MANAGERS DESIGNERS/CONSULTANTS

®

Finding of Suitability to Transfer (FOST)

for Phase I Parcels

Letterkenny Army Depot

U.S. Army Corps of Engineers

Baltimore District

October 1998

98P-2716

LETTERKENNY

PENNSYLVANIA

CHAMBERSBURG,

ARMY DEPOT

BALTIMORE DISTRICT

Proud Past

 Dynamic Future

 Final
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FINAL

FINDING OF SUITABILITY TO TRANSFER

FOR PHASE I PARCELS

LETTERKENNY ARMY DEPOT

CHAMBERSBURG, PENNSYLVANIA

Prepared for

U.S. ARMY CORPS OF ENGINEERS

BALTIMORE DISTRICT

10 South Howard Street

Baltimore, Maryland 21201

and

LETTERKENNY ARMY DEPOT

1 Overcash Avenue

Chambersburg, Pennsylvania 17201

Prepared by

ROY F. WESTON, INC.

1 Weston Way

West Chester, Pennsylvania 19380-1499

October 1998

W.O. No. 02281-016-005-0006-00
FOST for Phase I Parcels at Letterkenny Army Depot

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TABLE OF CONTENTS

Title Page

1. PURPOSE ...................................................................................................................... 1-1

2. PROPERTY DESCRIPTION...................................................................................... 2-1

2.1 SITE OVERVIEW .......................................................................................................... 2-1

3. ENVIRONMENTAL CONDITION OF THE PROPERTY................................... 3-1

3.1 ENVIRONMENTAL CONDITION OF PROPERTY CATEGORIES..................... 3-1

3.2 HAZARDOUS SUBSTANCES .................................................................................... 3-1

3.3 PETROLEUM AND PETROLEUM PRODUCTS ..................................................... 3-2

3.3.1 Storage, Release, or Disposal of Petroleum Products ....................... 3-2

3.3.2 Underground and Aboveground Storage Tanks (UST/AST) ......... 3-2

3.4 PCB TRANSFORMERS ................................................................................................ 3-2

3.5 ASBESTOS...................................................................................................................... 3-2

3.6 LEAD-BASED PAINT .................................................................................................. 3-3

3.7 RADIOLOGICAL SOURCES OF CONTAMINATION .......................................... 3-3

3.8 RADON .......................................................................................................................... 3-3

3.9 ORDNANCE AND/OR UNEXPLODED ORDNANCE......................................... 3-4

4. REMEDIATION........................................................................................................... 4-1

4.1 PHASE I PARCELS....................................................................................................... 4-1

4.1.1 Groundwater Contamination ............................................................... 4-1

4.1.2 Soil Contamination................................................................................. 4-1

4.2 PROPERTY ADJACENT TO PHASE I PARCELS.................................................... 4-1

5. REGULATORY COORDINATION AND THE PUBLIC REVIEW PROCESS5-1

6. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE ..... 6-1

7. ENVIRONMENTAL PROTECTION PROVISIONS............................................ 7-1

7.1 LAND USE RESTRICTIONS....................................................................................... 7-1

7.2 LEAD-BASED PAINT .................................................................................................. 7-2

7.3 ASBESTOS...................................................................................................................... 7-2

7.4 RADON .......................................................................................................................... 7-2

7.5 CERCLA PROVISIONS................................................................................................ 7-2
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TABLE OF CONTENTS

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8. FINDING OF SUITABILITY TO TRANSFER (FOST) ........................................ 8-1

ENCLOSURES

ENCLOSURE 1—FIGURES

ENCLOSURE 2—TABLE 1: SUMMARY OF ENVIRONMENTAL CONDITION OF

PROPERTY (ECP) CATEGORIES

ENCLOSURE 3—TABLE 2: NOTIFICATION OF HAZARDOUS SUBSTANCE

STORAGE, RELEASE, OR DISPOSAL

ENCLOSURE 4—TABLE 3: NOTIFICATION OF PETROLEUM PRODUCT

STORAGE, RELEASE, OR DISPOSAL

ENCLOSURE 5—APPENDICES

Appendix A—Phase I Parcel and Building Summaries

Appendix B—References

Appendix C—List of Acronyms

ENCLOSURE 6—SUMMARY OF BUILDING CONDITIONS, PHASE I TRANSFER

BULDINGS, RESULTS OF FINAL VISUAL SURVEYS

ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

ENCLOSURE 8—REGULATORY AGENCY CONCURRENCE LETTERS
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1.

PURPOSE

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

document the environmental suitability of the Phase I Parcels at

Letterkenny Army Depot (LEAD), Chambersburg, Pennsylvania, for

transfer to the Letterkenny Industrial Development Authority (LIDA)

consistent with Comprehensive Environmental Response, Compensation,

and Liability Act (CERCLA) Section 120 (h) and Department of Defense

(DoD) policy. In addition, the FOST identifies environmental protection

provisions necessary to protect human health or the environment after

such transfer.
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2.

PROPERTY DESCRIPTION

2.1 SITE OVERVIEW

LEAD is located in southcentral Pennsylvania in Franklin County, 5 miles

north of the Borough of Chambersburg, Pennsylvania. The Depot covers

19,243 acres, most of which is devoted to ammunition storage (16,432

acres). The industrial and maintenance areas, which are primarily located

in the southeast corner of LEAD, encompass approximately 3,088 acres.

The Base Realignment and Closure (BRAC) Parcel consists of

approximately 1,480 acres. The Phase I Parcels include approximately 233

acres (see Figure 1).

The Army will transfer the buildings, structures, and/or land associated

with the following parcels:

ß Parcels 1 and 2 (located near Gate 6); 23.6 acres.

ß Parcels 3 and 4 (Buildings 9 and 6); 12.3 acres.

ß Parcel 5 (Buildings S20-1 through S20-5); 8.0 acres.

ß Parcel 6 (Open Storage south of Parcel 7); 5.8 acres.

ß Parcel 7 (Building 238); 8.8 acres.

ß Parcel 8 (Buildings S26-1 through S26-4); 5.1 acres.

ß Parcel 9 (open storage east of Parcel 8); 4.5 acres.

ß Parcels 10 through 13 (Sheds at Docks 35, 36, 45, and 46); 13.1 acres.

ß Parcels 16 through 21 (Warehouses 34, 43, 44, 52, 53, and 54); 22.1

acres.

ß Parcels 22 and 31 (Railroad parcels); 13.6 acres.

ß Parcel 23 (Buildings T410, 411, 412, 416-418, and T455); 7.9 acres.

ß Parcel 24 (Building 500); 11.7 acres.

ß Parcel 25 (Building 19); 4.2 acres.

ß Parcel 26 (Building 581); 1.7 acres.
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PROPERTY DESCRIPTION

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ß Parcel 27 (Cargo Road parcel); 6.3 acres.

ß Parcel 28 (Building 524); 0.9 acres.

ß Parcel 29 (Agricultural lease parcel); 76.7 acres.

ß Parcels 33 and 34 (Buildings S637 and 639 and parking area); 6.7 acres.

The parcels are designated following the LIDA demarcations, as provided

by Benatec Associates, January 1998. Figure 1 presents the locations of the

Phase I Parcels within the to-be-excessed area. Appendix A is a summary

of the parcels, including environmental and building conditions.
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3.

ENVIRONMENTAL CONDITION OF THE PROPERTY

A determination of the environmental condition of the property was

made by the United States Army by conducting a review of existing

environmental documentation associated with the transfer parcels and by

visual site inspections. The documents reviewed included the

Environmental Baseline Survey (EBS) (August 1996), the Community

Environmental Response Facilitation Act (CERFA) Report (March 1997),

and the Area of Concern (AOC) documents completed for the Phase I

Parcels (WESTON, 1998). The review of documents, the August 1996 EBS

visual site inspections, and the final visual site inspections constitute an

EBS specific to the transfer parcels. All existing environmental

information was used to prepare and update the EBSs. Appendix B is a

list of the environmental documents associated with LEAD that will be

made available to the Grantee upon request. The environmental

conditions for each parcel are summarized in Table 1, Appendix A, and

Enclosure 6.

3.1 ENVIRONMENTAL CONDITION OF PROPERTY CATEGORIES

Recent DoD guidance requires bases undergoing closure to classify study

areas within their installation into one of seven area types. The purpose of

the classification of land and buildings into categories is to identify areas

that can easily be made available for transfer. The property that is being

considered for transfer is classified as DoD Environmental Condition of

Property (ECP) Category 4.

Note – All of the parcels in this FOST (i.e., Phase I Parcels) have

documented or suspected volatile organic compound (VOC)

contaminated groundwater beneath them. A Record of Decision (ROD)

has been prepared to document the selection of institutional controls as

the remedial alternative for the Phase I Parcels (30 September 1998). The

implementation of the institutional controls changed the ECP Category

from 5 (as documented in the CERFA Letter Report, March 1997) to

Category 4. The definitions of Category 4 and Category 5 are provided in

Table 1.

3.2 HAZARDOUS SUBSTANCES

Hazardous substances in excess of the 40 CFR Part 373 reportable

quantities were stored for 1 year or more at Building 19 (Parcel 25), Dock 35

(Parcel 11), and demolished Building S-26-5 (Parcel 8). There were no

reportable releases in the Phase I Parcels. There was a report of an
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ENVIRONMENTAL CONDITION OF THE PROPERTY

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unknown quantity of the pesticides diazinon and malathion at Dock 45

(Parcel 13) and the nearby railroad tracks. These soils were investigated;

diazinon and malathion were not detected at these sites. Buildings and

areas where hazardous substances have been used, stored, or released are

discussed in the Phase I EBS. A summary of the buildings or areas in which

hazardous substance activities have taken place is provided in Table 2—

Notification of Hazardous Substance Storage, Release, or Disposal

(Enclosure 3).

3.3 PETROLEUM AND PETROLEUM PRODUCTS

3.3.1 Storage, Release, or Disposal of Petroleum Products

Petroleum products in excess of 55 gallons were stored in the following

buildings (parcels): Building S-20-5 (Parcel 5); Dock 35 (Parcel 11); and

Building 19 (Parcel 25). The petroleum products stored at these areas

were reported to be used for industrial processes (i.e., lube oil, hydraulic

oil and greases). There are no records of petroleum product releases or

disposal in excess of 55 gallons in the Phase 1 Parcels.

3.3.2 Underground and Aboveground Storage Tanks (UST/AST)

There are nine unregulated underground and four aboveground storage

tanks (UST/AST) in the Phase I Parcels that were used for the storage of

petroleum products. There is no evidence of petroleum product releases

in excess of 55 gallons in the Phase I Parcels. A summary of the petroleum

product activities is provided in Table 3—Notification of Petroleum

Product Storage, Release, and Disposal (Enclosure 4).

3.4 PCB TRANSFORMERS

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

equipment currently located on the property discussed in this FOST and

no evidence of unremediated releases from PCB-containing equipment.

PCB-containing pole mounted transformers were formerly located at

Building 500 (3) and Building 19 (1). The soils directly below these

locations were sampled and analyzed, and PCBs were not detected.

3.5 ASBESTOS

There is known or suspect asbestos-containing material (ACM) in the

following Phase I Buildings: 6, 9, S-20-1, 19, 238, 34, 43, 44, 54, 53, 52, 412,

500, 581, 637, and 639. The ACM includes pipe insulation, transite board,

floor tile and mastic, gasket material, and pipe joint fittings. On 5 and 6

October 1998, the LEAD BRAC Cleanup Team (BCT) and LIDA conducted
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ENVIRONMENTAL CONDITION OF THE PROPERTY

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a final visual survey of the Phase I property. During this survey, the BCT

discovered damaged ACM in the Phase I buildings. All of the damaged

ACM was removed, enclosed, or encapsulated. A summary of the ACM is

provided in the Final Visual Survey Report (Enclosure 6) and supplements

the parcel-specific information contained in Appendix A. The ACM does

not currently pose a threat to human health or the environment because all

friable asbestos that posed an unacceptable risk to human health has been

removed or encapsulated. The deed will include the asbestos warning and

covenant (Enclosure 7).

3.6 LEAD-BASED PAINT

Based on the age of the buildings (constructed prior to 1978), all of the

Phase I Buildings are presumed to contain lead-based paint, with the

exception of Buildings 524, 416, 417, and 418. On 5 and 6 October 1998,

the LEAD BCT and LIDA conducted a final visual survey of the Phase I

property. A summary of the condition of the paint is provided in the

Final Visual Survey Report (Enclosure 6) and supplements the parcelspecific information contained in Appendix A. The lead-based paint does

not currently pose a threat to human health and the environment under

an industrial/commercial use scenario. The current use and the

anticipated future use are industrial/commercial. Furthermore, future

use of the parcels will be restricted to industrial/commercial activities.

The deed will include the lead-based paint warning and covenant

(Enclosure 7).

3.7 RADIOLOGICAL SOURCES OF CONTAMINATION

Military components (e.g., scopes, dials) containing radiological materials

were stored and/or used in Buildings 6, 9, and 19. Closure surveys were

completed for Buildings 6 and 9 (WESTON, 1998). Howitzers with tritium

components were stored for 1 day (1994) at Building 19. Wipe samples

were performed, and the historical assessment (WESTON, 1998)

determined that Building 19 was not impacted by this short-term storage.

The results of the radiological surveys indicate that these buildings are

suitable for unrestricted use.

3.8 RADON

Radon surveys were conducted in the following Phase I Buildings: 6, 9, 19,

581, 500, 524, 639, 637, 238, 43, 44, 52, 53, and 54. Radon was detected at or

above the U.S. Environmental Protection Agency (EPA) residential action

level of 4 picocuries per liter (pCi/L) at Building 639, the fitness center (19.6

pCi/L); Building 9, a warehouse/manufacturing building (5.0 pCi/L);

Building 6, warehouse and office space (4.0 pCi/L); and Building 44,

warehouse (6.0 pCi/L). These buildings are used for industrial,
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ENVIRONMENTAL CONDITION OF THE PROPERTY

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commercial, or administrative purposes. The deed will include the radon

notification provision (Enclosure 7).

3.9 ORDNANCE AND/OR UNEXPLODED ORDNANCE

No ordnance and/or unexploded ordnance has historically been or is

currently handled within the boundaries of the BRAC Parcel. All

ordnance and/or unexploded ordnance is limited to the Ammunition

Area (AA), which is part of the Enclave Area. The AA is not a part of the

BRAC Parcel or the property offered for transfer. Based on a review of

existing records and available information, none of the Phase I Parcels are

known to have stored or to have contained unexploded ordnance.
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4.

REMEDIATION

4.1 PHASE I PARCELS

In February 1989, LEAD, EPA, and the Pennsylvania Department of

Environmental Protection (PADEP) entered into a Federal Facilities

Interagency Agreement (IAG). The cleanup of the groundwater

associated with the two NPL sites at LEAD is being handled under this

agreement.

4.1.1 Groundwater Contamination

All of the groundwater beneath the Phase I Parcels covered in this FOST

has known or suspected VOC groundwater contamination as a result of

past LEAD practices and operations. Remedial strategies for the operable

units (OUs) that address the groundwater (PDO OU 2 and SE OU 3) are

being developed and will be reflected in future Records of Decision

(RODs). The groundwater associated with PDO OU 2 is beneath Parcels

29, 33, and 34 (see Figure 1). The groundwater associated with SE OU 3 is

beneath the remaining Phase I Parcels (see Figure 1). A Proposed Plan

and ROD have been prepared that identify institutional controls as the

interim remedial alternative selected to address the groundwater beneath

the Phase I Parcels. The Proposed Plan and ROD have been approved by

EPA, with written concurrence from PADEP. The final remedy for

groundwater will be addressed at a later date in separate RODs for the

relevant operable units.

4.1.2 Soil Contamination

Based on the results of the EBS and the screening sampling performed,

the conclusion presented in the ROD is that none of the soils within the

Phase I Parcels require an engineered remedial action (e.g., excavation or

treatment, provided that (1) the property is used for

industrial/commercial purposes only, and (2) all Deed Restrictions are

adhered to by current and future land users.

4.2 PROPERTY ADJACENT TO PHASE I PARCELS

Properties directly adjacent to the Phase I Parcels have the same

groundwater conditions as discussed above. Based on the results of

previous investigations and the EBS process, the shallow soils of
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REMEDIATION

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properties directly adjacent to the Phase I Parcels have not significantly

affected the Phase I Parcels and do not pose a threat to human health or

the environment. There is documented VOC and diesel fuel soil

contamination at Building 37, which is adjacent to Parcels 5, 8, and 10;

however, the contamination in the vicinity of Building 37 is below the

ground surface and poses no threat to the shallow soils on the adjacent

Phase I parcels.

The southwestern portion of Parcel 29 is adjacent to the DRMO scrap

yard where there is documented PCB contamination in the shallow soils.

Parcel 29 is topographically upgradient of the DRMO and has not been

affected by this soil contamination. In addition, PCBs were not detected

in the shallow soils directly adjacent to the border of Parcel 29.
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5.

REGULATORY COORDINATION AND THE PUBLIC

REVIEW PROCESS

PADEP, Southcentral Region, and EPA, Region III, have provided input

on the planning and report documents prepared to support the various

environmental programs at LEAD, and they were notified of the initiation

of the FOST. Regulatory comments received during the development of

the FOST have been incorporated into later versions of this document.

Relevant public comments on this document will be addressed by the

BRAC Cleanup Team (BCT). The regulatory comments have been

resolved as indicated in the concurrence letters in Enclosure 8.
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6.

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

COMPLIANCE

The environmental impacts associated with the proposed transfer of the

property have been analyzed in accordance with the National

Environmental Policy Act (NEPA). The results of this analysis are

documented in the Environmental Assessment (EA) Finding of No

Significant Impact (FONSI) dated 11 March 1998. The transfer of the

Phase I Parcels discussed in this FOST will be consistent with the

Environmental Assessment for the disposed property and with the Reuse

Strategy Plan prepared for LIDA (May 1997).
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7.

ENVIRONMENTAL PROTECTION PROVISIONS

On the basis of the results from the site-specific EBS and other

environmental studies and in consideration of the intended use of the

property, certain terms and conditions are required for the proposed

transfer. The following Environmental Protection Provisions will be

included in the deed. The Phase I Environmental Deed Provisions are

provided at Enclosure 7.

7.1 LAND USE RESTRICTIONS

ß Residential Use Restriction—The Grantee shall be restricted from

using the Property for residential purposes.

ß Groundwater Restrictions—The Grantee shall be prohibited from

installing any groundwater wells (domestic, municipal, agricultural,

or industrial) until all groundwater contamination associated with the

Depot has been remediated. The Grantee may install monitoring wells

with the prior written approval of the EPA/PADEP/Army.

ß Soil Excavation Restrictions—The Grantee shall not conduct any

excavation within 3 feet of the water table without the prior written

approval of the Army. If the Grantee discovers groundwater or

contaminated soils during excavation activities, the Grantee will

immediately cease excavation operations and notify the Army. The

Grantee may conduct excavation activities involving groundwater

with the written approval of the Army provided the Grantee complies

with an EPA/PADEP/Army- approved sampling and health/safety

plans and properly disposes of all contaminated soil/groundwater at

no cost to the Grantor.

ß Subsurface Construction—The Grantee shall not construct

subsurface structures for human occupation without the prior written

approval of the EPA/PADEP/Army.

ß Stormwater—The Grantee, its successors and assigns, shall not

undertake activities on the Property that would interfere with or

impede the completion of the CERCLA clean-up at LEAD. Activities

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

successors and assigns, taking appropriate action to ensure

stormwater is directed into existing or future stormwater sewer

systems or drainage ditches.
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ENVIRONMENTAL PROTECTION PROVISIONS

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7.2 LEAD-BASED PAINT

The Grantee shall be notified of the presence of lead-based paint in the

buildings and assume responsibility after transfer to ensure that the leadbased paint does not pose a threat to human health and the environment.

7.3 ASBESTOS

The Grantee, its successors, and assigns shall be notified of the presence

of asbestos in the buildings and assume responsibility after transfer to

ensure that asbestos-containing materials do not pose a threat to human

health and the environment.

7.4 RADON

The Grantee, its successors, and assigns shall be notified of the presence

of radon in the buildings and assume responsibility after transfer to

ensure that radon does not pose a threat to human health and the

environment.

7.5 CERCLA PROVISIONS

ß The covenant under CERCLA §120(h)(3)(A)(ii)(I) warranting that all

remedial action under CERCLA necessary to protect human health

and the environment with respect to hazardous substances remaining

on the Property has been taken before the date of transfer shall be

provided.

ß The covenant under CERCLA §120(h)(3)(A)(ii)(II) warranting that any

remedial action under CERCLA found to be necessary after the date

of transfer with respect to such hazardous substances remaining on

the Property shall be conducted by the United States shall be

provided.

ß The clause as required by CERCLA §120(h)(3)(A)(iii) granting the

United States access to the Property in any case in which remedial

action or corrective action is found to be necessary after the date of

transfer shall be required.

ß As required under the CERCLA §120(h) and DoD FOST Guidance,

notification of hazardous substance activities shall be provided in the

deed. See Table 2—Notification of Hazardous Substance Storage,

Release, or Disposal.
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8.

FINDING OF SUITABILITY TO TRANSFER (FOST)

Based on the above information, I conclude that all Department of

Defense (DoD) requirements to reach a finding of suitability to transfer

the property to the Letterkenny Industrial Development Authority

(LIDA) for redevelopment in accordance with the LIDA Reuse Plan have

been met for the property subject to the terms and conditions set forth in

the Environmental Protection Provisions. 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).

P. S. Morris

ColonelGS

Deputy Chief of Staff for Engineering, Housing,

Environment, and Installation Logistics

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ENCLOSURE 1

FIGURES

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ENCLOSURE 2

TABLE 1

SUMMARY OF ENVIRONMENTAL CONDITION OF

PROPERTY (ECP) CATEGORIES
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Table 1

Summary of Environmental Condition of Property (ECP) Categories

Letterkenny Army Depota, b

LIDA

Parcel

Building

(Descriptionc)

ECPd

Number

Size in

Acrese Remedial and/or Investigation Activities

1 and 2 N/A 4 23.6 Soils investigated; no further action planned.

3 9

(warehouse)

4 5.4 Reported spills were cleaned up using absorbent material. Building

investigated for radionuclides; no problems identified.f

4 6

(warehouse)

4 6.9 Building investigated for radionuclides; no problems identified.f

5 S-20-1 through

S-20-5

(storage sheds)

4 8.0 None.

6 N/A 5.8 None.

7 238

(office)

4 8.8 Reported spills were cleaned up using absorbent material, or soils

were removed.

8 and 9 S-26-1 through

S-26-4

(open storage

sheds)

4 9.6 RCRA Closure at former shed S-26-5; no further action planned.

10 through 13 Open storage

sheds

4 13.1 Soils investigated; no further action planned. RCRA closure at Dock

35 (Parcel 10); no further action planned.

16 34

(warehouse)

4 3.7 None.

17 44

(warehouse)

4 3.6 None.

18 43

(warehouse)

4 3.7 Containerized soils from diesel spill removed.
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Table 1

(Continued)

Summary of Environmental Condition of Property (ECP) Categories

Letterkenny Army Depota, b

LIDA

Parcel

Building

(Descriptionc)

ECPd

Number

Size in

Acrese Remedial and/or Investigation Activities

19 54

(warehouse)

4 3.7 None.

20 53

(warehouse)

4 3.7 None.

21 52

(warehouse)

4 3.7 None.

23 T-410 (storage)

T-411 (lift

station)

T-412 (conference

center)

T-416 (office)

T-417 (barracks)

T-418 (barracks)

T-455 (storage)

4 7.9 The gasoline spill at Building 412 was cleaned up using absorbent

material and contaminated soil was removed.

24 500

(office)

4 11.7 All reported spills were cleaned up using absorbent material. Soils

investigated; no further action planned.

25 19

(storage/

warehouse)

4 4.2 All reported spills were cleaned up using absorbent material. Soil

below reported PCB-containing transformer sampled; no further

action planned.

26 581

(office)

4 1.7 Suspected UST investigated; no further action planned.

27 N/A 4 6.3 Soils investigated; no further action planned.
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Table 1

(Continued)

Summary of Environmental Condition of Property (ECP) Categories

Letterkenny Army Depota, b

LIDA

Parcel

Building

(Descriptionc)

ECPd

Number

Size in

Acrese Remedial and/or Investigation Activities

28 524

(telecommunications)

4 0.9 None.

29 N/A 4 76.7 Soils investigated; no further action planned.

33 and 34 637 (Chapel) and

639 (Fitness

Center)

4 6.7 None.

22 and 31 Railroad Track

Parcels

4 13.6 Soils investigated; no further action planned.

N/A = Not Applicable

a

 The groundwater beneath the Phase I Parcels listed in this FOST has known or suspected VOC contamination.

b A ROD has been prepared that identifies institutional controls as the interim remedy selected to address the groundwater beneath the Phase I Parcels. The

ROD has been approved by EPA, with written concurrence from PADEP.

c Details of buildings are presented in Appendix A.

d ECP numbers are defined in the CERFA categories (WESTON, CERFA Letter Report, 1997). Category 4: Areas where release, disposal, and/or migration of

hazardous substances has occurred, and all removal or remedial actions to protect human health and the environment have been taken. The Phase I

Parcels all have known or suspected groundwater contamination, which will be addressed by institutional controls.

e Acreage sizes are approximate.

f Results of the radionuclide survey can be found in Final Termination Survey Report for Buildings 6 and 9 at Letterkenny Army Depot (Final) (WESTON, 1998).
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Table 1

(Continued)

Summary of Environmental Condition of Property (ECP) Categories

Letterkenny Army Depota, b

Category 1: Areas where no release or disposal of hazardous substances or petroleum product has occurred. (Including no migration of these substances from

adjacent areas).

Category 2: Areas where only release or disposal of petroleum products has occurred.

Category 3: Areas where release, disposal, and/or migration of hazardous substances has occurred, but at concentrations that do not require a removal or

remedial response.

Category 4: Areas where release, disposal, and/or migration of hazardous substance has occurred, and all removal or remedial actions to protect human health

and the environment have been taken.

Category 5: Areas where release, disposal, and/or migration of hazardous substances has occurred, and removal or remedial actions are underway, but all

required remedial actions have not yet been taken.

Category 6: Areas where release, disposal, and/or migration of hazardous substances has occurred, but required actions have not yet been implemented.

Category 7: Areas that are not evaluated or require additional evaluation.
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ENCLOSURE 3

TABLE 2

NOTIFICATION OF HAZARDOUS SUBSTANCE

STORAGE, RELEASE, OR DISPOSAL
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Table 2

Notification of Hazardous Substance Storage, Release, or Disposala

Letterkenny Army Depot

LIDA

Parcel Building

Hazardous Substance Storage, Release, or

Disposal Notificationb Remedial Action(s)

8 S-26-1

through

S-26-4

Hazardous material storage former shed S-26-5. Storage included

paint wastes, paint filters, solvents, corrosives, waste oils, and spent

blast media (WESTON, 1991).

RCRA closure; no further action planned.

10 Open storage

sheds

Hazardous material storage (Dock 35). Storage was drums of

protective mask filters (EQM, 1995).

RCRA closure at Dock 35; no further action

planned.

8 through 13 Open storage

sheds

Leaking containers of malathion and diazinon. Soils investigated; no further action planned.c

25 19 Hazardous material storage. None.

22 and 31 Railroad

Track Parcels

Possible diazinon and malathion spill on railroad tracks in Dock Area.

Use of herbicides along tracks.

Soils investigated; no further action planned.c

N/A = Not Applicable

a The information contained in this notice is required under the authority of regulations promulgated under section 120(h) of the Comprehensive

Environmental Response, Liability, and Compensation Act (CERCLA or “Superfund”) 42 U.S.C. section 9620(h). This table provides information on the

storage of hazardous substances for one year or more in quantities greater than or equal to 1,000 kilograms or the hazardous substance’s CERCLA

reportable quantity (which ever is greater). In addition, it provides information on the known release of hazardous substances in quantities greater than

or equal to the substances CERCLA reportable quantity. See 40 CFR Part 373.

b Hazardous substance storage quantities were not available nor was it practicable to estimate due to the varied nature of storage activities over the life of

the facilities.

c A ROD has been prepared that identifies institutional controls as the interim remedy selected to address the groundwater beneath the Phase I Parcels.

The ROD has been approved by EPA, with written concurrence from PADEP.
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ENCLOSURE 4

TABLE 3

NOTIFICATION OF PETROLEUM PRODUCT

STORAGE, RELEASE, OR DISPOSAL
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Table 3

Notification of Petroleum Product Storage, Release, and Disposal

Letterkenny Army Depota, b

LIDA

Parcel Building

Petroleum Product Storage, Release,

or Disposal Notification Remedial Action(s)

5 S-20-1

through

S-20-5

Petroleum products stored and released (some staining on concrete

floors).c No records of petroleum product spills. 500-gallon heating oil

AST at S-20-1.

None.

7 238 5,000-gallon heating oil UST in use from 1943 to 1996. An unknown

quantity of diesel fuel was spilled on 31 May 1991 at UST fill pipe.c

The spill was cleaned up using absorbent

material and the soils were removed.

8 and 9 S-26-1

through

S-26-4

Waste oil stored at former shed S-26-5.c RCRA closure; no further action planned.

18 43 7,500-gallon heating oil UST in use from 1974 to present. An unknown

quantity of diesel fuel was spilled on 31 May 1991 at the fill pipe for

UST.c

Contaminated soils from spill were

containerized and removed.

23 T-410, 411,

412, 416, 417,

418, T-455

Buildings 416, 417, and 418 each have a 1,000-gallon heating oil UST in

use from 1985 to the present. Building 412 has a 500-gallon heating oil

AST. Building T-410 has a 275-gallon heating oil AST.

None.

24 500 Building 500 has a 5,000-gallon heating oil UST in use from 1954 to the

present.

None.

25 19 Building 19 has a 7,500-gallon heating oil UST in use from 1954 to

present. Known petroleum product storage.c

None.

26 581 Building has a 500-gallon heating oil AST in use for an unknown

length of time.

None.

28 524 Building 524 has a 550-gallon heating oil UST in use for an unknown

length of time.

None.

33 and 34 637 and 639 Building 639 has a 3,000-gallon heating oil UST in use from 1945 to

present.

None.

N/A = Not Applicable

AST = Aboveground storage tank

UST = Underground storage tank

a

 The groundwater beneath the Phase I Parcels listed in this FOST has known or suspected VOC contamination.

b A ROD has been prepared that identifies institutional controls as the interim remedy selected to address the groundwater beneath the Phase I Parcels. The ROD has been approved by EPA, with

written concurrence from PADEP.

c Petroleum product storage and/or release quantities were not available nor was it practicable to estimate due to the varied nature of storage activities over the life of the facilities. Where

available, quantities of spills were provided. Spill records at LEAD start in 1988.
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ENCLOSURE 5

APPENDICES
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APPENDIX A

PHASE I PARCEL AND BUILDING SUMMARIES
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APPENDIX A

PHASE I PARCEL AND

BUILDING SUMMARIES

The following subsections summarize the previous use of each building

area and parcel and are based on the visual surveys completed for the

Phase I EBS, which were done in the fall of 1995. The current conditions

of these buildings are summarized in Enclosure 6. The environmental

conditions of the parcels and buildings are summarized in Table A-1. The

documents used to compile this information are listed in Appendix B.

A.1 PARCEL 4 (BUILDING 6—WAREHOUSE AND OFFICE SPACE)

Parcel 4 includes Building 6 and an adjacent parking area (see Figure A-1).

Building 6 is comprised of bin warehousing and office space. Constructed

in 1943 of brick, concrete, and steel, Building 6 is a controlled humidity

warehouse that is heated by steam generated from Building 8. The north

end of Building 6 is office space, which is finished with carpets, cubicles,

and 2-ft by 4-ft ceiling tile. The south end of Building 6 is a warehouse area

consisting of segregated storage for other countries. No hazardous

materials are stored in either end of Building 6. A small office located at the

southeast end of Building 6 (now vacated) was used by the

Communications-Electronics Command (CECOM). This office is finished

with 9-inch by 9-inch floor tile, which is suspected to be an asbestoscontaining material (ACM).

An asbestos survey conducted in 1993 at Building 6 identified the presence

of ACM in pipe insulation, floor tile, transite, and mastic. Some of this

material has been removed; however, records of the specific location or

extent of these removals are not well documented. No underground

storage tanks (USTs), aboveground storage tanks (ASTs), or

polychlorinated biphenyl (PCB)-containing equipment or materials were

noted to exist or were on record to have existed on the building property. A

lead-based paint (LBP) survey was not completed at Building 6; however,

the paint was noted to be in good condition.

A radon survey conducted during 1991-1992 at Building 6 indicated radon

present at concentrations near and above the U.S. Environmental

Protection Agency (EPA)-recommended action level for residential

properties of 4 picocuries per liter (pCi/L) (at levels ranging from 1.0 to 4.0

pCi/L). This building was retested in 1996, and the results were all below

EPA residential criteria; however, radon concentrations may change with

seasonal variations in the groundwater table. No spills were reported in the

LEAD spill inventory in association with Building 6.

Historical records indicate that Building 6 was used to temporarily store

radioactive components that were segregated from the shipping area.

Swipe sampling was conducted in 1989 and 1990. This sampling did not
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indicate radiological contamination. Additional sampling was conducted

to satisfy Nuclear Regulatory Commission (NRC) and Army requirements

and to document building conditions. The results of this sampling program

are provided in Decision Document for BRAC Buildings 6 and 9, Letterkenny

Army Depot (WESTON, 1998f).

There is documented volatile organic compound (VOC) groundwater

contamination under Building 6. There is no evidence of soil contamination

in the Building 6 area.

A.2 PARCEL 3 (BUILDING 9—WAREHOUSE)

Parcel 3 includes Building 9 and an adjacent parking area (see Figure A-1).

Building 9 is a general storage warehouse constructed in 1943. The building

consists of concrete and wood walls and a concrete foundation. The

building, a controlled humidity warehouse, is heated by a boiler located at

Building 8. A conveyor belt system, which facilitates movement of

warehouse articles, connects Buildings 5 through 9. The visual survey of

Building 9 identified the storage of parts, office supplies, and electronic

equipment. According to the building point of contact (POC), no

hazardous materials or liquids are stored in this building.

An asbestos survey conducted in 1993 at Building 9 identified the presence

of ACM in floor tile, transite, and pipe insulation. Some of this material has

been removed; however, records of the specific locations and/or the extent

of these removals are not well documented. No USTs, ASTs, or PCBcontaining equipment or materials were noted to exist or on record to have

existed on the building property. An LBP survey was not completed at

Building 9; however, the paint was noted to be in good condition.

A radon survey conducted in 1992 at Building 9 indicated radon present at

concentrations near and above the EPA residential action level of 4 pCi/L

(ranging from 4.0 to 5.0 pCi/L). This building was retested in 1996 and

some of the results are still above the EPA residential criteria of 4 pCi/L.

The effect of fluctuating groundwater table levels on the radon

concentrations has not been evaluated.

Two spills were reported in the LEAD spill inventory in association with

Building 9. These spills, a hydraulic oil leak (0.5 gallons) and an antifreeze

leak (5 gallons), were reportedly addressed immediately.

Historical records indicate that Building 9 was used to store military

components containing radiological materials. This storage occurred prior

to 1968 for an undetermined period of time. No record of sampling of this

building was found. Although there was no indication of a release during

the storage periods, closure sampling was performed to satisfy NRC and

Army requirements. The sampling did not indicate evidence of

contamination as a result of the storage of the radiological components.
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The results of this sampling are presented in Decision Document for BRAC

Buildings 6 and 9, Letterkenny Army Depot (WESTON, 1998f).

There is documented VOC groundwater contamination under Building 9.

There is no evidence of soil contamination in the Building 9 area.

Building 9 has recently (September 1997) been leased to a private entity as

part of the reuse/redevelopment effort of the LIDA. A Finding of

Suitability to Lease (FOSL) was completed to address Building 9 and other

high priority parcels (WESTON, July 1997). The building and selected

parking areas have been made available to the LIDA, through an interim

lease, as described in the DoD Base Reuse Implementation Manual (1995).

Tenant activities include the manufacturing and storage of garments. This

lease expires August 2002.

A.3 PARCELS 25 AND 26 (BUILDINGS 19, 581, AND 590)

Parcel 25 includes Building 19 and an open parcel to the south of the

railroad tracks (see Figure A-2). Building 19 was built in 1954 and is

constructed of brick on a concrete slab foundation. The south part of the

building is currently used for storage of glues, paints, solvents, and grease.

The north part of the building is currently empty and is designated for the

storage of classified vehicles. An ACM survey identified transite on the

doors and some pipe insulation as ACM. Some of these items have been

removed by the LEAD asbestos abatement program; however, records of

the specific locations and/or the extent of these removals are not well

documented. The building is heated by an oil-fueled heating furnace,

which is supplied by a non-regulated 7,500-gallon UST (which passed leak

testing in 1996).

Radon testing was conducted at Building 19 and was found at levels

ranging from 0.3 to 1.3 pCi/L, which are below the EPA residential action

level; however, radon concentrations may change with seasonal

fluctuations of the groundwater table. A lead-based paint survey was not

completed at Building 19; however, the paint was noted to be in good

condition. Documented spills that have occurred include polyurethane

(0.25 gallon), motor oil (5 gallons), diesel fuel (20 gallons), and lube oil (5

gallons). These spills were reported to have been cleaned up using sorbent

materials, and no migration or contamination of media was noted. A polemounted PCB-containing (725 ppm) transformer was removed from

outside of Building 19 on 25 August 1990. The soil below the transformer

was sampled and PCBs were not detected. There are inactive open storage

areas and a railroad siding (to be retained by the Army) near Building 19.

Historical records revealed that howitzers, containing components with

radiological sources, were stored in Building 19 for one day in 1994. Upon

removal, both the howitzers and the building were swipe-sampled, and no
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radiological contamination was noted. No further action was deemed

necessary as a result of this storage.

Parcel 26 includes Building 581 and the parking area to south (see Figure

A-2). Building 581 is an office building along Coffey Avenue that was built

in 1942 and constructed of concrete block and wood. The building is heated

with oil supplied by a 500-gallon AST, which may have replaced an UST.

There is evidence of a former UST; however, excavations conducted in the

vicinity of the suspected UST location did not identify the presence of an

UST or evidence of a former tank (i.e., non-native soils characteristic of

backfilling). According to LEAD files, some of the pipe insulation has been

removed by the LEAD asbestos abatement program. Radon testing was

conducted and found at levels ranging from 0.5 to 1.0 pCi/L, which are

below the EPA-recommended residential action level. An LBP survey was

not completed for Building 581; however, the paint was noted to be in good

condition.

Building 590 is an unoccupied structure that contains a lift station for the

sanitary sewage treatment plant. It was built in 1953 and has an asphalt

shingle roof. Based on the EBS visual survey, there did not appear to be any

ACM associated with this building. Because this is not an occupied

building it was not tested or surveyed for radon, ACM, or lead-based paint.

There are no UST or ASTs known to exist at Building 590.

There is documented VOC groundwater contamination beneath Buildings

19 and 581. There is no evidence of soil contamination in the Building 19

and 581 areas.

A.4 PARCEL 23 (BUILDINGS T-410, 411, 412, 416, 417, 418, AND T-455)

Parcel 23 (see Figure A-3) includes Buildings T-410, 411, 412, 416, 417,

418, and T-455, along with associated parking and open areas. The

following subsections describe the individual building areas.

A.4.1 Building 412—Conference Center

Building 412 (see Figure A-3) is a newly renovated conference center built

in 1943. Prior to the present use, it was a cafeteria (1943-1980) and an office

(1980-1990). The building is constructed of wood on a concrete slab

foundation. Building 412 is heated using oil supplied by a 500-gallon AST.

The ACM survey identified transite board, floor tile, and mastic as ACM.

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

been removed from Building 412 as part of the LEAD ACM abatement

program. Follow-up ACM surveys have not been completed to document

the ACM removals. Radon was not evaluated. An LBP survey for Building

412 was not completed; however, the paint was noted to be in good

condition. There is no record of PCB-containing transformers at Building
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412. The records show that a gasoline spill (10 to 12 gallons) occurred

outside the building in February 1989. The spill and contaminated soil

were reported to have been cleaned up.

A.4.2 Building T-410—Support Building

Building T-410 is a support building used for storage when the tent area in

the eastern portion of this parcel is in use. Building T-410 was constructed

in 1985 and is fabricated of wood and concrete. The building is heated by a

furnace supplied by a 275-gallon AST located outside the southwest corner

of the building. ACM, lead-based paint, and radon were not surveyed for

Building T-410. There is no record of PCB-containing transformers or spills

associated with Building T-410.

A.4.3 Building 411—Lift Station

Building 411 is a sanitary sewer lift station. This building was constructed

in 1945 of concrete and wood. ACM, lead-based paint, and radon were not

surveyed for Building 411. Suspect ACM was not identified during the EBS

visual survey. There is no record of PCB-containing transformers or spills

associated with Building 411.

A.4.4 Building 416—Office

Building 416 is a one-story structure constructed in 1985 of wood on a

concrete slab foundation. The building was used as office space and is

currently empty. Building 416 is heated using heating oil supplied by a

non-regulated 1,000-gallon UST (tested tight 1996). ACM, radon, and leadbased paint surveys have not been performed at this building. There is no

record of PCB-containing transformers at Building 416. No spills are on

record for Building 416.

A.4.5 Buildings 417 and 418—Barracks

Buildings 417 and 418 are one-story structures constructed in 1985 of

wood on a concrete slab foundation. These buildings were used as

barracks and are heated using heating oil supplied by non-regulated

1,000-gallon USTs (tested tight, 1996). ACM, radon, and lead-based paint

surveys have not been performed at these buildings. There are no records

of spills or PCB-containing transformers at Buildings 417 and 418.
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A.4.6 Building T-455—Storage

Building T-455 is an unheated storage building constructed in 1949 of steel

and wood on a concrete foundation. An ACM survey performed at

Building T-455 did not identify any ACM. Lead-based paint and radon

were not surveyed at this building. There is no record of PCB-containing

transformers or spills associated with Building T-455.

There is documented VOC groundwater contamination under the Parcel 23

area. The soils in this area have not been evaluated, but there are no records

or visual evidence of soil contamination.

A.5 PARCEL 24 (BUILDING 500—ADMINISTRATION OFFICE)

Parcel 24 includes Building 500, adjacent parking, and an open area to the

south of the building (see Figure A-4). Building 500 is the former Post

Headquarters and houses the medical clinic. It is a three-story structure

that includes a small auditorium. Building 500 was built in 1954 and is

constructed of concrete block.

An asbestos survey identified floor tiles as ACM in Building 500. LEAD

records indicate that some ACM tile, along with possible ACM pipe

insulation, has been removed. ACM floor tiles were identified during the

EBS visual survey. Lead-based paint has not been surveyed at Building 500;

however, the paint was noted to be in good condition. A non-regulated

5,000-gallon heating oil UST (tested tight 1996) is used to supply fuel for

heating. Radon surveys indicate that radon is below the EPA residential

action level.

Three pole-mounted PCB-containing transformers were formerly in use in

the Building 500 area, but were removed and properly disposed of in 1996.

Soil samples were collected directly below the locations of the former

transformers and analyzed for PCBs. PCBs were not detected in the soil

samples. Records indicate that two small spills occurred outside

Building 500, including 5 gallons of heating oil and 1⁄2 gallon of the

insecticide pyrethrin. Both spills were cleaned up immediately.

VOC-contaminated groundwater is suspected under the Parcel 24 area.

There is evidence of vehicle storage in the Building 500 area prior to

construction of the building. Two shallow test trenches were completed

south of the parking area. The results of this investigation indicate that

there is no evidence of soil contamination in this area. (See WESTON,

1998c).
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A.6 PARCEL 28 (BUILDING 524—ADMINISTRATION OFFICE)

Building 524 (see Figure A-4) is a televideo communications conference

center. It was constructed in 1986 of brick on a concrete foundation with a

wood roof. Building 524 is heated by a furnace using fuel oil supplied by

an unregulated 550-gallon UST. Radon was detected as 1.2 pCi/L in this

building, which is well below the EPA recommended residential action

level of 4 pCi/L. Asbestos and lead-based paint were not surveyed at

Building 524. However, based on the age of the building, the presence of

lead-based paint or asbestos is unlikely.

VOC-contaminated groundwater is suspected under the Parcel 28 area.

There is no evidence of soil contamination at Parcel 28.

A.7 PARCEL 29

Parcel 29 is approximately 75 acres and is located south of Vehicle Road,

north of railroad classification yard #2, and east of the DRMO area (see

Figure A-5). This parcel is currently under an agricultural lease until 31

December 2000. There are no buildings on the parcel and aerial

photography indicates that the area has been used for agricultural

purposes since at least 1963.

Based on findings from the EBS process (aerial photography analysis),

this area was once used for temporary vehicle storage (1949-1957). This

area has been evaluated as part of the PDO OU 5 investigation. Sixteen

test trenches and nine soil borings were completed in this parcel. The

results indicate very low concentrations of total petroleum hydrocarbons

(TPH), metals, and PCBs. The previous temporary vehicle storage in this

area did not have any significant impact to the soils. (See WESTON,

1998d). The groundwater below Parcel 29 has documented VOCcontamination.

A.8 PARCELS 33 AND 34 (BUILDINGS S637 AND 639)

Parcel 33 includes the community fitness center (Building 639) and the

chapel (Building S637). Parcel 34 is a parking lot located across Carbaugh

Avenue. Figure A-6 presents the locations of these two parcels.

Building 639 houses the community fitness center at LEAD, which is

located near the intersection of Carbaugh and Pennsylvania Avenues.

The original portion of the fitness center was constructed in 1945 of

concrete block and wood with a wood and shingle roof. The rear addition

(the gymnasium) was built later (exact date unknown) and is constructed

of steel with a concrete slab foundation. The fitness center is currently

comprised of a single-story, 10,055-square-foot building.
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The interior of the fitness center contains a basketball court, front office,

men’s and ladies’ locker rooms and shower facilities, racquetball courts,

and a weight room. The building is heated by a boiler, which also

supplies steam heat to the chapel (Building S637). A 1,000-gallon

unregulated UST, located between Buildings 639 and S637, supplies

heating oil to the boiler. This UST passed leak testing in 1996. File

reviews did not indicate information regarding lead-based paint surveys

for Building 639. No transformers, oil/water separators, or ASTs were

noted on the subject property.

Radon testing conducted at Building 639 indicated concentrations

exceeding EPA’s recommended residential action level of 4 pCi/L. The

latest sampling at Building 639, completed in December 1996, showed a

maximum radon concentration of 19.6 pCi/L. The potential impact of

fluctuating groundwater levels on the radon concentrations has not been

evaluated.

Building S637 houses the LEAD chapel. Constructed in 1944, the chapel

has been in use intermittently, serving as a nondenominational religious

facility. The tower is constructed of stone and mortar; the remainder of

the chapel is constructed of concrete block and wood with a wood truss

and shingle roof.

The interior of the chapel consists of an altar, pews, and a second story

choir loft. An ACM survey identified pipe insulation, floor tile (12” x 12”

and 9’ x 9’), gypsum board, spackle/joint compound, pipe mastic, tile

mastic, and black putty. Suspect ACM noted during the EBS visual

inspection (conducted in September 1995) included vinyl floor tiles in the

restroom and loft area, and wallboard in the alcoves leading to the loft

and in other areas, such as closets. Lead-based paint was not surveyed in

the chapel; however, the paint was noted to be in good condition. No

ASTs, oil/water separators, spills, or PCB-containing transformers were

noted in association with the subject property.

A radon survey was conducted at Building S637 as part of LEAD’s radon

testing program. Radon concentrations detected in the chapel ranged

from 2.7 to 3.4 pCi/L, which are below the EPA recommended residential

action level.

A.9 PARCELS 5, 6, AND 7 (SHED STORAGE AND OPEN STORAGE AREAS)

Parcels 5, 6, and 7 encompass approximately 19 acres and are located (see

Figure A-7) in a triangle formed by the intersections of California and

Michigan Avenues, with Oregon Avenue forming the southern border.

This area does not include the ingot storage area (Lot 29). Parcel 5 has a

total of five storage sheds; Parcel 6 is a fenced-in open storage area; and

Parcel 7 includes an office building (Building S-238), which is slated for

demolition.
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A.9.1 Parcel 5

Building S-20-1 was reportedly built in the late 1940s to early 1950s of

corrugated metal walls and roof with a concrete/asphalt floor. The

southwest corner is devoted to office space and the rest of the building is

used to sort and store recyclable materials, including metal, glass, plastic,

wood, and cardboard. Building S-20-1 is heated with heating oil supplied

by a 500-gallon AST located inside the building. An ACM survey

identified floor tile and mastic as ACM in the office area. There are no

records of ACM removal or spills in the LEAD files for Building S-20-1.

Radon and lead-based paint were not surveyed at S-20-1. No USTs or

PCB-containing equipment or materials were noted at or around S-20-1,

or were reported to have existed.

Buildings S-20-2 through S-20-5 are semipermanent storage structures

located near the ingot storage areas. Although the exact construction

dates are unknown, the buildings were reportedly constructed in the late

1940s to early 1950s of corrugated metal walls and concrete/asphalt

floors. None of the four buildings are heated, with the exception of the

offices located within the storage buildings, which have electric heat.

All of the buildings, with the exception of Building S-20-2, had curbing

around the foundation. Numerous oil stains were noted on the floors of

the storage buildings, which appeared to be the result of small leaks from

engines rather than from spills. According to LEAD personnel, the

current contents are typical of historical use of the buildings.

ACM has not been evaluated at Buildings S-20-2 through S-20-5;

however, the floor tile in the office area of Building S-20-4 is suspected

ACM. Radon and lead-based paint surveys have not been conducted in

these buildings. No USTs, ASTs, or PCB-containing equipment or

materials were noted at or around the subject property, or were reported

to have existed. The LEAD spill inventory did not identify any releases

associated with these buildings.

A.9.2 Parcel 6

Parcel 6 is an open storage area located south of Parcel 7. This area is

fenced and is used for storage of equipment. No structures or

improvements are present on this property, with the exception of the

fence.

A.9.3 Parcel 7

Building S-238 previously housed the financial administrative offices at

Letterkenny but is now unoccupied. Constructed in 1943, the two-story
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building consists of wood and siding over a concrete foundation. The

building is comprised of office space, with an unfinished storage area on

the third floor. The interior of the office area is finished with 9-inch by 9-

inch floor tile, 2-ft by 4-ft ceiling tile, and wallboard. Building S-238 was

heated by a boiler located in a room along the main building; fuel oil is

supplied to the boiler by a 5,000-gallon UST (tested tight, 1991).

An asbestos survey conducted at Building S-238 identified the presence

of ACM on pipe insulation, floor tile, and pipe joint fittings. Some of this

material has been abated and/or removed; however, no ACM surveys or

post-removal clearance air monitoring were completed/documented

after the removals. No PCB-containing equipment or materials or ASTs

were noted to exist on the building property. Paint chip sampling was

conducted for Building S-238, and lead was detected; however, the

location of the samples and the extent of lead-based paint in the building

have not been determined. Peeling paint was observed in some office

areas and sills during the site inspection. A radon survey conducted at

Building S-238 indicated radon present at concentrations ranging from

1.1 to 3.0 pCi/L, which are below the EPA-recommended action level (4

pCi/L).

Two spills were identified in the spill report file as having occurred at

Building S-238. These spills consisted of small quantities of liquids (i.e.,

diesel and hydraulic fluid) that were spilled on concrete or paved

surfaces. All of the spills were reported to have been addressed

immediately with absorbent material, and no migration was noted.

There is suspected VOC groundwater contamination under Parcels 5, 6,

and 7. There is no evidence of contaminated soil at these parcels. There is

potential soil contamination (metals) related to the ingot storage at

Lot 29, which is not part of the parcels addressed under this FOST. The

soil associated with Lot 29 will be evaluated as part of the CERCLA

investigation under the BRAC program, and will be transferred at a later

date.

A.10 PARCELS 8 AND 9

Parcels 8 and 9 are approximately 13 acres and are located in an area

bordered by California, Ohio, Overcash, and Oregon Avenues (see Figure

A-7). There are four open storage sheds (S-26-1 through S-26-4) that were

built using structural steel and corrugated steel roofs and sides. To the

south of these sheds is a former hazardous material storage area which

was used to store drums of paint wastes, paint filters, solvent, corrosives,

waste oils, and spent blast media. A RCRA closure has been completed

for this area (SS&M, 1991). ACM, radon, and lead-based paint surveys

have not been completed for these sheds. No USTs, ASTs, or PCBcontaining equipment were noted at or around these parcels, or were
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reported to have existed. Sheds S-26-1, S-26-2, and S-26-3 are in poor

physical condition.

Historical records indicated a spill of the pesticides malathion and/or

diazinon at Dock 45. However, a map identified three blocks of storage

sheds as the “spill area.” This area was investigated in December 1997 to

assess any potential environmental impacts from this release. No

pesticides were detected in any of the samples collected from this area.

(See WESTON, 1998b). There is documented VOC groundwater

contamination under Parcels 8 and 9.

A.11 PARCELS 1 AND 2

Parcels 1 and 2 encompass approximately 24 acres (total) and are located

south of Carbaugh Avenue near Gate 6 (see Figure A-8). Building 1 is

located to the west of these parcels and the Building 350 area is located

north of these parcels. Industrial processes are conducted in both

Buildings 1 and 350. There is a stormwater drainage ditch that runs

through the parcel to an area off-site near Gate 6. The 1949 aerial

photograph shows that this area was disturbed and shows patterns of

temporary vehicle storage. Subsequent aerial photographs (1957, 1963

and 1970) show that the area was open, vegetated, and not used for

vehicle storage. Evidence of coal storage can be seen in the aerial

photographs and on the ground surface at the western edge of the parcel.

A total of eight test trenches and two sediment samples were completed

in this area to determine if the previous vehicle storage, coal storage, or

proximity to Buildings 1 and 350 had any impacts. The results indicate

very little impact from previous use. (See WESTON, 1998a). Previous and

ongoing investigations indicate that the groundwater under this parcel

has been contaminated with VOCs.

A.12 PARCELS 10 THROUGH 13

Parcels 10, 11, 12, and 13 (Dock Storage Area), located on approximately

20 acres, consist of 23 open storage sheds (see Figure A-9) bounded by

California, Oregon, Overcash, and Oklahoma Avenues.

These semipermanent storage buildings are open on one side and are

used for storage of various types of equipment and supplies. The

buildings were all reported to have been constructed in the mid-1940s,

and are fabricated of steel walls and roofs with metal grating, asphalt, or

concrete floors. The sheds in storage areas S-35 and S-36 are in poor

physical conditions. The sheds in areas S-45 and S-46 are in fair physical

condition. No heat or water utilities are provided to the dock

warehouses. A visual survey was conducted of these buildings, and

materials identified within the buildings included small quantities (less

than 55 gallons) of petroleum-based oil and antifreeze, missile hardware,

engines and parts, and miscellaneous hardware. Evidence of small (i.e.,
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less than 5 ft in diameter) oil stains were noted in a few of the dockhouse

buildings, although no large areas of staining were observed. Because of

the open storage, it is unlikely that large quantities of petroleum products

or hazardous materials had been stored in these areas for security

reasons. The POC for the dock storage areas indicated that he had no

recollection of these materials being stored in this area. However, drums

of labeled hazardous waste identified as protective mask filters were

stored at Dock 35 in 1990, which prompted the Resource Conservation

and Recovery Act (RCRA) closure of this dock as a hazardous waste

storage area (EQM, 1995).

Asbestos, radon, and lead-based paint surveys have not been conducted

for the dock storage areas. No suspect ACM was noted during the site

inspection. The LEAD spill inventory did not identify any releases

associated with the dock storage area. No USTs, ASTs, or PCB-containing

equipment or materials were observed at the subject property during the

site inspection, or were identified in the facility records.

There is documented VOC groundwater contamination under Parcels 10

through 13. The closure at Dock 35 determined that no remediation or

further sampling is necessary in this area (EQM, 1995).

Historical records indicated a spill of the pesticides malathion and/or

diazinon at Dock 45. However, a map identified three blocks of storage

sheds as the “spill area.” This area was investigated in December 1997 to

assess any potential environmental impacts from this release. No

pesticides were detected in any of the samples collected from this area.

(See WESTON, 1998b).

A.13 PARCELS 16 THROUGH 21

Parcels 16, 17, 18, 19, 20 and 21 encompass approximately 31 acres and

include Buildings 34, 43, 44, 52, 53, and 54 (see Figure A-9). There is

documented VOC groundwater contamination under these parcels.

There is no evidence of soil contamination in this area. The following

subsections provide details on each building.

A.13.1Building 34

Building 34 is a general storage warehouse that was constructed in 1943.

The building consists of brick and wood walls and a concrete foundation.

The building is a controlled humidity warehouse that is unheated. A

visual survey of the building conducted as part of the EBS showed that

vehicle parts and general hardware were stored in the warehouse.

According to the LEAD POC, liquids and hazardous materials are not

stored at Building 34.
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An asbestos survey was conducted at Building 34, which identified the

presence of ACM as transite wallboard, mastic, and tile. No USTs, ASTs,

or PCB-containing equipment or materials were noted to exist on the

building property. A lead-based paint sample collected from Building 34

showed a lead concentration of 9.2%; however, no survey was completed

and the extent of lead-based paint is unknown in the warehouse. The

paint at Building 34 was noted to be in good condition. No spills were

identified at Building 34 in the LEAD spill inventory. A radon survey has

not been conducted for Building 34.

A.13.2Building 43

Building 43 is a general storage warehouse that was constructed in 1943.

The building consists of brick and wood walls and a concrete foundation.

The building is humidity controlled and the furnace is fueled by a 7,500-

gallon UST (which passed leak testing in 1996) located on the north side

of Building 43. The visual survey of the building indicated that it is used

for storage of corrosive materials, such as flashlight batteries, and

miscellaneous non-hazardous supplies, such as office supplies and hand

tools.

An asbestos survey conducted at Building 43 identified the presence of

ACM as transite wallboard, gasket material, and pipe insulation.

Remediation and abatement of these items have been partially

completed; however, the extent of these activities is not well

documented. No PCB-containing equipment or materials were noted to

exist on the building property. No lead-based paint surveys have been

conducted for Building 43; however, the paint was noted to be in good

condition. The LEAD spill inventory reported incidents of two fuel spills,

which were reported to have been cleaned up (including the

contaminated media). Radon levels obtained during testing of the

building ranged from concentrations of 1.8 to 2.3 pCi/L, which are well

below the EPA-recommended residential action level.

A.13.3Building 44

Building 44 is a general storage warehouse that was constructed in 1943.

The building consists of brick and wood walls and a concrete foundation.

The building is a controlled humidity warehouse that is unheated. The

visual survey of the building showed that equipment (i.e., generators,

clothing, equipment) for Army Reserve units is stored in the warehouse.

According to the LEAD POC, liquids and hazardous materials are not

stored at Building 44.

An asbestos survey conducted at Building 44 identified the presence of

transite wallboard. Suspect ACM noted during the site inspection

included damaged wallboard on the bay doors of the warehouse. LEAD
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PHASE I PARCEL AND BUILDING SUMMARIES

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records indicate that some of the transite board has been removed. No

USTs, ASTs, or PCB-containing equipment or materials were noted to

exist on the building property. A lead-based paint survey has not been

completed at Building 44; however, the paint was noted to be in good

condition. No spills were identified at Building 44 in the LEAD spill

inventory.

A radon survey conducted at Building 44 indicated radon concentrations

of 1.8 to 6.0 pCi/L, some of which were above the EPA-recommended

residential action level of 4 pCi/L. This building was resampled as part

of the 1995-1996 Army Radon Reduction Program (ARRP) at LEAD and

all radon concentrations were below 4 pCi/L. The potential effect of

groundwater table fluctuations on the radon concentration within the

building has not been assessed.

Building 44-1, a separate building used as rest rooms, was also identified

as having ACM (transite). Building 44-1 is independently heated and

fueled by a 300-gallon AST. Radon and lead-based paint were not

surveyed at 44-1.

A.13.4Building 52

Building 52 is a warehouse that is used for storage of radar-related

mobile equipment, including shop shelters, radars, and generators. The

equipment is drained of fluids before being stored in the building. No

significant stains were detected during the EBS visual survey. Building 52

was built in 1942 and is constructed of brick and wood on a concrete

foundation. The building is a controlled humidity warehouse that is not

heated. An ACM survey identified transite board, floor tile, and mastic as

ACM. No records of ACM removals were found in the LEAD files. Radon

was detected (0.8 to 1.2 pCi/L) at concentrations below the EPArecommended residential action level. A lead-based paint survey was not

completed at Building 52; however, the paint was noted to be in good

condition. No USTs, ASTs, or PCB-containing equipment or materials

were noted to exist at Building 52.

A.13.5Building 53

Building 53 is a general storage warehouse that was constructed in 1943.

The building consists of brick and wood walls and a concrete foundation.

The building is a controlled humidity warehouse that is unheated. The

EBS visual survey of the building indicated that the south half of the

warehouse is leased to the Navy for storage of electronic components,

transmissions, and foreign military equipment. Similar equipment is

stored in the north half, which is managed by the Army. According to the

LEAD POC, liquids and hazardous materials are not stored at Building

53.
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An asbestos survey conducted at Building 53 identified the presence of

ACM as transite wallboard. LEAD records indicate that some transite

board has been removed. No USTs, ASTs, or PCB-containing equipment

or materials were noted to exist on the building property. A lead-based

paint survey has not been completed for Building 53; however, the paint

was noted to be in good condition. The LEAD spill inventory did not

contain any reported incidents of spills associated with Building 53.

Radon levels obtained during testing of the building ranged from

concentrations of 0.9 to 1.7 pCi/L, which are well below the EPArecommended residential action level.

A.13.6Building 54

Building 54 is a general storage warehouse that was constructed in 1943.

The building consists of brick and wood walls and a concrete foundation.

The building is unheated and is not humidity controlled. The visual

survey of the building indicated that the building is used to store solid

materials, such as gas masks, cartridges, wood, and tires. According to

the LEAD POC, liquids and hazardous materials are not stored at

Building 54.

An asbestos survey conducted at Building 54 identified the presence of

ACM as transite wallboard. No USTs, ASTs, or PCB-containing

equipment or materials were noted to exist on the building property. A

lead-based paint survey has not been completed for Building 54;

however, the paint was noted to be in good condition. The LEAD spill

inventory did not contain any reported incidents of spills associated with

Building 54.

Radon levels obtained during testing of the building ranged from

concentrations of 0.5 to 1.1 pCi/L, which are well below the EPArecommended residential action level.

A.14 PARCEL 27 (CARGO ROAD PARCEL)

Parcel 27 is comprised of the paved area along Coffey Avenue east of the

water treatment plant (see Figure A-10). This parcel is approximately 11

acres and is an undeveloped parcel. The drainage near this parcel was

once used to discharge the water used to backwash the filters at the water

treatment plant. The soils in the drainageway will be investigated as part

of the CERCLA investigations under the BRAC program. This drainage

area will not be transferred under this FOST.

There is suspected VOC-contaminated groundwater beneath this parcel.

No evidence of soil contamination was identified for this parcel.
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PHASE I PARCEL AND BUILDING SUMMARIES

O:\02281016.005\fost1098\FOSTAPPA.doc 04/13/99 A-16

A.15 PARCELS 22 AND 31—RAILROAD TRACK PARCELS

Two railroad track parcels (22 and 31) were identified by LIDA for

transfer as part of the Phase I Parcels (see Figure A-11). Based on the

information obtained from the interview process of the EBS conducted

for LEAD, heavy doses of herbicides were reported to have been used

along the railroad tracks to suppress vegetation. Other potential

contaminants along the railroad tracks included pesticides, PCBs, metals,

and petroleum-based compounds (oil application for weed control).

A field reconnaissance of the railroad tracks was completed, and no

significantly stained areas were noted. The soil below the railroad tracks

was sampled, and the results indicated that the soil immediately below

the railroad tracks has not been significantly affected. (See WESTON,

1998e).
O:\02281016.005\fost1098\FOSTAPPA.doc 04/13/99 A-17

Table A-1

FOST Building and Parcel Area

Summary of Environmental Conditions

Letterkenny Army Depot

LIDA

Parcel Building Asbestos Radon PCBs LBP

Storage

Tank Spills Soils Groundwater Comments

1 and 2 N/A N/A N/A No N/A No No No Yes Soils evaluated; no further action.

3 9 Yes Yesa No NS No Yesc NS Yes Radon retested - still above criteria.

4 6 Yes No No NS No No NS Yes Radon retested - below criteria.

5 S-20-1 Yes NS No NS 500-gal

AST-HO

No No Yes

5 S-20-2

through

S-20-5

NS NS No NS No No No Yes Some oil staining on floors.

6 N/A N/A N/A N/A N/A No No NS Yes

7 238 Yes No No NS 5,000-gal

UST-HO

Yesc No Yes LBP found in one sample; location not

documented. No LBP survey was

completed.

8 and 9 S-26-1, 2,

3, 4

NS NS No NS No No No Yes

10-13 Dock

Storage

Open

Sheds

NS N/A No NS No Yes No Yes Drum storage closure at Dock 35; no

further action. Leaking canisters of

malathion and diazinon reported at

Dock 45; sampling showed no residual

concentrations.

16 34 Yes NS No NS No No No Yes LBP found in one sample - location

unknown.

17 44 Yes No No NS No No No Yes
Table A-1

FOST Building and Parcel Area

Summary of Environmental Conditions

Letterkenny Army Depot

(Continued)

O:\02281016.005\fost1098\FOSTAPPA.doc 04/13/99 A-18

LIDA

Parcel Building Asbestos Radon PCBs LBP

Storage

Tank Spills Soils Groundwater Comments

18 43 Yes No No NS 7,500-gal

UST-HO

Yesc No Yes

19 54 Yes No No NS No No No Yes

20 53 Yes No No NS No No No Yes

21 52 Yes No No NS No No No Yes

23 412 Yes NS No NS 500-gal

AST-HO

Yesc NS Yes

23 T-410 NS NS No NS 275-gal

AST-HO

No NS Yes

23 411 NS NS No NS No No NS Yes

23 416 NS NS No NS 1,000-gal

UST-HO

No NS Yes

23 417 NS NS No NS 1,000-gal

UST-HO

No NS Yes

23 418 NS NS No NS 1,000-gal

UST-HO

No NS Yes

23 T-455 No NS No NS No No NS Yes

24 500 Yes No Yesb NS 5,000-gal

UST-HO

Yesc No NS-S

25 19 Yes No Yesb NS 7,500-gal

UST-HO

Yesc NS Yes

26 581 Yes No No NS 500-gal

AST-HO

No NS NS-S

27 N/A N/A N/A N/A N/A No No No NS-S
Table A-1

FOST Building and Parcel Area

Summary of Environmental Conditions

Letterkenny Army Depot

(Continued)

O:\02281016.005\fost1098\FOSTAPPA.doc 04/13/99 A-19

LIDA

Parcel Building Asbestos Radon PCBs LBP

Storage

Tank Spills Soils Groundwater Comments

28 524 NS No No NS 550-gal

UST-HO

No NS NE-S

29 N/A N/A N/A N/A N/A No No No Yes Soils evaluated; no further action.

33 637 Yes No No NS No No NS Yes

33 639 Yes Yesa No NS 3,000-gal

UST-HO

No NS Yes

34 N/A N/A N/A N/A N/A No No NS Yes

22 and

31

Railroad

Track

Parcels

N/A N/A N/A N/A N/A Yes No Yes Soils sampled; no further action.

aRadon was detected above 4 pCi/L, which is an EPA residential action level; there is no industrial/commercial EPA action level.

bPCB-containing transformers were documented to be present in or near this building at one time. The soil around the former locations of the transformers was investigated

and PCBs were not detected.

cThese spill incidents are documented in the building discussions.

LBP = Lead-based paint

PCBs = Polychlorinated biphenyls

-S = Suspected, based on age of structure and/or EBS visual survey.

Yes = The presence of ACM, radon, LBP, PCB-containing equipment,

contaminated soil, and/or groundwater has been documented.

LIDA Parcel = Parcels as defined in Benatec Parcel Maps (January 1998).

N/A = Not Applicable

No = No documented occurrence, or a documented occurrence below

applicable criteria (i.e., radon).

NS = Not surveyed or sampled.

HO = Heating oil

UST = Underground storage tank

AST = Aboveground storage tank

gal = gallons











FOST for Phase I Parcels at Letterkenny Army Depot

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APPENDIX B

REFERENCES
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APPENDIX B

REFERENCES

Archaeological & Historical Consultants, Inc. December 1996. Phase I

Archaeological Survey, Letterkenny Army Depot. Franklin County,

Pennsylvania.

Battelle. June 1983. Geophysical Survey of the Southeast Area of LEAD.

Battelle. September 1983. Environmental Contamination Survey of LEAD:

Southeast Industrial Area.

Battelle. October 1983. Environmental Contamination Survey of LEAD:

Property Disposal Office Drainage System.

Battelle. December 1983. Environmental Contamination Survey of LEAD:

Exploratory and Confirmatory Phases.

Battelle. May 1984. Environmental Contamination Survey of LEAD:

Multi-Phase Investigation Summary.

Becher, A.E. and L.E. Taylor. 1982. Groundwater Resources in the

Cumberland and Contiguous Valleys of Franklin County, Pennsylvania.

Pennsylvania Geological Survey Water Resources Report 53. Harrisburg,

Pennsylvania.

Berger Associates. 1981. Army Pollution Abatement Program Studies.

Building Technology Incorporated. July 1984. Historic Properties Report,

Letterkenny Army Depot.

Dames and Moore, Inc. 1993. Asbestos Survey - Letterkenny Army Depot.

Dames and Moore, Inc. 1996. Lead-Based Paint Survey—Letterkenny Army

Depot.

EA (EA Engineering, Science, and Technology). 1991. Site Investigation,

LEAD.

EMC (Environmental Management Consultants). July 1988. Asbestos

Survey, Building 663, Letterkenny Army Depot.

EMC (Environmental Management Consultants). 1988. Asbestos Survey -

Building 1, Letterkenny Army Depot.

EMS (Environmental Management Systems). 1989. Asbestos Assessment

Survey for Letterkenny Army Depot.
FOST for Phase I Parcels at Letterkenny Army Depot

REFERENCES

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EQM (Environmental Quality Management). August 1995. Dock 35

Closure Report, Letterkenny Army Depot.

ERM (Environmental Resources Management, Inc.). January 1995.

Letterkenny Army Depot - SWMU Site Investigation Follow-on Report, ELIN

A009.

ESE (Environmental Science & Engineering, Inc.). August 1986. Remedial

Investigation of the Disposal Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). September 1987.

Remedial Investigation of the Property Disposal Office Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). December 1987.

Remedial Investigation of the Southeastern Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). August 1993. Draft

Addendum to the Remedial Investigation of the Southeastern Area at

Letterkenny Army Depot Contamination Assessment of K Area Soils.

ESE (Environmental Science & Engineering, Inc.). September 1995. PDO

New OU #5 Site Investigation, PCBs in Rocky Spring Lake, Draft Report.

FCADC (Franklin County Area Development Corporation). 1993. 1993

Franklin County Data Book.

Franklin County Reuse Committee (now know as the Letterkenny

Industrial Development Authority [LIDA]). May 1997. Letterkenny Army

Depot Reuse Strategy Summary Report.

Geonex Corporation. August 1995. Draft Wetlands Mapping Report for

United States Army, Letterkenny Army Depot.

John Milner Associates. 1981. An Archaeological Reconnaissance of Proposed

Development Sites at the Letterkenny Army Depot.

Kearney, A.T. and The Earth Technology Corporation. February 1988.

RCRA Facility Assessment Phase I Preliminary Review of Solid Waste

Management Units.

Nature Conservancy, Pennsylvania Science Office. December 1992. An

Inventory of Significant Ecological Features of the Letterkenny Army Depot,

Franklin County, Pennsylvania.

Pennsylvania State University and Envirosphere Company. January 1985.

An Archaeological Overview and Management Plan for the Letterkenny Army

Depot.

R.E. Wright Environmental, Inc. July 1994. Draft Report for Building

Investigations for Radon Recommendations.
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REFERENCES

O:\02281016.005\fost1098\FOSTAPPB.doc 04/13/9910/23/98 B-3

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

Army Depot.

R.E. Wright Environmental, Inc. March 1997. Draft Report for Building

Investigations for Radon Recommendations, Letterkenny Army Depot.

Root, S.I. 1971 (Reprinted 1974). Geology and Mineral Resources of

Northeastern Franklin County, Pennsylvania. Pennsylvania Department of

Environmental Resources, Atlas 119ab. Harrisburg, Pennsylvania.

SS&M (Spots, Stevens and McCoy). December 1991. Letter to PADEP on

Closure of Storage Pad at Building S26-5, Letterkenny Army Depot.

USATHAMA (U.S. Army Toxic and Hazardous Materials Agency). 1980.

Installation Assessment of Letterkenny Army Depot, Report 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.

Versar, Inc. May 1994. Remedial Investigation/Feasibility Study Letterkenny

Army Depot Property Disposal Office Area, Operable Units 3 and 4, Work

Plan.

WESTON (Roy F. Weston, Inc.). 1984. LEAD Remedial Investigation and

Feasibility Study.

WESTON (Roy F. Weston, Inc.), 1991. RCRA Closure Plan and Site Specific

Safety Plan, Tin Shed 26-5, Letterkenny Army Depot, Chambersburg, PA.

WESTON (Roy F. Weston, Inc.). 1996. Phase I Environmental Baseline

Survey, Letterkenny Army Depot, BRAC 95 Action.

WESTON (Roy F. Weston, Inc.). 1997. Phase II Environmental Baseline

Survey (Preliminary Draft) Letterkenny Army Depot, BRAC 95 Action.

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

Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1997. Finding of Suitability to Lease (FOSL)

for Buildings 6, 9, 19, 412, 416, 500, 522, and 2291 (Final) Letterkenny Army

Depot.
FOST for Phase I Parcels at Letterkenny Army Depot

REFERENCES

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WESTON (Roy F. Weston, Inc.). 1998a. Decision Document for BRAC

Parcels 1 and 2, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998b. Decision Document for BRAC

Parcels 8 through 13, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998c. Decision Document for BRAC Parcel

24, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998d. Decision Document for BRAC Parcel

29, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998e. Decision Document for BRAC

Railroad Parcels, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). 1998f. Decision Document for BRAC

Buildings 6 and 9, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). September 1998g. Record of Decision for

Phase I Parcels, Letterkenny Army Depot.

Weston Services, Inc. 1989. EPRDA Soil Gas Investigation Report.
FOST for Phase I Parcels at Letterkenny Army Depot

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APPENDIX C

LIST OF ACRONYMS
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APPENDIX C

LIST OF ACRONYMS

AA Ammunition Area

ACM asbestos-containing material

ARRP Army Radon Reduction Program

ASTM American Society for Testing and Materials

ASTs aboveground storage tanks

BCT BRAC Cleanup Team

BEC BRAC Environmental Coordinator

BRAC Base Realignment and Closure

CECOM Communications-Electronics Command

CERCLA Comprehensive Environmental Response, Compensation, and

Liability Act of 1980

CFR Code of Federal Regulations

CLP Contract Laboratory Program

DA Disposal Area

DoD Department of Defense

DRMO Defense Reutilization and Marketing Office

EA Environmental Assessment

EBS Environmental Baseline Survey

ECP Environmental Condition of Property

EPA U.S. Environmental Protection Agency

FFA Federal Facilities Agreement

FOSL Finding of Suitability to Lease

FOST Finding of Suitability to Transfer

ft feet or foot

GEOLIS Geologic Logging and Interpretation System

IAG Interagency Agreement

IRP Installation Restoration Program

LBP lead-based paint

LEAD Letterkenny Army Depot

LIDA Letterkenny Industrial Development Authority

mg/kg milligrams per kilogram

NEPA National Environmental Policy Act

NPDES National Pollutant Discharge Elimination System

NRC Nuclear Regulatory Commission

OU operable unit

OVM organic vapor meter

PADEP Pennsylvania Department of Environmental Protection (formerly the 

Pennsylvania Department of Environmental Resources)

PADER Pennsylvania Department of Environmental Resources (Now 

PADEP)
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LIST OF ACRONYMS

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PCB polychlorinated biphenyl

pCi/L picocuries per liter

PDO Property Disposal Office

PID photoionization detector

POC point of contact

PP Proposed Plan

ppm parts per million

QA/QC quality assurance/quality control

RBC Risk-Based Concentrations

RCRA Resource Conservation and Recovery Act

REC Record of Environmental Consideration

RI remedial investigation

ROD Record of Decision

RR railroad

SVOCs semivolatile organic compounds

TAL Target Analyte List

TCL Target Compound List

TPH total petroleum hydrocarbons

μg/L micrograms per liter

USTs underground storage tanks

VOC volatile organic compound
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ENCLOSURE 6

SUMMARY OF BUILDING CONDITIONS, PHASE I TRANSFER

BUILDINGS, RESULTS OF FINAL VISUAL SURVEYS
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ENCLOSURE 6

SUMMARY OF BUILDING CONDITIONS

PHASE I TRANSFER BUILDINGS

RESULTS OF FINAL VISUAL SURVEYS

On 5 and 6 October 1998, the Letterkenny (LEAD) BRAC Cleanup Team (BCT), along

with representatives from the Letterkenny Industrial Development Authority (LIDA),

completed the final walkthrough visual survey of the Phase I buildings. The purpose of the

visual surveys was to assess the current conditions of the Phase I buildings. Particular attention

was given to the current condition of accessible known asbestos-containing material (ACM) and

lead-based paint (LBP). Accessible ACM is defined as material that would be accessible to

occupants of a building under normal conditions. The visual survey for the condition of the

ACM did not include sampling or surveys of areas not normally accessible (i.e., crawl spaces,

areas above ceilings) to the building occupants.

Table 6-1 is a summary of the current building conditions, which includes accessible

ACM, radon, condition of LBP, documented spills (as of 1 October 1998), presence of UST/AST,

and comments. The Phase I buildings do not currently have PCB-containing transformers

associated with them.

Damaged accessible ACM was noted at some of the buildings during the final visual

survey. The Army has removed and disposed of loose ACM and encapsulated the edges of

damaged ACM with paint.
MK01|O:\02281016.005\FOST1098\FOST_E6.DOC 04/13/99 2

Table 6-1

Summary of Current Environmental Conditions

Phase I Buildings

(October 1998)

Letterkenny Army Depot

LIDA

Parcel Building

Accessible

ACM

Condition of

LBP

Storage

Tank Spills Comments

3 9 Transite – Roof Trusses Good No Yesb Radon detected above criteriaa.

4 6 Transite – Roof Trusses

Floor Tile – Limited Areas

Good No No Loose floor tile removed.

5 S-20-1 N/A – Demolition N/A – Demolition 500-gal

AST-HO

No Building planned for demolition.

5 S-20-2 No N/A – Demolition No No Building planned for demolition.

5 S-20-3 No N/A – Demolition No No Building planned for demolition.

5 S-20-4 No N/A – Demolition No No Building planned for demolition.

5 S-20-5 No N/A – Demolition No No Building planned for demolition.

7 238 N/A – Demolition N/A – Demolition 5000-gal

UST-HO

Yesb Building planned for demolition.

8 and 9 S-26-4 N/A – Age of Building Good No No

10-13 Dock Storage

Open Sheds

No N/A – Demolition No Yesb Demolition of sheds underway.

16 34 Transite – Doors, Vents, Valve Houses

Floor Tile – Small Office

Outside Doors – Small Area of

Paint in Poor Condition

No No Loose transite removed, edges

encapsulated with paint.

17 44 Transite - Doors, Vents, Valve Houses Outside Doors – Small Area of

Paint in Poor Condition

No No Loose transite removed, edges

encapsulated with paint.

18 43 Transite – Doors, Vents, Valve Houses,

Roof Trusses

Pipe Insulation – Heating Pipes

Outside Doors – Small Area of

Paint in Poor Condition

7,500-gal

UST-HO

Yesb Loose transite removed, edges

encapsulated with paint.

19 54 Transite – Valve Houses, Roof Trusses Outside Doors – Small Area of

Paint in Poor Condition

No No Loose transite removed, edges

encapsulated with paint.

20 53 Transite – Doors, Vents, Valve Houses Outside Doors – Small Area of

Paint in Poor Condition

No No Loose transite removed, edges

encapsulated with paint.
Table 6-1

Summary of Current Environmental Conditions

Phase I Buildings

(October 1998)

Letterkenny Army Depot

(Continued)

MK01|O:\02281016.005\FOST1098\FOST_E6.DOC 04/13/99 3

LIDA

Parcel Building

Accessible

ACM

Condition of

LBP

Storage

Tank Spills Comments

21 52 Transite – Doors Valve Houses Outside Doors – Small Area of

Paint in Poor Condition

No No Loose transite removed, edges

encapsulated with paint.

23 412 No Paint on Window Sills Peeling

50% of the sills are over grass/soil;

50 % are over pavement

500-gal

AST-HO

Yesb Documented ACM in building; no

longer accessible.

23 T-410 Not Suspected Good 275-gal

AST-HO

No

23 411 No Good No No

23 416 N/A – Age of Building N/A – Age of Building 1,000-gal

UST-HO

No

23 417 N/A – Age of Building N/A – Age of Building 1,000-gal

UST-HO

No

23 418 N/A – Age of Building N/A – Age of Building 1,000-gal

UST-HO

No

23 T-455 No Good No No

24 500 Floor Tile

Pipe Insulation

Good 5,000-gal

UST-HO

Yesb

25 19 Transite – Doors, Walls (south half),

Ceilings, Roof of Loading Docks

Pipe Insulation – From Boiler Room

Good 7,500-gal

UST-HO

Yesb Loose transite removed, edges

encapsulated with paint. Pipe

insulation repaired.

25 590 No Good No No

26 581 N/A – Demolition N/A – Demolition 500-gal

AST-HO

No Building planned for demolition.

28 524 N/A – Age of Building N/A – Age of Building 550-gal

UST-HO

No

33 637 Floor Tile

Pipe Insulation – Closet

Good No No Pipe insulation repaired.
Table 6-1

Summary of Current Environmental Conditions

Phase I Buildings

(October 1998)

Letterkenny Army Depot

(Continued)

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LIDA

Parcel Building

Accessible

ACM

Condition of

LBP

Storage

Tank Spills Comments

33 639 Transite – Storage Room, 2nd Floor

Floor Tile – Office

Outside – Masonary – Peeling

Outside – Wood Porch – Good

Condition

3,000-gal

UST-HO

No Radon detected above criteriaa.

aRadon was detected above 4 pCi/L, which is an EPA residential action level; there is no industrial/commercial EPA action level.

bThese spill incidents are documented in the building discussions.

LBP = Lead-based paint

PCBs = Polychlorinated biphenyls

Yes = Spills have been documented at this building. For

details, see building discussions in Enclosure 5,

Appendix A.

LIDA Parcel = Parcels as defined in Benatec Parcel Maps (January

1998).

N/A = Not Applicable

No = No documented occurrence.

HO = Heating oil

UST = Underground storage tank

AST = Aboveground storage tank

gal = gallons
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ENCLOSURE 7

ENVIRONMENTAL DEED PROVISIONS
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ENCLOSURE 7 - ENVIRONMENTAL DEED

PROVISIONS

1. STATUTORY INDEMNIFICATION

Subject to the availability of appropriated funds, the GRANTOR recognizes its

obligation to hold harmless, defend, and indemnify the GRANTEE and any successor, assignee,

transferee, lender, or lessee of the GRANTEE or its successors and assigns, as required and

limited by Section 330 of the Department of Defense Authorization Act of 1993, as amended,

and to otherwise meet its obligations under law.

2. CERCLA COVENANT AND NOTICE

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

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

A. Notice. The GRANTOR hereby notifies the GRANTEE of the storage, release, and

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

substances was remedied at the time of the release or, where required, was subsequently

addressed under the installation restoration program. For the purpose of this Deed, "hazardous

substances" shall have the same meaning as Section 101(14) of CERCLA. Available information

regarding the type, quantity, and location of such substances and the action taken is

summarized in Exhibit D hereto [Exhibit D of the Deed is Notification of Hazardous Substances

Storage, Release or Disposal]. More detailed information regarding the storage, release, and

disposal of hazardous substances on the Property has been provided to the GRANTEE in the

Environmental Baseline Survey for Letterkenny Army Depot dated August 1996 the receipt of

which the GRANTEE hereby acknowledges.

B. Covenant. The GRANTOR hereby covenants that:

1. All remedial action necessary to protect human health and the environment

with respect to any such hazardous substances remaining on the Property as of the date of this

conveyance has been taken; and

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

hazardous substances remaining on the Property as of the date of this conveyance shall be

conducted by the GRANTOR. This covenant in this Subsection B(2) shall not apply in any case

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

party under CERCLA with respect to the Property.

3. LAND USE RESTRICTIONS

The Department of the Army has undertaken careful environmental study of the

Property and concluded that the highest and best use of the Property is limited by its

environmental condition to commercial and industrial uses. In order to protect human health
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

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and the environment, promote community objectives, and further the common environmental

objectives and land use plans of the GRANTOR, Commonwealth of Pennsylvania, and

GRANTEE, the covenants and restrictions shall be included to assure the use of the Property is

consistent with the environmental condition of the Property. The following restrictions and

covenants benefit both the lands retained by the GRANTOR and the general public welfare and

are consistent with the Commonwealth of Pennsylvania and Federal environmental statutes.

A. Commercial/Industrial Use Restrictions

1. The GRANTEE covenants for itself, its successors and assigns, that the

Property shall be used solely for commercial, industrial and agricultural purposes and not for

residential purposes, the Property having been remediated only for commercial and industrial

uses. Commercial and industrial uses include, but are not limited to, administrative/office

space, manufacturing, warehousing, restaurants, hotels/motels, and retail activities.

Residential use includes, but is not limited to, housing, day care facilities, schools (excluding

education and training programs for persons over 18 years of age), assisted living facilities, and

outdoor recreational activities (excluding recreational activities by employees and their families

incidental to authorized commercial and industrial uses on the Property).

2. Nothing contained herein shall preclude the GRANTEE from undertaking, in

accordance with applicable laws and regulations, such additional remediation necessary to

allow for residential use of the Property. Any additional remediation will be at no additional

cost to the GRANTOR and with the GRANTOR's prior written consent. Consent may be

conditioned upon such terms and conditions as the GRANTOR deems reasonable and

appropriate, including performance and payment bonds and insurance. Upon completion of

such remediation required to allow residential use of the Property and upon the GRANTEE's

obtaining the approval of the Environmental Protection Agency (EPA) and the Pennsylvania

Department of Environmental Protection (PADEP) and, if required, any other regulatory

agency, the GRANTOR agrees to release or, if appropriate, modify this restriction by executing

and recording, in the same land records of the Commonwealth of Pennsylvania as the deed, a

Partial Release of Covenant. GRANTEE shall bear the cost of recording and reasonable

administrative fees.

B. Ground Water Restriction

The GRANTEE covenants for itself, its successors and assigns, not to access the ground

water, except as provided in Section 3C, or use ground water underlying the property for any

purpose without the prior written approval of GRANTOR, PADEP and the EPA. However, the

GRANTEE, its successors and assigns, are authorized to install monitoring wells with the prior

written approval of the GRANTOR, EPA and PADEP, which approval shall not be

unreasonably withheld. For the purpose of this restriction, "ground water" shall have the same

meaning as in section 101(12) of the Comprehensive Environmental Response, Compensation

and Liability Act (CERCLA).

C. Soil Excavation Restrictions

The GRANTEE, its successors and assigns, shall not conduct or permit others to: (1)

conduct any excavation, digging, drilling, or other disturbance of the soil or ground below a
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

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depth of 3 feet above the water table without prior written approval of the GRANTOR or (2)

construct any subsurface structure for human occupation, without the prior written approval of

the GRANTOR, PADEP, and the EPA. If the GRANTEE, its successors or assigns, encounters

ground water or contaminated soil while conducting any excavation activities, the GRANTEE,

its successors or assigns, will immediately cease such activities until the GRANTOR'S written

approval is obtained allowing such activities to continue. In granting excavation approval

under this Subsection C, the GRANTOR may impose reasonable terms and conditions, on a case

by case basis, that the GRANTOR deems necessary to (i) ensure compliance with the LIDA

Sampling plan dated October 1998 and any amendments thereto, the LIDA Health Safety plan

dated October 1998 and any amendments thereto, and other applicable requirements to protect

human health and the environment and (ii) to ensure proper disposal of contaminated soil

and/or groundwater at no expense to the GRANTOR.

D. Enforcement

1. The above covenants and land use restrictions shall inure to the benefit of the

public in general and adjacent lands, including lands retained by the United States, and,

therefore, are enforceable by the United States Government and Commonwealth of

Pennsylvania. These restrictions and covenants are binding on the GRANTEE, its successors

and assigns; shall run with the land; and are forever enforceable.

2. The GRANTEE covenants for itself, its successors and assigns, that it shall

include and otherwise make legally binding the above land use restrictions in all subsequent

lease, transfer or conveyance documents relating to the Property subject hereto.

Notwithstanding this provision, failure to include these land use restrictions in subsequent

conveyances does not abrogate the status of these restrictions as binding upon the parties, their

successors and assigns.

3. The GRANTEE, for itself, its successors and assigns, covenants that it will not

undertake or allow any activity on or use of the Property that would violate the land use

restrictions contained herein.

4. Notwithstanding any other provision of this Deed; any agreement between

the GRANTEE and the GRANTOR; the provisions of CERCLA, including CERCLA Section

120(h)(3); or Section 330 of the National Defense Authorization Act of 1993, as amended, the

GRANTEE on behalf of itself, its successors and assigns, covenants and agrees that the

GRANTEE or the then record owner of the Property will be fully responsible for any

investigation and/or remediation of hazardous substances, pollutants or contaminants, or

petroleum or petroleum derivatives, to the extent that such investigation and/or remediation

becomes necessary in response to a violation of the land use restrictions in this Section 3.

E. Submissions

1. Modification of Restrictions. The GRANTEE shall submit any requests to

install monitoring wells, to construct subsurface structures for human occupation, or for other

modifications to the above restrictions to GRANTOR, with a copy to EPA and PADEP, by first

class mail, postage prepaid, addressed as follows:
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

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a. to GRANTOR: Commander

Letterkenny Army Depot

1 Overcash Avenue

Chambersburg, Pennsylvania 17201-4150

b. to EPA: EPA Region 3

Superfund Federal Facilities Branch

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

c. to PADEP: Pennsylvania Department of Environmental Protection

Environmental Clean-up Program

909 Elmerton Avenue

Harrisburg, Pennsylvania 17110-8200

2. Excavation Requests. GRANTEE shall submit all requests for excavation

approval as required by Section 3C to the GRANTOR at the mailing address set forth in

Subsection 3E above.

4. CERCLA REMEDIATION

The GRANTOR acknowledges that Letterkenny Army Depot has been identified as a

National Priority List (NPL) site under the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA) of 1980, as amended. The GRANTEE acknowledges

that the GRANTOR has provided it with a copy of the Letterkenny Federal Facility Agreement

(FFA) dated February 3, 1989 and will provide the GRANTEE with a copy of any amendments

thereto.

A. The GRANTEE, its successors and assigns, agrees that should any conflict arise

between the terms of the FFA as they presently exist or may be amended, and the provisions of

this property transfer, the terms of the FFA will take precedence. The GRANTEE, its successors

and assigns, further agrees that notwithstanding any other provisions of the property transfer,

the United States assumes no liability to the GRANTEE, its successors and assigns, should

implementation of the FFA interfere with their use of the Property; and said parties shall have

no claim against the United States or any officer, agent, employee or contractor thereof on

account of any such interference, provided the GRANTOR complies with the requirements of

Section 4(D).

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

under CERCLA and the FFA for the Letterkenny Army Depot site:

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 clean-up at the

Letterkenny Army Depot NPL site. Activities required to avoid interference with the

completion of the CERCLA clean-up at Letterkenny Army Depot include but are not limited to

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

directed into existing or future stormwater sewer systems or drainage ditches; and
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

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

controls established or put in place by the GRANTOR relating to the Property which are

required by any Record of Decision ("ROD") or amendments thereto issued before or after the

date of this Deed. Additionally, the GRANTEE, its successors and assigns, shall ensure that any

leasehold it grants in the Property or any fee interest conveyance of any portion of the Property

provides for legally binding compliance with the institutional controls required by any such

ROD.

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

its successors and assigns, shall be expressly subject to the rights and duties of the United States

to continue operation of any monitoring wells, treatment facilities, or other response activities

undertaken pursuant to CERCLA or the FFA on said portion of the Property. The GRANTEE,

its successors and assigns, shall provide:

1. Pre-transfer Notice - 60 days written notice of any such conveyance (including

a description of the deed/lease provisions allowing for continued remediation activities) to the

GRANTOR, EPA, and PADEP; and

2. Deed/lease - Within 14 days after the effective date of the transaction,

GRANTEE, its successors and assigns, will provide to the GRANTOR, EPA, and PADEP, copies

of the deed, lease, or other conveying instrument evidencing such transaction.

D. The GRANTOR reserves a perpetual easement over and through and a right of

access to the Property to perform any additional environmental investigation, monitoring,

sampling, testing, remedial action, corrective action, or any other action necessary for the

GRANTOR to meet its environmental responsibilities under applicable laws and as provided

for in the Deed. This easement and right of access shall be binding on the GRANTEE, its

successors and assigns, and shall run with the land. This reservation includes the right to access

and use utilities on the Property at reasonable cost to the United States. In exercising this right

of access, except in case of imminent endangerment to human health or the environment, the

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

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

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

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

action found to be necessary after the date of transfer unless the GRANTEE, its successors or

assigns, is able to demonstrate that such release or such newly discovered substance was due to

GRANTOR's activities, ownership, use or occupation of the Property, or the activities of

GRANTOR's contractors and/or agents.

F. All subsequent leases, transfers, or conveyances shall be made expressly subject to

this easement. Upon a determination by the United States that all remedial action is complete at

the Letterkenny Army Depot NPL site, the GRANTOR shall execute and record a release of

easement.
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

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5. NOTICE OF THE PRESENCE OF ASBESTOS AND COVENANT

A. The GRANTEE is hereby informed and does acknowledge that friable and nonfriable asbestos or asbestos-containing materials ("ACM") has been found in buildings and

structures on the Property, as described in the final base-wide EBS [Letterkenny Army Depot

Phase I EBS, August, 1996]. To the best of the GRANTOR'S knowledge, the ACM in buildings

and structures on the Property does not currently pose a threat to human health or the

environment, and all friable asbestos that posed a risk to human health has either been removed

or encapsulated.

B. The GRANTEE covenants and agrees that its use and occupancy of the Property will

be in compliance with all applicable laws relating to asbestos; and that the Army assumes no

liability for future remediation of asbestos or damages for personal injury, illness, disability, or

death, to the GRANTEE, its successors or assigns, or to any other person, including members of

the general public, arising from or incident to the purchase, transportation, removal, handling,

use, disposition, or other activity causing or leading to contact of any kind whatsoever with

asbestos on the Property, whether the GRANTEE, its successors or assigns, have properly

warned or failed to properly warn the individual(s) injured. The GRANTEE agrees to be

responsible for any future remediation of asbestos in buildings and structures found to be

necessary on the Property.

C. Unprotected or unregulated exposures to asbestos in product manufacturing,

shipyard, and building construction workplaces have been associated with asbestos-related

diseases. Both the Occupational Safety and Health Administration (OSHA) and the

Environmental Protection Agency (EPA) regulate asbestos because of the potential hazards

associated with exposure to airborne asbestos fibers. Both OSHA and EPA have determined

that such exposure increases the risk of asbestos-related diseases, which include certain cancers

and which can result in disability or death.

D. The GRANTEE acknowledges that it has inspected the Property as to its asbestos

content and condition and any hazardous or environmental conditions relating thereto. The

GRANTEE shall be deemed to have relied solely on its own judgment in assessing the overall

condition of all or any portion of the Property, including, without limitation, any asbestos

hazards or concerns.

E. Notwithstanding the provisions of Section 5.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 asbestos containing materials (ACM) in

buildings and structures, or whether the property is or is not suitable for a particular purpose.

Furthermore, the GRANTEE agrees to make no claim or demand against the United States

based on the presence of asbestos or ACM in buildings and structures on the Property.

6. 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 which were constructed or rehabilitated prior to 1978, are presumed to contain leadbased paint. Lead from paint, paint chips, and dust can pose health hazards if not managed
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ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

MK01|O:\02281016.005\FOST1098\FOST_E7.DOC 04/13/99 7

properly. Every purchaser of any interest in Residential Real Property on which a residential

dwelling was built prior to 1978 is notified that such property may present exposure to lead

from lead-based paint that may place young children at risk of developing lead poisoning. Lead

poisoning in young children may produce permanent neurological damage, including learning

disabilities, reduced intelligence quotient, behavioral problems, and impaired memory. Lead

poisoning also poses a particular risk to pregnant women. The seller of any interest in

residential real property is required to provide the buyer with any information on lead-based

paint hazards from risk assessments or inspections in the seller's possession and notify the

buyer of any known lead-based paint hazards. "Residential Real Property" means any housing

constructed prior to 1978, except housing for the elderly (households reserved for and

composed of one or more persons 62 years of age or more at the time of initial occupancy) or

persons with disabilities (unless any child who is less than 6 years of age resides or is expected

to reside in such housing) or any 0-bedroom dwelling.

B. Available information concerning known lead-based paint and/or lead-based paint

hazards, the location of lead-based paint and/or lead-based paint hazards, and the condition of

painted surfaces is contained in the Environmental Baseline Survey and (for residential

properties) the lead-based paint risk assessment, which have been provided to the GRANTEE.

All purchasers must receive the federally-approved pamphlet on lead poisoning prevention.

The GRANTEE hereby acknowledges receipt of all of the information described in this

subparagraph.Additionally, the report entitled Lead Based Paint Survey- Letterkenny Army Depot

prepared by Dames and Moore, Inc. in 1996 pertaining to lead-based paint and/or lead-based

paint hazards has been provided to the GRANTEE.

C. The GRANTEE acknowledges that it has received the opportunity to conduct its own

risk assessment or inspection for the presence of lead-based paint and/or lead-based paint

hazards prior to execution of this document.

D. The GRANTEE covenants and agrees that it shall not permit the occupancy or use of

any buildings or structures on the Property as Residential Real Property without complying

with this section and all applicable federal, state, and local laws and regulations pertaining to

lead-based paint and/or lead-based paint hazards. Prior to permitting the occupancy of the

Property where its use subsequent to sale is intended for residential habitation, the GRANTEE

specifically agrees to perform, at its sole expense, the Army's abatement requirements under

Title X of the Housing and Community Development Act of 1992 (Residential Lead-Based Paint

Hazard Reduction Act of 1992) (hereinafter Title X).

The GRANTEE shall, after consideration of the guidelines and regulations established

pursuant to Title X: (1) comply with the joint HUD and EPA Disclosure Rule (24 CFR 35,

Subpart H, 40 CFR 745, Subpart F), when applicable, by disclosing to prospective purchasers the

known presence of lead-based paint and/or lead-based paint hazards as determined by

previous risk assessments; (2) abate lead-based paint hazards in pre-1978 buildings and

structures in paint, dust and bare soil in accordance with the HUD Guidelines, with the

addition of abatement of bare soil with lead levels higher than 2000 ppm; and (3) comply with

the EPA lead-based paint work standards when conducting lead-based paint activities (40 CFR

745, Subpart L). In cases where a transfer MOA has already been executed as of August 14,

1998, the GRANTEE is responsible for conducting lead-based paint activities in accordance with

the negotiated MOA transfer documents.
FOST for Phase I Parcels at Letterkenny Army Depot

ENCLOSURE 7—ENVIRONMENTAL DEED PROVISIONS

MK01|O:\02281016.005\FOST1098\FOST_E7.DOC 04/13/99 8

In complying with these requirements, the GRANTEE covenants and agrees to be

responsible for any abatement or remediation of lead-based paint or lead-based paint hazards

on the Property found to be necessary as a result of the subsequent use of the property for

residential purposes. The GRANTEE covenants and agrees to comply with solid or hazardous

waste laws that may apply to any waste that may be generated during the course of lead-based

paint abatement activities.

E. The covenants, restrictions, and requirements of this Section_6 shall be binding upon

the GRANTEE, its successors and assigns, and shall be deemed to run with the land. The

GRANTEE on behalf of itself, its successors and assigns, covenants that it will include and make

legally binding, this Section 6 in all subsequent transfers, leases, or conveyance documents.

7. NOTIFICATION OF THE PRESENCE OF RADON AND COVENANT

Available and relevant radon assessment data pertaining to the Property is located in the

"LEAD Phase 1 Environmental Baseline Survey" (EBS), dated August 1996. According to said

radon assessment data, those structures shown as Buildings 6, 9, 44, and 639 may contain

unhealthy levels of radon if those buildings are used for residential purposes. The Grantor shall

not be responsible for remediation of naturally occurring radon on the Property. The Grantee,

its successors and assigns, shall not permit the occupancy of said Buildings 6, 9, 44, and 639 for

residential use without first abating and eliminating the radon hazard, to the extent required by

law, in accordance with applicable regulatory standards and guidelines. This covenant shall

run with the land. The Grantee shall ensure that any assignee, transferee, affiliate, successor, or

foreclosure purchaser of the property shall be bound by the provisions hereof.

8. INCLUSION OF PROVISIONS

The GRANTEE, its successors and assigns, shall neither transfer the Property, lease the

Property, nor grant any interest, privilege, or license whatsoever in connection with the

Property without the inclusion of the environmental protection provisions contained herein,

and shall require the inclusion of such environmental protection provisions in all further deeds,

transfers, leases, or grants of any interest, privilege, or license.
FOST for Phase I Parcels at Letterkenny Army Depot

MK01|O:\02281016.005\FOST1098\FOST_BKR.DOC 04/13/99

ENCLOSURE 8

REGULATORY AGENCY CONCURRENCE LETTERS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

Mr. Bryan Hoke

BRAC Environmental Coordinator

SIOLE-CO, Bldg. 522

Letterkenny Anny Depot

Chambersburg, PA 17201-4150

Re: Finding of Suitability to Transfer

Phase I Parcels

Letterkenny Army Depot, Chambersburg, PA

Dear Mr. Hoke:

OCT 2 6 J99B

This letter is in response to the Anny's request for EPA comments on a Finding of

Suitability ofTransfer (FOST) for the Phase I Parcels of property located in Chambersburg, PA.

as submitted to EPA electronically by Stan Citron, HQDA, on October 23, 1998.

EPA has no comments on the subject FOST. Based on EPA's review ofthe FaST and

without any independent verification ofthe information contained or referenced therein, EPA

fmds that the FaST is sufficient to support the transfer ofthe subject property under the tenns

described therein.

EPA reserves all rights and authorities relating to information not contained or referenced

in this document whether or not such information was known when this document was issued or

discovered after such issuance.

This letter should accompany the subject document in an administrative record for the

Phase I Parcels which is available to the public for review.

If you have any questions regarding the above, please contact Stacie Driscoll of my staff

at (215) 814-3368.

Sincerely,

~~,~e~ A~~ Ferdas. Director

Hazardous Site Cleanup Division

cc: Noreen Wagner, PADEP

Customer Service Hotline: 1-800-438-2474
Pennsylvania Department of Environmental Protection

909 Elmerton Avenue

Harrisburg, Pennsylvania 17110-8200

October 26, 1998

717-705-4704

FAX 717-705-4930

Southcentral Regional Office

Mr. Bryan Hoke

BRAC Environmental Coordinator

SIOLE-CO, Building 522

Letterkenny Anny Depot

One Overcash Avenue

Chambersburg, PA 17201-4150

Re: Phase I Parcels

Finding of Suitability to Transfer

Concurrence Letter

Dear Mr. Hoke:

We have completed our review ofthe Finding of Suitability to Transfer (FaST) for the Phase I

Parcels at Letterkenny Anny Depot, which was received by the Department ofEnvironmental Protection

(DEP) on October 23, 1998. Our comments have been incorporated into the above document and DEP

has no additional comments.

This FaST supports the Record ofDecision (ROD) issued in September 1998 which documents

the selection ofinstitutional controls as the remedial action for the Phase I Parcels. The institutional

controls prohibit non-industrial use ofthe parcels and activities that would result in any exposure to

contaminants in the groundwater.

DEP hereby concurs with the proposed FaST, subject to the following condition. DEP reserves

its right and responsibility to take independent enforcement actions pursuant to state law.

Thank you for the opportunity to comment on the Finding of Suitability to Transfer. Ify~u have

any questions regarding this matter, please do not hesitate to contact me at 717-705-4704.

Sincerely,

~~(~ Regional Director

cc: Abraham Ferdas

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