................................12 

7. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE 

AND CONSISTENCY WITH REUSE PLAN...............................................................13 

8. FINDING OF SUITABILITY TO TRANSFER ...........................................................14 

ENCLOSURE 1—SITE MAPS OF PROPOSED TRANSFER AREAS 

(FIGURES 1 AND 2) 

ENCLOSURE 2—TABLE 1, PROPERTY DESCRIPTION OF PHASE III BRAC 

PARCELS FOR THE FOST 

ENCLOSURE 3—TABLE 2, NOTIFICATION OF HAZARDOUS SUBSTANCE 

STORAGE, RELEASE, AND/OR DISPOSAL AT PHASE III 

PARCELS 
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TABLE OF CONTENTS 

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ENCLOSURE 4—TABLE 3, NOTIFICATION OF PETROLEUM PRODUCT 

STORAGE, RELEASE, AND/OR DISPOSAL AT PHASE III 

PARCELS 

ENCLOSURE 5—APPENDIX A—SUMMARY OF PARCEL AND BUILDING 

CONDITIONS, FOST FOR THE PHASE III BRAC PARCELS 

ENCLOSURE 6—SUMMARY OF BUILDING AND PARCEL CONDITIONS, PHASE III 

PROPERTY TRANSFER, RESULTS OF FINAL VISUAL SURVEYS 

ENCLOSURE 7—ENVIRONMENTAL PROTECTION PROVISIONS 

ENCLOSURE 8— REGULATORY AGENCY/PUBLIC COMMENTS AND 

REGULATORY AGENCY CONCURRENCE LETTERS 

ENCLOSURE 9—REFERENCES AND BIBLIOGRAPHY 
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LIST OF ACRONYMS 
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LIST OF ACRONYMS 

AA Ammunition Area 

ACM asbestos-containing material 

AMC Army Materiel Command 

AST aboveground storage tank 

BCT BRAC Cleanup Team 

BRAC Base Realignment and Closure 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CERFA Community Environmental Response Facilitation Act 

CFR Code of Federal Regulations 

DoD U.S. Department of Defense 

DSERTS Defense Site Environmental Restoration Tracking System 

EA environmental assessment 

EBS environmental baseline survey 

ECP environmental condition of property 

EPA U.S. Environmental Protection Agency 

FCRC Franklin County Reuse Committee (now known as the Letterkenny Industrial 

 Development Authority) 

FFA Federal Facilities Agreement 

FONSI Finding of No Significant Impact 

FOSL Finding of Suitability to Lease 

FOST Finding of Suitability to Transfer 

ft2

 square feet 

FTA Fire Training Area 

ft bgs feet below ground surface 

gal gallon 

HUD U.S. Department of Housing and Urban Development 

LBP lead-based paint 

LEAD Letterkenny Army Depot 

LIDA Letterkenny Industrial Development Authority 

mg/cm2 milligrams per square centimeter 

MOA Memorandum of Agreement 

NEPA National Environmental Policy Act 

NPL National Priorities List 

NRC Nuclear Regulatory Commission 

OSHA Occupational Safety and Health Administration 
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LIST OF ACRONYMS 

(Continued) 

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OU Operable Unit 

OVSA Open Vehicle Storage Area 

PADEP Pennsylvania Department of Environmental Protection 

PAH polycyclic aromatic hydrocarbon 

PCB polychlorinated biphenyl 

pCi/L picoCuries per liter 

PDO Property Disposal Office 

PP Proposed Plan 

ROD Record of Decision 

SE Southeastern 

SMSR Southern Martinsburg Shale Region 

SVOC semivolatile organic compound 

UST underground storage tank 

UXO unexploded ordnance 

VOC volatile organic compound 

WESTON® Weston Solutions, Inc. (formerly Roy F. Weston, Inc.) 

XRF X-ray fluorescence 
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1. PURPOSE 

The purpose of this Finding of Suitability to Transfer (FOST) is to document 

environmental conditions at selected parcels and buildings (Phase III 

parcels) at the Letterkenny Army Depot (LEAD or the Depot) for transfer to 

the Letterkenny Industrial Development Authority (LIDA) consistent with 

the Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA) Section 120(h) and U.S. Department of Defense 

(DoD)/Army policy. In addition, the FOST identifies property notices, as 

specified in the attached Environmental Protection Provisions (Enclosure

7), necessary to protect human health and the environment after such 

transfer. 
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2. PROPERTY DESCRIPTION 

LEAD is located in south-central Pennsylvania in Franklin County, 5 miles 

north of the Borough of Chambersburg, PA. The Depot originally covered 

19,243 acres (prior to transferring land as a result of the Base Realignment 

and Closure [BRAC] 1995 action), most of which will continue to be 

devoted to ammunition storage (16,614 acres). The industrial, 

maintenance, and recreational areas, which are located primarily in the 

southeastern corner of LEAD, encompass approximately 2,500 acres. The 

BRAC parcel consists of approximately 1,450 acres. 

The property to be transferred under LEAD Phase III consists of 

approximately 201 acres, which includes 3 on-Depot parcels, 20 buildings, 

and a water tower. The parcels are identified as: Parcels 3-89, 3-90, and 3-

91. In addition, Phase III includes 28 acres of subsurface property that is 

deeper than 8 feet below ground surface (ft bgs), located underneath 

parcels previously transferred as part of Phase II. These subsurface 

parcels are associated with three Phase II land parcels and portions of 

three Phase II road parcels, and are identified as: Parcels 2-53L, 2-54L, 2-

70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3. The top portion of these parcels 

(surface to 8 ft bgs) is discussed in the Phase II FOST (WESTON, 2002a). 

Also included in the FOST is the Letterkenny Reservoir (129 acres), 

located off-Depot, which is part of the privatization of utilities transfer 

(unrelated to BRAC). The reservoir is identified as Parcel 3-92. 

The Phase III BRAC parcels were previously used for industrial operations, 

supply (including vehicle) storage, administration and recreational 

activities, and military housing. Prior to the establishment of LEAD, the 

area consisted of agricultural (predominantly single-family farms used for 

both subsistence and commercial purposes) and forest lands. The intended 

future property use of the Phase III parcels includes industrial/ 

commercial/agricultural use and continued use of the reservoir, as 

described in the LIDA reuse plan (FCRC, 1997). However, the property 

was evaluated for unrestricted use so that it could be transferred with no 

commercial/industrial use restrictions. 

The locations of the parcels are shown in Figure 1 (Parcels 3-89, 3-90, 3-

91, 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3) and Figure 2 

(Parcel 3-92) in Enclosure 1. Information about these parcels and 

buildings is summarized in Appendix A (Enclosure 5). More details about 

these parcels and buildings can be obtained from the LEAD 

Environmental Baseline Survey (EBS) (WESTON, 1996), and the LEAD 

EBS Addendum (WESTON, 1999a). 
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3. ENVIRONMENTAL CONDITION OF THE PROPERTY 

The Army has determined the environmental condition of the proposed 

parcels and buildings to be transferred based on the LEAD EBS (WESTON, 

1996), the LEAD EBS Addendum (WESTON, 1999a), Supplement 1 to the 

LEAD EBS (WESTON, 2000b), the Community Environmental Response 

Facilitation Act (CERFA) Report (WESTON, 1997), and the remedial 

investigation/risk assessment reports listed in the following paragraph. A 

complete review of LEAD, U.S. Environmental Protection Agency (EPA), 

and Pennsylvania Department of Environmental Protection (PADEP) files 

was conducted while developing the LEAD EBS, which provided 

information on the environmental condition of the property. A list of 

environmental documents that provided information to prepare the FOST 

is provided in Enclosure 9, References and Bibliography. The review of 

documents, the EBS visual site inspections (WESTON 1996, 1999a, and 

2000b), and the final site inspections constitute an EBS specific to the 

transfer parcels. The conditions noted during the final site inspections are 

provided in Enclosure 6. 

In addition to the EBS, there are several remedial investigation/risk 

assessment reports and other documents related to site investigations; 

these documents are listed in Enclosure 9, References and Bibliography 

(IT, 2001; WESTON, 2003c, 2003d, 2002b, 2002c, 2002d, 2000a). All of the 

Phase III parcels to be transferred, with the exception of Parcel 3-92, are 

located within two National Priorities List (NPL) sites. Therefore, a 

Proposed Plan (PP) (WESTON, 2003a) and a Record of Decision (ROD) 

(WESTON, 2003b) have been prepared for the Phase III parcels to 

document a decision of no further action for the parcels. 

A complete list of references is provided in Enclosure 9. 

3.1 ENVIRONMENTAL CONDITION OF PROPERTY CATEGORY 

The DoD Environmental Condition of Property (ECP) Categories for the 

property are described in the following paragraphs: 

The majority of the buildings and areas covered in this FOST are classified 

as ECP∗

 Category 1. ECP Category 1 is defined as areas where no release or 

disposal of hazardous substances or petroleum products has occurred 

(including no migration of these substances from adjacent areas). 

 

∗

The Army Materiel Command (AMC) FOST/Finding of Suitability to Lease (FOSL) Guidance (Environmental 

Quality Division Office of the Command Counsel, AMC BRAC Office, February 1998, updated February 2000) 

was used as guidance to determine the ECP categories for the parcels. 
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Building 558 is classified as ECP Category 2. ECP Category 2 is defined as 

areas where only the release of petroleum products has occurred. 

The Open Vehicle Storage Area (OVSA) site, which is located within Parcel 

2-89, along with Building 572 because it is located within the boundaries of 

the OVSA site, are classified as ECP Category 4. ECP Category 4 is defined 

as areas where release, disposal, and/or migration of hazardous substances 

has occurred, and all removal or remedial actions to protect human health 

and the environment have been taken. 

A summary of the ECP categories for specific buildings, parcels, or study 

areas is provided in Table 1 – Property Description (Enclosure 2). 

3.2 STORAGE, RELEASE, OR DISPOSAL OF HAZARDOUS SUBSTANCES 

Hazardous substances were stored for 1 year or more in excess of the 

quantities referenced in Title 40 of the Code of Federal Regulations (CFR), 

Section 373.2(b), at Parcel 3-89 (Buildings 554, 558, and 559). There was 

no evidence of hazardous substance releases in excess of the quantities 

referenced in 40 CFR 373 as a result of these storage operations. All 

government hazardous substance storage operations have been 

terminated on the Phase III parcels. 

Hazardous substances were released or disposed of in excess of the 

quantities referenced in 40 CFR 373 in the OVSA site in Parcel 3-89. The 

release or disposal of these hazardous substances was subsequently 

remediated as part of the installation’s BRAC restoration program. All 

necessary response actions have been taken at the OVSA site (see Section 

5 for additional information). 

A summary of the buildings in which hazardous substance activities 

occurred is provided in Table 2 – Notification of Hazardous Substance 

Storage, Release, and/or Disposal (Enclosure 3). 

3.3 PETROLEUM AND PETROLEUM PRODUCTS 

3.3.1 Underground and Aboveground Storage Tanks (USTs/ASTs) 

Current UST/AST Sites: There are seven underground storage tanks 

(USTs) and nine aboveground storage tanks (ASTs) that are currently 

used for storage of petroleum products. There is no evidence of 

petroleum product releases in excess of 55 gallons (gal) at any of the 

active UST/AST sites: Buildings 522 (1 UST); 527 (1 UST); 529 (1 UST and 

1 AST); 539 (2 ASTs); 540 (1 UST); 541 (1 AST); 542 (1 AST); 543 (1 AST); 

544 (1 AST); 545 (1 UST); 554 (1 UST); and 558 (1 UST and 2 ASTs). 
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Note: There is one UST at Building 527 (2,500-gal diesel fuel) that is 

currently registered with PADEP. 

Former UST/AST Sites: There were seven USTs and five ASTs formerly 

on the property that were used for storage of petroleum products; these 

USTs/ASTs have been closed. There was no evidence of petroleum 

product releases at the following former UST/AST sites: Buildings 522 (1 

UST); 523 (1 AST); 527 (1 UST); 532 (2 ASTs); 541 (1 UST); 542 (1 UST); 

543 (1 UST); 544 (1 UST); and 558 (2 ASTs). Petroleum product releases 

occurred at the following UST site: Building 558 (1 gasoline UST). The 

release of these petroleum products was remediated at the time of the 

UST closure, as demonstrated by a letter from PADEP (PADEP, 2000) and 

a closure report (SS&McC, 1992). 

A summary of the UST/AST petroleum product activities is provided in 

Table 3 – Notification of Petroleum Product Storage, Release, and/or 

Disposal (Enclosure 4). 

3.3.2 Non-UST/AST Storage, Release, or Disposal of Petroleum Products 

There is no evidence that any petroleum or petroleum products in excess 

of 55 gal at one time were stored, released, or disposed of on the Phase III 

property as the result of non-UST/AST petroleum activities. Accordingly, 

there is no need for any notification of non-UST/AST petroleum product 

storage, release, or disposal. 

3.4 POLYCHLORINATED BIPHENYLS (PCB) EQUIPMENT 

There are no PCB-containing transformers or other PCB-containing 

equipment located on the Phase III property and no evidence of 

unremediated releases from PCB equipment. 

3.5 ASBESTOS 

There is documented asbestos-containing material (ACM) in 11 buildings 

as discussed in this FOST (Dames and Moore, 1993). The ACM includes 

transite board, baseboard trim, floor tile, vinyl flooring, mastic, pipe 

insulation, pipe fitting/valve insulation, ceiling insulation, pipe fittings, 

spackle compound, wall board, and refractory cement. To the best of the 

Army’s knowledge, the ACM in these buildings does not pose a threat to 

human health because all friable asbestos that posed an unacceptable risk 

to human health has been removed or encapsulated (WESTON, 1996, 

1999a, 2001a). 
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A total of seven buildings in the LEAD Phase III FOST parcels were not 

surveyed for ACM, including four buildings that were constructed after 

1980. A visual survey was completed as part of the EBS process for all of 

the buildings discussed in this FOST. The presence of ACM was not noted 

for any of these seven buildings during the EBS visual survey. However, an 

EBS visual survey does not constitute a full ACM survey. Assessment of 

ACM for the Phase III buildings is consistent with DoD policy (DOD, 1994) 

and Army regulation (Army, 1997) for BRAC properties. 

The presence of ACM is summarized by building in Appendix A 

(Enclosure 5). The deed will include the asbestos notice and covenant 

included in the Environmental Protection Provisions (Enclosure 7). In 

addition, a provision has been added (Enclosure 7) to provide notification 

and management requirements for the suspect ACM in the three buildings 

constructed before 1981 that were not surveyed for ACM. 

3.6 LEAD-BASED PAINT 

Based on the age of the buildings, it is assumed that all painted building 

structures constructed prior to 1978 listed in this FOST contain lead-based 

paint (LBP). 

LBP surveys were completed in 1996 for six buildings included in the 

Phase III transfer that at the time were used as residential housing units 

(Kenny Hill housing units, Buildings 540 through 545). LBP was 

identified at each of the residential buildings and in 1996 was noted to be 

in good condition (Dames and Moore, 1996). In addition to the LBP 

surveys for the six residential units, limited survey sampling performed 

by LEAD personnel in 1994 identified LBP at Building 523. The results of 

the LBP testing and surveys are summarized by building in Enclosure 5 

(Appendix A). An LBP risk assessment was not performed because all of 

the buildings are being transferred with an intended future use of 

nonresidential. However, an LBP risk assessment was completed for the 

Kenny Hill housing units (Buildings 540 through 545), even though the 

intended future use for these buildings is nonresidential. This LBP risk 

assessment was done as specified by Article 5, paragraph 5.07.B of the 

1998 Memorandum of Agreement (MOA) between the Department of the 

Army and LIDA (LIDA, 1998) to evaluate potential future use for 

residential or daycare (see Enclosure 5 for more information).

The deed will include the LBP notice and covenant as set forth in the 

Environmental Protection Provisions (Enclosure 7). In accordance with 

the environmental provisions of the deed, the transferee is responsible for 

abatement of LBP hazards and lead-soil hazards associated with 

buildings to be used for residential purposes (including daycare) within 

12 months of the date of the risk assessment and prior to occupancy or 

use of the Residential Real Property. 
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3.7 RADIOLOGICAL SOURCES OR CONTAMINATION 

There is no evidence that radioactive material, components, or sources were 

used or stored on the Phase III parcels property. 

3.8 RADON 

Radon surveys were conducted for 11 of the 20 buildings included in this 

FOST (R.E. Wright Environmental, Inc., 1994, 1995, and 1997). Some 

buildings were not tested because they were unoccupied (e.g., storage 

buildings) or are not regularly occupied. Radon was detected at or above 

the EPA-recommended residential action level of 4 picoCuries per liter 

(pCi/L) in the following building: 

 Building 539 (5.0 pCi/L in the basement). This building was 

considered a residential dwelling for the purposes of radon testing 

because it was used as a guesthouse; there are no plans to use this 

building for residential purposes in the future. Cracks in the 

basement were sealed; following this action radon was detected at 

a concentration of 2.8 pCi/L in the basement, which is below the 

EPA-recommended residential action level.

The results of the radon surveys are summarized by building in 

Appendix A (Enclosure 5). Radon concentrations may change with 

seasonal variations in the groundwater table. 

3.9 UNEXPLODED ORDNANCE (UXO) 

No UXO has historically been or is currently handled within the 

boundaries of the BRAC parcel, which includes all parcels and buildings 

that are the subject of this FOST. UXO is limited to the two open demolition 

areas and the two open burning areas in the Ammunition Area (AA), 

which are located approximately 3.2 miles from the FOST property. The 

AA is part of the Enclave Area property and is not scheduled for property 

transfer.
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4. ADJACENT HAZARDOUS CONDITIONS 

Parcel 3-89 is adjacent to or in proximity of several BRAC investigation 

sites. The preliminary results of these investigations indicate that there is 

no soil contamination that would pose a threat to the Phase III parcels. 

There are no other hazardous conditions on the property or adjacent 

property that require remediation for the property to be suitable for 

transfer for the intended use. 
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5. REMEDIATION 

The following environmental agreement is applicable to the property: 

Federal Facility Agreement (FFA) (3 February 1989) to address the two 

NPL sites under CERCLA. Three of the four Phase III parcels (i.e., Parcels 

3-89, 3-90, and 3-91) are located within the two NPL sites – the 

Southeastern (SE) Area and Property Disposal Office (PDO) Area. The 

remaining parcel (Parcel 3-92) is located off-Depot and is not on the NPL. 

The following environmental investigation/remediation activities were 

conducted or are being conducted on the property: 

Groundwater

Phase III parcels 3-89, 3-90, 3-91, 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, 

and 2R-86L-3 are located within the Southern Martinsburg Shale Region 

(SMSR) within LEAD (operable units [OU] PDO OU 7 and SE OU 13). An 

investigation was conducted to evaluate the groundwater quality within 

the SMSR (underneath the Phase III property). The investigation 

concluded that the topographic position of the SMSR and the outward 

groundwater flow from the SMSR protects the shale groundwater from 

contaminated groundwater present in surrounding low-lying areas. The 

results of the risk assessment showed that human health and ecological 

risks based on current and likely future commercial/industrial use, as 

well as potential residential use, are within acceptable limits. 

Consequently, no remedial actions are necessary to protect human health 

or the environment. The findings are documented in the Summary Report on 

the Groundwater Quality in the Southern Martinsburg Shale Region (WESTON, 

2003d). Note: The investigation also concluded that 28 acres of Phase II 

subsurface property that is deeper than 8 ft bgs (Parcels 2-53L, 2-54L, 

2-70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3) are suitable for unrestricted use. 

This FOST for Phase III includes transferring these Phase II subsurface 

parcels. The Environmental Protection Provisions for the previouslytransferred Phase I parcels and the top portion of the Phase II parcels that 

are located within the SMSR (as shown in Figure 1) will be modified to 

remove soil excavation and groundwater restrictions. This modification 

will be done via a separate document. In addition, the land use controls 

map will be modified to reflect these changes. 

Soil Contamination: 

 Open Vehicle Storage Area (OVSA) Site (Defense Site 

Environmental Restoration Tracking System [DSERTS] site 

numbers LEAD-110 and LEAD-114, PDO OU 6 and SE OU 8): The 

site was used for storage of military vehicles from 1947 through 

1998. Field activities were performed at various periods between 

October 1998 and November 2000 to investigate soil, sediments, 
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and groundwater, and then additionally in November 2002 

(groundwater sampling). In 2000, a non-time-critical removal 

action was conducted to excavate polycyclic aromatic 

hydrocarbon (PAH) contaminated soils and dispose of them in 

off-site commercial disposal facilities. A subsequent risk 

assessment showed that concentrations of chemicals found in site 

soils and groundwater are low enough that there are no 

unacceptable levels of human health or ecological risk based on 

current and likely future commercial/industrial use, or as 

residential use. No further actions are warranted. The 

investigations, removal action, and risk assessment are 

documented in the Remedial Investigation and Risk Assessment Report 

for the Open Vehicle Storage Area, Property Disposal Office (PDO) 

Area Operable Unit (OU) 6 and Southeastern (SE) Area OU 8

(WESTON, 2003c). 

 Former Uncurbed AST at Building 532 site (DSERTS Site LEAD126, PDO OU 6): An uncurbed single-walled AST used for 

gasoline storage was located near Building 532. Field activities 

were performed in April 1999 to investigate soils. Results of the 

remedial investigation and risk assessment showed that 

concentrations of chemicals found in site soils are low enough that 

there are no unacceptable levels of human health or ecological risk 

based on current and likely future commercial/industrial use or 

residential use. No further actions are warranted, as documented 

in the Remedial Investigation and Risk Assessment Report for the 

Former Uncurbed AST (FAST) Site North of Building 532, Property 

Disposal Office (PDO) Area Operable Unit (OU) 6 (WESTON, 2002b). 

 Backwash Discharge Area from the Water Treatment Plant site 

(DSERTS Site LEAD-011, SE OU 8): Flocculant from the drinking 

water treatment plant was disposed of in this area in the past. 

Field activities were performed in October 1998 to investigate soils 

and drainageways. Results of the remedial investigation and risk 

assessment showed that concentrations of chemicals found in site 

soils are low enough that there are no unacceptable levels of 

human health or ecological risk based on current and likely future 

commercial/industrial use or residential use. No further actions 

are warranted, as documented in the Remedial Investigation and 

Risk Assessment Report for the Backwash Discharge Area, Southeastern 

(SE) Area Operable Unit (OU) 8 (WESTON, 2002d). 

 Building 400 Series Fire Training Area (FTA) site (DSERTS Site 

LEAD-118, SE OU 8): The area had been reportedly used in the 

past for a short period of time as a fire-fighting training area 

where a large metal pan was placed on the ground and filled with 

various flammable liquids, which were ignited. Field activities 

were performed in September 1998 to investigate soils. Results of 
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the remedial investigation and risk assessment showed that 

concentrations of chemicals found in site soils are low enough that 

there are no unacceptable levels of human health or ecological risk 

based on current and likely future commercial/industrial use or 

residential use. No further actions are warranted, as documented 

in the Remedial Investigation and Risk Assessment Report for the 

Building 400 Series Fire Training Area, Southeastern (SE) Area 

Operable Unit (OU) 8 (WESTON, 2002c). 
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6. REGULATORY AND PUBLIC COORDINATION 

EPA Region III, PADEP, and the public were notified of the initiation of 

the FOST. Regulatory/public comments received during the FOST 

development were reviewed and incorporated as appropriate. All 

regulatory agency comments were resolved. Copies of the 

regulatory/public comments and the regulatory agency concurrence 

letters are included in Enclosure 8. 
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7. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE 

AND CONSISTENCY WITH REUSE PLAN 

The environmental impacts associated with the proposed transfer of the 

property have been analyzed in accordance with NEPA. The results of 

this analysis have been documented in the Final Environmental Assessment 

(EA) for BRAC 95 Disposal and Reuse of Property at Letterkenny Army Depot, 

Chambersburg, Pennsylvania, dated January 1998. The environmental 

effects of the activities anticipated under the proposed transfer were 

determined not to be significant as documented in the Finding of No 

Significant Impact (FONSI) signed on 11 March 1998 (USAMC, 1998). In 

addition, the proposed transfer of the property is consistent with the 

intended reuse of the property as set forth in the LIDA reuse plan (FCRC, 

1997). 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST)

8. FINDING OF SUITABILITY TO TRANSFER

Final

Based on the previous information, I conclude that all removal or remedial actions necessary to

protect human health and the environment have been taken and the property is transferable

under CERCLA Section 120(h)(3). In addition, all DoD requirements to reach a FOST have been

met subject to the terms and conditions set forth in the attached Environmental Protection

Provisions, which shall be included in the deed for the property. The Environmental Protection

Provisions also include the CERCLA Section 120(h)(3) covenant and access provisions. Finally,

the hazardous substance notification (Table 2) will be included in the deed as required under

CERCLASocti= 120ih) =dI>on FOSTguiM=~d.,

JAMES R. DAVIDSON

Director

National Capital Region Field Office

U.S. Army Installation Support

Management Agency

ENCLOSURES

Enclosure 1 Site Maps of Proposed Transfer Areas (Figures 1 and 2)

Enclosure 2 Table 1, Property Description of Phase III BRAC Parcels for

theFOST

Enclosure 3 Table 2, Notification of Hazardous Substance Storage,

Release, and/or Disposal at Phase III Parcels

Enclosure 4 Table 3, Notification of Petroleum Product Storage, Release,

and/or Disposal at Phase III Parcels

Enclosure 5 Appendix A, Summary of Parcel and Building Conditions,

FOST for the Phase III BRAC Parcels

Enclosure 6 Summary of Building and Parcel Conditions, Phase III

Property Transfer-Results of Final Visual Surveys

Enclosure 7 Environmental Protection Provisions

Enclosure 8 Regulatory Agency/Public Comments and Regulatory

Agency Concurrence Letters

Enclosure 9 References and Bibliography

MK01 10:\02281016.008\PHASEHlFOSnPHASEHlFOST_TEXT.DOC 14 81812003
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_1&2_BKRS.DOC 9/9/2003 

ENCLOSURE 1 

SITE MAPS OF PROPOSED TRANSFER AREAS 

 Figure 1—Location of Phase III Parcels within PDO and SE 

Areas

 Figure 2—Location of Letterkenny Reservoir and Dam, Parcel 

3-92
STATE RT 433

GATE

 

GATE

RESERVATION BOUNDARY

RESERVATION BOUNDARY

8

7 COVERED WALKWAY

211

WALKOVER

8-1

9 1-7

5

COVERED WALKWAY

STATE RT 443

S

CLASSIFICATION YARD NO 1

GATE

R.R. NO. 5

GATE RESERVATION BOUNDARY

VALVE

HOUSE

357

BOILER PLANT

350

349

346

301

T

GATE

S

T

T

T

T

T

T

NO. 6

GATE

RESERVATION BOUNDARY

363

PLANT

360 T

372

371

INDUSTRIAL WASTE

TREATMENT PLANT

PARKING

401

S-400

403

247

11

397 CREDIT UNION

351

ATM

350-1

102

102-A

1

350

352

505

509

330

320

324

295

340

PARKING

PARKING

S

PARKING

PARKING

PARKING

GATE

GATE

GATE

PARKING

TOWER

PARKING

RADAR TEST SITE

RADAR TEST SITE

TOWER

PARKING

GATE

RADAR TEST SITE

GATE

PARKING

PIT

TRENCH DRAIN

450

19

S20-1

S20-2

S20-3

37

S20-4

S20-5

37-1

18

S36-1

S36-2

S38-1

S26-4

S38-2

S26-3

S26-2

S26-1

227

238

226

225 13

22412

S-234 BOTTONWOOD CAFETERIA 14

TS-10-2 TS-31-1 TS-10-3 TS-31-2 10 TS-10-4

10-1 TS-31-3 TS-10-5

3

233 TS-31-4

2

103

COVERED WALKWAY

T-5-1

6

5 5-2

4

SLAB SLAB

SLAB SLAB

SLAB

PARKING

SATELLITE

PARKING

DISH

S

S

PARKING

S

PARKING

SLAB

PARKING

507

5506

581

GOLF COURSE

GREASE RACK

PARKING

S

COVERED

429

421

S58-1

431

441

190

57

47

56

S46-7

T-56-2

47-1

S46-4

S46-8

37

S46-1

S46-5

S46-9

55

1-55

S46-2

S46-6

S36-5

S45-7

S46-3

S36-3

S36-6

S45-4

S45-8

S36-4

S45-1

54

S45-5

S45-9

S45-2

S45-6

S45-3

S35-5

1-54

S35-3

S35-6

44

53

S35-1

S35-4

S35-2

1-44

34

43

42-1

33

42

51-1

50

32

41

41-1

31

TRAILER

PARKING

PARKING

DOCK 36 DOCK 35

LONG TERM VEHICLE STORAG

LONG TERM VEHICLE

HAZARDOUS

MATERIALS

WAREHOUSE

2291

(HELIPORT)

APPROACH - DEPARTURE

ZONE

T-2283

1095

CARGO ROAD

GATE

ZONE

TAKEOFF - SAFETY

ZONE

APPROACH - DEPARTURE

ZONE

TAKEOFF - SAFETY

I-650

545 544 543 542

541 540

523

521

531

446

437

522

524 530

554

559

572

651

532

558

PAVED PARKING

PAVED PARKING

PLANT

SWIMMING

 

TENNIS

COURT

GRAVEL PARKING

RIP RAP

KENNY

HILL WATER

TOWER

PAVED

PARKING

PARKING

PARKING

ABANDONED

HELIPORT

GOLF COURSE

GOLF COURSE

GOLF COURSE

GOLF COURSE

GATE

WIND SOCK SIGN

PARKING

PARKING

HELIPORT

WATER TREATMENT

T-410 T-455

424

T-430

412

425

422

423

411

S58-2

433

428

418

417

416

WOODEN TENT PADS

PAVED PARKING

SLAB

SLAB

SLAB

PARKING

438

426

436

PARKING

511

PAVED PARKING

521

RESERVATION BOUNDARY

PARKING LOT

LOADING DOCK

GUARD HOUSE

BUS STOP

PARKING

2290

2279

T-2268

646

AVENUE

GATE

SCRAP YARD

SCRAP YARD

LOADING

BASKETBALL

R.R. GATE

COURT

GATE

GATE

GATE

WALL

2289

DRY WELL

CHILDDEVEL.

692 CENTER

PLAYGROUND

SOFTBALL

FIELD BASEBALL

FIELD

GARDENS

GARDENS

CONCRETE PADS 640

627 629

619

618

617

GRAVEL PARKING LOT

616

621

628

GATE NO. 17

T-635

STATEROUTE340

PAVED PARKING

PAVED PARKING

PAVED PARKING

CHAPEL GRAVEL PARKING 639 COMMUNITY FITNESS CENTER

SIGN

664

663

DIRECTOR

686

683

PARKING

652

675

691

FOOTBRIDGE

ASPHALT

601 602

603 604

605 606 607 608

610

PAVED PARKING

CONCRETE

GATE

PLAYGROUND

625

SOFTBALL

FIELD

OF PUBLIC

WORKS

FOOTBRIDGE

CONCRETE PADS

TRAILER CAMP

PAD

RESERVATION BOUNDARY

RESERVATION BOUNDARY

PARKING

PAVED

676

612

600

RESERVATION BOUNDARY

OPEN

STORAGE

OPEN STORAGE

OPEN STORAGE

2272

PARKING

HAZARDOUS

STORAGE

WASTE

SCRAP YARD

COMBAT VEHICLE

TEST TRACK

714 715 716 717 718 719

904

914

924

934

944

903

913

923 902

912

894

893

892

891

883

873

882

872

862

852

881

871

861

851

711

710

841

709708707706

705704

954

964

974

984

994

933

943

953

963

973

983

922

932

942

952

962

901

911

921

931

941

712 713

993

992

982

972

991

981

971

961

951

729728727726725724723722721

720 941-1

LONG TERM VEHICLE STORAGE TANKS 943-1944-1

LONG TERM VEHICLE STORAGE TANKS

1094

1044

1034

1024

1054

1014

1004

1084

1074

1064 1053

1043

1033

1093

1083

1073

1063

1023

1013

1003

1072

1062

1052

1042

1092

1082

1032

1022

1012

1002

1081

1071

1061

1091

1051

1041

1031

1021

1011

1001

841-1

842-1

RAILROAD CLASSIFICATION YARD NO. 2

PAD 5

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PAVED 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4-1 4-2

196

198 199 200

477

476

475 478 479

480

449

440

444

442

GATE 1

529 539

546

2282

676

676

688

695

694 684

679

680

681

682 678

659

658

637

696

615

614 613

623

644 648

649

645

3311

3321

3317

3335

344

343

342

354

399

331

2277

2271

2261

2270

2264

2262

2265

2260

2280

2274

2275

2276

299

2278 (Demolished)

2285 (Demolished)

2284 (Demolished)

536

527

528

 

STATE RT 443

COFFEY AVE

STATE RT 443

OVERCASH AVENUE

TANK ROAD

AVENUE

COFFEY AVENUE

COFFEY

CALIFORNIA

NEW YORK AVENUE

ARKANSAS AVENUE

OHIO AVENUE

NEBRASKA

OVERCASH AVENUE

AVENUE

OVERCASH AVE

WISCONSIN AVENUE

NEW JERSEY AVENUE

581

COFFEY AVENUE

ARKANSAS AVENUE

TEXAS AVENUE

IDAHO AVENUE

NEW MEXICO

OVERCASH AVENUE

AVENUE

OVERCASH AVENUE

INDIANA AVENUE

ILLINOIS AVENUE

KANSAS AVENUE

TANK ROAD

CARGO ROAD

CARGO ROAD

SANDBAG ROAD

COFFEY AVENUE

GERRY ROAD

COFFEY AVENUE

CARBAUGH AVENUE

MICHIGAN AVENUE

CARBAUGH AVENUE

CARBAUGH AVENUE

COFFEY

AVENUE

PENNSYLVANIA

GEORGIA AVENUE

T692

H PATROL ROAD

STATE ROUTE

CAISON ROAD

CARBAUGH AVENUE

SANDBAG ROAD

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AVENUE (LETTERKENNY WEST)

AVENUE (LETTERKENNY WEST) PENNSYLVANIA

MICHIGAN AVENUE (TECHNOLOGY)

OREGON AVENUE (OPPORTUNITY)

OREGON AVENUE (OPPORTUNITY)

CALIFORNIA AVENUE (ADVANTAGE)

CALIFORNIA AVENUE (ADVANTAGE)

AVENUE (ADVANTAGE)

E (ADVANTAGE)

CALIFORNIA AVENUE (ADVANTAGE)

TEXAS AVENUE (INNOVATION)

TEXAS AVE (INNOVATION)

WASHINGTON AVENUE (INNOVATION)

WASHINGTON AVENUE (INNOVATION) WASHINGTON AVENUE (INNOVATION)

VEHICLE ROAD (DEVELOPMENT AVENUE)

VEHICLE ROAD (DEVELOPMENT AVENUE)

SCALE HOUSE ROAD (PROSPERITY)

SANDBAG ROAD (EXCHANGE AVENUE)

CARGO ROAD (OPPORTUNITY)

OKLAHOMA AVENUE (SUPERIOR)

OKLAHOMA AVENUE (SUPERIOR)

AVENUE (CAPITAL)

NEW MEXICO AVENUE (CAPITAL)

MICHIGAN AVENUE (TECHNOLOGY)

340 (LETTERKENNY ROAD WEST)

NUE (RESOURCE)

URCE)

EAST PATROL ROAD (RESOURCE)

EAST PATROL ROAD (RESOURCE)

EAST PATROL ROAD (RESOURCE) EAST PATROL ROAD (RESOURCE)

EAST PATROL ROAD (RESOURCE)

ROL ROAD (RESOURCE)

(EXCHANGE

SANDBAG ROAD (EXCHANGE AVENUE)

AVENUE)

(EXCHANGE AVENUE)

OREGON AVENUE (OPPORTUNITY)

MICHIGAN AVENUE (TECHNOLOGY)

MICHIGAN AVENUE (TECHNOLOGY)

LETTERKENNY ROAD

2-36

2-74B

2-76

2-48

2-63

2-71

2-64

2-52

2-49

2-40

2-38

2-39

2-42

2-68

2-44

2-43

2-45

2-46 2-67

2-51

2-58

2-72

2-59

2-50

2-47

2-53 and 

2-53-L 2-41

2-65

2-54 and

2-54-L

2-61

2-35

2-56

2-62

2-60

2-57

2-66

2-77

2-55

2R-84L-3

(Texas)

2R-86L-3 

(Carbaugh)

2R-80L-3

(Coffey)

Parcel 3-89

Parcel 

3-91

3-90

Parcel

29

2

7

1

5

4

6

24

3

23 13

27

21

18

20

16

17

19

11

34

25

33

10

26

28

12

8

9

1

3

2

4

2-70 

and 

2-70-L

| Q:\LEAD\aprs\phase3.apr | Layout- smsr zoom E size | q:\lead\pdfs\phase_3\in\phase3_smsr_zoom.eps | 9:25 AM, 4/30/2003 |

1

Building 400 Series Fire Training Area

Former Uncurbed AST at Building 532

Open Vehicle Storage Area (OVSA)

BRAC Sites

Phase III Parcels

Phase III Parcel That is Lower Portion of Phase II Parcel (8ft. below ground surface to center of the earth)

Backwash Discharge Area from the Water Treatment Plant

2-70-L 2-70-L

3-90

1

2

3

4

Shale/Limestone Boundary

2-48 Phase II Parcels (Does not show all roads)

Phase I Parcels

Enclave

Drainage Divides 

Roads

Buildings

Date:

01-18-2001

U.S. Army Corps of Engineers

Baltimore District

Letterkenny Army Depot

Chambersburg, PA

400 0 400 Feet

N

W E

S

Figure 1

Location of Phase III Parcels

within PDO and SE Areas

SM

Township Line

Note: Parcel 3-92 (Letterkenny Reservoir) is located off-depot and is not shown here.
Parcel 

3-92

Parcel 

3-92

Figure 2

Location of Letterkenny 

Reservoir and Dam

Parcel 3-92

Source:

Pennsylvania USGS 7.5 Quadrangles (Fannettsburg 1966; Photorevised 1973, 

Photoinspected 1984; Saint Thomas 1944, Photorevised 1968 and 1973; Chambersburg 

1944, Photorevised 1968 and 1973, Photoinspected 1984; Roxbury 1966, 

Photorevised 1973) UTM Feet NAD 27 Zone PA-South SM

U.S. Army Corps of Engineers

Baltimore District

900 0 900 1800 Feet

N

| Q:\LEAD\aprs\reservoir.apr | Layout 11x17 | q:\lead\pdfs\in\reservoir.eps | 1:41 PM, 3/11/2003 |

600 0 600 Feet

LEAD
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_1&2_BKRS.DOC 9/9/2003 

ENCLOSURE 2 

TABLE 1 

PROPERTY DESCRIPTION OF PHASE III BRAC 

PARCELS FOR THE FOST 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC 

2-1

Table 1 

Property Description of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

Parcel 

No. 

Building 

No. 

Property Description 

(Area in sq. ft.) 

Parcel Area 

(Acres) 

Year 

Built 

EBS Parcel 

IDa 

Condition 

Categoryb 

3-89 522 Administration – Office 

(7,896) 

191 1942 12(5)HR 1 

3-89 523 Office (6,400) 191 1943 12(5)HR 1 3-89 527 Emergency Generator (263) 191 1988 12(5)HR 1 3-89 528 Swimming Pool Filter Room 

(60) 

191 1945 21(7)HR 1 

3-89 529 Community Club (10,903) 191 Unknown 

(renovated 

1942) 

19(5)HR 1 

3-89 530 Information Processing Center 

(1,045) 

191 1985 38(7)HR 1 

3-89 532 Golf Cart Storage 

Maintenance Building (3,600)/Former Uncurbed AST at Building 532 site

191 1991 19(5)HR 

37(7)PS 

(Former AST 

site) 

1 

3-89 536 Locker Room (2,000) 191 1942 21(7)HR 1 3-89 539 Guest/Temp Housing (2,830) 191 Unknown 

(renovated 

1943) 

38(7)HR 1 

3-89 540 Housing – Kenny Hill (2,542) 191 1954 12(5)HR 1 3-89 541 Housing – Kenny Hill (1,660) 191 1954 12(5)HR 1 3-89 542 Housing – Kenny Hill (1,660) 191 1954 12(5)HR 1 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 1 

Property Description of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC 

2-2

Parcel 

No. 

Building 

No. 

Property Description 

(Area in sq. ft.) 

Parcel Area 

(Acres) 

Year 

Built 

EBS Parcel 

IDa 

Condition 

Categoryb 

3-89 543 Housing – Kenny Hill (1,660) 191 1954 12(5)HR 1 3-89 544 Housing – Kenny Hill (1,660) 191 1954 12(5)HR 1 3-89 545 Housing – Kenny Hill (2,542) 191 1954 12(5)HR 1 3-89 546 Storage (864) 191 1973 12(5)HR 1 3-89 554 Water Treatment Plant (2,803) 191 1957 21(7)HR 1 3-89 558 Water Treatment Plant – 

Emergency Pump Building (1,643) 

191 1953 21(7)HR 2 In 

frore

3-89 559 Water Treatment Plant – 

Chlorinator Building (245) 

191 1968 21(7)HR 1 

3-89 572 Storage – Fire Dept (86) – 

located in Open Vehicle Storage Area (OVSA) site 

191 1982 13(7)PS/PR 1, 4 No

OV

3-89 N/A Water tower 191 39(7)HR 1 3-89 N/A Open Vehicle Storage Area 

(OVSA) site 

191 N/A 13(7)PS/PR, 

33(7)HR, 21(7)HR, 

19(5)HR 

4 So

PAthin 

3-89 N/A Backwash Discharge Area 

from the Water Treatment Plant site 

191 N/A 33(7)HR 1 

3-90 N/A Open area 8.2 N/A 19(5)HR 1 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 1 

Property Description of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC 

2-3

Parcel 

No. 

Building 

No. 

Property Description 

(Area in sq. ft.) 

Parcel Area 

(Acres) 

Year 

Built 

EBS Parcel 

IDa 

Condition 

Categoryb 

3-91 N/A Building 400 Series Fire 

Training Area (FTA) site(Open area) 

1.5 N/A 44(7)HR/PR 1 

3-92 N/A Reservoir 129 1957 N/A 1 

2-53L N/A Subsurface portion of Phase II 

Parcel 2-53 

10.1 e N/A 21(7)HR 1 

2-54L N/A Subsurface portion of Phase II 

Parcel 2-54 

6.6 e N/A 12(5)HR, 

21(7)HR 

1 

2-70L N/A Subsurface portion of Phase II 

Parcel 2-70 

2.3 e N/A 12(5)HR 1 

2R-80L3 N/A Subsurface portion of part of Phase II road Parcel 2R-80 6.0 e N/A 12(5)HR, 21(7)HR 1 2R-84L3 N/A Subsurface portion of part of Phase II road Parcel 2R-84 0.6 e N/A 12(5)HR 1 2R-86L3 N/A Subsurface portion of part of Phase II road Parcel 2R-86 2.6 e N/A 19(5)HR 1 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 1 

Property Description of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC 

2-4

Notes: 

 AMC = Army Materiel Command. N/A = Not applicable.  EBS = Environmental Baseline Survey. PR = Petroleum release/disposal.  ECP = Environmental Condition of Property. PS = Petroleum storage.  HR = Hazardous substance release. UST = Underground storage tank. 

 HS = Hazardous substance storage. 

a Environmental Baseline Survey parcel identification (ID) (from the Community Environmental Response Facilitati

Designation) (WESTON, 1997). Note that at the time of the CERFA Report, the groundwater was assumed to be ctherefore, these parcels had an HR associated with the EBS parcel designation. 

b U.S. Department of Defense (DoD) Environmental Condition of Property (ECP) Category number. ECP categories 

FOST/FOSL Guidance (AMC, 2000). 

Category 1: Areas where no release or disposal of hazardous substances or petroleum products has occur

no migration of these substances from adjacent areas). 

Category 2: Areas where only the release of petroleum products has occurred. Category 4: Areas where release, disposal, and/or migration of hazardous substances has occurred, and 

remedial actions to protect human health and the environment have been taken. 

c In 1991, a gasoline UST was removed and there was evidence of a release to soils. Contaminated soils were exc

1991. The groundwater was not affected. The soil removal and groundwater investigation was documented in a 1Closure at Building 558, Letterkenny Army Depot, Chambersburg, Pennsylvania (SS&McC, 1992). Closure was Pennsylvania Department of Environmental Protection (PADEP), documented in a letter from F.W. Noll of PAD

Letterkenny Army Depot (PADEP, 2000). The reports detailing the tank closures and the correspondence from P

the remedial measures and investigations completed are in the UST files at LEAD. 

d Results of the RI for soil conducted in 1998 through 2000 indicated that there was a release of polycyclic aromati

(a group of semivolatile organic compounds [SVOCs]) due to past storage activities. The data from the investiga

unacceptable levels of risk based on the commercial/industrial use scenario associated with elevated levels of PA

action alternatives were developed and evaluated for a non-time-critical removal action in an Engineering Evalua
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 1 

Property Description of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC 

2-5

document (WESTON, 2000a). The non-time-critical removal action was implemented from July to November 20removal action consisted of excavating PAH-contaminated soils and disposing of them in EPA and state-approvedisposal facilities. The risk assessment completed after the removal action showed that there are no longer enviro

site, meaning that there are no longer unacceptable risks to people and the environment under commercial/indus

residential use scenarios, as documented in the remedial investigation/risk assessment report (WESTON, 2003c)

e Acreage was already accounted for in Phase II property transfer. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_3&4_BKRS.DOC 9/9/2003 

ENCLOSURE 3 

TABLE 2 

NOTIFICATION OF HAZARDOUS SUBSTANCE STORAGE, RELEASE, 

AND/OR DISPOSAL AT PHASE III PARCELS 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_3.DOC 9/9/2003 3-1

Table 2 

Notification of Hazardous Substance Storage, Release, and/or Disposal,a 

Phase III Parcels, 

Letterkenny Army Depot, 

Chambersburg, PA 

Parcel 

Number 

Building 

Number 

Name of Hazardous 

Substance 

Date of Storage/ 

Disposal/Release

Remedial 

Action 

3-89 554 Unknown quantities of lime and 

aluminum sulfate stored. 

No records of storage 

dates.b 

None required 

3-89 558 Unknown quantities of chlorine 

stored for pool. 

No records of storage 

dates.b 

None required 

3-89 559 Unknown quantities of chlorine 

gas stored. 

No records of storage 

dates.b 

None required 

3-89 N/A OVSA No records of release 

date (vehicles stored at 

site from 1947 – 1998).

Soils 

contaminated with 

PAHs were found 

during the RI and 

were remediated 

in 2000.c

a The information contained in this notice is required under the authority of regulations promulgated under 

Section 120(h) of the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA or “Superfund”), 42 U.S.C. Section 9620(h). This table provides information on the storage of 

hazardous substances for 1 year or more in quantities greater than or equal to 1,000 kilograms or the 

hazardous substance’s CERCLA reportable quantity (whichever is greater). In addition, it provides 

information on the known release of hazardous substances in quantities greater than or equal to the 

quantities referenced in 40 CFR Part 373. 

b Hazardous substances were noted during the EBS visual survey. There are no records of how long the 

hazardous substances were stored and/or used. 

c Results of the RI for soil conducted in 1998 through 2000 indicated that there was a release of polycyclic 

aromatic hydrocarbons (PAHs) (a group of semivolatile organic compounds [SVOCs], for example, 

benzo(a)pyrene and naphthalene) due to past storage activities. The data from the investigations showed 

possible unacceptable levels of risk based on the commercial/industrial use scenario associated with elevated 

levels of PAHs in soil. Removal action alternatives were developed and evaluated for a non-time-critical 

removal action in an Engineering Evaluation/Cost Analysis document (WESTON, 2000a). The non-timecritical removal action was implemented from July to November 2000 (IT, 2001). This removal action 

consisted of excavating PAH-contaminated soils and disposing of them in EPA and state-approved off-site 

commercial disposal facilities. The risk assessment completed after the removal action showed that there are 

no longer environmental concerns at the site, meaning that there are no longer unacceptable risks to people 

and the environment (WESTON, 2003c). 

CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act 

CFR = Code of Federal Regulations 

EBS = Environmental Baseline Survey 

N/A = Not applicable 

OVSA = Open Vehicle Stoirage Area 

PAHs = Polycyclic aromatic hydrocarbon 

U.S.C. = United States Code 
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ENCLOSURE 4 

TABLE 3 

NOTIFICATION OF PETROLEUM PRODUCT STORAGE, RELEASE, 

AND/OR DISPOSAL AT PHASE III PARCELS 
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Table 3 

Notification of Petroleum Product Storage, Release, and/or Disposal, 

Phase III Parcels, 

Letterkenny Army Depot, 

Chambersburg, PA 

Building 

No. 

Parcel No. Name of Petroleum 

Product 

Date and Type of 

Storage/Release/Disposala

Remedial Action 

522 3-89 1. No. 2 Heating oil 

2. No. 2 Heating oil 

1. 2,000-gal UST; in use since 

1997. 

2. 2,000-gal UST; installed in 

1942; passed leak test in 

1996; removed and replaced 

with 2,000-gal UST in 1997. 

1. None required. 

2. None required. 

523 3-89 No. 2 Heating oil 500-gal AST; date of 

installation unknown. 

Removed in 1999. 

None required. 

527 3-89 1. Diesel (PADEP 

#072)b

1. 2,500-gal UST; in use since 

1996. Passed leak test in 

February 2000. 

1. None required. 

 2. Diesel 2. 2,000-gal UST; installation 

date unknown; removed and 

replaced with 2,500-gal UST 

in 1996. Passed leak test in 

1995. 

2. None required. 

529 3-89 1. No. 2 Heating oil 1. 3,000-gal UST; in use since 

1942. 

1. None required.

 2. Propane 2. 100-gal AST; currently in 

use. 

2. None required 

532 3-89 1. Gasoline 

2. Gasoline 

1. 275-gal double-walled AST; 

installation date unknown; 

tank removed in late 1990s. 

2. 275-gal uncurbed singlewalled AST; installation date 

unknown; tank removed and 

replaced with double-walled 

AST. 

1. None required. 

2. None required. 

539 3-89 1. No. 2 Heating oil 2 x 275-gal ASTs; currently in 

use; installation date unknown. 

1. None required. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

Table 3 

Notification of Petroleum Product Storage, Release, and/or Disposal, 

Phase III Parcels, Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

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Building 

No. 

Parcel No. Name of Petroleum 

Product 

Date and Type of 

Storage/Release/Disposala

Remedial Action 

540 3-89 No. 2 Heating oil 500-gal UST; currently in use, 

installation date unknown. 

Passed leak test in 1996. 

None required. 

541 3-89 1. No. 2 Heating oil 1. 500-gal AST; currently in 

use; installation date 

unknown. 

1. None required. 

 2. No. 2 Heating oil 2. 500-gal UST; installation 

date unknown; tank removed 

and replaced with 500-gal 

AST. 

2. None required 

542 3-89 1. No. 2 Heating oil 1. 500-gal AST; currently in 

use; installation date 

unknown. 

1. None required. 

 2. No. 2 Heating oil 2. 500-gal UST; installation 

date unknown; tank removed 

and replaced with 500-gal 

AST. 

2. None required. 

543 3-89 1. No. 2 Heating oil 1. 500-gal AST; currently in 

use; installation date 

unknown. 

1. None required. 

 2. No. 2 Heating oil 2. 500-gal UST; installation 

date unknown; tank removed 

and replaced with 500-gal 

AST. 

2. None required. 

544 3-89 1. No. 2 Heating oil 1. 500-gal AST; currently in 

use; installation date 

unknown. 

1. None required. 

 2. No. 2 Heating oil 2. 500-gal UST; installation 

date unknown; tanks removed 

and replaced with 500-gal 

AST. 

2. None required. 

545 3-89 No. 2 Heating oil 500-gal UST; currently in use, 

date of installation unknown. 

Passed leak test in 1996. 

None required. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

Table 3 

Notification of Petroleum Product Storage, Release, and/or Disposal, 

Phase III Parcels, Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

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Building 

No. 

Parcel No. Name of Petroleum 

Product 

Date and Type of 

Storage/Release/Disposala

Remedial Action 

554 3-89 No. 2 Heating oil 2,000-gal UST; in use since 

1957. Passed leak test in 1996. 

None required. 

558 3-89 1. No. 2 Heating oil 1. 1,000-gal UST; in use since 

1953. Passed leak test in 

1996. 

1. None required. 

 2. Diesel 2. 2 x 200-gal ASTs; currently 

in use, date of installation 

unknown. 

2. None required. 

 3. Diesel 3. 2 x 280-gal ASTs; date of 

installation unknown; tanks 

removed and replaced by 2 x 

200-gal ASTs. 

3. None required. 

 4. Gasoline 4. 1,000-gal UST; removed in 

1991. 

4. Confirmed 

release; soils 

removed to 

bedrock and 

groundwater 

investigation 

completed at 

time of UST 

closures. No 

further action 

planned.c

a

AMC’s policy for notification includes amounts of petroleum in excess of 55 gal either stored for greater than 1 year 

 or released/disposed of (AMC, 2000). 

b Tank currently regulated by PADEP.

c In 1991, a gasoline UST was removed and there was evidence of a release to soils. Contaminated soils were 

excavated to bedrock in 1991. The groundwater was not affected. The soil removal and groundwater investigation 

was documented in a 1992 report: UST Closure at Building 558, Letterkenny Army Depot, Chambersburg, 

Pennsylvania (SS&McC, 1992). Closure was approved by PADEP, documented in a letter from F.W. Noll of 

PADEP to B. Hoke of Letterkenny Army Depot (PADEP, 2000). The reports detailing the tank closures and the 

correspondence from PADEP approving the remedial measures and investigations completed are in the UST files at 

LEAD. 

AMC = Army Materiel Command. 

AST = Aboveground storage tank. 

UST = Underground storage tank. 
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ENCLOSURE 5 

APPENDIX A 

SUMMARY OF PARCEL AND BUILDING CONDITIONS, 

FOST FOR THE PHASE III BRAC PARCELS
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APPENDIX A 

SUMMARY OF PARCEL AND BUILDING CONDITIONS, 

FOST FOR THE PHASE III BRAC PARCELS 

A.1 INTRODUCTION 

Parcels 3-89, 3-90, 3-91, 3-92, 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, and 

2R-86L-3 have been selected for the Phase III parcel transfer. Parcels 3-89, 

3-90, and 2R-86L-3 are located in both the Southeastern (SE) Area and the 

Property Disposal Office (PDO) Area. Parcels 3-91, 2-53L, 2-54L, 2-70L, 

2R-80L-3, and 2R-84L-3 are located in the SE Area. Parcel 3-92 is located 

off-Depot, approximately 3 miles north of the LEAD property boundary. 

Locations of Parcels 3-89, 3-90, 3-91, 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R84L-3, and 2R-86L-3 are shown in Figure 1 (Enclosure 1). The location of 

Parcel 3-92 is shown in Figure 2 (Enclosure 1). A summary of the 

condition of the buildings included in the Phase III parcel transfer is 

presented in Table A-1 of this Appendix A. 

A description of each of the parcels is presented in the following 

subsections. For each parcel, a general description of the parcel, prior and 

current condition of the parcel/buildings (based on observations noted at 

the time of the Environmental Baseline Survey [EBS]), a list of buildings 

associated with the parcel, and other relevant information are provided. 

Unless otherwise noted, the Army, after a complete search of Army files 

and, in some cases, interviews, visual inspections, and limited sampling, 

found no records or evidence of petroleum or hazardous substance 

storage, release, or disposal at any of these parcels. Unless otherwise 

noted, there were no records of aboveground storage tanks (ASTs), 

underground storage tanks (USTs), or spills in the parcels or buildings. 

Some buildings were not tested for radon, lead-based paint (LBP), or 

asbestos-containing materials (ACM) because they are unoccupied (e.g., 

storage warehouse) or are not regularly occupied. A total of 7 buildings in 

the LEAD Phase III FOST parcels were not surveyed for ACM, including 4 

buildings that were constructed after 1980. A visual survey was completed 

as part of the EBS process in all the buildings discussed in this FOST. The 

presence of ACM was not noted in any of these 7 buildings (Buildings 527, 

528, 530, 532, 536, 546, and 572) during the EBS visual survey. However, an 

EBS visual survey does not constitute a full ACM survey. Assessment of 

ACM for the Phase III buildings is consistent with DoD policy (DoD, 1994) 

and Army regulations (Army, 1997) for BRAC properties. 
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There had been no polychlorinated biphenyl (PCB)-containing equipment 

present on any of the parcels at any time. 

A.2 PARCEL 3-89 

Parcel 3-89 is approximately 191 acres in size, located in the SE and PDO 

Areas of LEAD (Figure 1, Enclosure 1). The structures within Parcel 3-89 

include 20 buildings and a water tower. The building numbers and the 

descriptive titles of the buildings are as follows: 

Building 522 Administration Office 

Building 523 Office 

Building 527 Emergency Generator Building 

Building 528 Swimming Pool Filter Building 

Building 529 Community Club 

Building 530 Information Processing Center 

Building 532 Golf Cart Storage Maintenance Building 

Building 536 Locker Room 

Building 539 Guest/Temporary Housing 

Building 540 Kenny Hill Housing Unit 

Building 541 Kenny Hill Housing Unit 

Building 542 Kenny Hill Housing Unit 

Building 543 Kenny Hill Housing Unit 

Building 544 Kenny Hill Housing Unit 

Building 545 Kenny Hill Housing Unit 

Building 546 Storage Building 

Building 554 Water Treatment Plant 

Building 558 Emergency Pump Building for Water Treatment Plant 

Building 559 Chlorinator Building for Water Treatment Plant 

Building 572 Storage Building (Fire Dept.) 

--- Water Tower 

Descriptions of each of the buildings/structures are presented in the 

following subsections. Locations of the buildings are shown in Figure 1 of 

Enclosure 1. 
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BUILDING 522 (ADMINISTRATION OFFICE) 

Building 522 has two floors of office space and a basement, which is a 

communications command center. Building 522 was constructed in 1942 of 

brick with a concrete foundation and a wooden structure roof. The building 

is heated using heating oil supplied by a 2,000-gallon UST installed in 1997, 

which replaced a former 2,000-gallon UST installed in 1942. An ACM 

survey identified ceiling insulation, pipe insulation, transite board, floor 

tile, and mastic as ACM. Pipe insulation, floor tile, and transite board have 

been removed as part of the LEAD ACM abatement program. Radon was 

detected at levels of 0.5 to 1.8 picoCuries/liter (pCi/L), which are below the 

EPA-recommended action level of 4 pCi/L. LBP was not evaluated for this 

building. 

 BUILDING 523 (OFFICE) 

Building 523 is an office that was constructed in 1943 of wood with a 

concrete foundation. The building was heated using heating oil supplied by 

a 500-gallon AST. The tank was removed in 1999. An ACM survey 

identified pipe insulation, floor tile, and mastic as ACM. There are no 

records of ACM abatement or removal. Radon was detected at levels of 0.7 

to 1.2 pCi/L, which are below the EPA-recommended action level. LBP was 

not evaluated for this building. 

BUILDING 527 (EMERGENCY GENERATOR BUILDING)

Building 527 houses an emergency generator for buildings in the Building 

522 area. The generator is powered by a diesel engine, which is supplied by 

a 2,500-gallon UST (passed integrity test in February 2000). Building 527 

was constructed in 1988 of concrete block and brick on a concrete 

foundation with a steel roof. Asbestos, radon, and LBP were not evaluated 

for Building 527. 

 BUILDING 528 (SWIMMING POOL FILTER BUILDING) 

Building 528 is the chlorine and filter room for the swimming pool. It was 

built in 1945 and is constructed of brick and wood. Building 528 was not 

evaluated for ACM, radon, or LBP. This building is used to store treatment 

chemicals (chlorine) for the pool.

 BUILDING 529 (COMMUNITY CLUB) 

Building 529 is the Community Club for the golf course. Building 529 was 

originally a barn (of unknown construction date) that has been extensively 

renovated (original renovation date was 1942). There are two stories: the 

first floor consists of a lounge, kitchen, and pro-shop; the second floor 
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consists of a dining area for social gatherings. Building 529 is heated using 

fuel oil supplied by a 3,000-gallon UST. Slight staining around the fillpipe 

of the UST was noted during the EBS visual survey. There is a 100-gallon 

propane UST at the building. There is a grease trap for the kitchen located 

on the south side of the building. An ACM survey identified pipe 

insulation, valve insulation, floor tile, and mastic as ACM. LEAD records 

indicate that transite board, floor tile, and pipe insulation have been 

removed as part of the LEAD ACM abatement program. Radon was 

detected at 0.3 to 1.0 pCi/L, which are below the EPA-recommended action 

level. LBP was not evaluated at Building 529. 

 BUILDING 530 (INFORMATION PROCESSING CENTER) 

Building 530 is an information processing center that was constructed in 

1985 of steel on a concrete slab foundation. The building is apparently 

heated using electricity. Asbestos, radon, and LBP have not been evaluated 

at Building 530.

 BUILDING 532 (GOLF CART STORAGE MAINTENANCE BUILDING) 

Building 532 is used for storage of golf carts. Based on its appearance, it 

was built recently (no date on records) and is constructed with steel sides 

and roof and a dirt floor. Building 532 is not heated. A 275-gallon 

uncurbed gasoline AST was located north of Building 532. This tank was 

removed and replaced with a double-walled AST, which was also removed 

(late 1990s). ACM, radon, and LBP were not evaluated at Building 532. 

BUILDING 536 (LOCKER ROOM)

Building 536 is unheated and is the locker room for the pool and golf 

course. It was built in 1942 and is constructed of wood. Based on its 

appearance at the time of the EBS survey, it had been renovated recently. 

Building 536 has not been evaluated for ACM, radon, or LBP. 

 BUILDING 539 (GUEST AND TEMPORARY HOUSING) 

Building 539 is the guest and temporary housing for LEAD. It was 

originally a farm house, and the date of construction is unknown; the 

building was renovated and made into several apartments in 1943. It is a 

two-story building constructed of stone, brick, and wood. It is heated using 

fuel oil supplied by two 275-gallon ASTs located in the basement. An ACM 

survey identified plaster, spackle compound, refractory cement, floor tile, 

and mastic as ACM. LEAD records indicate some pipe insulation had been 

removed as part of the ACM abatement program. 
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Sampling conducted in 1989 indicated a radon level of 1.6 pCi/L at 

Apartment 02, and 5.0 pCi/L in the basement, which was above the EPArecommended action level of 4 pCi/L. The basement is not accessible from 

the house and is seldom entered. Cracks in the basement have been sealed. 

A radon report submitted by R.E. Wright Associates, Inc. (R.E. Wright 

Associates, Inc., 1994) recommended no further action for Building 539. 

Sampling conducted in 1995 at two apartments and the basement by R.E. 

Wright Environmental, Inc. (R.E. Wright Environmental, Inc., 1997) 

indicated radon levels ranging from 0.2 to 2.8 pCi/L, which are below the 

EPA-recommended action level. 

LBP was not evaluated for Building 539. A LBP survey was not done for 

Building 539 because it is not considered a residential dwelling like Kenny 

Hill and the other full-time use military houses. Building 539 consists of 

three small apartments/efficiencies that were only used as very short-term 

temporary quarters (similar to a hotel use) for officers or other military 

adult guests on temporary travel. The building was not used for housing 

children and the lengths of stay for guests consisted of only weekends or 

several days. In addition, the building is being transferred for 

industrial/commercial use and will not be used as residential housing. 

 BUILDINGS 540 – 545 (KENNY HILL HOUSING UNITS) 

The Kenny Hill housing units are located in the SE and PDO Areas near the 

golf course and Community Club. This housing area consists of six 

residential buildings (Nos. 540-545) and six one-car detached garages. The 

Kenny Hill housing units were constructed in 1954 and have been in 

operation since their construction. The two-story units are built of concrete, 

brick, and wood, and currently have vinyl siding on the second floor 

exteriors. Four of the buildings are single family dwellings (Nos. 541 

through 544), and two of the buildings are duplex (two-family) units (Nos. 

540 and 545). 

A building inspection of the Kenny Hill property was conducted on 25 

September 1995. This inspection consisted of a reconnaissance of the entire 

outside area, along with interior inspections of vacant units (Unit 102 in 

Building 545 and Unit 104 in Building 543). The units were generally in fair 

physical condition. Potential environmental liabilities identified during the 

building inspection included LBP, suspect ACM, and USTs. The garages 

that were inspected did not show signs of spills or leaks, and do not appear 

to pose an environmental concern for the property. 

Previous environmental work conducted at Kenny Hill includes paint chip 

sampling, radon surveys, and asbestos surveys. Paint chip sampling 

indicated lead concentrations ranging from 0.008% to 0.6% total lead 

content. A LBP survey was conducted by Dames and Moore (Dames and 

Moore, 1996) in all apartments in Buildings 540 through 545 using an X-ray 
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fluorescence (XRF) analyzer. Some of the samples tested indicated lead 

concentrations exceeding the EPA and U.S. Department of Housing and 

Urban Development (HUD) LBP standard of 1 milligram per square 

centimeter (mg/cm2) indicating the presence of lead in the paint. No 

remediation of these surfaces has been conducted to date because the paint 

has been maintained in good condition and managed in place. As part of 

the LBP risk assessment completed as specified in the Memorandum of 

Agreement (MOA) between the Department of the Army and LIDA (LIDA, 

1998), soil sampling was conducted in bare soil areas adjacent to the Kenny 

Hill housing units in accordance with HUD guidance. Lead concentrations 

in soil were less than EPA and PADEP criteria and no further action is 

necessary (WESTON, 2003e). 

An ACM survey identified mastic and floor tiles. According to the LEAD 

asbestos records, a limited asbestos removal project was conducted to 

remove ACM associated with overflow tanks in the units. Most of the 

asbestos floor tile in the Kenny Hill units has been covered with carpet or 

vinyl to prevent exposure to tenants. 

Radon testing was conducted for the Kenny Hill housing units. Radon 

concentrations ranged from 1.0 to 3.3 pCi/L in the housing units, which are 

below the EPA-recommended action level of 4 pCi/L. 

No compliance issues, permit problems, or Notices of Violation were 

identified in the files for the Kenny Hill property. No PCB transformers (or 

other transformers) or oil/water separators were identified at the property. 

Each of the housing units was formerly heated with fuel supplied by a 500-

gallon UST. These USTs have been removed on a case-by-case basis during 

maintenance or repair activities, with the exception of two tanks (at 

Buildings 540 and 545), which remain in place. These two tanks have 

reportedly had small overflows at the fillpipe when they were filled to 

capacity and then expanded (the vent pipes to the tanks reportedly do not 

function well). These small overflows have been remediated (as they occur) 

by digging up the soil around the fillpipe and disposing of it. No tank 

tightness or leak testing reportedly has been conducted on the two 

remaining tanks. The heating for the rest of the units is now supplied by 

500-gallon ASTs located behind each unit. No leakage or spills were 

apparent around the ASTs. 

 BUILDING 546 (STORAGE BUILDING) 

Building 546 is a storage building for the residents of Kenny Hill. It was 

built in 1973 and is constructed of wood on a concrete slab foundation. 

Building 546 is not heated. ACM, radon, and LBP have not been evaluated 

at Building 546. 
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 BUILDING 554 (WATER TREATMENT PLANT) 

Building 554, the water treatment plant building, is located in the SE Area 

at LEAD. Built in 1957, Building 554 consists of two floors and is 

constructed with a concrete foundation and walls and a steel-supported, 

light concrete roof. On the first floor is the meter and gauge room and 

post-chlorinator. The second floor has an office and some chemical 

storage (lime and alum). The filter bed structures are immediately 

northwest of Building 554. Building 554 is heated by fuel supplied from a 

2,000-gallon heating oil UST. 

An asbestos survey completed at Building 554 identified transite board, 

floor tile, mastic, pipe insulation, and pipe fitting as ACM. Radon testing 

at Building 554 indicated a low level of radon (1 pCi/L), which is below 

the EPA-recommended residential action level of 4 pCi/L. LBP was not 

evaluated at Building 554. In the past, the water from the filter backwash 

was released to the drainageways near the water treatment plant. 

 BUILDING 558 (EMERGENCY PUMP BUILDING FOR WATER TREATMENT 

PLANT) 

Building 558 houses the emergency pumps (diesel-powered) for the water 

treatment plant. Building 558 was built in 1953 with a concrete slab 

foundation, cinder-block walls, and steel-supported, light concrete roof. 

The building is heated by heating oil, which is supplied by a 1,000-gallon 

UST. There are two 200-gallon diesel ASTs inside the building to supply 

the emergency pumps; these ASTs replaced two former 280-gallon ASTs. 

A former 1,000-gallon gasoline UST was removed at Building 558 in 1991. 

There were four floor drains of unknown exit paths noted during the 

visual survey. An asbestos survey completed at Building 558 did not 

identify any ACM. Radon and LBP have not been evaluated at Building 

558. There was a confirmed release of product that was reported to 

PADEP. A soil removal action and a groundwater investigation were 

conducted and no detectable levels of contaminants were found in the 

groundwater (SS&McC, 1992). 

 BUILDING 559 (CHLORINATOR BUILDING FOR WATER TREATMENT PLANT) 

Building 559 houses the pumps for the raw water supply and 

pretreatment chlorinator. Building 559 was built in 1968 and is 

constructed using a concrete slab foundation, cinder-block walls, and a 

wood-frame roof. The building is heated using electricity. An asbestos 

survey did not identify any ACM in Building 559. Radon and LBP were 

not evaluated at Building 559. 

 BUILDING 572 

Building 572 is a small storage building constructed in 1968 and is normally 

used by the fire department for storage of fire extinguishers for emergency 
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use at the heliport. At the time of the visual survey, Building 572 was 

empty. Building 572 is not heated; it has not been evaluated for ACM, 

radon, or LBP. 

BRAC INVESTIGATION AREAS

Based on the findings of the EBS, several study areas within this parcel 

underwent soil, drainageway, and groundwater investigations to 

determine their environmental condition. In addition, risk assessment 

evaluations were conducted to rule out the potential for contamination 

due to past operations, or to provide information to support a decision to 

investigate further, implement a removal action, or conduct no further 

action at the site, as indicated here: 

OVSA Site (Defense Site Environmental Restoration Tracking System 

[DSERTS] site numbers LEAD-110 and LEAD-114, PDO Operable Unit 

[OU] 6 and SE OU 8): The site was used for storage of military vehicles 

from 1947 through 1998. Field activities were performed at various 

periods between October 1998 and November 2000 to investigate soil, 

sediments, and groundwater, and then additionally in November 2002 

(groundwater sampling). The results of the remedial investigation for soil 

indicated possible unacceptable risks associated with elevated levels of a 

group of semivolatile organic compounds (SVOCs) referred to as 

polycyclic aromatic hydrocarbons (PAHs). Alternatives were developed 

and evaluated in the Engineering Evaluation/Cost Analysis (WESTON, 

2000a). A non-time-critical removal action was then implemented from 

July to November 2000 to reduce or eliminate potential risks to people 

and the environment at the site (IT, 2001). This removal action consisted 

of excavating contaminated soils and disposing of them at off-site 

commercial disposal facilities. 

Results of the risk assessment, completed using confirmation samples, 

showed that concentrations of chemicals found in site soils and 

groundwater are low enough that there are no unacceptable levels of 

human health or ecological risks based on current and likely future 

commercial/industrial use, or residential use. No further actions are 

warranted (WESTON, 2003c). 

Former Uncurbed AST at Building 532 site (DSERTS Site LEAD-126, PDO 

OU 6): An uncurbed single-walled AST used for gasoline storage was 

located near Building 532. Field activities were performed in April 1999 to 

investigate soils. The results of the remedial investigation and risk 

assessment showed that concentrations of chemicals found in site soils 

are low enough that there are no unacceptable levels of human health or 

ecological risk based on current and likely future commercial/industrial 

use, or residential use. No further actions are warranted (WESTON, 

2002b). 
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Backwash Discharge Area from the Water Treatment Plant site (DSERTS 

Site LEAD-011, SE OU 8): Flocculant from the drinking water treatment 

plant was disposed of in this area in the past. Field activities were 

performed in October 1998 to investigate soils and drainageways. Results 

of the remedial investigation and risk assessment showed that 

concentrations of chemicals found in site soils are low enough that there 

are no unacceptable levels of human health or ecological risk based on 

current and likely future commercial/industrial use, or residential use. 

No further actions are warranted (WESTON, 2002d). 

SMSR INVESTIGATION AREA

Phase III Parcel 3-89, as well as Parcels 3-90, 3-91, 2-53L, 2-54L, 2-70L, 2R80L-3, 2R-84L-3, and 2R-86L-3 are located within the Southern 

Martinsburg Shale Region (SMSR) within LEAD (PDO OU 7 and SE OU 

13). An investigation was conducted to evaluate the groundwater quality 

within the SMSR (underneath the Phase III property). Known and 

potential volatile organic compound (VOC) sources to groundwater exist 

in the areas at LEAD surrounding the SMSR. However, historical records 

surveys and the results of the investigation (WESTON, 2003d) showed 

that there are no sources of groundwater contamination evident in the 

SMSR. In addition, the study concluded that these source areas are 

located in low-lying valley areas underlain by limestone bedrock where 

groundwater flows are away from the SMSR. Based on current 

conditions, the SMSR is topographically higher than surrounding areas 

and groundwater flows radially away from the SMSR. This situation 

protects the SMSR from the surrounding contaminated groundwater in the 

low-lying limestone areas. The results of the risk assessment show that 

human health and ecological risks based on current and likely future 

commercial/industrial use, as well as potential residential use, are within 

acceptable limits. Consequently, no remedial actions are necessary to 

protect human health and the environment. 

A.3 PARCEL 3-90 (Open Area) 

Parcel 3-90 is approximately 8.2 acres in size and is located in the SE and 

PDO Areas of LEAD (Figure 1, Enclosure 1). There are no structures on 

Parcel 3-90. This parcel is currently open land and has been an open area 

in the past with no apparent storage or industrial activities. 

A.4 PARCEL 3-91 (Open Area) 

Parcel 3-91 is approximately 1.5 acres in size and is located in the SE Area 

of LEAD (Figure 1, Enclosure 1). There are no structures on Parcel 3-91. 

This parcel is currently open land and consists of a BRAC investigation 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 9/9/2003 A-10

area, the Building 400 Series Fire Training Area site (DSERTS Site LEAD118, SE OU 8). This area, based on the findings of the EBS, underwent a 

soil investigation to determine the environmental condition, and risk 

assessment evaluations to rule out the potential for contamination due to 

past operations. The area had been reportedly used in the past for a short 

period of time as a fire-fighting training area where a large metal pan was 

placed on the ground and filled with various flammable liquids, which 

were ignited. Field activities were performed in September 1998 to 

investigate soils. Results of the remedial investigation and risk 

assessment showed that concentrations of chemicals found in site soils 

are low enough that there are no unacceptable levels of human health or 

ecological risk based on current and likely future commercial/industrial 

use, or residential use. No further actions are warranted (WESTON, 

2002c). 

A.5 PARCEL 3-92 (Reservoir) 

Parcel 3-92 is an area of approximately 129 acres located north of LEAD 

approximately 2 miles west of the town of Roxbury (Figure 2, Enclosure 

1). The 300-million-gallon Letterkenny Reservoir is located within this 

parcel. The reservoir began supplying water to LEAD in 1957, and it 

supplies all the potable and industrial water to LEAD. There are no 

buildings associated with this property. A visual survey was conducted, 

and no evidence of dumping or any other activities that would 

potentially impact the property or the quality of the water supply were 

noted. The reservoir is managed by the Pennsylvania Fish and Game 

Commission, and is open for fishing. Gas-powered boat motors are 

prohibited in the reservoir. 

A.6 PARCELS 2-53L, 2-54L, 2-70L, 2R-80L-3, 2R-84L-3, and 2R-86L-3 

These parcels consist of 28.2 acres of property 8 feet or more beneath 

surface soil and roadways that were previously transferred as part of the 

Phase II BRAC property transfer at LEAD, as shown in Figure 1, 

Enclosure 1 (specifically, starting from 8 feet below the ground to the 

center of the earth). They are located in the southern part of the 

SMSR/Phase III area. The entire land area was not originally transferred 

all at once because it was thought the groundwater located underneath 

the land was potentially contaminated with VOCs. These parcels were 

investigated as part of the SMSR groundwater investigation described 

previously. The Army has completed its investigation and risk 

assessment for the SMSR groundwater and found no environmental 

concerns at the site. The top portions of these parcels were transferred 

with soil excavation and groundwater use restrictions because at that 

time it was thought that the groundwater underneath the parcels was 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 9/9/2003 A-11

contaminated. The soil excavation and groundwater restrictions can now 

be removed as part of the no further action alternative. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-12

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented

Removals 

PCBContaining 

Transformer 

Radon 

(pCi/L) LBP Survey UST AST 

522 3-89, 1 CINS, PINS, TILE, 

TRAN, MAST 

TILE, PINS, 

TRAN 

NO 0.5-1.8 NE 2,000 gal HO NO 

523 3-89, 1 PINS, TILE, MAST NO NO 0.7-1.2 NEc NO NO 527 3-89, 1 NE NO NO NE NE 2,500 gal 

Diesel T 

(2000) 

NO 

528 3-89, 1 NE NO NO NE NE NO NO 529 3-89, 1 TILE, PINS, 

MAST, TRAN 

TILE, PINS, 

TRAN 

NO 0.3-1.0 NE 3,000 gal HO 100 gal Pr

530 3-89, 1 NE NO NO NE NE NO NO 532 3-89, 1 NE NO NO NE NE NO NO 536 3-89, 1 NE NO NO NE NE NO NO 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-13

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented

Removals 

PCBContaining 

Transformer 

Radon 

(pCi/L) LBP Survey UST AST 

539 3-89, 1 REFC, SPAC, 

MAST, TILE, 

PLASTER, PINS 

PINS NO 1.6 – 5.0 

(1990)d 

0.2 – 2.8 

(1995) d

NE NO 2 x 275 g

540 3-89, 1 TILE, MAST NO NO 1.0-1.9 YES – GC 

LBP soil 

assessment – 

no releases to 

soile 

500 gal HO 

T (1996) 

NO 

541 3-89, 1 TILE, MAST NO NO 2.5 YES – GC 

LBP soil 

assessment – 

no releases to 

soile

NO 500 gal 

542 3-89, 1 TILE, MAST TINS NO 1.2 YES – GC 

LBP soil 

assessment – 

no releases to 

soile

NO 500 gal 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-14

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented

Removals 

PCBContaining 

Transformer 

Radon 

(pCi/L) LBP Survey UST AST 

543 3-89, 1 TILE, MAST TINS NO 3.3 YES – GC 

LBP soil 

assessment – 

no releases to 

soile

NO 

500 gal 

544 3-89, 1 TILE, MAST NO NO 2.7 YES – GC 

LBP soil 

assessment – 

no releases to 

soile

NO 500 gal 

545 3-89, 1 TILE, MAST NO NO 1.5-1.9 YES – GC 

LBP soil 

assessment – 

no releases to 

soile

500 gal HO 

T (1996) 

NO 

546 3-89, 1 NE NO NO NE NE NO NO 554 3-89, 1 PFIT, PINS, 

TRAN, TILE, 

MAST, TINS 

TINS, PINS, 

boiler 

insulation 

NO 1.0 NE 2,000 gal HO

T (1996) 

NO 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-15

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented

Removals 

PCBContaining 

Transformer 

Radon 

(pCi/L) LBP Survey UST AST 

558 3-89, 2 NO NO NO NE NE 1,000 gal HO

T (1996) 

2 x 200 

Diese

559 3-89, 1 NO NO NO NE NE NO NO 572 3-89, 1 and 

4 

NE NO NO NE NE NO NO 

Notes:a ECP categories determined using AMC FOST/FOSL Guidance (AMC, 2000): 

Category 1 = Areas where no release or disposal of hazardous substances or petroleum products has occurred (including no m

substances  from adjacent areas). 

Category 2 = Areas where only a release of petroleum products has occurred. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-16

Category 4 = Areas where release, disposal, and/or migration of hazardous substances has occurred, and all removal or remedial actio

health and the environment have been taken. 

b This column includes some spills that are not listed in Table 2 (Enclosure 3) or Table 3 (Enclosure 4). These spills do not meet the req

under CERCLA (see note in Table 2) or are less than 55 gal for petroleum substances (AMC policy). However, these spills have been 

for additional information purposes. 

c A complete LBP survey has not been conducted at Building 523. However, one lead paint sample collected in 1994 indicated a lead c

The  sample location or the exact type of paint sample is unknown. 

d Sampling conducted in 1989 indicated a radon level of 1.6 pCi/L at Apartment 02, and 5.0 pCi/L in the basement, which was above the E

level of 4 pCi/L. The basement is not accessible from the house and is seldom entered. Cracks in the basement have been sealed. A radon 

Wright Associates, Inc. (R.E. Wright Associates, Inc., 1994) recommended no further action for Building 539 because the basement is no

and the cracks in the basement have been sealed. Sampling conducted in 1995 at two of the apartments and the basement in Building 539 

ranging from 0.2 to 2.8 pCi/L, which are below the EPA-recommended action level. 

e As part of the lead-based paint risk assessment completed as specified in the Memorandum of Agreement between the Department of 

Letterkenny Industrial Development Authority (LIDA, 1998), soil sampling was conducted in bare soil areas adjacent to the Kenny H

concentrations in soil were less than EPA and PADEP criteria and no further action is necessary (WESTON, 2003e). 

f In 1991, a gasoline UST was removed and there was evidence of a release to soils. Contaminated soils were excavated to bedrock in 

was not affected. The soil removal and groundwater investigation were documented in a 1992 report: UST Closure at Building 558, L

Chambersburg, Pennsylvania (SS&McC, 1992). Closure was approved by the Pennsylvania Department of Environmental Protection 

a letter from F.W. Noll of PADEP to B. Hoke of Letterkenny Army Depot (PADEP, 2000). The reports detailing the tank closures anfrom PADEP approving the remedial measures and investigations completed are in the UST files at LEAD. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table A-1 

Summary of Building Conditions of Phase III BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC 

A-17

NFA = No further action necessary TANKSAST = Aboveground storage tank. G = Gasoline. gal = Gallons. HO = Heating oil. NE = Not evaluated. NO = Not present. T(date) = Tank tightness tested, which means passed integrity

 test (date of test). 

UST = Underground storage tank. PCB

NO = Not present. PCB = Polychlorinated biphenyl. 

RADONNE = Not evaluated/not surveyed. PCi/L = picoCuries per liter. ASBESTOSBB = Baseboard trim. CINS = Ceiling insulation. CT = Ceiling tile. MAST = Floor tile mastic. NE = Not evaluated/not surveyed. NO = No records of removal. PINS = Pipe/duct insulation. REFC = Refractory cement SPAC = Spackle/joint compound. TILE = Floor tile. TINS = Tank insulation. TRAN = Transite board. VINYL = Vinyl flooring. WALL = Wall board. 

LBP SURVEGC = PainLBP = LeaNE = Not ppm = PartYes = Surv
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 09/09/03 

ENCLOSURE 6 

SUMMARY OF BUILDING AND PARCEL CONDITIONS 

PHASE III PROPERTY TRANSFER — RESULTS OF FINAL 

VISUAL SURVEYS 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 09/09/03 6-1

ENCLOSURE 6 

SUMMARY OF BUILDING AND PARCEL CONDITIONS, 

PHASE III PROPERTY TRANSFER — RESULTS OF FINAL 

VISUAL SURVEYS 

On 11 June 2003 the Letterkenny Army Depot (LEAD) Base Realignment and Closure (BRAC) 

Cleanup Team (BCT), along with a representative from the Letterkenny Industrial Development 

Authority (LIDA), completed the final walkthrough visual surveys of the Phase III buildings 

and parcels. The purpose of the visual surveys was to assess the current conditions of the Phase 

III buildings and parcels. Particular attention was given to the current condition of accessible 

known asbestos-containing material (ACM) and lead-based paint (LBP). Accessible ACM is 

defined as material that would be accessible to occupants of a building under normal 

conditions. The visual survey for the condition of the ACM did not include sampling or surveys 

of areas not normally accessible (i.e., crawlspaces, areas above ceilings) to the building 

occupants. 

Table 6-1 is a summary of the current building conditions, including accessible ACM, radon, 

LBP, documented spills (as of 30 May 2003), presence of underground/aboveground storage 

tanks (USTs/ASTs), and comments. The Phase III buildings did not have polychlorinated 

biphenyl (PCB)-containing transformers associated with them at any time. 

Damaged accessible ACM was noted at one of the buildings during the final visual surveys. The 

Army has removed and disposed of loose ACM and encapsulated the edges of damaged ACM 

with paint. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-2

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 522 Administration – 

Office (7,896) 

1942 Ceiling tile mastic and dust 

above ceiling tiles throughout building; most is above existing drop ceiling. Steamline pipe insulation – removal done but some may remain in-place. 9 x 9 floor tile and mastic—in upper floors (under carpeting) and in basement. Transite board/cement asbestos board – NE corner first floor behind gypsum wallboards/wood paneling. 

Good condition inside; good to fair condition outside. 

2,000-gal UST - HO 

Y

3-89 523 Office (6,400) 1943 9 x 9 floor tile and mastic 

throughout building. Pipe insulation – appears to have been replaced with black foam, some remains in crawlspace. 

Fair to poor condition inside (some areas of peeling paint); poor condition outside (excessive peeling). 

No N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-3

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 527 Emergency Generator 

(263) 

1988 No ACM based on year 

built. N/A based on year built. 2,500-gal UST – Diesel N

3-89 528 Swimming Pool Filter 

Room (60) 

1945 Not suspected. Fair to poor 

condition. 

No N

3-89 529 Community Club 

(10,903) 

Unknown 

(initially 

renovated 

by Army 

in 1942) 

9 x 9 tile/mastic — air handler room and possibly some remaining throughout below carpet. Mastic below 12 x 12 red/white tile in first floor corridor. Site records indicate pipe insulation removed – no remaining pipe insulation noted. 

Good condition inside, some peeling/chipped in localized areas. Fair to poor condition outside (peeling and chipped areas on trim and doors). 

3,000-gal UST – HO 100-gal AST – Propane 

N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-4

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 530 Information 

Processing Center (1,045) 

1985 No ACM based on year 

built. N/A based on year built. No N

3-89 532 Golf Cart Storage 

Maintenance Building (3,600)/Former Uncurbed AST North of Building 532 Site 

1991 No ACM based on year 

built. N/A based on year built. No N

3-89 536 Locker Room (2,000) 1942 Not suspected. Good to fair 

condition inside and outside; some localized areas of peeling/chipped paint. 

No N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-5

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 539 Guest/Temporary 

Housing (2,830) 

Unknown 

(renovated 

by Army 

in 1943) 

Refractory cement in boiler room in basement. Spackle/joint compound in washroom (under wallpaper) and throughout apartment 3. Vinyl floor backing (green vinyl floor under tan vinyl floor and tan vinyl floor in several locations). Wall plaster in apartment 2 (mostly covered with wallpaper). 9 x 9 floor tiles/mastic throughout apartment 3 (under carpet). 

Good to fair condition inside with some localized areas of peeling paint. Fair to poor condition outside with some areas of excessive peeling paint on porch, trim, and doors. 

500-gal AST – HO (basement) 

N

3-89 540 

(Units 

107 and 

108) 

Housing – Kenny Hill (2,542) 

1954 9 x 9 tile/mastic throughout 

— most covered by carpets (except air handler room/some closets). 

Good to fair condition inside. Outside fair condition with some peeling on doors and 2nd floor 

windows. 

500-gal UST 

– HO (front 

yard) 

(T, 1996) 

Ye
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-6

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 541 (Unit 

106) 

Housing – Kenny Hill (1,660) 

1954 9 x 9 tile/mastic throughout 

— most covered by carpets (except air handler room). 

Good to fair condition inside. Outside fair condition with some peeling on doors and 2nd floor 

windows. 

500-gal AST — HO 

N

3-89 542 (Unit 

105) 

Housing – Kenny Hill (1,660) 

1954 9 x 9 tile/mastic throughout 

— most covered by carpets (except air handler room/some closets). 

Good to fair condition inside. Outside fair to poor condition with some peeling on porch/steps, doors, and 2nd floor 

windows. 

500-gal AST 

—HO 

Y

3-89 543 (Unit 

104) 

Housing – Kenny Hill (1,660) 

1954 9 x 9 tile/mastic throughout 

— most covered by carpets (except air handler room/some closets). 

Good to fair condition inside. Outside fair to poor condition with some peeling on porch/steps, doors, and 2nd floor 

windows. 

500-gal AST 

– HO (pipe 

stickup in ground at 

side of 

building 

may indicate 

old UST 

abandoned 

in-place) 

N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-7

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 544 (Unit 

103) 

Housing – Kenny Hill (1,660) 

1954 9 x 9 tile/mastic throughout 

—most covered by carpets (except air handler room). 

Good to fair condition inside. Outside fair to poor condition with some peeling on porch/steps, doors, and 2nd floor 

windows. 

500-gal AST — HO 

N

3-89 545 

(Units 

101 and 

102) 

Housing – Kenny Hill (2,542) 

1954 9 x 9 tile/mastic 

throughout— most covered by carpets. Duct connection cloth in utility room – appears that it may have been replaced. 

Good to fair condition inside. Outside fair to poor condition with some peeling on porch/steps, doors, and 2nd floor 

windows. 

500-gal UST 

— HO 

Y

3-89 546 Storage (864) 1973 Not suspected. Paint on doors 

peeling. 

No N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-8

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 554 Water Treatment Plant 

(2,803) 

1957 9 x 9 tile and mastic north 

side of second floor. Pipe insulation throughout – removals and repairs/encapsulations have been done in past – appears to have been replaced but some may still remain inplace. Transite/cement boards (hallway board – may have been replaced). 

Inside good to fair condition - some isolated areas with peeling/chipped paint. Outside fair to poor (areas of peeling paint). 

2,000- gal UST – HO (T, 1996) 

N

3-89 558 Water Treatment Plant 

(1,643) 

1953 None identified from past 

sampling. Fair to poor condition inside 

and outside. 

1,000-gal 

UST – HO 

(T, 1996) 

2 x 200-gal 

AST—Diesel 

Y
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-9

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-89 559 Water Treatment Plant 

(245) 

1968 None identified from past 

sampling. 

Paint fair condition. 

3-89 572 Storage – Fire 

Department (86) 

1982 No ACM based on year 

built. N/A based on year built. N

3-89 N/A Water tower 2001 No ACM based on year 

built. 

N/A based on year built. 

No N

3-89 N/A Open area that is 

balance of Parcel 3-89 (includes Backwash Discharge Area from the water treatment plant and the OVSAc

sites) 

N/A N/A N/A No N
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) 

Table 6-1 

Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Ph

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC 

6-10

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Year Built Accessible ACM Condition of LBP 

Storage 

Tanks Sp

3-90 N/A Open area N/A N/A N/A No N3-91 N/A Open area/Building 

400 Series Fire Training Area site 

N/A N/A N/A No N

3-92 N/A Reservoir N/A N/A N/A No N

aThese spill incidents are documented in the building discussions. This column includes some spills that are not listed in Table 2 or 3. These spills do n

reportable under CERCLA (see note in Table 2) or are less than 55 gal for petroleum substances (AMC policy). However, these spills have been provadditional information purposes. 

bRadon was detected above 4 pCi/L, which is an EPA residential action level; there is no industrial/commercial EPA action level. cNo spills on record for this building but it is located within the footprint of the Open Vehicle Storage Area (OVSA) site where there were releases tha

action. 

N/A = Not applicable or none present. TANKS

AST = Aboveground storage tank. T = Tightness tested. gal = Gallons UST = Underground storage tank. HO = Heating oil. 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_7.DOC 9/9/2003 

ENCLOSURE 7 

ENVIRONMENTAL PROTECTION PROVISIONS 
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_7.DOC 9/9/2003 7-1

1. CERCLA COVENANTS AND NOTICE 

Pursuant to Section 120(h)(3) of the Comprehensive Environmental Response, Compensation, and 

Liability Act, as amended, 42 U.S.C. Section 9601 et seq. ("CERCLA"): 

A. Notification and Covenants 

1. The GRANTOR hereby notifies the GRANTEE of the storage, release, and disposal of hazardous 

substances on the Property. The release or disposal of these hazardous substances was remedied at the 

time of the release or, where required, was subsequently addressed under the Installation Restoration 

Program. For the purpose of this Deed, "hazardous substances" shall have the same meaning attributed to 

such term under Section 101(14) of CERCLA, 42 U.S.C. §9601(14). Available information regarding the 

type, quantity, and location of such hazardous substances and action taken to address such hazardous 

substances is described in Exhibit D herein [Exhibit D of the Deed is the FOST Table 2 (Enclosure 3) - 

Notification of Hazardous Substances Storage, Release, or Disposal]. More detailed information 

regarding the storage, release, and disposal of hazardous substances on the Property has been provided to 

the GRANTEE in the Environmental Baseline Survey for Letterkenny Army Depot dated August 1996, 

amended May 1999, and as supplemented in November 2000 (collectively the “EBS”) and the Finding of 

Suitability to Transfer (FOST) for the Property dated July 2003, the receipt of which the GRANTEE 

hereby acknowledges. 

2. The GRANTOR hereby covenants that: 

a. All remedial action necessary to protect human health and the environment with respect to 

any such hazardous substances remaining on the Property has been taken before the date of 

conveyance hereunder; and 

b. Any additional remedial action found to be necessary with regard to such hazardous 

substances remaining on the Property after the date of this conveyance shall be conducted by 

the GRANTOR. This covenant in this Subsection 1(A)(2) shall not apply in any case in 

which the person or entity to whom the Property is transferred is a potentially responsible 

party under CERCLA with respect to the Property. 

2. CERCLA REMEDIATION 

The GRANTOR acknowledges that Letterkenny Army Depot (LEAD) has been identified as a National 

Priorities List (NPL) site under the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA) of 1980, as amended. The GRANTEE acknowledges that the GRANTOR has 

provided it with a copy of the LEAD Federal Facility Agreement (FFA) dated February 3, 1989 and will 

provide the GRANTEE with a copy of any amendments thereto. 

A. The GRANTEE, its successors and assigns, agrees that should any conflict arise between the terms of 

the FFA as they presently exist or may be amended, and the provisions of this property transfer, the terms 

of the FFA will take precedence. The GRANTEE, its successors and assigns, further agrees that 

notwithstanding any other provisions of this Deed, the GRANTOR assumes no liability to the 

GRANTEE, its successors and assigns, should implementation of the FFA interfere with their use of the 

Property; and said parties shall have no claim against the United States or any officer, agent, employee, or 

contractor thereof on account of any such interference, provided the GRANTOR complies with the 

requirements of Section 2(D). 

B. Prior to the determination by the United States that all remedial action is complete under CERCLA 

and the FFA for the LEAD site: 
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1. The GRANTEE, its successors and assigns, shall not undertake activities on the Property that 

would interfere with or impede the completion of the CERCLA cleanup at the LEAD NPL site. Activities 

required to avoid interference with the completion of the CERCLA cleanup at LEAD include, but are not 

limited to, the GRANTEE, its successors and assigns, taking appropriate action to ensure stormwater is 

directed into existing or future stormwater sewer systems or drainage ditches and forbearing from 

installing groundwater extraction wells that interfere with the site hydrology; and 

2. The GRANTEE, its successors and assigns, shall comply with any institutional controls 

established or put in place by the GRANTOR relating to the Property that are required by any Record of 

Decision ("ROD") or amendments thereto issued before or after the date of this Deed. Additionally, the 

GRANTEE, its successors and assigns, shall ensure that any leasehold it grants in the Property or any fee 

interest conveyance of any portion of the Property provides for legally binding compliance with the 

institutional controls required by any such ROD. 

C. All subsequent conveyances of the Property or any interests therein by GRANTEE, its successors and 

assigns, shall be expressly subject to the rights and duties of the United States to continue operation of 

any monitoring wells, treatment facilities, or other response activities undertaken pursuant to CERCLA or 

the FFA on said portion of the Property. The GRANTEE, its successors and assigns, shall provide: 

1. Pretransfer Notice—60 days written notice of any such conveyance (including a description of 

the deed/lease provisions allowing for continued remediation activities) to the GRANTOR, the U.S. 

Environmental Protection Agency (EPA), and the Pennsylvania Department of Environmental Protection 

(PADEP); and 

2. Deed/Lease—Within 14 days after the effective date of the transaction, GRANTEE, its 

successors and assigns, will provide to the GRANTOR, EPA, and PADEP, copies of the deed, lease, or 

other conveying instrument evidencing such transaction. 

D. The GRANTOR reserves a perpetual easement over and through and a right of access to the Property 

to perform any additional environmental investigation, monitoring, sampling, testing, remedial action, 

corrective action, or any other action necessary for the GRANTOR to meet its environmental 

responsibilities under applicable laws and as provided for in the Deed. This easement and right of access 

shall be binding on the GRANTEE, its successors and assigns, and shall run with the land. This 

reservation includes the right to access and use utilities on the Property at reasonable cost to the United 

States. In exercising this right of access, except in case of imminent endangerment to human health or the 

environment, the GRANTOR shall give the GRANTEE, or the then record owner, reasonable notice of 

actions to be taken on the Property and shall use reasonable means, without significant additional cost to 

the GRANTOR, to avoid and/or minimize interference with the use of the Property. 

E. The GRANTOR shall not incur liability for additional response action or corrective action found to be 

necessary after the date of transfer unless the GRANTEE, its successors or assigns, is able to demonstrate 

that such release or such newly discovered substance was due to GRANTOR's activities, ownership, use 

or occupation of the Property, or the activities of GRANTOR's contractors and/or agents. 

F. All subsequent leases, transfers, or conveyances shall be made expressly subject to this easement. 

Upon a determination by the United States that all remedial action is complete at the LEAD NPL site, the 

GRANTOR shall execute and record a release of easement. 

3. NOTICE OF THE PRESENCE OF LEAD-BASED PAINT AND COVENANT AGAINST THE 

USE OF THE PROPERTY FOR RESIDENTIAL PURPOSES 

A. The GRANTEE is hereby informed and does acknowledge that all buildings on the Property that were 

constructed or rehabilitated prior to 1978 are presumed to contain lead-based paint. Lead from paint, 
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paint chips, and dust can pose health hazards if not managed properly. Every purchaser of any interest in 

Residential Real Property on which a residential dwelling was built prior to 1978 is notified that such 

property may present exposure to lead from lead-based paint that may place young children at risk of 

developing lead poisoning. Lead poisoning in young children may produce permanent neurological 

damage, including learning disabilities, reduced intelligence quotient, behavioral problems, and impaired 

memory. Lead poisoning also poses a particular risk to pregnant women. The seller of any interest in 

Residential Real Property is required to provide the buyer with any information on lead-based paint 

hazards from risk assessments or inspections in the seller's possession and notify the buyer of any known 

lead-based paint hazards. "Residential Real Property" means any housing constructed prior to 1978, 

except housing for the elderly (households reserved for and composed of one or more persons 62 years of 

age or more at the time of initial occupancy) or persons with disabilities (unless any child who is less than 

6 years of age resides or is expected to reside in such housing) or any 0-bedroom dwelling. For the 

purpose of this deed, child-occupied facilities are included in the definition of "Residential Real Property" 

and means a building, or portion of a building, constructed prior to 1978, visited regularly by the same 

child, less than 6 years of age, on at least two different days within any week (Sunday through Saturday), 

provided that each day's visit lasts at least 3 hours, that the combined weekly visits last at least 6 hours, 

and that the combined annual visits last at least 60 hours. Child-occupied facilities may include, but are 

not limited to, day-care centers, pre-schools, and kindergarten classrooms. 

B. Available information concerning known lead-based paint and/or lead-based paint hazards, the 

location of lead-based paint and/or lead-based paint hazards, and the condition of painted surfaces is 

contained in the EBS documents, the FOST, and (for residential properties) the lead-based paint risk 

assessment, which have been provided to the GRANTEE. All purchasers must receive the Federallyapproved pamphlet on lead poisoning prevention. The GRANTEE hereby acknowledges receipt of all of 

the information described in this subparagraph. Additionally, the report entitled Lead-Based Paint Survey, 

Letterkenny Army Depot prepared by Dames and Moore, Inc. in 1996 pertaining to lead-based paint 

and/or lead-based paint hazards has been provided to the GRANTEE. 

C. The GRANTEE acknowledges that it has received the opportunity to conduct its own risk assessment 

or inspection for the presence of lead-based paint and/or lead-based paint hazards prior to execution of 

this document. 

D. The GRANTEE covenants and agrees that it shall not permit the occupancy or use of any buildings or 

structures on the Property as Residential Real Property without complying with this section and all 

applicable Federal, state, and local laws and regulations pertaining to lead-based paint and/or lead-based 

paint hazards. Prior to permitting the occupancy of the Property where its use subsequent to sale is 

intended for residential habitation, the GRANTEE specifically agrees to perform, at its sole expense, the 

Army's abatement requirements under Title X of the Housing and Community Development Act of 1992 

(Residential Lead-Based Paint Hazard Reduction Act of 1992) (hereinafter Title X). 

The GRANTEE shall, after consideration of the guidelines and regulations established pursuant to Title 

X: (1) perform a risk assessment if more than 12 months have elapsed since the date of the last risk 

assessment; (2) comply with the joint U.S. Department of Housing and Urban Development (HUD) and 

EPA Disclosure Rule (24 CFR 35, Subpart H; 40 CFR 745, Subpart F), when applicable, by disclosing to 

prospective purchasers the known presence of lead-based paint and/or lead-based paint hazards as 

determined by previous risk assessments; (3) abate lead dust and lead-based paint hazards in pre-1960 

Residential Real Property, as defined in paragraph A, above, in accordance with the procedures in 24 

CFR 35; (4) abate soil-lead hazards in pre-1978 Residential Real Property, as defined in paragraph A, 

above, in accordance with the procedures in 24 CFR 35; (5) abate lead-soil hazards following demolition 

and redevelopment of structures in areas that will be developed as Residential Real Property; (6) comply 

with the EPA lead-based paint work standards when conducting lead-based paint activities (40 CFR 745, 

Subpart L); (7) perform the activities described in this paragraph within 12 months of the date of the lead-
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based paint risk assessment and prior to occupancy or use of the Residential Real Property; and (8) send a 

copy of the clearance documentation to the GRANTOR. 

In complying with these requirements, the GRANTEE covenants and agrees to be responsible for any 

abatement or remediation of lead-based paint or lead-based paint hazards on the Property found to be 

necessary as a result of the subsequent use of the property for residential purposes. The GRANTEE 

covenants and agrees to comply with solid or hazardous waste laws that may apply to any waste that may 

be generated during the course of lead-based paint abatement activities. 

E. The covenants, restrictions, and requirements of this Section 3 shall be binding upon the GRANTEE, 

its successors and assigns, and all future owners, and shall be deemed to run with the land. The 

GRANTEE on behalf of itself, its successors and assigns, covenants that it will include and make legally 

binding, this Section 4 in all subsequent transfers, leases, or conveyance documents. 

4. NOTICE OF THE PRESENCE OF ASBESTOS AND COVENANT 

A. The GRANTEE is hereby informed and does acknowledge that friable and nonfriable asbestos or 

asbestos-containing materials ("ACM") has been found in buildings and structures on the Property, as 

described in the EBS documents. To the best of the GRANTOR's knowledge, the ACM in buildings and 

structures on the Property does not currently pose a threat to human health or the environment, and all 

friable asbestos that posed a risk to human health has either been removed or encapsulated. 

B. The GRANTEE covenants and agrees that its use and occupancy of the Property will be in 

compliance with all applicable laws relating to asbestos; and that the Army assumes no liability for future 

remediation of asbestos or damages for personal injury, illness, disability, or death, to the GRANTEE, its 

successors or assigns, or to any other person, including members of the general public, arising from or 

incident to the purchase, transportation, removal, handling, use, disposition, or other activity causing or 

leading to contact of any kind whatsoever with asbestos on the Property, whether the GRANTEE, its 

successors or assigns, have properly warned or failed to properly warn the individual(s) injured. The 

GRANTEE agrees to be responsible for any future remediation of asbestos in buildings and structures 

found to be necessary on the Property.

C. The following buildings were constructed prior to 1981 and have not had an ACM survey completed 

and may contain ACM: 

Buildings 528, 536, and 546. 

In accordance with the Occupational Safety and Health Administration (OSHA) guidelines, the following 

materials, if present in these structures, must be considered as asbestos-containing and handled as such 

unless tested negative through a certified EPA asbestos building inspector: 

• Thermal system insulation (e.g., pipe insulation, pipe wrap, mudded fittings, or other material 

applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to 

prevent heat loss or gain). 

• Spray-on texture surfacing/fireproofing (i.e., material that is sprayed, troweled-on, or 

otherwise applied to surfaces [such as acoustical plaster on ceilings and fireproofing materials 

on structural members, or other materials on surfaces for acoustical, fireproofing, and other 

purposes]). 

• Asphalt and vinyl floor tile installed no later than 1980. 
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The buildings listed here may contain none, some, or all of the above building materials. The GRANTEE 

acknowledges that these materials shall not be disturbed, and that any maintenance that directly or 

indirectly disturbs these materials shall need to be performed by appropriately trained personnel, 

according to the requirements of OSHA. 

D. Unprotected or unregulated exposures to asbestos in product manufacturing, shipyard, and building 

construction workplaces have been associated with asbestos-related diseases. Both OSHA and EPA 

regulate asbestos because of the potential hazards associated with exposure to airborne asbestos fibers. 

Both OSHA and EPA have determined that such exposure increases the risk of asbestos-related diseases, 

which include certain cancers, and which can result in disability or death. 

E. The GRANTEE acknowledges that it has inspected the Property as to its asbestos content and 

condition and any hazardous or environmental conditions relating thereto. The GRANTEE shall be 

deemed to have relied solely on its own judgment in assessing the overall condition of all or any portion 

of the Property, including, without limitation, any asbestos hazards or concerns. 

F. Notwithstanding the provisions of Section 4.A, the GRANTOR assumes no liability for any damages 

to person or property, and gives no warranties, either express or implied, with regard to the presence or 

absence of asbestos or ACM in buildings and structures, or whether the property is or is not suitable for a 

particular purpose. Furthermore, the GRANTEE agrees to make no claim or demand against the United 

States based on the presence of asbestos or ACM in buildings and structures on the Property. 

5. NOTICE OF GROUNDWATER RESTRICTIONS 

The GRANTEE is hereby notified that the Cumberland Valley Business Park's Declaration of Covenants, 

Conditions and Restrictions, Section 8.9.4, dated 1999, prohibits water drilling. In addition, the 

GRANTEE is hereby notified that the Greene Township Code, Section 85-52, Paragraph F, dated March 

26, 2002, requires the subdivider or developer of any proposed subdivision within 500 feet of any public 

water system of a public water supplier to design and install a complete water system, which shall be 

connected to said water system. 

6. STATUTORY INDEMNIFICATION 

Subject to the availability of appropriated funds, the GRANTOR recognizes its obligation to hold 

harmless, defend, and indemnify the GRANTEE and any successor, assignee, transferee, lender, or lessee 

of the GRANTEE or its successors and assigns as required and limited by Section 330 of the U.S. 

Department of Defense Authorization Act of 1993, as amended, and to otherwise meet its obligations 

under law. 

7. INCLUSION OF PROVISIONS 

The GRANTEE, its successors and assigns, shall neither transfer the Property, lease the Property, nor 

grant any interest, privilege, or license whatsoever in connection with the Property without the inclusion 

of the environmental protection provisions contained herein, and shall require the inclusion of such 

environmental protection provisions in all further deeds, transfers, leases, or grants of any interest, 

privilege, or license.
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ENCLOSURE 8 

REGULATORY AGENCY/PUBLIC COMMENTS AND REGULATORY 

AGENCY CONCURRENCE LETTERS 
P,"",yl,,,', O'p'rtm," of E,,'coom,"tal P,otect'"

~~ . 909 Elmerton Avenue

Harrisburg, PA 17110-8200

May 1,2003

Southcentral Regional Office

Mr. Bryan Hoke

BRAC Envirorunental Coordinator

SIDLE-CO, Building 522

Letterkenny Army Depot

One Overcash Avenue

Chambersburg, PA 17201-4150

Dear Mr. Hoke:

7I7-705-4705

FAX 717-705-4830

Re: Draft FOST for Phase III BRAC Parcels

Letterkenny Army Depot

Greene Township, Franklin County

The purpose of this letter is to provide the Department's acceptance of the draft Finding of

Suitability to Transfer (FOSn, dated March 2003, for selected buildings and parcels at Letterkenny

Army Depot.

The 2003 FOST includes approximately 201 acres consisting of three on-depot parcels, 20

buildings, and a water tower. The parcels are identified as Parcels 3-89, 3-90, and 3-91. Phase III also

includes 28 acres of subsurface property (deeper than 8 feet below ground surface) located beneath

parcels transferred as part of Phase II. These parcels are identified as 2-53L, 2-54L, 2-70L, 2R-80L-3,

2R-84L-3, and 2R-86L-3. Also included in this FOST is the Letterkenny Reservoir, located off-depot.

The reservoir is identified as Parcel 3-92.

Thank you for your continued cooperation and your coordination of depot cleanup and base

realigrunent efforts. Please forward two copies of the final signed version for our files. If you have any

questions or need additional information, you can contact me at 717-705-4860.

Sinc/5ly,

/~;; cI./2~1/' _____ ,t/lo7 ufJJ!::; (/'"

Gi.hOny L. Rathfon. anager

Envirorunental Cleanup Program

cc: Frank Vavra, EPA (3HS13)

Greg Daloisio. Weston Solutions, Inc.V

www.dep.state.pa.us -- .- Pr,n:('d ,lr. Rt>(~(i{'d PJPt'f
Responses to EPA Region III Comments (rec. May 13, 2003) to

Draft Finding ofSuitability to Transfer (FOST) for Phase III Parcels, March 2001

Letterkenny Army Depot (LEAD), Chambersburg, Pennsylvania

Comments From Frank A. Fritz, III (3RC44), Offiee of Regional Counsel, EPA Region III

I've reviewed the draft FaST and marked some comments in pencil. Additional comments arc below. If you have a

problem responding to any ofthe comments, or you have questions, please do not hesitate to call me at 215-814-

2664.

These comments arc based on review ofthe draft FOST, without any independent investigation or verification ofthe

information contained in the FOST.

General Response: The Draft-Final FOST rejlects changes made in accordance with EPA's

comments on the markup given to Bryan Hoke on May 13, 2003. Also, regarding the comment

on page 2 ofSection 2 about the total BRAC acreage, the correct number is approximately 1,450

acres (this number was listed in the Draft ROD), and the numbers listed in the Proposed Plan

and Draft FOSTwere incorrect.

EPA Region III Specifie Comments: Section/Page followed by Comments

Sec. 3, r t sentence

This says Army is relying on various documents to determine the environmental condition ofthe property. The cited

documents are 4-7 years old. Do we rely on more recent documents (RIIRisk Assessment reports, EBS supplement) to

determine the environmental condition ofthe property? Ifso, cite them here.

Response: The references mentioned in the secondparagraph ofSection 3 and additional references

listed in Enclosure 8 are all meant to be references providing current information related to the

environmental condition ofthe property. The jlrst sentence was revised asfollows to clarifY this:

"The Army has determined the environmental condition ofthe proposedparcels and buildings to be

transferred based on the LEAD EBS (WESTON, 1996), the LEAD EBS Addendum (WESTON,

1999a), Supplement 1 to the LEAD EBS (WESTON, 2000b), the Community Environmental

Response Facilitation Act (CERFA) Report (WESTON, 1997), and the remedial investigation/risk

assessment reports listed in the following paragraph. "

In addition, the current site conditions based on the 11 June 2003 final walkthroughs/visual survtys

are reported in Enclosure 6, Table 6-1

Table 2, Parcel 3-89. Building 554

Were lime and aluminum sulfate stored or released? Please write something like: "Unknown quantities oflime and

aluminum sulfate stored" or "'released" in the Name of Hazardous Substance column.

Response: "Stored" was added to the table entry.

Table 2. footnote c, last sentence

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Responses to EPA Region III Comments to

Draft FOST for Phase III Parcels (continued)

"there are no longer unacceptable risks to people and the environment." Under what exposure assumptions? Would it

be truthful to VvTite something like "no longer unacceptable risks to people and the environment under

commerciallindustrial, agricultural or residential use scenarios"?

Response: Requested change was incorporated.

Appendix A, A-I

Some buildings were not tested for asbestos-containing materials because they were unoccupied or not regularly

occupied. Is there a law or policy that says no Army testing for ACM is OK in these circumstances? Please provide a

citation.

Perhaps it would help to explain (as you do in section 3.5) that the Army visually inspected all of the buildings for

ACM. ACM was not noted in 7 of the buildings (list 'em) and no further ACM survey, testing or evaluation was done

in these buildings. However, the visual survey does not constitute a full ACM survey.

Response.' The evaluation ofasbestos priorto transferfor the Phase III parcels at LEAD is

consistent with the "DoD Policy on Asbestos at Base Realignments and Closure

Properties"(Attachment to DoD Memorandum, "Asbestos, Lead Paint and Radon Policies at BRAC

Properties," 31 October 1994), and "Army Regulation (AR) 420-70, Buildings and Structures,"

Facilities Engineering, Department ofthe Army, 10 October 1997. These references were added to

Enclosure 8 and the following sentence was added to Section 3.5 and Appendix A: "Assessment of

ACMfor the Phase III buildings is consistent with DoD policy (DOD, 1994) and Army regulation

(Army, 1997)for BRACproperties." The DoD policy and Army regulation callfor reasonably

available information on the type, location, and condition ofasbestos in buildings and the

documents note that special studies ortests to obtain the information are not required (i.e., it is not

stated thatfull ACM surveys are required on every building/structure). The main objective noted in

the Army Regulation and DoD asbestos policy is to identify conditions that could pose a threat to

human health, which can be accomplished via the EBS site inspections and the FOST visual

inspectionsfor those buildings where afull survey was not performed.

For the second part ofthe comment, the requested changes were made to Appendix A.

Appendix A. Building 539

Why wasn't lead-based paint evaluated in this building, which was for guest and temporary housing'? Explain

Response.' The following explanation was added at the end ofthe Building 539 section, Appendix A:

"A LBP survey was not done for Building 539 because it is not considered a residential dwelling like

Kenny Hill and the otherfull-time use military houses. Building 539 consists ofthree small

apartments/efficiencies that were only used as very short-term temporary quarters (similar to a hotel

use) for officers or other military adult guests on temporary travel. The building was not used for

housing children and the lengths ofstay for guests consisted ofonly weekends or several days. In

addition, the building is being transferredfor industrial/commercial use and will not be used as

residential housing. "

MKO110:\02281 016.008\PHASEIIlFOST\PHASEIIIFOST~ENCl~8RTCS. DOC 2 711612003
Responses to EPA Region III Comments to

Draft FOST for Phase //I Parcels (continued)

Environmental Protection Provisions, Section 1.A.2 (second instance)

You've got two subparagraphs number LA.2 and LA.2.a. Delete the second set.

Response: Requested change was incorporated.

Environmental Protection Provisions, Sec, 3 and 4 Titles

Some courts disregard section titles when interpreting contracts. That means a court might disregard "EXCEPTION

TO THIS CLAUSE IS PARCEL 3-92, LETTERKENNY RESERVOIR" in the titles of these sections.

Army might want to move this language to separate numbered paragraphs in the bodies of the sections

Response: Suggested changes were incorporated,

Environmental Protection Provisions, Section 4,F, 1" sent,

Change "provisions of 5.A" to "provisions of 4.A"

Response: Requested change was incorporated.

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ENCLOSURE 9 

REFERENCES AND BIBLIOGRAPHY 
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REFERENCES AND BIBLIOGRAPHY 

Acker, R.C. 1955. Water Supply from Wells for Letterkenny Ordnance. Letter Report to 

District Engineer, U.S. Army Corps of Engineers, Baltimore District. 

Archaeological & Historical Consultants, Inc. December 1996. Phase I Archaeological 

Survey, Letterkenny Army Depot. Franklin County, Pennsylvania. 

Army Materiel Command (AMC). 2000. FOST/FOSL Guidance. Environmental Quality 

Division. Office of the Command Counsel, AMC BRAC Office. February 1998, updated 

February 2000. 

Army (Department of the Army). 1997. Army Regulation 420-70, Building and 

Structures. Facilities Engineering, Headquarters Department of the Army. Unclassified.

10 October 1997. 

Battelle. May 1984. Environmental Contamination Survey of LEAD: Multi-Phase 

Investigation Summary. 

Battelle. December 1983a. Environmental Contamination Survey of LEAD: Exploratory 

and Confirmatory Phases. 

Battelle. October 1983b. Environmental Contamination Survey of LEAD: Property 

Disposal Office Drainage System. 

Battelle. September 1983c. Environmental Contamination Survey of LEAD: Southeast 

Industrial Area. 

Battelle. June 1983d. Geophysical Survey of the Southeast Area of LEAD.

Becher, A.E. and L.E. Taylor. 1982. Groundwater Resources in the Cumberland and 

Contiguous Valleys of Franklin County, Pennsylvania. Pennsylvania Geological Survey 

Water Resources Report 53. Harrisburg, Pennsylvania. 

Berger Associates. 1981. Army Pollution Abatement Program Studies. 

Building Technology Incorporated. July 1984. Historic Properties Report, Letterkenny 

Army Depot. 

Dames and Moore, 1996. Lead-Based Paint Survey—Letterkenny Army Depot. 

Dames and Moore, 1993. Asbestos Survey—Letterkenny Army Depot.

DoD (Department of Defense). 1994. DoD Policy on Asbestos at Base Realignments and 

Closure Properties. Attachment to DoD Memorandum, Asbestos, Lead Paint and Radon 

Policies at BRAC Properties. 31 October 1994 

Dragun, J. and A. Chiasson. 1991. Elements in North American Soils. Hazardous 

Materials Control Resources Institute, Greenbelt, Maryland. 

EA (EA Engineering, Science, and Technology). 1991. Site Investigation, LEAD.
Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final 

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EMC (Environmental Management Consultants). July 1988a. Asbestos Survey, Building 

663, Letterkenny Army Depot.

EMC (Environmental Management Consultants). 1988b. Asbestos Survey—Building 1, 

Letterkenny Army Depot. 

EMS (Environmental Management Systems). 1989. Asbestos Assessment Survey for 

Letterkenny Army Depot.

ESE (Environmental Science & Engineering, Inc.). September 1995. PDO New OU #5 

Site Investigation, PCBs in Rocky Spring Lake. Draft Report. 

ESE (Environmental Science & Engineering, Inc.). July 1994. Risk Assessment of the 

Southeastern Area at Letterkenny Army Depot, Operable Units One and Three. Final 

Report. 

ESE (Environmental Science & Engineering, Inc.). January 1993a. Remedial 

Investigation of the Property Disposal Office Area at Letterkenny Army Depot. Final 

Report. 

ESE (Environmental Science & Engineering, Inc.). June 1993b. Risk Assessment of the 

Property Disposal Office Area at Letterkenny Army Depot, Operable Units 1 and 2. Final 

Report. 

ESE (Environmental Science & Engineering, Inc.). June 1993c. Remedial Investigation of 

the Southeastern Area at Letterkenny Army Depot. Final Report. 

ESE (Environmental Science & Engineering, Inc.). September 1987a. Remedial 

Investigation of the Property Disposal Office Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). December 1987b. Remedial 

Investigation of the Southeastern Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). August 1986. Remedial Investigation 

of the Disposal Area at LEAD.

FCADC (Franklin County Area Development Corporation). 1993. 1993 Franklin County 

Data Book. 

FCRC (Franklin County Reuse Committee, now known as the Letterkenny Industrial 

Development Authority [LIDA]). May 1997. Letterkenny Army Depot Reuse Strategy 

Summary Report 

Fluor Daniel, Inc. 1977. Final Site Inspection Report, Southeastern Area Operable Unit 7 

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