# Finding of Suitability to Transfer (FOST) for the Phase III BRAC Parcels Letterkenny Army Depot

U.S. Army Corps of Engineers Baltimore District

August 2003

03P-1178 L E T T E R

K

E

N

N

Y

P E

N

N S Y L V A N I A C H A M B E R S

B

U

R

G
, A R

M

Y

D E P O T B A L T I M O R E D I S T R I C T **Proud Past**

**Dynamic Future**



# Final SMLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST)

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

## 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. 02281.016.008.3102Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### ii 

## TABLE OF CONTENTS

Section Page

1. PURPOS E

.................................................................................................................... . ......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 P ETROLEUM 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 HAZARDO US CONDITIONS...................................................................8

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

6. REGULATORY AND PUBLI C COORDINATION....................................................12

7. NATIONAL ENVIRONMENTAL PO LICY 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 PARCELSLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final



## TABLE OF CONTENTS (Continued)

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

### iii 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 BIBLIOGRAPHYLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

## LIST OF ACRONYMSLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### iv 

## 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 Res ponse, 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

ft 2 square feet FTA Fire Training Area ft bgs feet below ground surface gal gallon HUD U.S. Department of Hous ing and Urban Development LBP lead-based paint LEAD Letterkenny Army Depot LIDA Letterkenny Industrial Development Authority mg/cm 2 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 AdministrationLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final



## LIST OF ACRONYMS (Continued)

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

### v 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 fluorescenceLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 1 

## 1. PURPOSE

The purpose of this Finding of Suitabilit y to Transfer (FOST) is to document environmental conditions at select ed parcels and buildings (Phase III parcels) at the Letterkenny Army Depot (LEAD or the Depot) for transfer to the Letterkenny Industrial Developmen t Authority (LIDA) consistent with the Comprehensive Environmental Re sponse, Compensation, and Liability Act (CERCLA) Section 120(h) and U.S. Department of Defense (DoD)/Army policy. In addition, the FO ST identifies property notices, as specified in the attached Environmenta l Protection Provisions ( Enclosure 7 ), necessary to protect human hea l th and the environment after such transfer.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 2 

## 2. PROPERTY DESCRIPTION

LEAD is located in south-central Penns ylvania 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 iden tified as: Parcels 3-89, 3-90, and 3- 91. In addition, Phase III includes 28 ac res of subsurface property that is deeper than 8 feet below ground surface (ft bgs), located underneath parcels previously transferred as pa rt of Phase II. These subsurface parcels are associated with three P hase 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 reservoi r is identified as Parcel 3-92. The Phase III BRAC parcels were previous ly used for industrial operations, supply (including vehicle) storage, administration and recreational activities, and military housing. Prio r to the establishment of LEAD, the area consisted of agricultural (predo minantly single-family farms used for both subsistence and commercial purpos es) and forest lands. The intended future property use of the Phas e III parcels includes industrial/ commercial/agricultural use and cont inued use of the reservoir, as described in the LIDA reuse plan (FCRC, 1997). However, the property was evaluated for unrestricted use so th at 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).Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 3 

## 3. ENVIRONMENTAL CONDITION OF THE PROPERTY

The Army has determined the environmental condition of the proposed parcels and buildings to be transfe rred 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. Envi ronmental Protection Agency (EPA), and Pennsylvania Department of Envi ronmental Protection (PADEP) files was conducted while developing the LEAD EBS, which provided information on the environmental co ndition of the property. A list of environmental documents that provided information to prepare the FOST is provided in Enclosure 9 , Referen c es 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 Enclos ure 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 Prioriti es 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 su bstances from adjacent areas).

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

Quality Division Office of the Co mmand Counsel, AMC BRAC Office, Febr uary 1998, updated February 2000) was used as guidance to determine the ECP categories for the parcels.Letterkenny Ar m y Depot Phase III Finding of Suitability to Transfer (FOST) Final

M K01|O:\02281016.008\P H ASEIIIFOS T \P H ASEIIIFOS T

_ T E X T

. D OC 9/9/2003 

### 4 Building 558 is classified as ECP Category 2. ECP Category 2 is defined as areas where only the release of pe troleum 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 Cat e gory 4. ECP Category 4 is defined as areas where release, disposal, and / or migration of hazardous substances has occurred, and all removal or remed i al actions to protect human health and the environment have been taken.

A summary of the ECP categories for s p ecific buildings, parcels, or study areas is provided in Table 1 – P r operty Description ( Enclosure 2 ).



### 3.2 STORAGE, RELEASE, OR D I SPOSAL OF HAZARDOUS SUBSTANCES

Hazardous substances were stored f o r 1 year or more in e x cess 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 e x cess of the q u antities 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 e x cess of the
q u antities referenced in 40 CFR 373 in the OVSA site in Parcel 3-89. The release or disposal of these hazard o us substances was subse q uently remediated as part of the installat i on’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 w h ich hazardous substance activities occurred is provided in Table 2 – N o tification 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 storag e 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).Letterkenny Ar m y Depot Phase III Finding of Suitability to Transfer (FOST) Final

M K01|O:\02281016.008\P H ASEIIIFOS T \P H ASEIIIFOS T

_ T E X T

. D OC 9/9/2003 

### 5 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 p r oduct activities is provided in Table 3 – Notification of Petrole u m Product Storage, Release, and/or Disposal ( Enclosure 4 ).



### 3.3.2 Non-UST/AST Storag e, Release, or Disposal of Petroleum Products

There is no evidence that any petrol eum 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/AS T petroleum activities. Accordingly, there is no need for any notificati on of non-UST/AST petroleum product storage, release, or disposal.



### 3.4 POLYCHLORINATED BIPH ENYLS (PCB) EQUIPMENT

There are no PCB-containing trans formers 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-contain ing 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 insulati on, 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 asbest os that posed an unacceptable risk to human health has been removed or encapsulated (WESTON, 1996, 1999a, 2001a).Letterkenny Ar m y Depot Phase III Finding of Suitability to Transfer (FOST) Final

M K01|O:\02281016.008\P H ASEIIIFOS T \P H ASEIIIFOS T

_ T E X T

. D OC 9/9/2003 

### 6 A total of seven buildings in the LEAD Phase III FOST parcels were not surveyed for ACM, including four b u ildings 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 constit u te 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 summari zed by building in Appendix A ( Enclosure 5 ). The deed will include the asbestos notice and covenant included in the Environmental Prote c tion Provisions ( Enclosure 7 ). In addition, a provision has been added ( E nclosure 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 summ a rized 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 d eed, 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.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 7 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 occupi ed. 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 fo r 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, whic h 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 area s in the Ammunition Area (AA), which are located approximately 3.2 miles from the FOST property. The AA is part of the Enclave Area proper ty and is not scheduled for property transfer.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 8 

## 4. ADJACENT HAZARDOUS CONDITIONS

Parcel 3-89 is adjacent to or in pr oximity 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 fo r the property to be suitable for transfer for the intended use.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 9 

## 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 locate d off-Depot and is not on the NPL.

The following environmental investig ation/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 evalua te the groundwater quality within the SMSR (underneath the Phase III property). The investigation concluded that the topographic posi tion of the SMSR and the outward groundwater flow from the SMSR pr otects 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 futu re commercial/industrial use, as well as potential residential use, are within acceptable limits. Consequently, no remedial actions ar e 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 tr ansferring these Phase II subsurface parcels. The Environmental Protecti on 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 groundwate r 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 perfor med at various periods between October 1998 and November 2000 to investigate soil, sediments,Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 10 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 heal th 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 resi dential 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 we re ignited. Field activities were performed in September 1998 to investigate soils. Results ofLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 11 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).Letterkenny Ar m y Depot Phase III Finding of Suitability to Transfer (FOST) Final

M K01|O:\02281016.008\P H ASEIIIFOS T \P H ASEIIIFOS T

_ T E X T

. D OC 9/9/2003 

### 12 

## 6. REGUL A T O R Y AND PUBLIC COORDIN A TION

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 in corporated 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

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

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

### 13 

## 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 acco rdance 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 th e 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) =d I>on FOST

### guiM=~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:\02281 016.008\PHASEHlFOSnPHASEHlFOST _TEXT. DOC 

### 14 81812003Letterkenny 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 w i thin PDO and SE Areas

 Figure 2—Location of Letterkenny Reservoir and Dam, Parcel 3-92STATE 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 37 1

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

224

12 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 

### 692 CHILD

DEVEL. CENTER

PLAYGROUND SOFTBALL FIELD BASEBALL FIELD

GARDENS GARDENS 

### 640 CONCRETE PADS



### 627 629 619 618 617 GRAVEL PARKING LOT

616 621 628 GATE NO. 17 T-635

STATE

ROUTE

340 PAVED PARKING PAVED PARKING

PAVED PARKING GRAVEL PARKING 

### CHAPEL 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 TR ACK

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

709

708 707

706 705

704

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

729

728

727

726

725

724

723

722 721 720 941-1 LONG TERM VEHICLE STORAGE TANKS 943-1

944-1 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 2270 2261 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

OVER CASH AVENUE AVENU E 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 PA TROL 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)

W ASHINGTON 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 (RE SO URCE) URCE ) EAST PATROL ROAD (RESOURCE)

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

EAST PATROL ROAD (RESOURCE)

ROL

R OAD (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 2-4 1
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 E W 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



# LEADLetterkenny 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 FOSTLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FinalMK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC9/9/20032-1Table 1Property Description of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PAParcelNo.BuildingNo.Property Description(Area in sq. ft.)Parcel Area(Acres)YearBuiltEBS ParcelIDaConditionCategorybRemedial Actions3-89 522 Administration – Office(7,896)191 1942 12(5)HR1None3-89 523 Office (6,400) 191 1943 12(5)HR1None3-89 527 Emergency Generator (263) 191 1988 12(5)HR1None3-89 528 Swimming Pool Filter Room(60)191 1945 21(7)HR1None3-89 529 Community Club (10,903) 191 Unknown(renovated1942)19(5)HR1None3-89 530 Information Processing Center(1,045)191 1985 38(7)HR1None3-89 532 Golf Cart StorageMaintenance Building(3,600)/Former UncurbedAST at Building 532 site191 199119(5)HR37(7)PS(Former ASTsite)1None3-89 536 Locker Room (2,000) 191 1942 21(7)HR1None3-89 539 Guest/Temp Housing (2,830) 191 Unknown(renovated1943)38(7)HR1None3-89 540 Housing – Kenny Hill (2,542) 191 1954 12(5)HR1None3-89 541 Housing – Kenny Hill (1,660) 191 1954 12(5)HR1None3-89 542 Housing – Kenny Hill (1,660) 191 1954 12(5)HR1NoneLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FinalTable 1Property Description of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC9/9/20032-2ParcelNo.BuildingNo.Property Description(Area in sq. ft.)Parcel Area(Acres)YearBuiltEBS ParcelIDaConditionCategorybRemedial Actions3-89 543 Housing – Kenny Hill (1,660) 191 1954 12(5)HR1None3-89 544 Housing – Kenny Hill (1,660) 191 1954 12(5)HR1None3-89 545 Housing – Kenny Hill (2,542) 191 1954 12(5)HR1None3-89 546 Storage (864) 191 1973 12(5)HR1None3-89 554 Water Treatment Plant (2,803) 191 1957 21(7)HR1None3-89 558 Water Treatment Plant –Emergency Pump Building(1,643)191 1953 21(7)HR2In 1991 contaminated soilsfrom a UST release wereremediatedc3-89 559 Water Treatment Plant –Chlorinator Building (245)191 1968 21(7)HR1None3-89 572 Storage – Fire Dept (86) –located in Open VehicleStorage Area (OVSA) site191 1982 13(7)PS/PR1, 4None for the building - seeOVSA site belowd3-89 N/A Water tower 191 39(7)HR1None3-89 N/AOpen Vehicle Storage Area(OVSA) site191 N/A 13(7)PS/PR,33(7)HR,21(7)HR,19(5)HR4Soils contaminated withPAHs were found duringthe RI and were remediatedin 2000d3-89 N/ABackwash Discharge Areafrom the Water TreatmentPlant site191 N/A 33(7)HR1None3-90 N/A Open area 8.2 N/A 19(5)HR1NoneLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FinalTable 1Property Description of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC9/9/20032-3ParcelNo.BuildingNo.Property Description(Area in sq. ft.)Parcel Area(Acres)YearBuiltEBS ParcelIDaConditionCategorybRemedial Actions3-91 N/A Building 400 Series FireTraining Area (FTA) site(Open area)1.5 N/A 44(7)HR/PR1None3-92 N/A Reservoir 129 1957 N/A1None2-53L N/A Subsurface portion of Phase IIParcel 2-5310.1eN/A 21(7)HR1None2-54L N/A Subsurface portion of Phase IIParcel 2-546.6eN/A 12(5)HR,21(7)HR1None2-70L N/A Subsurface portion of Phase IIParcel 2-702.3eN/A 12(5)HR1None2R-80L3N/A Subsurface portion of part ofPhase II road Parcel 2R-806.0eN/A 12(5)HR,21(7)HR1None2R-84L3N/A Subsurface portion of part ofPhase II road Parcel 2R-840.6eN/A 12(5)HR1None2R-86L3N/A Subsurface portion of part ofPhase II road Parcel 2R-862.6eN/A 19(5)HR1NoneLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FinalTable 1Property Description of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC9/9/20032-4Notes: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.aEnvironmental Baseline Survey parcel identification (ID) (fromthe Community Environmental Response Facilitation Act [CERFA] ParcelDesignation) (WESTON, 1997). Note that at the time of the CERFAReport, the groundwater was assumed to be contaminated, andtherefore, these parcels had an HR associated with the EBS parcel designation.bU.S.Department of Defense (DoD) Environmental Condition of Property (ECP) Category number. ECP categories are defined in the AMCFOST/FOSL Guidance (AMC, 2000).Category 1:Areas where no release or disposal of hazardous substances or petroleum products has occurred (includingno 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 ofhazardous substances has occurred, and all removal orremedial actions to protect human healthand the environment have been taken.cIn 1991, a gasoline UST was removed and there was evidence of arelease to soils. Contaminated soils were excavated to bedrock in1991. The groundwater was not affected. The soil removal andgroundwater investigation was documented in a 1992 report:USTClosure at Building 558, Letterkenny Army Depot, Chambersburg, Pennsylvania(SS&McC, 1992). Closure was approved by thePennsylvania Department of EnvironmentalProtection (PADEP), documented in a letter from F.W. Noll of PADEP to B. Hoke ofLetterkenny Army Depot (PADEP, 2000).The reports detailing the tank closures and the correspondence from PADEP approvingthe remedial measures and investigations completed are in the UST files at LEAD.dResults of the RI for soil conducted in 1998 through 2000 indicatedthat there was a release of polycyclic aromatic hydrocarbons (PAHs)(a group of semivolatile organic compounds [SVOCs]) due to paststorage activities. The data from the investigations showed possibleunacceptable levels of risk based on the commercial/industrial usescenario associated with elevated levels of PAHs in soil.Removalaction alternatives were developed and evaluated for a non-time-critical removal action in an Engineering Evaluation/Cost AnalysisLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FinalTable 1Property Description of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_2.DOC9/9/20032-5document (WESTON, 2000a). The non-time-critical removal action was implemented from July to November 2000 (IT, 2001). Thisremoval action consisted of excavating PAH-contaminated soils and disposing of themin EPA and state-approved off-site commercialdisposal facilities. The risk assessment completed after the removal action showed thatthere are no longer environmental concerns at thesite, meaning that there are no longer unacceptable risks to people and the environmentundercommercial/industrial, agricultural,orresidential usescenarios, as documented in the remedial investigation/risk assessment report (WESTON, 2003c).eAcreage 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 PARCELSLetterkenny 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 substa nces for 1 year or more in quantities greater than or equal to 1, 000 kilograms or the hazardous subs tance’s CERCLA reportable quantity (whichev er is greater). In addition, it provides information on the known release of hazardous substa nces in quantities greater than or equal to the quantities referenced in 40 CFR Part 373.

b Hazardous substances were noted during the EBS visu al 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 20 00 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-criticalremoval 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 di sposing of them in EPA and state-approved off-site commercial disposal facilities. The risk assessment comp leted after the removal acti on showed that there are no longer environmental concer ns 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 CodeLetterkenny 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 4

TABLE 3 NOTIFICATION OF PETROLEUM PRODUCT STORAGE, RELEASE, AND/OR DISPOSAL AT PHASE III PARCELSLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_4.DOC 9/9/2003 

### 4-1 Table 3

Notification of Petroleum Product St orage, 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/Disposal a 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 St orage, Release, and/or Disposal, Phase III Parcels, Letterkenny Army Depot, Chambersburg, PA (Continued)

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_4.DOC 9/9/2003 

### 4-2 Building No. Parcel No. Name of Petroleum Product Date and Type of Storage/Release/Disposal a 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 St orage, Release, and/or Disposal, Phase III Parcels, Letterkenny Army Depot, Chambersburg, PA (Continued)

MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_4.DOC 9/9/2003 

### 4-3 Building No. Parcel No. Name of Petroleum Product Date and Type of Storage/Release/Disposal a 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 a ffected. The soil removal a nd groundwater investigation was documented in a 1992 report: UST Closure at Building 558, Letter kenny 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 reme dial measures and inve stigations completed are in the UST files at LEAD.
AMC = Army Materiel Command. AST = Aboveground storage tank. UST = Underground storage tank.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

## ENCLOSURE 5

APPENDIX A SUMMARY OF PARCEL AND BUILDING CONDITIONS, FOST FOR THE PHASE III BRAC PARCELSLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### A-1 

## 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 P hase 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) Ar ea. 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 genera l description of the parcel, prior and current condition of the parcel/buildin gs (based on observations noted at the time of the Environmental Baselin e Survey [EBS]), a list of buildings associated with the parcel, and othe r 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 afte r 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 th e EBS visual survey. However, an EBS visual survey does not constitu te 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.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-2 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 buildin gs/structures are presented in the following subsections. Locations of th e buildings are shown in Figure 1 of Enclosure 1.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-3 B UILDING 

### 522 (A DMINISTRATION 

### O FFICE 

### ) Building 522 has two floors of office space and a basement, which is a communications command center. Build ing 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, pi pe insulation, transite board, floor tile, and mastic as ACM. Pipe insulati on, 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.

B UILDING 

### 523 (O FFICE 

### )
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.

B UILDING 

### 527 (E MERGENCY 

### G ENERATOR 

### B UILDING 

### )
Building 527 houses an emergency gene rator 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.

B UILDING 

### 528 (S WIMMING 

### P OOL 

### F ILTER 

### B UILDING 

### )

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.

B UILDING 

### 529 (C OMMUNITY 

### C LUB 

### )

Building 529 is the Community Club for the golf course. Building 529 was originally a barn (of unknown construc tion date) that has been extensively renovated (original renovation date was 1942). There are two stories: the first floor consists of a lounge, kitc hen, and pro-shop; the second floorLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### A-4 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 t ile, 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.

B UILDING 

### 530 (I NFORMATION 

### P ROCESSING 

### C ENTER 

### )
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, ra don, and LBP have not been evaluated at Building 530.

B UILDING 

### 532 (G OLF 

### C ART 

### S TORAGE 

### M AINTENANCE 

### B UILDING 

### )
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 nort h 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.

B UILDING 

### 536 (L OCKER 

### R OOM 

### )

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.

B UILDING 

### 539 (G UEST AND 

### T EMPORARY 

### H OUSING 

### )
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 co mpound, refractory cement, floor tile, and mastic as ACM. LEAD records indica te some pipe insulation had been removed as part of the ACM abatement program.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-5 Sampling conducted in 1989 indicated a radon level of 1.6 pCi/L atApartment 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 consider ed a residential dwelling like Kenny Hill and the other full-time use milit ary 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. Th e building was not used for housing children and the lengths of stay for guests consisted of only weekends or several days. In addition, the bu ilding is being transferred for industrial/commercial use and will not be used as residential housing.

B UILDINGS 

### 540

– 545 (K ENNY 

### H ILL 

### H OUSING 

### U NITS 

### )
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 consiste d of a reconnaissance of the entire outside area, along with interior insp ections of vacant units (Unit 102 in Building 545 and Unit 104 in Building 543). The units were generally in fair physical condition. Potential environm ental liabilities identified during the building inspection included LBP, su spect 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 conducte d 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-rayLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### A-6 fluorescence (XRF) analyzer. Some of the samples tested indicated lead concentrations exceeding the EPA an d U.S. Department of Housing and Urban Development (HUD) LBP stan dard of 1 milligram per square centimeter (mg/cm 2 

### ) 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 conditio n 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 un its 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 proble ms, or Notices of Violation were identified in the files for the Kenny Hill property. No PCB transformers (or other transformers) or oil/water separato rs 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 remo ved on a case-by-case basis during maintenance or repair activities, wi th 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.

B UILDING 

### 546 (S TORAGE 

### B UILDING 

### )
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.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-7 B UILDING 

### 554 (W ATER 

### T REATMENT 

### P LANT 

### )
Building 554, the water treatment plant bu ilding, is located in the SE Area at LEAD. Built in 1957, Building 554 consists of two floors and is constructed with a concrete foundati on 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 filt er 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.

B UILDING 

### 558 (E MERGENCY 

### P UMP 

### B UILDING FOR 

### W ATER 

### T REATMENT 

### P LANT 

### )
Building 558 houses the emergency pumps (diesel-powered) for the water treatment plant. Building 558 was bu ilt 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 re placed 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 un known exit paths noted during the visual survey. An asbestos surv ey 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).

B UILDING 

### 559 (C HLORINATOR 

### B UILDING FOR 

### W ATER 

### T REATMENT 

### P LANT 

### )
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 fo undation, 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.

B UILDING 

### 572
Building 572 is a small storage building constructed in 1968 and is normally used by the fire department for storag e of fire extinguishers for emergencyLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### A-8 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 I NVESTIGATION 

### A REAS


### Based on the findings of the EBS, seve ral study areas within this parcel underwent soil, drainageway, and groundwater investigations to determine their environmental condit ion. 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 remo val action, or conduct no further action at the site, as indicated here:

OVSA Site (Defense Site Environm ental 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 activiti es were performed at various periods between October 1998 and November 2000 to investigate soil, sediments, and groundwater, and th en additionally in November 2002 (groundwater sampling). The results of the remedial investigation for soil indicated possible unacceptable risks a ssociated with elevated levels of a group of semivolatile organic compounds (SVOCs) referred to as polycyclic aromatic hydrocarbons (P AHs). Alternatives were developed and evaluated in the Engineering Ev aluation/Cost Analysis (WESTON, 2000a). A non-time-critical removal ac tion 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 ther e are no unacceptable levels of human health or ecological risks based on current and likely future commercial/industrial use, or reside ntial 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 AS T used for gasoline storage was located near Building 532. Field activi ties 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 una cceptable 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).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-9 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/in dustrial use, or residential use. No further actions are warranted (WESTON, 2002d).

SMSR I NVESTIGATION 

### A REA



### Phase III Parcel 3-89, as well as Parc els 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) wi thin LEAD (PDO OU 7 and SE OU 13). An investigation was conducted to evaluate the groundwater quality within the SMSR (underneath th e 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 ground water contamination evident in the SMSR. In addition, the study conclu ded that these source areas are located in low-lying valley areas un derlain by limestone bedrock where groundwater flows are away from the SMSR. Based on current conditions, the SMSR is topographi cally higher than surrounding areas and groundwater flows radially away from the SMSR. This situation protects the SMSR from the surroundi ng 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, Enclosur e 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 st orage 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). Ther e are no structures on Parcel 3-91. This parcel is currently open land and consists of a BRAC investigationLetterkenny 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 Trai ning 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 th e 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 trai ning area where a large metal pan was placed on the ground and filled wi th 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 una cceptable 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 approxim ately 129 acres located north of LEAD approximately 2 miles west of the to wn of Roxbury (Figure 2, Enclosure 1). The 300-million-gallon Letterkenny Reservoir is located within this parcel. The reservoir began supplyi ng water to LEAD in 1957, and it supplies all the potable and industri al water to LEAD. There are no buildings associated with this proper ty. 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 fr om 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 wasLetterkenny 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) FinalMK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_5.DOC9/9/2003A-12Table A-1Summary of Building Conditions of Phase III BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PAAsbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L) LBP Survey UST ASTReported Spills,RadiologicalSources, andOtherCommentsb522 3-89, 1 CINS, PINS, TILE,TRAN, MASTTILE, PINS,TRANNO 0.5-1.8 NE 2,000 gal HO NO Hydraulic fluid8/96 < 1 gal –soils collected fordisposal, NFA;gasoline 12/97approx. 10 gal –used speedi dri toclean up at time ofrelease.523 3-89, 1 PINS, TILE, MAST NO NO 0.7-1.2NEcNO NO527 3-89, 1 NE NO NO NE NE 2,500 galDiesel T(2000)NO528 3-89, 1 NE NO NO NE NE NO NO529 3-89, 1 TILE, PINS,MAST, TRANTILE, PINS,TRANNO 0.3-1.0 NE 3,000 gal HO 100 gal Propane530 3-89, 1 NE NO NO NE NE NO NO532 3-89, 1 NE NO NO NE NE NO NO536 3-89, 1 NE NO NO NE NE NO NOLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) FinalTable A-1Summary 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.DOC9/9/2003A-13Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L) LBP Survey UST ASTReported Spills,RadiologicalSources, andOtherCommentsb539 3-89, 1 REFC, SPAC,MAST, TILE,PLASTER, PINSPINS NO 1.6 – 5.0(1990)d0.2 – 2.8(1995)dNE NO 2 x 275 gal HO540 3-89, 1 TILE, MAST NONO 1.0-1.9 YES – GCLBP soilassessment –no releases tosoile500 gal HOT (1996)NO Evidence of someminor fillpipeoverflows – soilswere removed attime of release,NFA.541 3-89, 1 TILE, MAST NONO 2.5 YES – GCLBP soilassessment –no releases tosoileNO 500 gal HO542 3-89, 1 TILE, MAST TINS NO 1.2 YES – GCLBP soilassessment –no releases tosoileNO 500 gal HO #2 Fuel oil spill(53 gal) 5/94when filling AST– affected soilremoved anddeposed of at timeof release, NFA.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) FinalTable A-1Summary 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.DOC9/9/2003A-14Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L) LBP Survey UST ASTReported Spills,RadiologicalSources, andOtherCommentsb543 3-89, 1 TILE, MAST TINS NO 3.3 YES – GCLBP soilassessment –no releases tosoileNO500 gal HO544 3-89, 1 TILE, MAST NONO 2.7 YES – GCLBP soilassessment –no releases tosoileNO 500 gal HO545 3-89, 1 TILE, MAST NONO 1.5-1.9 YES – GCLBP soilassessment –no releases tosoile500 gal HOT (1996)NO Evidence of someminor fillpipeoverflows – soilswere removed attime of release,NFA.546 3-89, 1 NE NO NO NE NE NO NO554 3-89, 1 PFIT, PINS,TRAN, TILE,MAST, TINSTINS, PINS,boilerinsulationNO 1.0 NE 2,000 gal HOT (1996)NOLetterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) FinalTable A-1Summary 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.DOC9/9/2003A-15Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L) LBP Survey UST ASTReported Spills,RadiologicalSources, andOtherCommentsb558 3-89, 2 NO NO NO NE NE 1,000 gal HOT (1996)2 x 200 galDieselConfirmed releasefound whenremoving gasolineUST in 1991 -PADEP wasnotified. Affectedsoil was removed.No groundwatercontaminationfound.f559 3-89, 1 NO NO NO NE NE NO NO572 3-89, 1 and4NE NO NO NE NE NO NO Category 4 is forthe OVSA site –Building 572 islocated within theOVSA area.Notes:aECP categories determined using AMC FOST/FOSL Guidance (AMC, 2000):Category 1 = Areas where no release or disposal of hazardous substances or petroleum productshas occurred (including no migration of thesesubstancesfrom 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) FinalTable A-1Summary 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.DOC9/9/2003A-16Category 4 = Areas where release, disposal,and/or migration of hazardous substances has occurred, and all removal or remedialactions to protect humanhealth and the environment have been taken.bThis column includes some spills that are not listed in Table 2 (Enclosure 3) or Table 3 (Enclosure 4). These spills do not meet the requirement as reportableunder CERCLA (see note in Table 2) or are less than 55 gal for petroleum substances (AMC policy). However, these spills have been provided to the Granteefor additional information purposes.cA complete LBP survey has not been conducted at Building 523. However, one lead paint sample collected in 1994 indicated a lead concentration of 8.1%.Thesample location or the exact type of paint sample is unknown.dSampling conducted in 1989 indicated a radon level of 1.6 pCi/L atApartment 02, and 5.0 pCi/L in the basement, which was abovethe EPA-recommended actionlevel 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 forBuilding 539 because the basement is not accessible from the houseand the cracks in the basement have been sealed. Sampling conducted in 1995 at two of the apartments and the basement in Building 539 indicated radon levelsranging from 0.2 to 2.8 pCi/L, which are below the EPA-recommended action level.eAs part of the lead-based paint risk assessment completed asspecified in the Memorandum of Agreement between the Department of the Army and theLetterkenny Industrial Development Authority (LIDA, 1998), soil sampling was conductedin bare soil areas adjacent to the KennyHill housing units. Leadconcentrations in soil were less than EPA and PADEP criteria and no further action is necessary (WESTON, 2003e).fIn 1991, a gasoline UST was removed and there was evidence of a release to soils. Contaminated soils were excavated to bedrock in 1991. The groundwaterwas not affected. The soil removal and groundwaterinvestigation were documented in a 1992 report:UST Closure at Building 558, Letterkenny Army Depot,Chambersburg, Pennsylvania(SS&McC, 1992). Closure was approved by the Pennsylvania Department of Environmental Protection (PADEP), documented ina letter from F.W. Noll of PADEP to B. Hoke of Letterkenny Army Depot (PADEP, 2000). The reports detailing the tank closures and the correspondencefrom 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) FinalTable A-1Summary 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.DOC9/9/2003A-17NFA = No further action necessaryTANKSAST = Aboveground storage tank.G = Gasoline.gal = Gallons.HO = Heating oil.NE = Not evaluated.NO = Not present.T(date) = Tank tightness tested, which means passed integritytest (date of test).UST = Underground storage tank.PCBNO = 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 cementSPAC = Spackle/joint compound.TILE = Floor tile.TINS = Tank insulation.TRAN = Transite board.VINYL = Vinyl flooring.WALL = Wall board.LBP SURVEYGC = Paint in good condition.LBP = Lead-based paint.NE = Not evaluated/not surveyed.ppm = Parts per million.Yes = Survey completed; LBP identified.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 TRANSF ER — RESULTS OF FINAL VISUAL SURVEYSLetterkenny 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 A ND PARCEL CONDITIONS, PHASE III PROPERTY TRANSF ER — 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 walkthroug h visual surveys of th e Phase III buildings and parcels. The purpose of the vi sual surveys was to assess the current conditions of the Phase III buildings and parcels. Particular attention wa s 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 accessibl e 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., crawls paces, 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), pr esence 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 bu ildings 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 Findingof Suitability to Transfer (FOST)FinalMK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-2Table 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PAParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 522Administration –Office (7,896)1942Ceiling tile mastic and dustabove ceiling tilesthroughout building; most isabove existing drop ceiling.Steamline pipe insulation –removal done but some mayremain in-place.9 x 9 floor tile and mastic—inupper floors (undercarpeting) and in basement.Transite board/cementasbestos board – NE cornerfirst floor behind gypsumwallboards/wood paneling.Good conditioninside; good to faircondition outside.2,000-galUST - HOYesa3-89 523Office (6,400)19439 x 9 floor tile and masticthroughout building.Pipe insulation – appears tohave been replaced withblack foam, some remains incrawlspace.Fair to poorcondition inside(some areas ofpeeling paint); poorcondition outside(excessive peeling).No NoLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-3ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 527Emergency Generator(263)1988No ACM based on yearbuilt.N/A based on yearbuilt.2,500-galUST – DieselNo3-89 528Swimming Pool FilterRoom (60)1945Not suspected.Fair to poorcondition.No No3-89 529Community Club(10,903)Unknown(initiallyrenovatedby Armyin 1942)9 x 9 tile/mastic — airhandler room and possiblysome remaining throughoutbelow carpet.Mastic below 12 x 12red/white tile in first floorcorridor. Site recordsindicate pipe insulationremoved – no remainingpipe insulation noted.Good conditioninside, somepeeling/chipped inlocalized areas. Fairto poor conditionoutside (peelingand chipped areason trim and doors).3,000-galUST – HO100-gal AST– PropaneNo Pieces of damaged/loose transite boardon ground and onoutside of door northside of boiler roomremoved prior toproperty transfer.Letterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-4ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 530InformationProcessing Center(1,045)1985No ACM based on yearbuilt.N/A based on yearbuilt.No No3-89 532Golf Cart StorageMaintenance Building(3,600)/FormerUncurbed AST Northof Building 532 Site1991No ACM based on yearbuilt.N/A based on yearbuilt.No No3-89 536Locker Room (2,000)1942Not suspected.Good to faircondition insideand outside; somelocalized areas ofpeeling/chippedpaint.No NoLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-5ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 539Guest/TemporaryHousing (2,830)Unknown(renovatedby Armyin 1943)Refractory cement in boilerroom in basement.Spackle/joint compound inwashroom (underwallpaper) and throughoutapartment 3.Vinyl floor backing (greenvinyl floor under tan vinylfloor and tan vinyl floor inseveral locations).Wall plaster in apartment 2(mostly covered withwallpaper).9 x 9 floor tiles/masticthroughout apartment 3(under carpet).Good to faircondition insidewith some localizedareas of peelingpaint. Fair to poorcondition outsidewith some areas ofexcessive peelingpaint on porch,trim, and doors.500-gal AST– HO(basement)No Radon detectedabove criteria in 1990but below criterionin 1995 followingabatement.b3-89 540(Units107 and108)Housing – Kenny Hill(2,542)19549 x 9 tile/mastic throughout— most covered by carpets(except air handlerroom/some closets).Good to faircondition inside.Outside faircondition withsome peeling ondoors and 2ndfloorwindows.500-gal UST– HO (frontyard)(T, 1996)YesbLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-6ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 541 (Unit106)Housing – Kenny Hill(1,660)19549 x 9 tile/mastic throughout— most covered by carpets(except air handler room).Good to faircondition inside.Outside faircondition withsome peeling ondoors and 2ndfloorwindows.500-gal AST— HONo3-89 542 (Unit105)Housing – Kenny Hill(1,660)19549 x 9 tile/mastic throughout— most covered by carpets(except air handlerroom/some closets).Good to faircondition inside.Outside fair to poorcondition withsome peeling onporch/steps, doors,and 2ndfloorwindows.500-gal AST—HOYesa3-89 543 (Unit104)Housing – Kenny Hill(1,660)19549 x 9 tile/mastic throughout— most covered by carpets(except air handlerroom/some closets).Good to faircondition inside.Outside fair to poorcondition withsome peeling onporch/steps, doors,and 2ndfloorwindows.500-gal AST– HO (pipestickup inground atside ofbuildingmay indicateold USTabandonedin-place)NoLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-7ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 544 (Unit103)Housing – Kenny Hill(1,660)19549 x 9 tile/mastic throughout—most covered by carpets(except air handler room).Good to faircondition inside.Outside fair to poorcondition withsome peeling onporch/steps, doors,and 2ndfloorwindows.500-gal AST— HONo3-89 545(Units101 and102)Housing – Kenny Hill(2,542)19549 x 9 tile/masticthroughout— most coveredby carpets.Duct connection cloth inutility room – appears that itmay have been replaced.Good to faircondition inside.Outside fair to poorcondition withsome peeling onporch/steps, doors,and 2ndfloorwindows.500-gal UST— HOYesa3-89 546Storage (864)1973Not suspected.Paint on doorspeeling.No NoLetterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-8ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 554Water Treatment Plant(2,803)19579 x 9 tile and mastic northside of second floor.Pipe insulation throughout –removals andrepairs/encapsulations havebeen done in past – appearsto have been replaced butsome may still remain inplace.Transite/cement boards(hallway board – may havebeen replaced).Inside good to faircondition - someisolated areas withpeeling/chippedpaint. Outside fairto poor (areas ofpeeling paint).2,000- galUST – HO(T, 1996)No Aluminum sulfateand lime stored/used by LIDA’scontractor forpotable watertreatment; buildingleased by LIDA.3-89 558Water Treatment Plant(1,643)1953None identified from pastsampling.Fair to poorcondition insideand outside.1,000-galUST – HO(T, 1996)2 x 200-galAST—DieselYes Zinc orthophosphate, sodiumhydroxide, andaluminum sulfatestored/used byLIDA’s contractor forcorrosion control andpotable watertreatment; buildingleased by LIDA.Letterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-9ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-89 559Water Treatment Plant(245)1968None identified from pastsampling.Paint fair condition. Chlorinestored/used byLIDA’s contractor forpotable watertreatment; buildingleased by LIDA.3-89 572Storage – FireDepartment (86)1982No ACM based on yearbuilt.N/A based on yearbuilt.NocOVSA sitec3-89 N/AWater tower2001 No ACM based on yearbuilt.N/A based on yearbuilt.No No3-89 N/AOpen area that isbalance of Parcel 3-89(includes BackwashDischarge Area fromthe water treatmentplant and the OVSAcsites)N/A N/A N/A No No No buildings orstructures exist onthis portion of theparcel.Letterkenny Army Depot Phase III Finding ofSuitability to Transfer (FOST) FInalTable 6-1Summary of Current Building and ParcelConditions and Results of Final Visual Surveys, Phase III Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)MK01|O:\02281016.008\PHASEIIIFOST\PHASEIIIFOST_ENCL_6,8,9.DOC09/09/036-10ParcelNo.BuildingNo.Description(Square Footage)Year Built Accessible ACM Condition of LBPStorageTanks Spills Comments3-90 N/AOpen areaN/A N/A N/A No No No buildings orstructures exist onthis parcel.3-91 N/AOpen area/Building400 Series FireTraining Area siteN/A N/A N/A No No No buildings orstructures exist onthis parcel.3-92 N/A Reservoir N/A N/A N/A No No No buildings orstructures exist onthis parcel.aThese spill incidents are documented in the building discussions.This column includes some spills that are not listed in Table2 or 3. These spills do not meet the requirement asreportable under CERCLA (see note in Table 2)or are less than 55 gal for petroleum substances (AMC policy). However, these spills have been provided to the Grantee foradditional information purposes.bRadon was detected above 4 pCi/L, which isan EPA residential action level; thereis 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 wherethere were releases that resulted in a removalaction.N/A = Not applicable or none present.TANKSAST = 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 PROVISIONSLetterkenny 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 Comprehens ive 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 th e 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 subse quently addressed under the Installation Restoration Program. For the purpose of this Deed, "hazardous substa nces" 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 subs tances 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 h azardous 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 da ted 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 Pr operty 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 da te of this conveyance shall be conducted by the GRANTOR. This covenant in this Sub section 1(A)(2) shall not apply in any case in which the person or entity to whom the Propert y is transferred is a potentially responsible party under CERCLA with respect to the Property.

2. CERCLA REMEDIATION

The GRANTOR acknowledges that Lette rkenny Army Depot (LEAD) has been identified as a National Priorities List (NPL) site under the Comprehens ive 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 Fe bruary 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, a nd the provisions of this pr operty 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 implementati on 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 interfe rence, provided the GRANTOR complies with the requirements of Section 2(D).

B. Prior to the determination by the United Stat es that all remedial action is complete under CERCLA and the FFA for the LEAD site:Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 7-2 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, ta king 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, sha ll 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 du ties 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 GR ANTEE, its successors and assigns, shall provide:

1. Pretransfer Notice—60 days written notice of an y such conveyance (including a description of the deed/lease provisions allowing for continued re mediation activities) to the GRANTOR, the U.S. Environmental Protection Agency (EPA), and the Penn sylvania Department of Environmental Protection (PADEP); and

2. Deed/Lease—Within 14 days after the eff ective 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 environmen tal 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 fo r in the Deed. This easement and right of access shall be binding on the GRANTEE, its successors a nd 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 reaso nable means, without significant additional cost to the GRANTOR, to avoid and/or minimize interfe rence with the use of the Property.

E. The GRANTOR shall not incur liability for additiona l 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 substan ce 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 reme dial 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,Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 7-3 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 dwelli ng was built prior to 1978 is notified that such property may present exposure to lead from lead-base d 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 inte lligence 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 Propert y" 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 pers ons with disabilities (unless an y 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 include d in the definition of "Residential Real Property" and means a building, or portion of a building, constr ucted prior to 1978, visited regularly by the same child, less than 6 years of age, on at least two differe nt 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 pain t 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 GRAN TEE. All purchasers must receive the Federallyapproved pamphlet on lead poisoning prevention. Th e GRANTEE hereby acknowledg es receipt of all of the information described in this subp aragraph. 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 a nd/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 us e of any buildings or structures on the Property as Residential Real Prope rty without complying w ith this section and all applicable Federal, state, and local laws and regula tions pertaining to lead-based paint and/or lead-based paint hazards. Prior to permitting the occupancy of th e Property where its use subsequent to sale is intended for residential habitation, the GRANTEE specifi cally agrees to perform, at its sole expense, the Army's abatement requirements under Title X of th e Housing and Community Development Act of 1992 (Residential Lead-Based Paint Hazard Reducti on Act of 1992) (hereinafter Title X).

The GRANTEE shall, after consideration of the guide lines and regulations established pursuant to Title X: (1) perform a risk assessment if more than 12 m onths have elapsed since the date of the last risk assessment; (2) comply with the joint U.S. Depart ment 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-bas ed 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 paragra ph A, above, in accordance with the procedures in 24 CFR 35; (4) abate soil-lead hazards in pre-1978 Reside ntial 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 wh en 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-Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 7-4 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 l ead-based paint hazards on the Property found to be necessary as a result of the subsequent use of th e 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 l ead-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, a nd shall be deemed to run with the land. The GRANTEE on behalf of itself, its successors and assigns , covenants that it will in clude 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 acknowle dge that friable and nonfriable asbestos or asbestos-containing materials ("ACM") has been foun d 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 thr eat to human health or the environment, and all friable asbestos that posed a risk to human hea lth has either been removed or encapsulated.

B. The GRANTEE covenants and agrees that its u se and occupancy of th e Property will be in compliance with all applicable laws relating to asbest os; 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, includ ing members of the general public, arising from or incident to the purchase, transportation, removal, ha ndling, 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 re mediation 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 H ealth 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, ta nks, ducts, or other structural components to prevent heat loss or gain).

• Spray-on texture surfacing/fireproofing (i.e., mate rial 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.Letterkenny Army Depot Phase III Finding of Suitability to Transfer (FOST) Final

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

### 7-5 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 associ ated with exposure to airborne asbestos fibers. Both OSHA and EPA have determined that such expo sure 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 cond itions 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 limita tion, 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 agre es 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, Secti on 8.9.4, dated 1999, prohibits wa ter drilling. In addition, the GRANTEE is hereby notified that the Greene Township Code, Section 85-52, Pa ragraph F, dated March 26, 2002, requires the subdivider or developer of an y proposed subdivision within 500 feet of any public water system of a public water supplier to design an d install a complete water system, which shall be connected to said water system.

6. STATUTORY INDEMNIFICATION

Subject to the availability of appropriated f unds, the GRANTOR recognizes its obligation to hold harmless, defend, and i ndemnify the GRANTEE and any successor, assi gnee, transferee, lender, or lessee of the GRANTEE or its successors and assigns as requ ired 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 containe d herein, and shall require the inclusion of such environmental protection provisions in all further deed s, transfers, leases, or grants of any interest, privilege, or license.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 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



### South central 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: 7 

### I7 -705-4 705 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 of Suitability 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 of the comments, or you have questions, please do not hesitate to call me at 215-814- 2664.

These comments arc based on review of the draft FOST, without any independent investigation or verification of the 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 

### of Section 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 of the 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 of the property? If so, cite them here.



### Response: The references mentioned in the second paragraph of Section 3 

### and additional references listed in Enclosure 8 

### are all meant to be references providing current information related to the environmental condition of the property. The jlrst sentence was revised as follows to clarifY this: "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 (CERF A) 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 of lime 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

MKO 1 iO: 102281 0 16 -008\PHASEIIIF osnPHA8EIII faST

_ ENCL 3RT CS, DOC 712312003

### 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 of asbestos prior to transfer for 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 of the 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 ACM for the Phase III buildings is consistent with DoD policy (DOD, 1994) 

### and Army regulation (Army, 1997) 

### for BRAC properties." The DoD policy and Army regulation call for reasonably available information on the type, location, and condition of asbestos in buildings and the documents note that special studies or tests 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 inspections for those buildings where afull survey was not performed.

For the second part of the 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 of the 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 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. "

MKO 110:\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.

MKO 1/0:\02281 0 16.008\PHASEIlIFOSTIPHASEIIIFOST _ENCL_ 8ATGS. DOC 

### 3 7/1612003Letterkenny 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 9

REFERENCES AND BIBLIOGRAPHYLetterkenny 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 

### 9-1 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 Contaminatio n 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 Frank lin County, Pennsylvania. Pennsylvania Geological Survey Water Resources Report 53. Ha rrisburg, 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

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

### 9-2 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 O ffice Area at Letterkenny Army Depot. Final Report.

ESE (Environmental Science & Engineering, Inc.). June 1993b. Risk Assessment of the Property Disposal Office Area at Letterke nny 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 Truck Open Storage Area and Waste Oil Sum p, Letterkenny Army Depot, Chambersburg, Pennsylvania.

Geonex Corporation. August 1995. Draft Wetlands Mapping Report for United States Army, Letterkenny Army Depot.

IT (IT Corporation). 2001. Property Disposal Office Area Operable Unit 6 Southeast Area, Operable Unit 8 – Removal Action Completion Report PAH-Contaminated Soils atLetterkenny 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 

### 9-3 the Open Vehicle Storage Area (OVSA) , Letterkenny Army Depot, Chambersburg, Pennsylvania. Final. May 2001.

John Milner Associates. 1981. An Archaeological Reconnaissance of Proposed Development Sites at the Letterkenny Army Depot.

Kaselaan & D’Angelo Associates. 1987. Asbestos Exposure Assessment with Corrective Action Alternatives and Construction Cost Estimates at the Letterkenny Army Depot, Chambersburg, Pennsylvania.

Kearney, A.T. and The Earth Technol ogy Corporation. February 1988. RCRA Facility Assessment Phase I Preliminary Review of Solid Waste Management Units.

LIDA (Letterkenny Industrial Development Authority). 1998. Memorandum of Agreement between the Department of the Army and Letterkenny Industrial Development Authority for the Transfer of a Portion of Letterkenny Army Depot, Pennsylvania

. November 1998.

Nature Conservancy, Pennsylvania Science Office. December 1992. An Inventory of Significant Ecological Features of the Le tterkenny Army Depot, Franklin County, Pennsylvania.

NRC (Nuclear Regulatory Commission). 1993. Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material.

NRC (Nuclear Regulatory Commission). 1992. Manual for Conducting Radiological Surveys in Support of License Termination . NUREG/CR-5849.

PADEP (Pennsylvania Department of Envir onmental Protection). July 2000. Letter from F.W. Noll, Environmental Cleanup Program, PADEP to B. Hoke, BRAC Environmental Coordinator, Letterkenny Army Depot, Re: St atus of Former Storage Tank Areas Bldgs. #3, 423, 435, 558, 686, 1456, 3223, and 5647, 14 July 2000.

Pennsylvania State University (PSU) and Envirosphere Company. January 1985. An Archaeological Overview and Management Plan for the Letterkenny Army Depot.

R.E. Wright Environmental, Inc. March 1997. Draft Report for Building Investigations for Radon Recommendations, Letterkenny Army Depot.

R.E. Wright Environmental, Inc. July 1995. Radon Testing Plan, Letterkenny Army Depot.

R.E. Wright Associates, Inc. July 1994. Draft Report for Building Investigations for Radon Recommendations.

SS&McC (Spots, Stevens, and McCoy). December 1992. UST Closure at Building 558, Letterkenny Army Depot, C hambersburg, Pennsylvania.

Tetra Tech (Tetra Tech, Inc.). 2001. Integrated Natural Resources Management Plan for Letterkenny Army Depot, PA. Final. February 2001.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 

### 9-4 TNC (The Nature Conservancy), Pennsylvania Science Office. 1992. An Inventory of Significant Ecological Features of the Le tterkenny Army Depot, Franklin County, Pennsylvania. December 1992.

URS Greiner Woodward Clyde. April 1999. Phase I and II Environmental Site Assessment, Building 56 and Vehicle Storage Area, Letterkenny Army Depot, Chambersburg, Pennsylvania

. USACE (U.S. Army Corps of Engineers), Mobile District. January 1998. Final Environmental Assessment for BRAC 95 Dispos al and Reuse of Property at Letterkenny Army Depot, Chambersburg, Pennsylvania.

USAMC (U.S. Army Materiel Command). March 1998. Finding of No Significant Impact
, BRAC 1995 Disposal and Reuse of Prop erty at Letterkenny Army Depot, Chambersburg, PA. 11 March 1998.

USATHAMA (U.S. Army Toxic and Hazardous Materials Agency). 1980. Installation Assessment of Letterkenny Army Depot, Re port No. 161, Aberdeen Proving Ground, Maryland.

U.S. Department of Defense. Fall 1995. BRAC Cleanup Plan (BCP) Guidebook.

U.S. Department of Defense. 1995. DoD Base Reuse Implementation Manual.

U.S. Department of the Army. February 1987. Evaluation of Solid Waste Management Units.

U.S. Department of the Interior, National Park Service. 1992. Standards for Rehabilitation and Illustrated Guidelines for Rehabilitating Historic Buildings.

WESTON (Weston Solutions, Inc.). April 2003a. Proposed Plan for the Phase III Parcels, Letterkenny Army Depot. Final.

WESTON (Weston Solutions, Inc.). July 2003b. Record of Decision for the Phase III Parcels, Letterkenny Army Depot. Final.

WESTON (Weston Solutions, Inc.). April 2003c. Remedial Investigation and Risk Assessment Report for the Open Vehicle Storage Area (DSERTS Sites LEAD-110 and LEAD-114), Property Disposal Office (PDO) Area Operable Unit (OU) 6 and Southeastern (SE) Area OU 8, Letterkenny Army Depot. Final.

WESTON (Weston Solutions, Inc.). April 2003d. Summary Report on the Groundwater Quality in the Southern Martinsburg Shale Region, Letterkenny Army Depot. Final.

WESTON (Weston Solutions, Inc.). June 2003e. Lead-Based Paint Risk Assessment, Kenny Hill Housing Units, Letterkenny Army Depot. Final.

WESTON (Roy F. Weston, Inc.). 2002a. Finding of Suitability to Transfer (FOST) for the Phase II BRAC Parcels, Letterkenny Army Depot. February 2002.

WESTON (Roy F. Weston, Inc.). September 2002b. Remedial Investigation and Risk Assessment Report for the Form er Uncurbed AST Site North of Building 532, PropertyLetterkenny 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 

### 9-5 Disposal Office (PDO) Area Operable Unit (OU) 6, DSERTS Site LEAD-126, Letterkenny Army Depot . Final.

WESTON (Roy F. Weston, Inc.). September 2002c. Remedial Investigation and Risk Assessment Report for the Building 400 Seri es Fire Training Area (DSERTS Site LEAD118), Southeastern (SE) Area Operable Unit (OU) 8, Letterkenny Army Depot . Final.

WESTON (Roy F. Weston, Inc.). October 2002d. Remedial Investigation and Risk Assessment Report for the Backwash Discharge Area (DSERTS Site LEAD-011), Southeastern (SE) Area Operable Un it (OU) 8, Letterkenny Army Depot . Final.

WESTON (Roy F. Weston, Inc.). April 2001a. Asbestos Air Sampling Results for BRAC Buildings, Property Disposal Office (PDO) Area Operable Unit (OU) 6 and Southeastern Area (SE) OU 8, DSERTS Site LEAD-124, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). July 2001b. Record of Decision for the Phase II Parcels, Letterkenny Army Depot. Final.

WESTON (Roy F. Weston, Inc.). June 2000a. Engineering Evaluation/Cost Analysis for the Open Vehicle Storage Area Soils, Prop erty Disposal Office (PDO) Area Operable Unit (OU) 6 and Southeastern (SE) Area OU 8, Letterkenny Army Depot. Final.

WESTON (Roy F. Weston, Inc.). November 2000b. Supplement 1 to the Final Environmental Baseline Survey for Letterkenny Army Depo t, BRAC 95 Action

. WESTON (Roy F. Weston, Inc.). May 1999a. Addendum to the Environmental Baseline Survey for Letterkenny Army Depot.
WESTON (Roy F. Weston, Inc.). June 1999b. Historical Assessment of Radiological Activity at Letterkenny Army Depot

 Revision 1.
WESTON (Roy F. Weston, Inc.). 1998a. Historical Assessment of Radiological Activity at Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). August 1998b. Historical Assessment of Radiological Activity in Defense Logistics Agency Buildings at Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1997. CERFA Letter Report (Final), Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1996. Environmental Baseline Survey, Letterkenny Army Depot, BRAC 95 Action.

WESTON (Roy F. Weston, Inc.). 1984. LEAD Remedial Investi gation and Feasibility Study.