®



# Finding of Suitability to Transfer (FOST) for the

Phase II BRAC Parcels Letterkenny Army Depot

U.S. Army Corps of Engineers

Baltimore District

February 2002

01P-2009 L E T T E R K E N N Y

P

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

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

Dynamic Future



# FinalO:\02281016.008\PHIIFOST_F.DOC 

### FINAL

FINDING OF SUITABILITY TO TRANSFER (FOST) FOR THE

PHASE II BRAC PARCELS

LETTERKENNY ARMY DEPOT

Prepared for

U.S. ARMY CORPS OF ENGINEERS

HTRW-EN-HM
Baltimore District Baltimore, Maryland 21201

and

LETTERKENNY ARMY DEPOT
1 Overcash Avenue Chambersburg, Pennsylvania 17201

Prepared by

ROY F. WESTON, INC. 1400 Weston Way

P.O. Box 2653 West Chester, Pennsylvania 19380

February 2002

W.O. No. 02281.016.008.3100Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### ii 

## TABLE OF CONTENTS

Section Page

1. P UR P OSE

....................................................................................................................... . .. 1

2. P R O P ERTY DESCRI P T ION

.......................................................................................... 2

3. ENVIRONMENTAL CONDITION OF THE P R O P ERT Y

......................................... 3

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

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

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

3.3.1 Underground and Aboveground Storage Tanks (USTs/ASTs)................... 4 3.3.2 Non-UST/AST Storage, Release, or Disposal of Petroleum Products........ 5

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

3.5 ASBESTOS............................................................................................................. 6

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

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

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

3.9 UNEXPLODED ORDNANCE (UXO)................................................................... 8

4. ADJACENT HA Z ARDOUS CONDITION S

.................................................................. 9

5. REMEDIATION

............................................................................................................. 10

6. RE G U LATORY AND P U BLIC COORDINATIO N

................................................... 12

7. NA T IONAL E NVIRONM E N T AL P O L I CY ACT (N E P A) COM P L I ANCE

AND CONSISTENCY WITH REUSE P L A N

.............................................................. 13

8. F INDING OF SUITABILITY TO TRANS F E R

.......................................................... 14

E NC L O S URE 1— S I T E MA P S OF P R O P O S E D T RAN S F E R AR E AS ( F I G UR E S 1 AND 2)

ENCLOSURE 2—TABLE 1, P R O P ERTY DESCRI P T ION OF P H ASE II BRAC

P ARC ELS F OR THE F OST

ENCLOSURE 3—TABLE 2, NOTI F ICATION OF HA Z ARDOUS SUBSTANCE

STORA G E, RELEASE, AND/OR DIS P OSAL

ENCLOSURE 4—TABLE 3, NOTI F ICATION OF P ETROLEUM P R ODUCT

STORA G E, RELEASE, AND/OR DIS P OSAL

E NC L O S URE 5—A PP E NDIX A— S UMMARY OF P ARC E L AND B UI L DING

CONDI T I ON S

, F O S T F O R T H E P H A S E II B RAC P ARC EL SLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)



## TABLE OF CONTENTS (Continued)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### iii E NC L O S URE 6— S UMMARY OF B U I L DING AND P ARC E L CONDI T I ON S

, P H A S E II

P R O P E R T Y T RAN S F E R, R E S U LT S OF F I NAL VI S UAL S URV E YS

E NC L O S URE 7— E NVIRONM E N T A L P R O TE C T I ON P R OVI S IONS

ENCLOSURE 8—RE G ULATORY A G ENCY CONCURRENCE LETTERS

E NC L O S URE 9—R E F E R E NC E S AND B I BL I O G RA P HYLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

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

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### iv 

## LIST OF ACRONYMS

AA Ammunition Area

ACM asbestos-containing material

AMC Army Materiel Command

AST aboveground storage tank

BRAC Base Realignment and Closure

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CERFA Community Environmental Response Facilitation Act

CFR Code of Federal Regulations

DoD U.S. Department of Defense

DOP diophiothalate

DRMO Defense Reutilization and Marketing Office

EA environmental assessment

EBS environmental baseline survey

ECP environmental condition of property

EPA U.S. Environmental Protection Agency

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

FFA Federal Facilities Agreement

FONSI Finding of No Significant Impact

FOST Finding of Suitability to Transfer

FPT former PCB-containing transformer

ft bgs feet below ground surface

ft 2 square feet

gal gallon

Hg mercury

HUD U.S. Department of Housing and Urban Development

I.D. identification

LBP lead-based paint

LEAD Letterkenny Army Depot

LIDA Letterkenny Industrial Development Authority

LUCAP Land Use Control Assurance Plan

LUCIP Land Use Control Implementation Plan

μg/g micrograms per gram

μg/L micrograms per liter

mg/kg milligrams per kilogram

MOA Memorandum of AgreementLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)



## LIST OF ACRONYMS (Continued)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### v NEPA National Environmental Policy Act

NPL National Priorities List

NRC Nuclear Regulatory Commission

OSHA Occupational Safety and Health Administration

PADEP Pennsylvania Department of Environmental Protection

PCB polychlorinated biphenyl

pCi/L picoCuries per liter

PDO Property Disposal Office

PP Proposed Plan

PX post exchange

RA risk assessment

RI remedial investigation

ROD Record of Decision

SE Southeastern

SI site investigation

SLRA screening level risk assessment

SSTP sanitary sewage treatment plant

TCA 1,1,1-trichloroethane

TCE trichloroethylene

TMDE Testing Measurements Diagnostic and Engineering Building

UDLP United Defense Limited Partnership

UST underground storage tank

UXO unexploded ordnance

VOC volatile organic compound

WESTON® Roy F. Weston, Inc.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 1 

## 1. PURPOSE

The purpose of this Finding of Suitability to Transfer (FOST) is to document environmental conditions at selected parcels and buildings (Phase II parcels) at the Letterkenny Army Depot (LEAD or the Depot) for transfer to the Letterkenny Industrial Development Authority (LIDA) consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120(h) and U.S. Department of Defense (DoD)/Army policy. In addition, the FOST identifies use restrictions, as specified in the attached Environmental Protection Provisions ( Enclos u re 7 ), necessary to protect h u man health and

the environment after such transfer.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 2 

## 2. PROPERTY DESCRIPTION

LEAD is located in south-central Pennsylvania in Franklin County, 5 miles north of the Borough of Chambersburg, PA. The Depot covers 19,243 acres, most of which is devoted to ammunition storage (16,614 acres). The
industrial, maintenance, and recreational areas, which are located primarily in the southeastern corner of LEAD, encompass approximately 2,500 acres. The Base Realignment and Closure (BRAC) parcel consists of approximately 1,465 acres.

The LEAD Phase II FOST property consists of approximately 358 acres, which includes 70 buildings on 298 acres and approximately 60 acres of roads. Due to groundwater contamination, the property will be transferred by a limited depth transfer, which means that the property to be transferred includes buildings, structures, and soil from the ground surface down to a depth of 8 feet below ground surface (ft bgs), which is above the seasonal high groundwater table. This transfer will not include contaminated groundwater that lies below the property. The subsurface property will be transferred to LIDA after a final remedy for the groundwater is in place and operating properly and successfully.

The Phase II BRAC parcels were previously used for industrial operations, supply storage, administration and recreational activities, and military housing. Prior to the establishment of LEAD, the area consisted of agricultural (predominantly single-family farms used for both subsistence and commercial purposes) and forest lands. The intended future property use of the Phase II parcels includes industrial/commercial/agricultural, as described in the LIDA Reuse Plan (FCRC, 1997) and as defined in Subsection 3.A.1 of the Environmental Protection Provisions provided in Enclosure 7. The future uses of the portions of the property designated as Parcels 2-74A and 2-74B potentially include uses that are less restrictive than industrial/commercial/agricultural (e.g., educational or daycare).

The locations of the parcels are shown in Fig u re 1 (land parcels) and Fig u re 2 (road parcels), which are incl u d ed in Enclos u r e 1 . Information

abo u t these parcels and b u ildings is s u mmarized in Enclos u r e 5 (Appendix A). More details about these buildings can be obtained from the LEAD Environmental Baseline Survey (EBS) (WESTON, 1996), the LEAD EBS Addendum (WESTON, 1999a), and Supplement 1 of the LEAD EBS (WESTON, 2000a).Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 3 

## 3. ENVIRONMENTAL CONDITION OF THE PROPERTY

The Army has determined the environmental condition of the proposed parcels and buildings to be transferred based on the LEAD EBS (WESTON, 1996), the LEAD EBS Addendum (WESTON, 1999a), Supplement 1 to the LEAD EBS (WESTON, 2000a), and the Community Environmental Response Facilitation Act (CERFA) Report (WESTON, 1997a). A complete review of LEAD, U.S. Environmental Protection Agency (EPA), and Pennsylvania Department of Environmental Protection (PADEP) files was conducted while developing the LEAD EBS, which provided information on the environmental condition of the property. A list of environmental documents that provided information to prepare the FOST is provided in

Enclos u r e 9 , References and Bibliography. The review of doc u ments, the EBS visual site inspections (1996, 1999, and 2000) and the final site inspections constitute an EBS specific to the transfer parcels. The conditions

n

o

ted duri n g t h

e fi n al site i n spectio n

s are provided in E n closure 6

.

In order to document the interim remedy for groundwater (environmental provisions with groundwater restrictions), and to document that the groundwater restrictions and future land use restrictions will ensure protection of human health and the environment, and because the property to be transferred is part of a National Priorities List (NPL) site, a Proposed Plan (PP) (WESTON, 2001a) and a Record of Decision (ROD) (WESTON, 2001e) have been prepared for the Phase II parcels.

A complete list of references is provided in Enclosure 9.



### 3.1 ENVIRONMENTAL CONDITION OF PROPERTY CATEGORY

Most of the parcels associated with the buildings and areas covered in this FOST are in the Environmental Condition of Property ∗ (ECP) Category 1. ECP Category 1 is defined as areas where no release or disposal of hazardous substances or petroleum products has occurred (including no migration of these substances from adjacent areas). However, it should be noted that there is volatile organic compound (VOC)-contaminated groundwater that is under the property being transferred (see Section 5 for a discussion of VOC groundwater contamination). The VOC groundwater contamination did not originate at any of the Phase II parcels.

∗ The Army Materiel Command (AMC) FOST/FOSL Guidance (Environmental Quality Division Office of the

Command Counsel, AMC BRAC Office, February 1998, updated February 2000) was used as guidance to determine the ECP categories for the parcels.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 4 The areas in the vicinity of the fuel storage tanks at Buildings 33 (Parcel 2-42), 41-1 (Parcel 2-46), and 686 (2-72) (see Subsection 3.3) are classified as ECP Category 2. In addition, the area in the vicinity of the loading bay at Building 5 (Parcel 2-39) is classified as ECP Category 2 (due to a release from a truck’s ruptured fuel tank). ECP Category 2 is defined as areas where only the release of petroleum products has occurred. It should be noted that there is VOC-contaminated groundwater that is under the property being transferred (see Section 4 for a discussion of VOC groundwater contamination).

Enclos u r e 2, Table 1 , provides a description of the property and a s u mmary of the DoD ECP categories for the parcels and buildings in the LEAD Phase

II FOST.



### 3.2 STORAGE, RELEASE, OR DISPOSAL OF HAZARDOUS SUBSTANCES

Hazardous substances were stored for 1 year or more in excess of the quantities referenced in Title 40 of the Code of Federal Regulations (CFR) Section 373.2(b) at Parcels 2-50 (Building 18), 2-39 (Building 5), 2-40 (Building 8), 2-45 (Building 42), 2-42 (Building 33), 2-46 (Building 41), 2-57 (Building 424), and 2-58 (Buildings 475, 476, 477, 478, 479, and 480).

There was no evidence of hazardous substance releases in excess of the quantities referenced in 40 CFR 373 as a result of these storage operations. All government hazardous substance storage operations have been terminated on the Phase II parcels.

A summary of the buildings in which hazardous substance activities

occ u rred is provided in Enclos u r e 3, Table 2 , Notification of Hazardo u s Substance Storage, Release, and/or Disposal.



### 3.3 PETROLEUM AND PETROLEUM PRODUCTS

3.3.1 Underground and Aboveground Storage Tanks (USTs/ASTs)

There are 6 underground and 15 aboveground storage tanks (USTs/ASTs) on the property discussed in this FOST that are currently in use for the storage of petroleum products. Petroleum releases in excess of 55 gallons (gal) related to UST/AST activities occurred at Buildings 33 and 41-1. These releases at Buildings 33 and 41-1 were related to spills associated with the storage tanks (not due to leaks) and were remediated at the time of the spill.

Note: There is one UST at Building 521 (550-gal diesel fuel) that is currently registered with PADEP.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 5 There were two ASTs and four USTs formerly on the property that were used for the storage of petroleum products that have been removed or abandoned in place. There is no evidence of a petroleum release at the previous AST sites (Buildings 59 and 511). There were confirmed petroleum product releases at two of the USTs (Building 686) and a suspected petroleum product release, which was determined not to require remediation (Building 511 UST). There is one UST (Building 616) that was abandoned in place and there were no records found indicating

a release from this UST.

A summary of the petroleum product activities, including additional details concerning the ASTs and USTs discussed here, is provided in

Enclos u r e 4, Table 3 , Notification of Petrole u m Prod u c ts Storage, Release, and/or Disposal.



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

Petroleum products in excess of 55 gal were stored in Building 56 (Parcel 2-67) and Buildings 58-1 and 58-2 (Parcel 2-64). The storage consisted of hydraulic oil and petroleum-based lubricants that were used for general vehicle and tracked vehicle maintenance. There is no record of any release and/or disposal of petroleum products at these buildings. A release of diesel fuel (60 gal) was reported from a truck’s ruptured tank at the loading dock at Building 5, which was remediated at the time of the spill.

A summary of the buildings or areas in which petroleum products were stored, released, and/or disposed of is provided in Enclosure 4, Table 3, Notification of Petroleum Products Storage, Release, and/or Disposal.



### 3.4 POLYCHLORINATED BIPHENYLS (PCBs) EQUIPMENT

Currently there are no PCB-containing transformers located in the Phase II FOST parcels. Previously, there were nine known PCB transformers located on the Phase II transfer property at the following locations:

!" Parcel 2-50: Building 18 (two transformers; removed in November 1986 and January 1988).

!" Parcel 2-36: Building 211 (removed in January 1994).

!" Parcel 2-38: Building 7 (three transformers; removed in April 1993).

!" Parcel 2-45: Building 42 (removed in April 1995).

!" Parcel 2-55: Building 436 (two transformers; removed in January 1995).Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 6 There are no records or evidence to indicate any release occurred from the former PCB-containing transformers (FPTs). The results of sampling

conducted in 1998 of these FPT sites verified that there were no releases at the sites, and indicated that no remedial action was necessary to ensure protection of human health and the environment. The sampling and

evaluation of the FPTs is documented in the Decision Document — Former
PCB Transformer Sites in the Southeastern (SE) Area, Operable Unit (OU) 8 (DSERTS Site LEAD-125) (WESTON, 2000b).



### 3.5 ASBESTOS

There is documented asbestos-containing material (ACM) in 43 of the buildings discussed in this FOST (Dames and Moore, 1993). The ACM includes transite board, floor tile, mastic, pipe insulation, ceiling tile, and pipe fittings. To the best of the Army’s knowledge, the ACM in these buildings does not pose a threat to human health because all friable asbestos that posed an unacceptable risk to human health has been removed or encapsulated (WESTON, 1996, 1999a, 2000a, 2001d).

A total of 23 buildings in the LEAD Phase II FOST parcels were not surveyed for ACM, including 2 buildings that were constructed after 1980. A visual survey was completed as part of the EBS process for all the buildings discussed in this FOST. Any suspect ACM seen during the visual survey was noted and is reported in the building summaries in the LEAD EBS, EBS Addendum, and Supplement 1 to the EBS; however, an EBS visual survey does not constitute a full ACM survey.

The presence of ACM is summarized by building in Enclosure 5. The deed
will include the Asbestos Notice as set forth in Enclosure 7. In addition, a provision has been added (Enclosure 7) to provide notification and management requirements for the suspect ACM in the 23 buildings that were not surveyed for ACM.



### 3.6 LEAD-BASED PAINT

Based on the age of the buildings (constructed prior to 1978), it is assumed that all painted building structures contain lead-based paint (LBP). For the most part, only small portions of the exterior of these buildings have been painted (door and window frames). The limited painted outside surfaces of the buildings in this FOST appeared to be in good condition at the time of the EBS visual surveys.

LBP surveys were completed in 1996 for 11 buildings included in the Phase II transfer property that at the time were used as residential housing units. LBP was identified at each of the residential buildings and in 1996 was noted to be in good condition (Dames and Moore, 1996). In addition to the LBP surveys for the 11 residential units, limited surveyLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 7 sampling performed by LEAD personnel in 1993 and 1994 identified LBP at Buildings 616, 619, and 627. The results of the LBP testing and surveys are summarized by building in Enclosure 5 (Appendix A). All of the buildings tested are being transferred with an intended future use of

nonresidential.

The deed will include the LBP warning and covenant as set forth in Enclosure 7. In accordance with the environmental provisions of the deed, the transferee is responsible for abatement of LBP hazards and lead-soil hazards associated with buildings to be used for residential purposes (including daycare) within 12 months of the date of the risk assessment and prior to occupancy or use of the Residential Real Property.



### 3.7 RADIOLOGICAL SOURCES OR CONTAMINATION

Radioactive components (materials/sources) were stored in Buildings 7, 8, 32, 33, 56, 431, and 441 prior to 1968 (WESTON, 2000c, 1999c, 1999d, 1999e, 1998a, 1998b, 1998c, 1998d). All of the buildings have been determined suitable for unrestricted use. Final Termination Reports were prepared for all of the buildings except Building 56 (which was classified as nonimpacted) and Building 431 (which has ongoing radiological operations). See Table 1, Description of Property (Enclos u re 2), and Table

A-1 (Enclos u re 5) for additional information.



### 3.8 RADON

Radon surveys were conducted for 37 of the 70 buildings covered in this FOST (R.E. Wright Environmental, Inc., 1994, 1995, and 1997). Some buildings were not tested because they are unoccupied (e.g., storage buildings) or are not regularly occupied. Radon was detected at or above the EPA-recommended residential action level of 4 picoCuries per liter (pCi/L) in the following buildings:

!" Residential—Buildings 503 and 2279. The radon has been mitigated in Building 2279 but not in Building 503. Ventilation units were installed in Building 2279. Building 503 is for transient residential use and no mitigation was completed for this structure.

!" Nonresidential—Buildings 5, 7, 8, 33, 421, 426, and 627. These buildings are not residential dwellings and there were no plans in place to use these buildings for residences. The EPA-recommended level of 4 pCi/L applies to residential dwellings and a value has not been established for industrial/commercial uses. According to Army policy (AR 200-1), these buildings were given a low priority for mitigation because they were not being used for residential purposes and because Army use of the buildings was to be discontinued.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 8 Therefore, no mitigation actions were taken for these industrial buildings.

The results of the radon surveys are summarized by building in Enclosure 5, Appendix A. Radon concentrations may change with seasonal variations in the groundwater table. The deed will include the radon notification provision as set forth in Enclosure 7.



### 3.9 UNEXPLODED ORDNANCE (UXO)

No UXO has historically been or is currently handled within the boundaries of the BRAC parcel, which includes all parcels and buildings that are the subject of this FOST. UXO is limited to the two open demolition areas and the two open burning areas in the Ammunition Area (AA), which are located approximately 2.5 miles from the FOST property. The AA is part of the enclave property and is not scheduled to be transferred.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 9 

## 4. ADJACENT HAZARDOUS CONDITIONS

There is documented VOC and diesel fuel soil contamination at Building 37, which is adjacent to Parcels 2-65 and 2-66. This soil contamination is below the ground surface and poses no threat to the shallow soils of the adjacent parcels.

Many of the Phase II parcels are adjacent to or in proximity to BRAC investigation sites. The preliminary results of these investigations indicate that there is no soil contamination that would pose a threat to the Phase II parcels.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 10 

## 5. REMEDIATION

LEAD contains two NPL sites, the Southeastern (SE) Area and the Property Disposal Office (PDO) Area, that are being addressed in accordance with a Federal Facilities Agreement (FFA) dated 3 February

1989.

!" Soil contamination—All soil investigation and remediation activities on the property have been completed. No remediation activities,
other than institutional controls for the Gate 1 Guardhouse, were necessary for protection of human health and the environment based on the intended future use of the property, which means that the Gate 1 Guardhouse area will only be used for industrial/commercial purposes. The only remedial action necessary is to implement

institutional controls to ensure that the Gate 1 Guardhouse is used only for industrial/commercial purposes. All of the Phase II parcels, except the Gate 1 Guardhouse area and the five FPT sites, were determined to be unimpacted by site activities based on the EBS process. Therefore, no additional soil investigation or remediation is

necessary.

A summary of the five FPT sites and the Gate 1 Guardhouse, Building 511 (part of SE OU 8, BRAC sites), is as follows:

− Five FPT Sites—The Army, in consultation with EPA and PADEP, prepared a Decision Document for the FPTs (WESTON, 2000b). The FPT Decision Document (see Subsection 3.4) supports the finding that no response action was necessary in these areas to protect human health and the environment (e.g., the areas were deemed suitable for unrestricted use).

− Gate 1 Guardhouse, Building 511—The Army, in consultation with EPA and PADEP, prepared a remedial investigation/risk assessment (RI/RA) report for the Gate 1 Guardhouse building (WESTON, 2001c). The conclusions of this RI/RA Report are that this site is suitable (e.g., there is no unacceptable risk to human health and the environment) for the intended future industrial/commercial use. The environmental deed provisions will restrict the use of the Gate 1 Guardhouse area (Parcel 2R-80) to commercial/industrial activities (Enclosure 7).

!" Groundwater contamination—The groundwater underneath the property is contaminated with VOCs. Total VOC concentrations up to 60 micrograms per liter (μg/L) and 112 μg/L have been detected in groundwater in the PDO and SE Areas, respectively. This transfer will not include contaminated groundwater because the transfer is limited to the buildings and structures, and soil from ground surfaceLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 11 down to a depth of 8 ft bgs. The conclusions of a Phase II parcels risk assessment (RA) (WESTON, 2001b) are that there is no unacceptable level of health risk from the indoor (and trench) inhalation exposure pathway (e.g., inhalation of vapors from VOC contaminants in groundwater), as long as groundwater heights are 3 or more feet away from the floor or the workspace. Excavation restrictions and groundwater use restrictions will be specified in the environmental deed provisions to ensure an adequate buffer zone (Enclosure 7).

Remedial actions are ongoing in several areas within the BRAC parcel, and many other areas are anticipated to require various degrees of investigation and/or remediation in the future, prior to transfer of the property. The buildings and areas covered in this FOST do not have any planned investigations at this time. In the event that investigations and remediation are required in the future, the deed will include a provision reserving the Army’s right to conduct remediation activities as set forth in Enclosure 7.

The deed will include provisions restricting excavation activities and prohibiting the use of groundwater as set forth in Enclosure 7.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 12 

## 6. REGULATORY AND PUBLIC COORDINATION

EPA Region III, PADEP, and the public were notified of the initiation of the FOST. Regulatory/public comments received during the FOST development were reviewed and incorporated as appropriate. All regulatory agency comments were resolved. Copies of the regulatory

agency conc u rrence letters are incl u d ed in Enclos u r e 8 of this FOST.

The restrictions on excavation, use of groundwater, and the use of the Gate 1 Guardhouse, described previously, are known as “land use controls” or “institutional controls.” The Army will be responsible for implementing and maintaining the land use controls for the Phase II parcels. The Army, EPA, and PADEP plan to sign a Land Use Control Assurance Plan (LUCAP) before transfer of the Phase II parcels, which will set out procedures for implementing and maintaining the land use controls for the Phase II parcels. The Army, with EPA and PADEP approval, may arrange with other entities such as LIDA to maintain land use controls as long as the Army remains ultimately responsible for the effectiveness of the controls. The site-specific plan to implement and

maintain the institutional controls will be contained in the Land Use Control Implementation Plan (LUCIP), which will be prepared as an

attachment to the LUCAP.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F.DOC 04/30/02 

### 13 

## 7. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE

AND CONSISTENCY WITH REUSE PLAN

The environmental impacts associated with proposed transfer of the property have been analyzed in accordance with NEPA. The results of this analysis have been documented in the Final Environmental Assessment (EA) for BRAC 95 Disposal and Reuse of Property at Letterkenny Army Depot, Chambersburg, Pennsylvania, dated January 1998. The environmental effects of the activities anticipated under the proposed transfer were determined not to be significant as documented in the Finding of No Significant Impact (FONSI) signed on 11 March 1998 (USAMC, 1998). In addition, the proposed transfer of the property is consistent with the intended reuse of the property as set forth in the LIDA reuse plan (FCRC, 1997).APR. 2.2002 12:32PM REAL ESTATE DIV HALT

l.eIlerltenny Anny Depot PtIsse II Finding of SuItabIlIty to Transfer (FOST)



### 8. FINDING OF SUITABILITY TO 

### TRANSFER NO.421 P.2

Based on the previous information. I conclude that all removal or remedial actions necessary to protect human health and the environment

have been taken and the property is transferable under CERCLA Section
12O(h)(3). In acidition. aD. DoD requirements to reach a FOST have been

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

environmental protection provisions, which &hall be mcluded in the deed

for the property. The environmental protection provisions also include

the CERCLA section l2O(h)(3) covenant and access provisions. Finally,
the hauadous substance notification (Table 2) will be included in the

deed as required under CERCLA Section 120(h) and DoD FOST guidance.



# -

Col., 

### as Deputy Chief of Staff for

. ODS

Enclosure!

Enclosure 2

End.osure4

EnclosureS

Enclosure 6

Enc:losure 7

EnclosureS

Enclosure 9 ENUOSURES

Sib! Maps of Proposed Transfer Areas (Figures 1 and 2)

Table 1, Property Desaiption of Phase II BRAC Parcels for
theFOST "

Table 2, Notification of Hazarci011S Substance Storage,
Release, and! or Disposal

Table 3, Notification of Petroleum Product Storage, Release, and! or DispOsal

Appendix A, Summary of Parcel and Building Conditions,

FC5l" for the Phase II BRAC Parcels

Summaty of Building and Puce! Conditions, Phase II Property Transfer, Results of Final Visual Surveys

Environment:al Protection Provisions

Regulatory Agency Con.cur:rence Letters

References and Bibliography

14 FiNAl

llJ271ttfLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_F_ENC12.DOC 4/30/2002 

## ENCLOSURE 1

SITE MAPS OF PROPOSED TRANSFER AREAS

! Figure 1—Phase II Parcels

! Figure 2—Phase II R o ad w a y Parcels

# t

U &

..... , IOclrp5 or DIg 1.001"5

Jo,I1;I •• r. D Islrl ct Township Line



## °_1IIIIIIII

__ • 1100

Fllel Buildingll

_ Road Parcel Enclave Area

_ _ Dashed portions of the

roa.d parcels are located in
the Enclave area and will not
bs trBnl!lferrsd. Public acesllll to
theBe roa.ds will be permitted.



### Figure 2

Location of Phase II

Road ParcelB at LEAD 

## Letterkenny 

## Army Depot Chambersburg. PA - I - Dra.inage Divide 21'-86 !!! Phase II Parcel 

### m Oregon(Opportunity) !!! LBAD Road Name

(LIDA Dellignated Road N IIJIlS ) 

### Legend:



### Building 301



### GATE 6

2R-:84 TEXAS/WASmNGTON (INNOVATION) 

### Letterkenny Township RoadsLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_F_ENC12.DOC 4/30/2002 

## ENCLOSURE 2

TABLE 1
PROPERTY DESCRIPTION OF PHASE II BRAC

PARCELS FOR THE FOSTFINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-1Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PAParcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2-35 N/A Open Area 1.5 – 12(5) HR 1 (1)2-36 N/A Railroad Yard 27 – 12(5) HR 1 (1)2-36 211 Patriot Project Office (1,232) 27 1943 12(5) HR 1 (1)2-37 49 Lift Station – Sanitary (142) 5 1972 12(5) HR 1 (1)2-37 N/A Two temporary sheds in Electrical Distribution Area 5 1988/1990s12(5) HR 1 (1)2-38 7 Warehouse (90,000) 5.5 1943 12(5) HR 1 (1)2-38 1-7 Restrooms (384) 5.5 1943 12(5) HR 1 (1)2-39 5 Shipping Warehouse (90,000) 5.5 1943 12(5) HR 2 (1)2-39 5-2 Outbuilding – 5 (384) 5.5 1943 12(5) HR 2 (1)2-40 8 Warehouse (90,000) 5.7 1943 12(5) HR 1 (1)2-40 1-8 Restrooms (384) 5.7 1943 12(5) HR 1 (1)2-41 N/A Open Area 2.6 – 12(5) HR 1 (1)2-42 33 Warehouse (90,527) 5.4 1943 12(5) HR 2 (1)2-43 32 Warehouse (90,180) 5.3 1943 12(5) HR 1 (1)2-44 31 Warehouse (90,180) 5.4 1943 12(5) HR 1 (1)2-45 42 Warehouse/Shipping Packaging (90,000) 5.3 1943 12(5) HR 1 (1)2-45 42-1 Air Compressor (384) 5.3 1943 12(5) HR 1 (1)2-46 41 Warehouse (90,527) 5.3 1943 12(5) HR 2 (1)2-46 41-1 Outbuilding – 41 (180) 5.3 1943 12(5) HR 2 (1)Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-2Parcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2-46 51-2 Bus Shelter 5.3 – 12(5) HR 2 (1)2-47 247 Office (2,946) 3 1943 12(5) HR 1 (1)2-48 N/A Golf Course 14.9 1963 12(5) HR 1 (1)2-49 502 Base Guest House (384) 5.9 – 12(5) HR 1 (1)2-49 503 Base Housing (1,456) 5.9 – 12(5) HR 1 (1)2-49 504 Garage (240) 5.9 – 12(5) HR 1 (1)2-49 508 Lift Station (87) 5.9 1960 12(5) HR 1 (1)2-50 18 Alkaline Storage (12,000) 2.9 1943 12(5) HR 1 (1)2-51 N/A Golf Course 4.7 1963 12(5) HR 1 (1)2-52 N/A Golf Course 6 1963 12(5) HR 1 (1)2-53 N/A Golf Course 10 1963 12(5) HR 1 (1)2-54 531 Lift Station – Sanitary Sewer (148) 6.6 1945 12(5) HR 1 (1)2-55 436 Filter Apparatus Testing Building (4,436) 0.7 1943 12(5) HR 1 (1)2-56 426 Maintenance (18,928) 1.4 1942 12(5) HR 1 (1)2-57 424 Maintenance – Woodwork, Upholstery, Cable(18,928)1.4 1942 12(5) HR 1 (1)2-57 425 Former Barber Shop (400) 1.4 1942 12(5) HR 1 (1)2-58 475 Storage (1,152) 4.4 1962 12(5) HR 1 (1)2-58 476 Storage (1,152) 4.4 1962 12(5) HR 1 (1)Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-3Parcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2-58 477 Storage (320) 4.4 1962 12(5) HR 1 (1)2-58 478 Storage (1,229) 4.4 1971 12(5) HR 1 (1)2-58 479 Storage (1,152) 4.4 1971 12(5) HR 1 (1)2-58 480 Storage (1,152) 4.4 1971 12(5) HR 1 (1)2-59 N/A Open Area 3.8 – 12(5) HR 1 (1)2-60 441 Radioactive Material Warehouse (13,601) 1.4 1942 12(5) HR 1 (1)2-61 431 Instrument Maintenance – Testing (13,601) 1.5 1943 12(5) HR 1 (1)2-61 431-1 Lift Station 1.5 1960 12(5) HR 1 (1)2-61 3335 Bus Shelter 1.5 – 12(5) HR 1 (1)2-62 421 Administration (7,911) 1.4 1942 12(5) HR 1 (1)2-63 N/A Open Area 8.1 – 12(5) HR 1 (1)2-64 N/A Open Area (Former Building 59 Storage) 7.2 1961 12(5) HR 1 (1)2-65 N/A Open Area (Former Sheds) 1.8 – 12(5) HR 1 (1)2-66 N/A Open Area (Former Sheds) 1.2 – 12(5) HR 1 (1)2-67 56 Industrial (92,222) 4.8 1943 12(5) HR 1 (1)2-68 55 Warehouse (90,180) 5.4 1943 12(5) HR 1 (1)2-68 1-55 Office (384) 5.4 1943 12(5) HR 1 (1)2-69 N/A Open Area 10.9 – 12(5) HR 1 (1)2-70 521 Fire Station (11,336) 2.3 1942 12(5) HR 1 (1)Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-4Parcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2-71 N/A Open Area 7.8 – 19(5) HR 1 (2)2-72 664 Administration Office (9,917) 4.2 1943 19(5) HR 2 (2)2-72 686 Storage (1,080) 4.2 1949 19(5) HR 2 (2)2-74A N/A Open Area 40.8 – 19(5) HR 1 (2)2-74B 600 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 1 (2)2-74B 601 Housing - Kenny Gardens (3,605) 30.6 1954 19(5) HR 1 (2)2-74B 602 Housing - Kenny Gardens (3,452) 30.6 1954 19(5) HR 1 (2)2-74B 603 Housing - Kenny Gardens (4,241) 30.6 1954 19(5) HR 1 (2)2-74B 604 Housing – Kenny Gardens (3,790) 30.6 1954 19(5) HR 1 (2)2-74B 605 Housing – Kenny Gardens (3,605) 30.6 1954 19(5) HR 1 (2)2-74B 606 Housing – Kenny Gardens (3,605) 30.6 1954 19(5) HR 1 (2)2-74B 607 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 1 (2)2-74B 608 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 1 (2)2-74B 610 Storage - Kenny Gardens (1,777) 30.6 1968 19(5) HR 1 (2)2-74B 612 Storage - Kenny Gardens (1,475) 30.6 1973 19(5) HR 1 (2)2-74B 616 Police Station (3,360) 30.6 1944 19(5) HR 1 (2)2-74B 618 Environmental Offices (6,136) 30.6 1943 19(5) HR 1 (2)2-74B 619 Former Enlisted Men’s Club (5,454) 30.6 1943 19(5) HR 1 (2)2-74B 621 Storage Shed (140) 30.6 1966 19(5) HR 1 (2)Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-5Parcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2-74B 623 Storage Housing (80) 30.6 1988 19(5) HR 1 (2)2-74B 625 Concession Stand—Softball Field (144) 30.6 1990 19(5) HR 1 (2)2-74B 627 Post Exchange (PX) (4,135) 30.6 1944 19(5) HR 1 (2)2-74B 628 Security Office (5,130) 30.6 1943 19(5) HR 1 (2)2-74B 629 Office (empty) (1,040) 30.6 1944 19(5) HR 1 (2)2-74B 638 Gate 17 Guardhouse (144) 30.6 1942 19(5) HR 1 (2)2-76 2279 Family Housing (2,160) 22 – 19(5) HR 1 (2)2-76 2280 Garage (384) 22 1980 19(5) HR 1 (2)2-77 N/A Railroad track area between Phase I Parcels 1 and 2 1.1 – 12(5) HR 1 (1)2R-80 511 Gate 1 – Gatehouse (462) – Coffey Avenue 15.3 1942 12(5) HR 1 (1)2R-80 301 Gate 6 – Gatehouse (270) – Coffey Avenue 15.3 1973 12(5) HR 1 (1)2R-81 245 Sentry Station – Gate 5 (48) 27 – 12(5) HR 1 (1)2R-81 N/A Michigan Avenue (Technology) 5.8 – 12(5) HR 1 (1)2R-82 N/A California Avenue (Advantage) 5.7 – 12(5) HR 1 (1)2R-83 N/A Overcash Avenue 3.6 – 12(5) HR 1 (1)2R-84 N/A Texas Avenue (Innovation) 11.4 – 12(5) HR 1 (1)2R-85 N/A Oregon Avenue (Opportunity) 4.5 – 12(5) HR 1 (1)2R-86 N/A Carbaugh Avenue 5.9 – 12(5) HR/19(5) HR1 (1)/(2)Table 1Property Description of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01|O:\02281016.008\PHIIFOST_T1_F.DOC4/30/20022-6Parcel No.BuildingNo.Description(Square Footage of Facility)Area(acres)YearBuiltEBSParcelI.D.ECPNumberRemedialActions2R-87 N/A Pennsylvania Avenue (Letterkenny West) 4.2 – 19(5) HR 1 (2)2R-88 N/A Vehicle Road (Development) 3.8 – 19(5) HR 1 (2)Notes:EBS Parcel I.D. = The Community Environmental Response Facilitation Act (CERFA) parcel designation (WESTON, 1997a).N/A = Not applicable.HR = Hazardous substance release.PR = Petroleum release.HS = Hazardous substance storage.PS = Petroleum storage.TBD = To be determined.TBD-R = To be determined; under reconsideration.ECP Categories (determined using AMC FOST/FOSL Guidance [AMC, 2000]):1 = Areas where no release or disposal of hazardous substances or petroleum products has occurred (including no migration of these substances from adjacentareas).2 = Areas where only a release of petroleum products has occurred.Note that known or potentially VOC-contaminated groundwater underlies the property being transferred. The VOC groundwater contamination did notoriginate at any of the Phase II parcels. Also note that release of petroleum products is defined as greater than 55 gal (AMC policy).(1) Groundwater below parcel known to be contaminated or potentially contaminated with VOCs. This building is not a source areafor the contaminatedgroundwater. Groundwater contamination will be addressed in the SE OU 3 and/or SE OU 10 ROD.(2) Groundwater below parcel known to be contaminated or potentially contaminated with VOCs. This building is not a source areafor the contaminatedgroundwater. Groundwater contamination will be addressed in the PDO OU 2 ROD.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_F_ENC34.DOC 4/30/2002 

## ENCLOSURE 3

TABLE 2 NOTIFICATION OF HAZARDOUS SUBSTANCE STORAGE, RELEASE,

AND/OR DISPOSALLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_T2_F.DOC 4/30/2002 

### 3-1 Table 2

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

### Phase II Parcels, Letterkenny Army Depot, Chambersburg, PA

Parcel

Number Building

Number Name of Hazardous Substance Date of Storage/ Disposal/Release Remedial Actions

2-39 5 Solvents and cleaning fluids were stored and used in dip tanks. No records of storage/use

dates. b None required

2-40 8 Sodium hydroxide, potassium hydroxide, sodium sulfite, morpholine, and cyclohexamine. These are corrosive liquids stored in 30-gal plastic drums. These

corrosives are used as conditioners

for the water used in the boiler (heating) system. These corrosives

have been stored

in the boiler room at Building 8 in varying amounts

between 1988 and

1998. None required

2-50 18 Unknown quantities of alkaline materials, including soaps and decontamination fluid (DS-1). No records of storage dates. b None required

2-42 33 1. Unknown quantities of antifreeze,
corrosives, desiccants, aerosol cleaners, and dry cleaning

solvents.

2. Dip tanks were used to preserve metal parts for long-term storage. 1. No records of storage dates. b

2. Dip tanks were

used between

1994 and 1998. 1. None required

2. None required

2-46 41 Electrical transformers; no records of

numbers. No records as to whether transformers were PCB-containing. No records of storage dates. b None required

2-45 42 Unknown quantities of used solvents (TCA and TCE) stored in drums. Unknown quantities of

metal/flux residue also stored in

drums. No records of storage dates. Area investigated (ESE, 1987); no

further action.

2-57 424 Small quantities of acetone, paint thinners, gasket remover solvent,

and adhesives stored in a flammable cabinet; and a parts washer that uses

PD680. No records of storage/use

dates. b None required

2-58 475 Unknown quantities of argon gas. No records of storage dates. b None requiredLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)



### Table 2

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

### Phase II Parcels, Letterkenny Army Depot, Chambersburg, PA (Continued)

FINAL
MK01|O:\02281016.008\PHIIFOST_T2_F.DOC 4/30/2002 

### 3-2 Parcel

Number Building

Number Name of Hazardous Substance Date of Storage/ Disposal/Release Remedial Actions

2-58 476 Unknown quantities of acetylene gas, freon 12, and propane. No records of storage dates. b None required

2-58 477 Unknown quantities of chlorine gas. No records of storage dates. b None required

2-58 478 Unknown quantities of nitrogen gas and halon-containing fire extinguishers. No records of storage dates. b None required

2-58 479 Unknown quantities of refrigerants and fire extinguishers. No records of storage dates. b None required

2-58 480 Unknown quantities of oxygen, refrigerants, and nitrous oxide. No records of storage dates. b None required

a The information contained in this notice is required under the authority of regulations promulgated under Section 120(h) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”) 42 U.S.C. Section 9620(h). This table provides information on the storage of hazardous substances for 1 year or more in quantities greater than or equal to 1,000 kilograms or the hazardous substance’s CERCLA reportable quantity (whichever is greater). In addition, it provides information on the known release of hazardous substances in quantities greater than or equal to the quantities referenced in 40 CFR Part 373.

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

hazardous substances were stored and/or used.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_F_ENC34.DOC 4/30/2002 

## ENCLOSURE 4

TABLE 3 NOTIFICATION OF PETROLEUM PRODUCT STORAGE, RELEASE,

AND/OR DISPOSALLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL
MK01|O:\02281016.008\PHIIFOST_T3_F.DOC 4/30/2002 

### 4-1 Table 3

Notification of Petroleum Product Storage, Release, and/or Disposal, Phase II Parcels, Letterkenny Army Depot, Chambersburg, PA

Building

Number Parcel

Number Name of Petroleum

Product Date and Type of Storage/Release/Disposal a Remedial

Actions

5 2-39 Diesel fuel A 60-gal spill in loading bay No. 3 on 8 May 1992 from ruptured

fuel tank of a truck. Spill was

confined and cleaned up immediately.

1-7 2-38 No. 2 heating oil 300-gal AST installed in 1989. None required.

1-8 2-40 No. 2 heating oil 300-gal AST installed in 1989. None required.

8 2-40 No. 2 heating oil 20,000-gal UST in use from 1943 to present. Passed leak test in 1996 (ESS, 1996). None required.

33 2-42 1. No. 2 heating oil

2. No. 2 heating oil 1. 7,500-gal UST; installed in

1974. Passed leak test in 1996.

2. Unspecified amount of heating fuel released during tank integrity testing on 31 May 1991. 1. None required.

2. Spill and

affected soils

were cleaned

up immediately.

41-1 2-46 1. No. 2 heating oil

2. No. 2 heating oil 1. 60-gal spill on 1 March 1990.

2. 300-gal AST; currently in use,

installation date not known. 1. Area cleaned up with

absorbent and disposed of properly.

2. None required.

42 2-45 No. 2 heating oil 7,500- UST in use from 1974 to present. Passed leak test in 1996 (ESS, 1996). None required.

42-1 2-45 Water/oil condensate 182-gal sump/holding tank.

Dates of use undetermined. None required.

1-55 2-68 No. 2 heating oil 275-gal AST; currently in use,

installation date unknown. None required.

56 2-67 1. No. 2 heating oil

2. Hydraulic fluid 1. Three 2,500-gal ASTs installed

in 1993.

2. Several 55-gal drums stored and used at any one time. 1. None required.

2. None required.

211 2-36 No. 2 heating oil 300-gal AST; currently in use,

date of installation unknown. None required.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)



### Table 3

Notification of Petroleum Product Storage, Release, and/or Disposal, Phase II Parcels, Letterkenny Army Depot, Chambersburg, PA (Continued)

FINAL
MK01|O:\02281016.008\PHIIFOST_T3_F.DOC 4/30/2002 

### 4-2 Building

Number Parcel

Number Name of Petroleum

Product Date and Type of Storage/Release/Disposal a Remedial

Actions

58-1

58-2 2-64 Lube oils Unknown quantities previously stored in 55-gal drums in these
metal sheds; sheds have been

demolished. None required.

59 (demolished) 2-64 No. 2 heating oil 275-gal AST removed between

1995 and 1999. None required.

247 2-47 No. 2 heating oil 500-gal AST; currently in use,

date of installation unknown. None required.

503 2-49 No. 2 heating oil Two 275-gal ASTs; currently in
use, date of installation

unknown. None required.

511 2R-80 No. 2 heating oil Unknown size UST taken out of service (unknown date); 300-gal

AST removed from service 1999. None required. b

521 2-70 1. No. 2 heating oil

2. Diesel c

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

1988. Passed leak test in 2000.

2. One 550-gal UST currently in use, installed in 1994; passed tightness test in 1996.

3. 500-gal UST; removed in

1998. d 1. None required.

2. None required.

3. No record of

release; none required.

604 2-74B No. 2 heating oil 6,000-gal UST; in use since 1954.

Passed leak test in 1996. None required.

616 2-74B No. 2 heating oil 1. 500-gal AST; currently in use,

date of installation unknown.

2. 500-gal UST; installed in 1944,

taken out of service, no record

of tank removal. 1. None required.

2. Tank contents

removed in
March 2001;

no evidence of

release.

618 2-74B No. 2 heating oil 500-gal AST; currently in use,

date of installation unknown. None required.

619 2-74B No. 2 heating oil 275-gal AST; currently in use,

date of installation unknown. None required.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)



### Table 3

Notification of Petroleum Product Storage, Release, and/or Disposal, Phase II Parcels, Letterkenny Army Depot, Chambersburg, PA (Continued)

FINAL
MK01|O:\02281016.008\PHIIFOST_T3_F.DOC 4/30/2002 

### 4-3 Building

Number Parcel

Number Name of Petroleum

Product Date and Type of Storage/Release/Disposal a Remedial

Actions

627 2-74B No. 2 heating oil 500-gal AST; currently in use,

date of installation unknown. None required.

628 2-74B No. 2 heating oil 500-gal AST; currently in use,

date of installation unknown. None required.

664 2-72 Gasoline 300-gal AST; currently in use,

date of installation unknown. None required.

686 2-72 Gasoline Two 1,000-gal USTs removed in

1992. d Confirmed
release; soils

removed to

bedrock and groundwater investigation completed at time

of UST closures.

No further action planned.

2279 2-76 No. 2 heating oil Two 275-gal ASTs; currently in
use, date of installation

unknown. None required.

a AMC’s policy for notification includes amounts of petroleum in excess of 55 gal either stored for greater than 1 year or released (AMC, 2000).

b Sampling completed in 1999 and a risk assessment (RA) performed in 2000 for Building 511 indicated that no

remedial action is necessary to protect human health and the environment based on the intended future

industrial use of the site. This evaluation is documented in Final Remedial Investigation (RI)/Risk Assessment (RA) Report, Gate 1 Guardhouse, Building 511 (WESTON, 2001c).

c Tank currently regulated by PADEP.

d The reports detailing the tank closures and the correspondence from the Pennsylvania Department of

Environmental Protection (PADEP) approving the remedial measures and investigations completed are in the

UST files at LEAD.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

## ENCLOSURE 5

APPENDIX A SUMMARY OF PARCEL AND BUILDING CONDITIONS,

FOST FOR THE PHASE II BRAC PARCELSLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-1 

## APPENDIX A

SUMMARY OF PARCEL AND BUILDING CONDITIONS,

FOST FOR THE PHASE II BRAC PARCELS

A.1 INTRODUCTION

A total of 51 parcels have been selected for the Phase II parcel transfer. A total of 37 of these parcels are located in the Southeastern (SE) Area, 5 parcels are located in the Property Disposal Office (PDO) Area, and 9 areas are located on roadways within both the PDO and SE Areas. The locations of the parcels are shown on maps in Enclosure 1. The parcels

are shown in more detail in Fig u res A-1 thro u g h A-11 , which are located at the end of this appendix. The following narrative summarizes the environmental condition of the parcels. Table A-1 presents a summary of the condition of the buildings included in the Phase II parcel transfer.

A description of each of the parcels is presented in the following subsections. For each parcel, a general description of the parcel, prior and current condition of the parcel/buildings, a list of buildings associated with the parcel, and other relevant information are provided. Unless otherwise noted below, the Army, after a complete search of Army files and, in some cases, interviews, visual inspections, and limited sampling, found no records or evidence of petroleum or hazardous substance storage, release, or disposal at any of these parcels. In addition, unless otherwise noted, there were no records of aboveground storage tanks (ASTs), underground storage tanks (USTs), or polychlorinated biphenyl (PCB)-containing equipment at the parcels.

Some buildings were not tested for radon, LBP, or ACM because they are unoccupied (e.g., storage warehouse) or are not regularly occupied. Parcels where PCB transformers were formerly located (referred to as the Former PCB Transformer Sites [FPTs]) are listed here and are noted with an asterisk in the parcel descriptions. Brief descriptions of the FPTs are included as part of the parcel descriptions. The results of soil sampling and analysis for PCBs associated with the FPTs are documented in the Final Decision Document, Former PCB Transformer Sites in the Southeastern (SE) Area, Operable Unit (OU) 8, DSERTS Site LEAD-125, Letterkenny Army Depot

, Chambersburg, PA (WESTON, 2001b), hereafter referred to as the

FPTs Decision Document. Based on the results of the data evaluation presented in the FPTs Decision Document, which included a comparison of analytical data against residential/high occupancy use screening criteria, it was concluded that the sites evaluated require no furtherLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-2 action under the continued industrial scenario. The Decision Document is

contained in the Administrative Record for the site.

!" Parcel 2-36

!" Parcel 2-38

!" Parcel 2-45

!" Parcel 2-50

!" Parcel 2-55



## A.2 PARCEL 2-35 (Open Area)

Parcel 2-35 (Figure A-1) is approximately 1.5 acres in size and is located north of Building 7 and east of the parking area for Buildings 1 and 4. There are no structures on Parcel 2-35; it is currently open land. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or industrial activities.



## A.3 PARCEL 2-36* (Railroad Yard and Building 211—Office)

Parcel 2-36 (Fig u r es A-1 and A-2 ) is appro x

imately 27 acres in size and is located on the eastern boundary of LEAD. The parcel is currently comprised of a railroad yard (Yard No. 1), a perimeter patrol road, open grassy areas, and Building 211. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been a railroad yard with no apparent storage or industrial activities other than railroad use. Building 211 is currently used as the Patriot Project Office and serves as an administrative facility. The building was a former train station, but was converted into offices several years ago. Building 211 was built in 1943 and is constructed of brick and wood. An attachment to the building houses the furnace, which is fueled by a 300-gallon (gal) heating oil AST. An asbestos-containing material (ACM) survey conducted for Building 211 identified transite board, cement asbestos board, and refractory cement (Dames and Moore, 1993). Some of the transite boards in the building have been removed. A lead-based paint (LBP) survey has not been conducted at the building. A radon survey conducted at Building 211 identified only minimal levels of radon (0.8 picoCuries per liter [pCi/L]), below the U.S. Environmental Protection Agency (EPA)- recommended residential action level of equal to or greater than 4 pCi/L. The FPT associated with Building 211 was formerly located in a grassy area east of the building on East Patrol Road; it was removed in January 1994. Sewage from this building is routed to a septic system north of Building 211.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-3 

## A.4 PARCEL 2-37 (Building 49—Lift Station)

Parcel 2-37 (Figure A-2) is approximately 5 acres in size and is located in the southeastern corner of LEAD. The northern part of the parcel is currently primarily open land with railroad tracks, a perimeter patrol road, Building 49, and a paved area used for parking by the security office personnel. The southern part of the parcel is a fenced area used for electrical transmission equipment and contains two structures. The area is currently used and maintained by Allegheny Power. Historical aerial photographs indicate that this parcel may have been used for temporary structures (1949 and 1957) and as open space (1963 and 1970). The two structures in the southern (fenced) area of the parcel house electrical equipment. The southernmost structure is owned by the Army. It was built by the Army in 1988, and is constructed of steel walls and roof on a concrete slab foundation. Allegheny Power owns the structure in the northern fenced-in area, which was built in the early 1990s, and is

constructed of steel walls and roof on a concrete slab. These structures are
not heated and have not been evaluated for ACM, radon, and LBP.

Building 49 is a lift station for sanitary sewage. It was built in 1972 and is

constructed of cinder blocks and a wooden roof on a concrete foundation. Building 49 has not been evaluated for ACM, radon, and LBP.



## A.5 PARCEL 2-38* (Buildings 7 and 1-7—Warehouse)

Parcel 2-38 (Figure A-1) is approximately 5.5 acres in size and is located north of Building 8 and east of Building 4. The parcel consists of Buildings 7 and 1-7, and parking areas. Building 7 is currently leased by the Letterkenny Industrial Development Authority (LIDA) and is used for wood-working activities (manufacture of banisters and cabinets). The building was previously used by the Army for warehousing. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing. Building 7 is a 90,000-square foot (ft 2 ), former warehouse that was built in 1943, and is constructed of concrete, wood, and steel. Building 7 was used to store miscellaneous metal parts. The building is heated using steam generated from the Building 1 boiler system. An asbestos survey conducted at Building 7 identified the presence of ACM in transite and pipe insulation (Dames and Moore, 1993). LEAD records indicate that some of this material may have
been abated and/or removed; however, records of these removals are not well documented. The FPT associated with Building 7 was formerly located on an asphalt lot located west of the building, between the building and Washington Avenue. This FPT was removed in April 1993. LBP was not evaluated at Building 7. A radon survey conducted at Building 7 indicated radon concentrations (4.4 to 12.4 pCi/L) above the EPA-recommended residential action level of 4 pCi/L.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-4 Radioactive components were stored in Building 7 prior to 1968. Building 7 was classified by the Army under the Nuclear Regulatory Commission (NRC) guidance as “unaffected” (WESTON, 1998a, 1999c). The NRC defines unaffected as “Any area in which radioactive materials were handled but which have a very low potential for residual contamination.” The radiological investigation for Building 7 was completed (July 1998) and the results of the radiological survey concluded that Building 7 is suitable for unrestricted use (WESTON, 1998e).

Building 1-7 is a 384-ft 2 building associated with Building 7 that is used as restroom facilities. Building 1-7 was built in 1943 and is constructed of concrete, brick, and wood. Building 1-7 is heated by a furnace, which uses fuel oil supplied by a 300-gal AST. ACM, radon, and LBP have not been evaluated at Building 1-7.



## A.6 PARCEL 2-39 (Buildings 5 and 5-2—Warehouse)

Parcel 2-39 (Figure A-1) is approximately 5.5 acres in size and is located north of Building 6 and west of Building 8. The parcel consists of Buildings 5 and 5-2. A recent fire (February 1999) in Building 5 caused damage to the interior and to the roof, which was repaired. Building 5 is currently leased by LIDA and is undergoing renovation. Building 5 was the receiving warehouse for LEAD, and some of the shipments received may have contained hazardous substances in amounts equal to or greater than quantities referenced in 40 Code of Federal Regulations [CFR] Part 373. The Army, after a complete search of Army files and interviews of personnel, found no evidence that any hazardous substances were stored for 1 year or more. Several minor spills (less than quantities referenced in 40 CFR 373) of hazardous substances were documented for Building 5.
Therefore, there was no need for notification of hazardous substance storage, release, and/or disposal. Building 5 was constructed in 1943 of brick, concrete, and steel. Building 5 was used for receiving and distributing shipments to LEAD. Building 5 is divided into two parts. The southern part is the operations end, where the shipments were handled. A radioactive storage room was located in the southern end for shipments containing sealed radioactive components. The northern end of Building 5 is comprised of office space. The building is heated by steam generated at Building 1. There are no ASTs or USTs associated with Building 5. An asbestos survey (Dames and Moore, 1993) conducted at Building 5 identified the presence of ACM, including pipe insulation, spackle compound, floor tile, tile mastic, duct mastic, duct cloth, transite wallboard, and a small area of roofing material. LEAD records indicate that some of the floor tile and pipe insulation ACM has been removed. Radon was detected above the EPA-recommended residential action level (1.0 to 5.6 pCi/L) at Building 5. LBP was not evaluated at Building 5.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-5 Radioactive components (materials/sources) were handled in Building 5. The radioactive storage area at Building 5 was classified as affected by the Army following NRC guidance, which the NRC defines as “any area that has the potential for radioactive contamination that exceeds or is a significant fraction of release limits.” The Final Termination Report (WESTON, 1999b) on the storage area at Building 5 indicates that Building 5 is suitable for use without any restrictions.

Building 5-2, located south of Building 5, is a 384-ft 2 outbuilding that was built in 1943 and is constructed of concrete, brick, and wood. Building 5-2 was formerly used as restroom facilities and then used to store propane tanks. Building 5-2 is currently empty and is not heated. The roofing material at Building 5-2 was identified by LEAD as ACM. There is no evidence that the Army used or stored radioactive materials at Building 5-2. LBP and radon were not evaluated at Building 5-2.

Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing.



## A.7 PARCEL 2-40 (Buildings 8 and 1-8—Warehouse)

Parcel 2-40 (Figure A-1) is approximately 5.7 acres in size and is located south of Building 7 and east of Building 5. The parcel consists of Buildings 8 and 1-8, and parking areas. Building 8 is a 90,000-ft 2 former
warehouse, which was built in 1943 and is constructed of concrete, wood, and steel. Building 8 was used to store miscellaneous parts, office supplies, and electronic equipment. Building 8 is currently leased by LIDA and is used for the molding of faux-marble counter tops made from polyester resin. The building was previously used by the Army for warehousing. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing. Hazardous substances were stored in the boiler room for 1 year or more in excess of the quantities listed in 40 CFR 373.2(b). The materials stored in the boiler room at Building 8 were liquid corrosives, which are routinely used as conditioners for the water used in the boiler heating system. The Army, after a complete search of Army files, an inspection of the boiler room, and interviews, found no records or evidence of any

release of these corrosives.

Building 8 is heated by a boiler fueled by heating oil, which is stored in a 20,000-gal AST. An asbestos survey conducted at Building 8 identified the presence of ACM in floor tile, transite, and gasket material. Some of this material has been abated and/or removed; however, records of these removals are not well documented. LBP was not evaluated at Building 8. A 20,000-gal heating oil AST is located south of the boiler room. Two spills were reported in the LEAD spill inventory in association with Building 8. These spills, a No. 2 fuel oil spill and a diesel spill, were reportedlyLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-6 addressed at the time of the spills (i.e., contaminated soil was excavated and disposed of at an off-depot facility). A radon survey conducted at Building 8 indicated radon present at concentrations near and above the EPA-recommended residential action level of 4 pCi/L (at levels ranging from 2.7 to 5.3 pCi/L).

Radioactive components were stored in Building 8 prior to 1968. Building 8 was classified as “unaffected” by the Army following NRC guidance (WESTON, 1998a, 1999c). The radiological investigation for Building 8 has been completed (July 1998) and the results of the radiological survey concluded that Building 8 is suitable for unrestricted use (WESTON, 1998d).

Building 1-8 is a 384-ft 2 building associated with Building 8 that is used as restroom facilities. Building 1-8 was built in 1943 and is constructed of concrete, brick, and wood. Building 1-8 is heated by fuel oil supplied by a 300-gal AST. Refractory cement was identified as ACM at Building 1-8. LBP and radon were not evaluated at Building 1-8.



## A.8 PARCEL 2-41 (Open Area)

Parcel 2-41 (Figures A-1 and A-2) is approximately 2.6 acres in size and is located east of Building 9. The parcel contains a railroad spur and an open grassy area. There are no buildings associated with Parcel 2-41. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or industrial

activities.



## A.9 PARCEL 2-42 (Building 33—Warehouse)

Parcel 2-42 (Figure A-2) is approximately 5.4 acres in size and is located north of Building 43 and east of Building 34. The parcel contains Building 33, which was used as a warehouse by the Army. H azardous materials, such as antifreeze, corrosives, and desiccant, were stored in the building. These materials were contained in 55-gal drums stored on pallets or in 5- gal buckets. A caged area along the northern end of the building contained electronics and some small quantities of aerosol materials (i.e., cleaners). The southern end of the building contained dip tanks, with solvents in them. These tanks were reportedly there for over 1 year; they had been moved from Building 42 and were used for the treatment of metal parts prior to storage. Drums of dry-cleaning solvent were also present near the dip tanks. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing. An unspecified amount of heating oil was spilled near Building 33 (31 May 1991), which was cleaned up properly.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-7 Building 33 is a general storage warehouse constructed in 1943. The building consists of brick and wood walls and a concrete foundation. The building is a controlled humidity warehouse that is heated. An asbestos survey was conducted at Building 33, which identified the presence of

transite wallboard. LEAD records indicate that some transite board has been removed. No LBP surveys were conducted at Building 33. A 7,500- gal fuel oil UST, which provides fuel for the heating system, is located along the eastern side of the building. A radon survey conducted at Building 33 indicated a radon concentration of 7.2 pCi/L, which is above the EPA-recommended residential action level of 4 pCi/L.

A radioactive storage room was located in the southeastern end of Building 33. This room is used for the storage of equipment containing radioactive components. Building 33 contained areas that were classified as affected by the Army based on NRC regulations. The Final Termination Report for Building 33 (WESTON, 1999d) indicates that Building 33 is suitable for unrestricted use.



## A.10 PARCEL 2-43 (Building 32—Warehouse)

Parcel 2-43 (Figure A-2) is approximately 5.3 acres in size and is located north of Building 42 and east of Building 31. The parcel contains Building 32, which was used as a warehouse by the Army. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used as a warehouse. An Oakite powder spill (March 1990) and a hydraulic oil spill (May 1997) were reported at Building 32, which were cleaned up properly at the time of the spills.

Building 32 is a general storage unheated 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 vehicle parts and general hardware were stored in the warehouse. An asbestos survey was conducted at Building 32, which identified the presence of transite wallboard. No LBP surveys were conducted at Building 32. A radon survey conducted at Building 32 indicated radon concentrations of 0.9 to 2.1 pCi/L, which are below the EPA-recommended residential action level of 4 pCi/L.

Radioactive components (materials/sources) were stored in Building 32 prior to 1968. Building 32 was classified as unaffected (WESTON, 1999c) by the Army based on NRC regulations. The Final Termination Report for Building 32 indicates that Building 32 is suitable for unrestricted use (WESTON, 1999f).Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-8 

## A.11 PARCEL 2-44 (Building 31—Warehouse)

Parcel 2-44 (Figure A-2) is approximately 5.4 acres in size and is located north of Building 41 and east of Building 32. The parcel contains Building 31, which has been used by the Army for warehousing. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing. Building 31 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. An asbestos survey was conducted at Building 31, which identified the presence of transite wallboard. No LBP surveys were conducted at Building 31. A radon survey conducted at Building 31 indicated radon concentrations of 0.7 to 1.0 pCi/L, which are below the EPA-recommended residential action level of 4 pCi/L.



## A.12 PARCEL 2-45* (Buildings 42 and 42-1—Warehouse)

Parcel 2-45 (Figure A-2) is approximately 5.3 acres in size and is located north of Building 52 and east of Building 43. The parcel contains Building 42, which is currently leased by LIDA and is used for making recycled wood products. In the early 1980s, an undisclosed number of drums were reported to be stored outside the southern end of Building 42. The drums were reported to contain used solvents (1,1,1-trichloroethane [TCA] and trichloroethylene [TCE]) and metal/flux residue. The actual number of drums was not reported; however, it is assumed that there were quantities

of hazardous materials referenced in 40 CFR 373 stored in this area. This drum storage area at Building 42 was investigated in 1987 (ESE, 1987b). The results of this site investigation (SI), which consisted of soil gas sampling performed in the vicinity of the former drum storage area,

indicated that there was not a release from the drums and no further action was recommended for the site (ESE, 1993). In addition, there was no visual evidence of spills/ releases/disposal in the area during the environmental baseline survey (EBS) inspection. The Army and ESE found no records or

visual evidence of releases of TCA or lithium.

The following hazardous substance activities involving quantities less than the quantities referenced in 40 CFR 373 occurred in Building 42:

!" Storage of lithium batteries and drums of a urethane foam resin used to make packing material.

!" Records indicate small amounts of TCA and TCE were used to clean parts prior to painting and/or long-term storage.

There was also a paint booth in Building 42. The paint booth was selfcontained and was used to paint small parts for engines. According to aLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-9 LEAD employee, the paint booth was not used to strip or clean the parts and no solvents were used or stored in the booth. The paint booth was dismantled and removed in 1994. There are no records or evidence of any releases from paint booth activities.

At Building 42, 0.5 gal of motor oil (20 July 1990) and an undetermined amount of diesel fuel (31 May 1991) were spilled. The spills were all properly reported, recovered, contained, and/or cleaned up (WESTON, 1996).

Building 42 is a former warehouse and shipping facility that was built in
1943 and constructed of concrete, brick, and wood. The southern end of Building 42 was used to store engines. The northern end of Building 42 was used as a shop for construction of custom shipping packaging (wooden crates). The building is heated by a furnace fueled by heating oil that is stored in a 7,500-gal UST. An asbestos survey conducted at Building 42 identified the presence of ACM, including transite wallboard on the bay doors and fire sprinkler valve boxes, floor tile, wall spackling, and pipe insulation. The FPT associated with Building 42 was formerly located just north of the building, between the building and New Mexico Avenue. This FPT was removed in April 1995. No LBP surveys have been conducted for Building 42. Radon levels obtained during testing of the building ranged from concentrations of 0.4 to 1.6 pCi/L, which are below the EPA-recommended residential action level of 4 pCi/L.

A tritium room was located in the northeastern corner of Building 42. The tritium room was decommissioned in March 1995 following NRC guidance. Building 42 is suitable for unrestricted use (WESTON, 1999c).

Parcel 2-45 also contains Building 42-1, a 384-ft 2 building associated with Building 42 that is used to house an air compressor. Building 42-1 was built in 1943 and is constructed of concrete, brick, and wood. Building 42-1 is unheated. No ACM was identified in Building 42-1. LBP and radon were not evaluated at Building 42-1.



## A.13 PARCEL 2-46 (Buildings 41, 41-2, and 51-2—Warehouse and Outbuildings)

Parcel 2-46 (Figure A-2) is approximately 5.3 acres in size and is located north of Building 51 and east of Building 42. The parcel contains Buildings 41, 41-1, and 51-2. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for warehousing. Transformers were once stored temporarily in the warehouse. It is not known if the transformers stored at Building 41 were PCB-containing. A hydraulic oil spill occurred at Building 41 (January 1989) and a heating oil spill occurred at Building 41-1 (March 1996). Both spills were cleaned up properly.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-10 Building 41 is a general storage warehouse that was constructed in 1943
and is constructed of brick walls with a wooden roof, and a concrete foundation. The building is a controlled humidity warehouse that is unheated. An asbestos survey was conducted at Building 41, which identified the presence of transite. No LBP surveys were conducted at Building 41. Radon testing was conducted at Building 41, which showedthat radon concentrations of 1.4 to 2.2 pCi/L were below the EPArecommended residential action level of 4 pCi/L.

Building 41-1 is an outbuilding that was used as a restroom facility. There was no ACM found in Building 41-1. The building has not been evaluated for LBP or radon. The building is heated using heating oil supplied by a 300-gal AST.

Building 51-2 is an open, unheated bus shelter constructed of wood. Building 51-2 has not been evaluated for ACM, radon, or LBP.



## A.14 PARCEL 2-47 (Building 247—Office)

Parcel 2-47 ( Fig u r e A-3 ) is appro x

imately 3 acres in size and is located northwest of the intersection of Michigan and California Avenues. Parcel 2-47, which contains Building 247, is surrounded by open grassy areas. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been open, containing only Building 247. A fuel oil spill was reported for Building 247 (June 1988), which was cleaned up properly.

Building 247 is an office building that was used for the property book inventory, and appears to have originally been a firehouse. Building 247

was built in 1943 and is constructed with a concrete foundation and wooden walls and roof. Building 247 is heated using fuel oil supplied by a 500-gal AST. An ACM survey identified ceiling tile, transite board, floor
tile, and mastic as ACM. Records from the LEAD ACM abatement program indicate that some ceiling tile and pipe insulation have been removed at Building 247. Radon and LBP have not been evaluated at Building 247.



## A.15 PARCEL 2-48 (Golf Course)

Parcel 2-48 (Figure A-3) is approximately 14.9 acres in size and contains a portion of the golf course. The parcel is bordered to the north by Coffey Avenue, to the east by railroad tracks, and to the south by Building 19. Historical aerial photographs indicate that this parcel has always been open (1949 and 1957), with the first evidence of the golf course in 1963. There are no permanent structures on Parcel 2-48.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-11 

## A.16 PARCEL 2-49 (Buildings 502, 503, 504, and 508—Base Housing and Outbuildings)

Parcel 2-49 (Figure A-3) is approximately 5.9 acres in size and contains a portion of the golf course and Buildings 502 (guesthouse), Building 503 (house), Building 504 (garage), and Building 508 (lift station). The lift station was used for transporting sanitary wastewater from the adjacent base houses to the sanitary sewage treatment plant (SSTP). The parcel is bordered to the north and west by Coffey Avenue and to the south by former Building 581. Historical aerial photographs indicate that this parcel has always been mostly open land with the structures mentioned (1949 and 1957), with the first evidence of the golf course in 1963. The guest house (Building 502) and the garage (Building 504) were built in 1943; both are constructed of wood. The guesthouse is heated using electricity. The asbestos survey for Building 502 identified tile as ACM. Building 504 was not evaluated for ACM. Buildings 502 and 504 were not

evaluated for LBP or radon.

Building 502, a very small guesthouse, was not evaluated for radon because it was used, and could only be used in the future, for transient visitors and was not used as a full-time residence or part-time work

location.

The house (Building 503) was built in the 18th century of logs and stucco. The house is heated using heating oil supplied by two 275-gal ASTs located in the basement. The ACM survey conducted at the house identified refractory cement, floor tile, and mastic as ACM. According to
LEAD records, transite board has been removed from the house. Radon concentrations of 1.9 to 5.6 pCi/L were detected in the house, which are above the EPA-recommended residential action level of 4 pCi/L. The house is used for transient residential use, and radon mitigation was not completed for this structure. LBP was identified at Building 503, and was noted to be in good condition.

Building 508 is a lift station, which was built in 1960 and is constructed of brick and wood on a reinforced concrete foundation. Building 508 was
not evaluated for ACM, LBP, or radon.



## A.17 PARCEL 2-50* (Building 18—Storage)

Parcel 2-50 (Figure A-3) is approximately 2.9 acres in size and consists of some open storage space and Building 18. The parcel is located south of Building 38-1 and west of Michigan Avenue. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been open; Building 18 was used to store alkaline materials, including soaps and DS-1, a fluid used to decontaminate vehicles. TheLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-12 FPTs associated with Building 18 were formerly located together on one pole in a grassy area approximately 50 ft northeast of the building, between the building and Michigan Avenue. These FPTs were removed in November 1986 and January 1986. Building 18 was built in 1943 and is constructed of brick and wood with a concrete slab foundation. Building 18 is not heated. An ACM survey identified transite board, floor tile, and mastic as ACM. Radon was detected at a level of 1.6 pCi/L, which is below the EPA-recommended residential action level of 4 pCi/L. LBP was not evaluated at Building 18.



## A.18 PARCEL 2-51 (Golf Course)

Parcel 2-51 ( Fig u r e A-4 ) is appro x

imately 4.7 acres in size and contains a portion of the golf course. The parcel is bordered to the north by Coffey Avenue and to the south by Oregon Avenue. Historical aerial photographs indicate that this parcel has always been open land (1949 and 1957), with the first evidence of the golf course in 1963. There are no permanent structures on Parcel 2-51.



## A

. 19 P A RCEL 2-52 (Golf Course)

Parcel 2-52 (Figure A-4) is approximately 6 acres in size and contains a portion of the golf course. The parcel is bordered to the north by Building 19 and to the south by Oregon Avenue. Historical aerial photographs indicate that this parcel has always been open land (1949 and 1957), with the first evidence of the golf course in 1963. There are no permanent

structures on Parcel 2-52.



## A.20 PARCEL 2-53 (Golf Course)

Parcel 2-53 ( Fig u r e A-5 ) is appro x

imately 10 acres in size and contains a portion of the golf course. The parcel is bordered to the northwest by Coffey Avenue and to the northeast by Oregon Avenue. Historical aerial photographs indicate that this parcel has always been open land (1949 and 1957) with the first evidence of the golf course in 1963. There are no permanent structures on Parcel 2-53.



## A.21 PARCEL 2-54 (Building 531—Lift Station)

Parcel 2-54 (Figure A-5) is approximately 6.6 acres in size and contains a portion of the golf course and Building 531. The parcel is bordered to the north by Coffey Avenue and to the south by Carbaugh Avenue.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-13 Historical aerial photographs indicate that this parcel has always been open land (1949 and 1957), with the first evidence of the golf course in

1963.

Building 531 is a lift station for sanitary sewage east of Building 521. The lift station was used for transporting sanitary wastewater from the adjacent base houses to the SSTP. It was built in 1945 and is constructed of cinder blocks on a concrete foundation with a wooden roof. Building
531 is not heated and has not been evaluated for ACM, radon, or LBP.



## A.22 PARCEL 2-55* (Building 436 – Maintenance)

Parcel 2-55 ( Fig u r e A-6 ) is appro x

imately 0.7 acre in size and is located north of Carbaugh Avenue and west of New York Avenue. Parcel 2-55 consists of Building 436.

Building 436 is currently used to test filter apparatus. In the past, this building was used to rehabilitate gas masks. Building 436 was built in
1943 and is constructed with a concrete slab foundation, brick walls, and a steel-structure, concrete roof. Evidence of a pit or bay for vehicle repair was noted during the visual survey. Several chemicals, used in small quantities and related to the testing of filter units, were noted, including diophiothalate (DOP), Emeruz 3004, ether, freon (calibration gas), insecticides, paints, lube oils, and TCA.

An asbestos survey did not identify any ACM at Building 436. LBP wasnot evaluated. Radon was detected (2.1 pCi/L) below the EPArecommended residential action level of 4 pCi/L.

The LEAD records indicate that the FPT located near Building 436 was removed in January 1995. This FPT was located in a grassy area between Buildings 426 and 436 along New York Avenue. Although it was located in Parcel 2-55, this FPT was associated with Building 426 (located in Parcel 2-56) in the Decision Document for purposes of identification/sampling.



## A.23 PARCEL 2-56 (Building 426—Maintenance)

Parcel 2-56 (Figure A-6) is approximately 1.4 acres in size and is located north of Carbaugh Avenue and west of New York Avenue. The parcel consists of Building 426. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for the activities associated with Building 426. Small amounts of solvents (acetone), isopropanol, paints, paint thinners, and adhesives are used and are stored in two flammables cabinets at Building 426. A spill of 1 gal ofLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-14 battery acid from a forklift was reported (October 1995). The acid was neutralized, and the residue cleaned up using absorbent material. Building 426, the former Box Shop, has been extensively renovated (1994) and is now being used for the Tow Bradley and Cobra mission. Building
426 was built in 1942 and is constructed on a concrete slab foundation, with brick walls and a steel-structure, concrete roof. An asbestos survey identified pipe insulation, wallboard spackling, floor tile, and mastic as ACM. LEAD records indicate some ACM has been removed, including pipe insulation, transite board, floor tile, and mastic. The building is heated with steam produced at Building 423. LBP has not been evaluatedat Building 426. Radon has been detected (4.2 pCi/L) above the EPArecommended residential action level of 4 pCi/L. The FPT associated with Building 426 was formerly located in Parcel 2-55; see write-up for Parcel 2-55 (Subsection A.22).



## A.24 PARCEL 2-57 (Buildings 424 and 425—Maintenance/Shop)

Parcel 2-57 (Figure A-6) is approximately 1.4 acres in size and is located north of Carbaugh Avenue and east of New York Avenue. The parcel consists of Buildings 424 and 425. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been used for the activities associated with Buildings 424 and 425.

Building 424 was built in 1942 and is constructed of a concrete slab foundation, brick walls, and a steel-supported reinforced concrete roof. The building is heated with steam produced at Building 423. Small amounts of hazardous materials were stored (in flammables cabinets) and used in Building 424, including petroleum-based chemicals, adhesives, polyurethanes, stains, paint thinners, paint removers, paints, acetone, and gasket remover solvent. There was also a parts washer that used PD 680 (petroleum-based cleaning agent). The northern end of Building 424 was used as an upholstery shop, the southern end was used as a cable and harness (electrical) shop, and the center was used as a woodworking shop. According to LEAD personnel, the upholstery shop formerly had dip tanks (circa 1975) in the northeastern corner of the building and was once used to test gas masks and maintain/repair optical equipment. An asbestos survey completed for Building 424 identified pipe insulation, pipe fitting(s), transite board, floor tile, and mastic as ACM. Records indicate that some ACM pipe insulation has been removed. LBP has not been evaluated at Building 424. A radon survey conducted at the building indicated radon levels between 0.6 and 1.5 pCi/L, which are below the EPA-recommended residential action level of 4 pCi/L.

Building 425 was built in 1942 and is constructed with a concrete slab
foundation, brick walls, and a wood structure roof, and is heated with steam produced at Building 423. Building 425 was formerly used as aLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-15 barber shop, but LEAD records (archive photograph and UST removals) indicate that it was previously used as a gasoline station. Four USTs associated with Building 425 (located across the side street), which are not part of this parcel, were removed in late 1990. There was evidence of a release of product to the soil, which was reported to the Pennsylvania Department of Environmental Protection (PADEP). The contaminated soil was subsequently removed. PADEP approved the closure report for these tanks in 1991 (Brooks, 1991). Currently, there are no USTs or ASTs associated with Building 425. An asbestos survey conducted at the building identified floor tile and mastic as ACM. There are no records of ACM removals. LBP has not been evaluated at Building 425. A radon survey conducted at the building indicated a radon level of 1.8 pCi/L,

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



## A.25 PARCEL 2-58 (Buildings 475 to 480—Storage)

Parcel 2-58 (Figure A-4) is approximately 4.4 acres in size and is located south of Oregon Avenue and east of New York Avenue. The parcel consists of open storage areas and Buildings 475, 476, 477, 478, 479, and 480. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used for storage prior to the construction of the storage buildings. Buildings 475 through 480 comprise the gas cylinder storage area at LEAD. These buildings, constructed of corrugated steel
sides and roof on concrete slabs, were erected between 1962 and 1971 to provide storage shelters for cylinders in use at LEAD. An inspection of

the interior and exterior of these structures was conducted on 4 October 1995. At the time of the inspection, the following contents of the buildings were noted:

!" Building S-475—Argon gas.

!" Building S-476—Acetylene gas, Freon 12, propane for forklifts.

!" Building S-477—Chlorine gas.

!" Building S-478—Nitrogen gas, halon-containing ball-type fire extinguishers.

!" Building S-479—Refrigerants, fire extinguishers.

!" Building S-480—Oxygen, refrigerants, nitrous oxide.

No evidence of spills or leaks was noted during the facility inspection. The chlorine gas storage building (Building 477) is equipped with a leak detection system that alerts the fire department in the event of a leak. Chlorine gas leaks were reported in August 1990 in Building 477. The leaks were repaired as soon as possible after detection. None of the other buildings are equipped with utilities of any kind (electric, heat, phone,Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-16 etc.). No radon, LBP, or asbestos surveys were reported for these buildings.



## A.26 PARCEL 2-59 (Open Area)

Parcel 2-59 (Figure A-4) is approximately 3.8 acres in size and is located south of Oregon Avenue and west of Michigan Avenue. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used for storage activities. There are no permanent structures on

Parcel 2-59.



## A.27 PARCEL 2-60 (Building 441—Warehouse)

Parcel 2-60 (Figure A-4) is approximately 1.4 acres in size and consists of Building 441. The parcel is located north of Building 431 and west of Michigan Avenue. Building 441 was the radioactive material storage building. There were no other substances stored at Building 441. There were no releases of radioactive material reported to NRC. In addition, the building underwent an NRC closure for an affected building. An affected building is “any area that has the potential for radioactive contamination that exceeds or is a significant fraction of release limits.” It was concluded in the Final Termination Survey Report (WESTON, 1999e) that the building is suitable for unrestricted use based on the NRC release guidelines and EPA’s risk standard.

Building 441 was constructed in 1942 of brick and steel on a concrete foundation. Building 441 is not heated. The ACM survey identified floor tile and transite board with no records of any ACM removals. Radon wasfound at levels ranging from 2.8 to 3.2 pCi/L, which are below the EPArecommended residential action level of 4 pCi/L. LBP was not evaluated. A hydraulic oil spill occurred in December 1988. The spill was properly

remediated.



## A.28 PARCEL 2-61 (Buildings 431, 431-1, and 3335—Maintenance and Outbuildings)

Parcel 2-61 (Figure A-6) is approximately 1.5 acres in size and consists of Buildings 431, 431-1, and 3335. The parcel is located north of Building 421 and west of Michigan Avenue.

Building 431 was constructed in 1943 of brick and steel on a concrete foundation. Since 1969, Building 431 has been the Testing Measurements Diagnostic and Engineering (TMDE) Building at LEAD. The Army plans to lease back this building after transfer for continued TMDE use. Prior toLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-17 1969, the building was reportedly used as a warehouse. The southern end of Building 431 is used for offices. There are five temperature and humidity-controlled calibration testing laboratories associated with Building 431. Laboratory 1 tests physical dimensions and has associated mercury (Hg) columns. The mercury is reclaimed once a year and sent to Redstone Arsenal. Grain (ethyl) alcohol is used as a cleaning fluid. Laboratory 2 tests microwave components and has no chemical use. Laboratory 3 tests electrical components and uses a constant temperature oil bath. The oil is changed out every 5 years and disposed of through the Defense Reutilization and Marketing Office (DRMO). Laboratory 4 tests electrical components with no associated chemical use. Laboratory 5 tests and stores radiation sources, including ionizing and nonionizing sources. Daily surveys and monthly wipe tests are performed at Laboratory 5. A flammables cabinet and a 55-gal drum of light mineral oil (MARCOL) were noted during the visual survey. An asbestos survey identified ACM dust (on the ceiling tile), pipe insulation, transite board, floor tile, and mastic as ACM. LEAD records indicate that some pipe insulation and transite board have been removed. Transite board was noted during the EBS visual survey. LBP has not been evaluated at Building 431. Building 431 is heated by steam, which is generated at Building 423. Radon was detected (1.9 to 2.8 pCi/L) below the EPA-recommended residential action level of 4 pCi/L.

Building 431-1 is a small concrete block structure that contains a lift station for sanitary sewage. The lift station was used for transporting sanitary wastewater from the adjacent base houses to the SSTP. The structure was built in 1960 and is located south of Building 431. Building
431-1 is not heated and has not been evaluated for ACM, radon, or LBP.

Building 3335 is an open, unheated bus shelter constructed of wood. Building 3335 is located west of Building 431. Building 3335 has not been
evaluated for ACM, radon, or LBP.



## A.29 PARCEL 2-62 (Building 421—Office)

Parcel 2-62 (Figure A-6) is approximately 1 acre in size and consists of Building 421. The parcel is located south of Building 431 and west of Michigan Avenue. Building 421 is an office administration building that was built in 1942, and is heated by steam produced at Building 423. Building 421 is constructed with a concrete slab foundation, brick walls, and a concrete roof with steel structure. An asbestos survey conducted for Building 421 identified pipe insulation, a pipe fitting, floor tile, and mastic as ACM. LEAD records indicate that some ACM pipe insulation has been removed. LBP was not evaluated at Building 421. Radon was detected (2.7 to 4.6 pCi/L) above the EPA-recommended residential criterion of 4 pCi/L.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-18 

## A.30 PARCEL 2-63 (Open Area)

Parcel 2-63 (Figure A-6) is approximately 8.1 acres in size and is located east of Building 431. The parcel consists of open storage areas with no permanent structures. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used as a storage area.



## A.31 PARCEL 2-64 (Building 59—Storage)

Parcel 2-64 (Figure A-6) is approximately 7.2 acres in size and is located north of Texas Avenue and east of Michigan Avenue. The parcel currently consists of paved storage areas and Building 59. Two storage sheds, 58-1 and 58-2, have recently been removed from the parcel. Building 59 was used to store vehicles and office furniture. Buildings 58-1 and 58-2 were used to store antifreeze, lube oil, grease, paints, tires, and transmission fluid. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used as a storage area. Buildings 58-1, 58-2, and 59 were constructed of steel on concrete pad foundations. ACM, LBP, and radon were not evaluated for any of these buildings. Buildings 58-1 and 58-2 were not heated. Building 59 was heated with heating oil stored in a 275-gal AST. The AST has been removed.



## A.32 PARCEL 2-65 (Open Area)

Parcel 2-65 ( Fig u r e A-7 ) is appro x

imately 1.8 acres in size and is located east of Building 37. The parcel consists of an open area where storage sheds 36-1, 36-3, and 36-5 were formerly located; the sheds were recently demolished. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used as a storage area.



## A.33 PARCEL 2-66 (Open Area)

Parcel 2-66 (Figure A-7) is approximately 1.2 acres in size and is located east of Building 47. The parcel consists of an open area where storage sheds 46-1, 46-4, and 46-7 were formerly located; the sheds were recently demolished. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been used as a storage area.



## A.34 PARCEL 2-67 (Building 56—Warehouse/Industrial)

Parcel 2-67 (Figure A-7) is approximately 4.8 acres in size and consists of Building 56. The parcel is located north of Texas Avenue and east ofLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-19 Building 57. There is no evidence that quantities of hazardous substances in excess of the quantities referenced in 40 CFR 373 were stored, released, or disposed of at Building 56.

Building 56 is a 92,222-ft 2 light industrial building. Building 56 was a former refrigerated warehouse that until recently contained the Paladin integration and assembly facility, which was operated by United Defense Limited Partnership (UDLP). The Paladin mission at Building 56 consisted of an upgrade of the M-109 howitzer, which is a tracked mobile artillery vehicle. The Paladin upgrade process included the attachment of an upgraded turret on a rebuilt chassis. Activities related to this process included testing hydraulic lines and minor amounts of painting. Building
56 was constructed in 1943 and consists of a concrete slab foundation, brick wall, and a wood-frame roof structure. Building 56 has been extensively remodeled to correspond to the new use. As part of the remodeling effort, the roof in the centerline of the building was removed and replaced with a higher steel structure to allow the installation of a crane. The building is heated using fuel oil, which is supplied by three 2,500-gal ASTs. An asbestos survey conducted at Building 56 identified the presence of ACM, which was transite wallboard on the bay doors. The transite wallboard was removed when the building was remodeled. Radon was detected between 1.2 and 2.0 pCi/L, which is below the EPA recommended residential action level of 4 pCi/L.

Sealed radioactive (tritium) components (scopes containing sealed radioactive components) were routinely staged (pre-positioned) for short periods (less than 30 days) at Building 56 prior to shipment with the Paladins. The components were swipe-sampled at Building 51, verified as acceptable, and packaged in boxes prior to the short-term staging at Building 56. These boxes were then loaded into the Paladins for shipment. There have been no documented releases of radioactive materials resulting from the short-term staging of these components. The Army sampled the Building 56 areas used for staging the sealed sources

in June 1999 and confirmed that residual tritium contamination is not present. The results of the sampling at Building 56 are summarized in the revised historical assessment (WESTON, 1999c). Building 56 is classified as nonimpacted by the Army following NRC regulations. Building 56 is suitable for transfer without any use restrictions.



## A.35 PARCEL 2-68 (Buildings 55 and 1-55—Warehouse)

Parcel 2-68 (Figure A-7) is approximately 5.4 acres in size and consists of Buildings 55 and 1-55. The parcel is located north of Texas Avenue and east of Building 56. Building 55 was used for the storage of miscellaneous equipment and hardware (i.e., field refrigerators, sand-blasting grit, grenade launchers, barrier fabric, plywood, and missile targets). LIDALetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-20 currently plans to lease Building 55 from the Army prior to the property transfer; under the lease the building will be used as a warehouse.

Building 55 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. An asbestos survey conducted at Building 55 identified the presence of transite wallboard, floor tile, and mastic. No LBP or radon surveys were conducted at Building 55.

Building 1-55 is a former restroom facility located adjacent to Building 55. Floor tile and mastic were identified as ACM at Building 1-55. In the more recent past, the building was used for an office and housed ice machines. No LBP or radon surveys were conducted at Building 1-55.



## A.36 PARCEL 2-69 (Open Area)

Parcel 2-69 (Figures A-2, A-6, and A-7) is approximately 10.9 acres in size and is located south of Texas Avenue, along the southern boundary of LEAD. There are no structures on Parcel 2-69 and the parcel is currently open land. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or

industrial activities.



## A.37 PARCEL 2-70 (Building 521—Fire Station)

Parcel 2-70 (Figure A-5) is approximately 2.3 acres in size and is located at the intersection of Carbaugh and Coffey Avenues. The parcel consists of Building 521, which is the LEAD fire station. After transfer, the Army plans to lease back this building for continued use as a fire station. Building 521 is heated using heating oil that is supplied by a 2,000-gal UST installed in 1998. There is one existing registered 550-gal UST (No. 069) that contains diesel that is used to fuel the emergency generator. A registered 550-gal gasoline UST (No. 004) was removed in July 1998. Based on LEAD records, there was no evidence of any petroleum release associated with this UST. Small amounts of cleaning materials and lubricant oils are stored in the basement. Fire-fighting foaming agents are stored in a shed outside the building.

Building 521 is constructed with a concrete foundation, brick walls, and a wood-frame roof. The first floor consists of offices and emergency vehicle storage. The second floor is a dormitory area for employees on 24-hour duty. The basement is used for storage and houses the heating plant for the building. An asbestos survey completed at Building 521 identified transite board, floor tile, mastic, pipe insulation, pipe fittings, and tankLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-21 insulation as ACM. LEAD records indicate that tank insulation, pipe insulation, and tiles have been removed at Building 521. Radon testing at Building 521 indicated low levels of radon (0.7 to 3.8 pCi/L), which are below the EPA-recommended residential action level of 4.0 pCi/L. LBP was not evaluated for Building 521.



## A.38 PARCEL 2-71 (Open Area)

Parcel 2-71 ( Fig u r e A-8 ) is appro x

imately 7.8 acres in size and is located south of Carbaugh Avenue along the southern boundary of LEAD. There are no structures on Parcel 2-71 and the parcel is currently open. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or industrial

activities.



## A.39 PARCEL 2-72 (Buildings 664 and 686—Office and Storage)

Parcel 2-72 (Figure A-8) is approximately 4.2 acres in size and consists of Buildings 664 and 686. A 300-gal AST (with berm) containing gasoline was identified in the parking area northwest of Building 664. Gasoline in this AST is reportedly used to fuel lawn maintenance vehicles.

Building 664 is an office building that was constructed in 1943 of wood frame on a concrete slab. An asbestos survey conducted in the building identified the presence of ACM in pipe insulation, floor tile, transite
wallboard, and mastic. Some floor tile and mastic have been removed. Radon was detected (1.6 to 3.1 pCi/L) below the EPA recommended residential criterion of 4 pCi/L. LBP has not been evaluated for Building

664.

Building 686 was built in 1949 and is constructed of corrugated steel with a concrete floor. Building 686 is not heated. ACM, radon, and LBP have not been evaluated for Building 686.



## A.40 PARCEL 2-74A (Open Area – Agricultural Parcel)

Parcel 2-74A ( Fig u r e A-9 ) is appro x

imately 40.8 acres in size and is located south of the SSTP on South Patrol Road along the southern boundary of LEAD. There are no structures on Parcel 2-74A and the parcel is currently open land. The parcel is currently leased, and has been leased in the past, for agricultural use. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or industrial activities.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-22 

## A.41 PARCEL 2-74B (Buildings 600 to 608, 610, 612, 623, and 625— Housing, Storage, and Outbuildings)

Parcel 2-74B (Figure A-9) is approximately 30.6 acres in size and is located south of the intersection of South Patrol Road and Pennsylvania Avenue, along the southern boundary of LEAD. The parcel consists of a former base housing area (Kenny Gardens and associated storage buildings – Buildings 600 to 608, 610, 612, 623), ballfields, and Building 625 (a concession stand for the softball field). In addition, this parcel contains the Building 618 area, which includes Buildings 616, 618, 619,
621, 627, 628, 629, and 638. This area is located at the northeastern corner of the parcel, southwest of the intersection of Carbaugh and Pennsylvania Avenues and South Patrol Road. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel, other than the Building 618 area, was an open area with no apparent storage or

industrial activities.

One UST provides fuel oil for the boiler that services all of Kenny Gardens. This UST is located in front of Building 604.

Kenny Gardens was constructed in 1954 to house enlisted men and their families. The housing units consist of nine residential buildings (Buildings 600 through 608) constructed of concrete and wood, originally with aluminum siding (now covered with vinyl siding), and wood truss and shingle roofs. Some of the units are constructed on subgrade foundations with crawlspaces, whereas most are built on concrete slabs. The 9 buildings are divided into 29 residential dwellings comprised of first- and second-story units. In 1968 and 1973, two additional buildings (Buildings 610, 612, and 623) were constructed at Kenny Gardens to provide storage units for the residences. These buildings are located behind the housing. ACM, including vinyl flooring, floor tile, mastic, baseboard trim, and wallboard, was identified in the housing units at Kenny Gardens (Buildings 600 through 608). ACM was not evaluated in Buildings 610, 612, or 623. Radon testing was conducted in the housing units. None of the radon concentrations detected (ranging from 0.5 to 2.0 pCi/L) were above the EPA-recommended residential action level of 4 pCi/L. LBP was identified in the Kenny Gardens housing units and was noted to be in good condition.

Building 625 is a concession stand for the softball field. Building 625 was

built in 1990 and is constructed of cinder blocks and wood. The inside of the building was not accessible during the EBS visual survey. The building is not heated. ACM, radon, and LBP were not evaluated for Building 625.

The Building 618 area includes Buildings 616, 618, 619, 621, 627, 628, 629, and 638. This area is located at the northeastern corner of the parcel,Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-23 southwest of the intersection of Carbaugh and Pennsylvania Avenues

and South Patrol Road.

Building 616 houses the LEAD directorate of law enforcement and security. The one-story building was constructed in 1944 of wood frame. The building was used as a locker facility and weapons storage area for the Depot police. A 500-gal AST is located near the western corner of the building to provide fuel for the heating system. There is a 500-gal heating oil UST in the same area that is no longer in service. There are no records that indicate the tank has been removed. An asbestos survey conducted at Building 616 identified the presence of ACM (i.e., floor tile/mastic and transite). Radon testing for Building 616 has not been conducted. LBP has been evaluated from one sample collected in this building, which showed the presence of lead at a concentration of 5.9%. Building 617 was formerly located near Building 616. The one-story building formerly contained the wood shop and was demolished in 1996.

Building 618 houses the environmental offices for LEAD. The two-story building was constructed in 1943 of wood on a concrete pad. The building is used as administrative offices by various departments of the environmental office, and no industrial operations are conducted in this building. The building is heated by a boiler fueled from a 500-gal AST located south of the building. An asbestos survey conducted at Building 618 identified the presence of ACM (i.e., spackle/joint compound, tile, and transite). Radon testing for Building 618 indicated levels ranging from 0.7 to 0.8 pCi/L, which are below the EPA-recommended action level of 4 pCi/L. LBP has not been evaluated in this building. The LEAD spill inventory contained one incident report associated with Building 618, which was a hydraulic fluid spill in the parking area in March 1991. This spill was reportedly cleaned up with absorbent material, and no migration into the soils occurred.

Building 619 is the former enlisted men’s club. The building has been used as a daycare facility for LEAD personnel ever since the enlisted personnel recreational activities ceased. The one-story building was constructed in 1943 of structural tile and wood. In the past, enlisted personnel used the building as a recreational facility, and no industrial operations are conducted in this building. The building is heated by a boiler located inside the northern part of the building; the boiler is fueled by a 275-gal AST. An asbestos survey conducted at Building 619 identified the presence of ACM (i.e., floor tile and mastic). Radon testing for Building 619 indicated a concentration of 1.3 pCi/L, which is below the EPA-recommended action level of 4 pCi/L. LBP has been evaluated in this building and was detected at a concentration of 101 micrograms per gram ( μ g/g).

Building 627 serves as LEAD’s post exchange (PX), where active and retired military personnel can purchase food and sundries. The buildingLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-24 was constructed in 1944 of concrete block. The interior of the building consists of a shopping area with refrigeration units for beverages and frozen foods, and a separate storage area in the rear of the building. The building is heated by a boiler supplied by a 500-gal fuel oil AST located outside the building. No asbestos survey has been conducted at Building 627. Suspect ACM noted during the site inspection includes wallboard and floor tile. Radon testing conducted at Building 627 indicated radon concentrations ranging from 2.3 to 11.2 pCi/L; 8 of the 10 sample results are above the EPA-recommended action level of 4 pCi/L. These results include the results of retesting conducted in 1996. A lead paint sample collected from Building 627 contained lead at a concentration of 76 μ g/g. Building 621 is a storage shed associated with the PX, used to store extra shelving and promotional displays. The shed was built in 1966 and is
constructed of steel. ACM, radon, and LBP were not evaluated at Building 621.

Building 628 was the security office. The two-story building was constructed in 1943 of wood frame on a concrete slab. The security personnel used the building as administrative offices, and no industrial operations were conducted in the past, or are currently conducted in this building. The building is heated by a boiler fueled from two 275-gal ASTs located north of the building. An asbestos survey conducted at Building 628 identified the presence of the following ACM: pipe insulation, mastic, tile, and spackle/joint compound. Radon testing for Building 628indicated levels ranging from 1.2 to 2.3 pCi/L, which are below the EPArecommended action level of 4 pCi/L. LBP has not been evaluated in this building.

Building 629 formerly served as the Hunting and Fishing Office. The building was also formerly used as a training facility for LEAD personnel. The building was constructed in 1944 of wood frame. An asbestos survey conducted at Building 629 identified the present of ACM in the form of floor tile/mastic and spackle/joint compound. Radon testing conducted in the building showed radon levels well below the EPA-recommended action level of 4 pCi/L, with concentrations ranging from 1.0 to 1.2 pCi/L. LBP has not been evaluated at the building.

Building 638 is located northeast of Building 628 and was formerly used as a guardhouse at Gate 17. Building 638 was built in 1942, and is constructed of brick and wood. It is heated using electricity. ACM, radon, and LBP have not been evaluated at Building 638.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-25 

## A.42 PARCEL 2-76 (Buildings 2279 and 2280—Housing and Outbuildings)

Parcel 2-76 ( Fig u r e A-10 ) is appro x

imately 22 acres in size and consists of mostly open space (agricultural use) and one residential unit. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel was an open area with no apparent storage or industrial activities.

Family quarters 2279 (the Sergeant Major’s house) is located just north of the DRMO area off Pennsylvania Avenue and includes a garage (T-2280). The construction date of the house is unknown and the garage was built

in 1960. The house is constructed of brick and field stone with a wood roof. The garage is constructed of wood. The ACM survey identified pipe insulation, duct insulation, rope gasket, debris, floor tile, and mastic as ACM. There are no records of ACM removal at Building 2279. An LBP survey identified LBP, which was noted to be in good condition. Radon was detected between 1.4 and 7.5 pCi/L, the maximum of which is above the EPA-recommended residential action level of 4 pCi/L. The cracks in the concrete foundation were sealed to prevent future radon gas seepage. The house is heated using fuel oil supplied by two 275-gal ASTs in the basement. The garage was not evaluated for ACM, LBP, or radon.



## A.43 PARCEL 2-77 (Railroad Tracks)

Parcel 2-77 ( Fig u r e A-11 ) is appro x

imately 1.1 acres in s i z e a n

d c o

n

s

i s

t s o f the railroad tracks area located between the areas designated as “Parcel 1” and “Parcel 2” in the Phase I BRAC property transfer. The parcel is located southwest of the intersection of Coffey Avenue and East Patrol Road. There are no buildings associated with Parcel 2-77. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has always been railroad tracks with no apparent storage or industrial activities other than

railroad use.



## A.44 ROAD PARCELS

Many of the roads in the Phase II parcels are being renamed by LIDA. These new names are shown in brackets following the respective LEAD road name. The roadway parcels are shown in Enclosure 1, Figure 2.



### A.44.1 Parcel 2R-80 (Coffey Avenue—Buildings 301 and 511)

Parcel 2R-80 is approximately 15.3 acres in size and consists of Coffey Avenue between Gate 1 and Gate 6. The parcel includes Buildings 301 (Gate 6 Guardhouse) and 511 (Gate 1 Guardhouse). Historical aerialLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-26 photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.

Building 511 served as the guardhouse for Gate No. 1 to LEAD. This building was constructed in 1942 of brick and wood on a concrete foundation. The building was used to control access to the LEAD property, but is now vacant. An asbestos survey conducted at Building 511 identified the presence of ACM in floor tile and mastic. Radon testing conducted at Building 511 showed a radon concentration of 0.4 pCi/L,

which is well below the EPA-recommended residential action level of 4 pCi/L. LBP has not been evaluated for this building. The building was heated by a boiler system fueled by a 300-gal heating oil AST located adjacent to the building. A UST was used to store the fuel prior to the use of the AST. An investigation was completed to determine if the UST had released any petroleum in the past. The details of the investigation are documented in the Gate 1 Guardhouse remedial investigation/risk assessment (RI/RA) (WESTON, 2001a). The results of sampling and analysis of soils at the site and a screening level risk assessment (SLRA) indicated that no unacceptable risk to human health exists from

contaminants in soil based on the industrial/commercial use scenario.

Building 301 served as the guardhouse for Gate No. 6 to LEAD. The building was used to control access to the LEAD property, but is now vacant. Built in 1973, this building is constructed with cinder block and wood on a concrete foundation. Building 301 is heated using electricity. An ACM survey identified floor tile and mastic as ACM. Radon was detected at a level of 0.9 pCi/L, which is below the EPA-recommended residential action level of 4 pCi/L. LBP was not evaluated at Building

301.



### A.44.2 Parcel 2R-81 (Michigan [Technology] Avenue—Building 245)

Parcel 2R-81 is approximately 5.8 acres in size and consists of two sections of Michigan (Technology) Avenue; from Texas (Innovation) Avenue to California (Advantage) Avenue, and from Gate 5 to Washington Avenue. The parcel includes Building 245, which is the former Gate 5 Guardhouse. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.

Building 245 is a small guardhouse building (currently not used) for Gate 5 at LEAD. Building 245 was built in 1986 and is constructed of a concrete slab foundation, aluminum walls, and wood-frame roof. Building 245 is heated with electricity. Building 245 has not been evaluated for ACM,
radon, or LBP.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-27 A.44.3 Parcel 2R-82 (California [Advantage] Avenue)

Parcel 2R-82 is approximately 5.7 acres in size and consists of California (Advantage) Avenue between Texas (Innovation) and Coffey Avenues. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.



### A.44.4 Parcel 2R-83 (Overcash and Ohio Avenues)

Parcel 2R-83 is approximately 3.6 acres in size and consists of Overcash Avenue from Texas (Innovation) Avenue to the Enclave Area, and a short section of Ohio Avenue from California Avenue (Advantage) to the Enclave Area. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.



### A.44.5 Parcel 2R-84 (Texas [Innovation] Avenue)

Parcel 2R-84 is approximately 11.4 acres in size and consists of Texas (Innovation) Avenue from Coffey Avenue to Washington Avenue, continuing to Michigan (Technology) Avenue. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.



### A.44.6 Parcel 2R-85 (Oregon [Opportunity] Avenue)

Parcel 2R-85 is approximately 4.5 acres in size and consists of Oregon (Opportunity) Avenue from Washington (Innovation) Avenue to Coffey Avenue. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.



### A.44.7 Parcel 2R-86 (Carbaugh [Excel] Avenue)

Parcel 2R-86 is approximately 5.9 acres in size and consists of Carbaugh (Excel) Avenue from Michigan (Technology) Avenue to Pennsylvania (Letterkenny West) Avenue. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.



### A.44.8 Parcel 2R-87 (Pennsylvania [Letterkenny West] Avenue)

Parcel 2R-87 is approximately 4.2 acres in size and consists of Pennsylvania (Letterkenny West) Avenue from Carbaugh (Excel) Avenue to the entrance to the Ammunition Area (AA). Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC 4/30/2002 

### A-28 A.44.9 Parcel 2R-88 (Vehicle [Development] Road)

Parcel 2R-88 is approximately 3.8 acres in size and consists of Vehicle (Development) Road from Pennsylvania (Letterkenny West) Avenue to Scale House Road. Historical aerial photographs (1949, 1957, 1963, and 1970) indicate that this parcel has been a roadway.FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-29Table A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PAAsbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb5 2-392PINS, SPAC, TILE,TRAN, ROOF, MAST,DCTM, DCTCTILE, PINS No 1.0-5.6 NE No No 60-gal spill from a tanktruck in 5/92; smallamount (specific amountnot reported) ofpetroleum product spilledon 3/20/98; < 2 quarts“vinyl acid” spilled on8/13/97, cleaned up.5-2 2-392ROOF No No NE NE No No7 2-381TRAN, PINS TRAN Yes(removed4/93)4.4-12.4 NE No No Classified as unaffectedfrom storage ofradiological components;suitable for unrestricteduse.c1-7 2-381No No No NE NE No 300-gal HOTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-30Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb8 2-401TRAN, TILE, GASK GASK, TRAN No 2.7-5.3 NE 20,000-galHONo 5 gal No. 2 HO spill on12/15/95; < 50 gal No. 2HO spill on 5/14/97 inboiler room.Classified as unaffectedfrom storage ofradiological components;suitable for unrestricteduse.c1-8 2-401REFC No No NE NE No 300-gal HO18 2-501TILE, TRAN, MAST No Yes(removed11/86 and1/88)1.6 NE No No31 2-441TRAN No No 0.73-1.0 NE No No32 2-431TRAN No No 0.9-2.1 NE No No Oakite powder spill 3/90;hydraulic oil spill 5/97(<55 gal).Classified as unaffectedfrom storage ofradiological components;suitable for unrestricteduse.cTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-31Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb33 2-422TRAN TRAN No 7.2 NE 7,500-galHONo Heating oil spill 5/91(<55 gal); paint spill7/94; 1 bag aluminumsulfide powder spill 2/90.Classified as affectedfrom storage ofradiological components;suitable for unrestricteduse.d41 2-462TRAN No No 1.4-2.2 NE No No Hydraulic fluid spill1/89.41-1 2-462No No No NE NE No 300-gal HO 60-gal No. 2 fuel oil spill3/90.42 2-451TRAN, TILE, SPAC,PINSTRAN, PINS Yes(removed4/95)0.4-1.6 NE 7,500-galHONo Motor oil spill 7/90 (<55gal); diesel fuel spill5/91.42-1 2-451No No No NE NE No No49 2-371NE No No NE NE No No51-2 2-462NE No No NE NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-32Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb55 2-681TRAN, TILE, MAST No No NE NE No No1-55 2-681TILE, MAST, REFC No No NE NE No 275-gal HO56 2-671TRAN TRAN No 1.2-2.0 NE No 3 x 2,500-galHOClassified asnonimpacted fromstorage of radiologicalcomponents; suitable forunrestricted use.e211 2-361REFC, TRAN No Yes (removed1/94)0.8 NE No 300-gal HO245 2R-811NE No No NE NE No No247 2-471CT, TILE, MAST,TAR, PFIT, PINSPINS, CT No NE NE No 500-gal HO No. 2 fuel oil spill 6/88(<55 gal).301 2R-801TILE, MAST No No 0.9 NE No No421 2-621PINS, PFIT, TILE,MASTPINS No 2.7-4.6 NE No No424 2-571PINS, PFIT, TRAN,TILE, MASTPINS No 0.6-1.5 NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-33Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb425 2-571TILE, MAST No No NE NE No No426 2-561PINS, SPAC, TILE,MASTPINS, SPAC,TILE, MASTNo 4.2 NE No No 1 gal of battery acid fromforklift spilled (10/4/95);neutralized, absorbed, andabsorbent drummed.431 2-611PINS, TRAN, TILE,MASTPINS, TRANS No 1.9-2.0 NE No No 2 gal of hydraulic oilspilled on 1/6/99, cleanedup.Classified as unaffectedfrom storage of radiologicalcomponents; suitable forunrestricted use (ongoingoperations).c431-1 2-611NE No No NE NE No No436 2-551No No Yes(removed1/95)2.1 NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-34Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb441 2-601TILE, TRAN No No 2.8-3.2 NE No No Hydraulic fluid spill,12/88 and 8/90.Classified as affectedfrom storage ofradiological components;suitable for unrestricteduse.d475 2-581NE No No NE NE No No476 2-581NE No No NE NE No No477 2-581NE No No NE NE No No Chlorine gas leak 8/90.478 2-581NE No No NE NE No No479 2-581NE No No NE NE No No480 2-581NE No No NE NE No No502 2-491TILE No No NE NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-35Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb503 2-491TILE, MAST, REFC,TAPETRAN No 1.9-5.6 Yes – GC No 2 x 275-galHO504 2-491NE No No NE NE No No508 2-491NE No No NE NE No No511 2R-801MAST, TILE No No 0.4 NE Size of tankunknown –HO (not inservice)300-gal HO(REM)HO UST is still in place.It is not known whenUST was taken out ofservice.f521 2-701CINS, PINS, TILE,TRAN, MASTTILE, PINS,TRANNo 0.5-1.8 NE 2,000-galHOT (2000)550-gal DT (1996)gNo Hydraulic fluid spill 8/96(<55 gal); gasoline spill2/97 (<55 gal); 500-galUST removed in 1998,no record of release.g531 2-541NE No No NE NE No No600 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.1-1.9 Yes – GC See 604 No601 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.4-2.0 Yes – GC See 604 NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-36Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb602 2-74B1VINYL, TILE, MAST,BB, WALLNo No 0.5-1.3 Yes – GC See 604 No603 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.1-1.4 Yes – GC See 604 No604 2-74B1VINYL, TILE, MAST,BB, WALL, PINSPINS No 1.1-1.7 Yes – GC 6,000-galHOT (1996)No One UST serves all ofKenny Gardens.605 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.6-1.8 Yes – GC See 604 No606 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.0-1.3 Yes – GC See 604 No607 2-74B1VINYL, TILE, MAST,BB, WALLNo No 0.9-1.3 Yes – GC See 604 No608 2-74B1VINYL, TILE, MAST,BB, WALLNo No 1.0-1.1 Yes – GC See 604 No610 2-74B1NE No No NE NE No No612 2-74B1NE No No NE NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-37Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb616 2-74B1TILE, MAST, TRAN No No NE Yes – GC 500-gal HO(not inservice)500-gal HO HO UST still in place butnot in use since mid1990s; tank contentsremoved in 3/01, noevidence of release.618 2-74B1SPAC, TILE, TRAN No No 0.7-0.8 NE No 500-gal HO Hydraulic fluid spill 3/91(<55 gal).619 2-74B1TILE, MAST No No 1.3 Yes – GC No 275-gal HO621 2-74B1NE No No NE NE No No623 2-74B1NE No No NE NE No No625 2-74B1NE No No NE NE No No627 2-74B1NE; TILE - Visual No No 2.3-11.2 Yes – GC No 500-gal HO ACM identified duringvisual survey.628 2-74B1PINS, SPAC, TILE,MASTPINS, SPAC,TILE, MASTNo 1.2-2.3 NE No 500-gal HO629 2-74B1SPAC, TILE, MAST No No 1.0-1.2 NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-38Asbestos (ACM)BuildingParcelandECPCategoryaACMIdentifiedDocumentedRemovalsPCBContainingTransformerRadon(pCi/L)LBP Survey(1993/1994/1996) UST ASTReported Spills,Radiological Sources,andOther Commentsb638 2-74B1NE No No NE NE No No664 2-722PINS, TILE, TRAN,MASTTILE, PINS No 1.6-3.1 NE No 300-gal G inparking lot686 2-722NE No No NE NE No No Two 1,000-gal USTswere removed in 1992.There was evidence of arelease. Soils wereremoved and agroundwater study wascompleted.g2279 2-761TILE, CT (debris),MAST, GASK, PINSNo No 1.4-7.5 Yes – GC No 2 x 275-galHOOld well in yard.2280 2-761NE No No NE NE No No3335 2-611NE No No NE NE No NoTable A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-39aECP categories determined using AMC FOST/FOSL Guidance (AMC, 2000):Category 1 = Areas where no release or disposal of hazardous substances or petroleum products has occurred (including no migration of these substances from adjacent areas).Category 2 = Areas where only a release of petroleum products has occurred.Note that known or potentially VOC-contaminated groundwater underlies the property being transferred. The VOC groundwater contamination did not originate at any of thePhase II parcels. Also note that a release of petroleum products, for the purposes of the ECP category, is defined as greater than 55 gal (AMC policy), and for hazardoussubstances is defined as a CERCLA reportable release (see note in Table 2).bThis column includes some spills that are not listed in Table 2 or 3. These spills do not meet the requirement as reportable under CERCLA (see note in Table 2) or are less than 55gal for petroleum substances (AMC policy). However, these spills have been provided to the grantee for additional information purposes.cBuildings 7, 8, 32, and 431 were classified as unaffected (WESTON, 1999c). NRC defines unaffected as any area in which radioactive materials were handled but that have a verylow potential for residual contamination. The Final Termination Reports for Buildings 7 (WESTON, 1998e), 8 (WESTON, 1998d), and 32 (WESTON, 2000c), indicate that theyare suitable for unrestricted use. Building 431 has ongoing operations and reuse will remain the same; therefore, a Final Termination Survey is not needed at this time.dBuildings 33 and 441 contained areas that were classified as affected, which NRC defines as any area that has the potential forradioactive contamination that exceeds or is asignificant fraction of release limits. Final Termination Reports for Buildings 33 (WESTON, 1999d) and 441 (WESTON, 1999e) indicate that these buildings are suitable forunrestricted use.eBuilding 56 was classified as nonimpacted, which NRC defines as any area for which there is no reasonable potential for residual contamination. Building 56 does not require aFinal Termination Survey and is suitable for unrestricted use (WESTON, 1999c).fSampling completed in 1999 and a risk assessment (RA) performed in 2000 for Building 511 indicated that no remedial action is necessary to protect human health and theenvironment based on the intended future industrial use of the site. This evaluation is documented inFinal Remedial Investigation (RI)/Risk Assessment (RA) Report, Gate 1Guardhouse, Building 511(WESTON, 2001c).gThe 550-gal UST at Building 521 is currently regulated by the Pennsylvania Department of Environmental Protection (PADEP). Thereports detailing the tank closures forBuildings 521 and 686 and the correspondence from PADEP approving the remedial measures and investigations completed are in theUST files at LEAD.Table A-1Summary of Building Conditions of Phase II BRAC Parcels for the FOST,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALMK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC4/30/2002A-40KEY:TANKSCRDEP = Confirmed release, PADEP notified.D = Diesel.DW = Double-walled tank.G = Gas.gal = Gallons.HO = Heating oil.I = Installed.NE = Not evaluated.NGW = Groundwater near tank was not evaluated.NT = Not integrity tested.REM = Removed.SR = Soils removed.T(date) = Tank tightness tested, which means passed integritytest (date of test).RADONNE = Not evaluated/not surveyed.ASBESTOSBB = Baseboard trim.CINS = Ceiling insulation.CT = Ceiling tile.DCTC = Duct cloth.DCTM = Duct mastic.GASK = Gasket.MAST = Floor tile mastic.NE = Not evaluated/not surveyed.PFIT = Pipe fitting.PINS = Pipe/duct insulation.REFC = Refractory cement.ROOF = Roofing material.SINS = Stack insulation.SPAC = Spackle/joint compound.TAR = Tar wrap.TILE = Floor tile.TINS = Tank insulation.TRAN = Transite board.VINYL = Vinyl flooring.WALL = Wall board.LBP SURVEYGC = Paint in good condition.NE = Not evaluated/not surveyed.ppm = Parts per million.Yes = Survey completed; LBP identified.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC FINAL
04/30/02 

## ENCLOSURE 6

SUMMARY OF BUILDING CONDITIONS
PHASE II TRANSFER — BUILDINGS AND PARCELS
RESULTS OF FINAL VISUAL SURVEYSLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 4/30/2002 

### 6-1 

### ENCLOSURE 6

SUMMARY OF BUILDING CONDITIONS, PHASE II TRANSFER — BUILDINGS AND PARCELS,
RESULTS OF FINAL VISUAL SURVEYS

On 12 December 2000, 9 through 11 January 2001, and 3 April 2001 the Letterkenny Army Depot (LEAD) Base Realignment and Closure (BRAC) Cleanup Team (BCT), along with a representative from the Letterkenny Industrial Development Authority (LIDA), completed the final walkthrough visual surveys of the Phase II buildings and parcels. The purpose of the visual surveys was to assess the current conditions of the Phase II buildings and parcels. Particular attention was given to the current condition of accessible known asbestos-containing material (ACM) and lead-based paint (LBP). Accessible ACM is defined as material that would be accessible to occupants of a building under normal conditions. The visual survey for the condition of the ACM did not include sampling or surveys of areas not normally accessible (i.e., crawl spaces, areas above ceilings) to the building occupants.

Table 6

- 1 is a s u mmary of the c u rrent b u i l d i ng c o

nditi o ns, i n cl u d i n g ac c

e

s

s

ible ACM, rad o n, LBP, documented spills (as of 27 November 2001), presence of underground/aboveground storage tanks (USTs/ASTs), and comments. The Phase II buildings do not currently have polychlorinated biphenyl (PCB)-containing transformers associated with them.

Damaged accessible ACM was noted at some of the buildings during the final visual surveys. The Army has removed and disposed of loose ACM and encapsulated the edges of damaged ACM with paint.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-2Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PAParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-35 N/A Open area N/A N/A No No No buildings or structuresexist on parcel.2-36 211 Patriot project office(1,232)Refractory cement—furnace room(separate entrance)Good inside, outside painton trim peeling in isolatedspots.300-gal AST-HO No Loose ACM refractorycement removed in furnaceroom; edges encapsulatedwith paint.2-36 N/A Railroad yard N/A N/A No No2-37 49 Lift station – sanitary(142)Not suspected Good condition No No2-38 7 Warehouse (90,000) Transite—roof trusses ("draftboard"), valve housesFloor tile and masticPipe insulation—north endGood; minor chipping ofpaint on brick.No No Radon detected abovecriteria.a2-38 1-7 Restrooms (384) No Paint in fair to poorcondition.300-gal AST-HO No2-39 5 Shipping warehouse(90,000)Floor tile and masticTransite—roof trusses, pump housedoorDuct cloth and duct masticSpackle/joint compoundGenerally good, paintpeeling/chipped in isolatedlocations.No YesbRadon detected abovecriteria.aLoose ACM transiteremoved from roof trusses:edges encapsulated withpaint.2-39 5-2 Outbuilding – 5 (384) Roofing material Paint chipped and peeling. No No2-40 8 Warehouse (90,000) Transite—roof trusses, valve houseFloor tile and masticGasket—boiler roomGenerally good; paintpeeling/chipped in somelocations.20,000-gal USTHOYesbRadon detected abovecriteria.aLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-3ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-40 1-8 Restrooms (384) Refractory cement Paint chipped and peeling. 300-gal AST-HO No2-41 N/A Open area N/A N/A No No No buildings or structuresexist on parcel.2-42 33 Warehouse (90,527) Transite—roof trussesVinyl flooring—officeGood except for paintchipped/peeling in someoutside areas.7,500-gal UST-HO Yesb2-43 32 Warehouse (90,180) Transite—roof trusses Only paint is on portions offloor—good condition.No Yesb2-44 31 Warehouse (90,180) Transite—roof trussesFloor tile and masticOnly paint is on portions offloor—good condition.No No2-45 42 Warehouse/shippingpackaging (90,000)Transite—roof trusses and doorsFloor tile and masticPipe insulation—south end,bathroom, and steamlineSpackle/joint compound—southeastoffice exteriorGenerally good; some wearon floor and brick.7,500-gal UST-HO Yes Damaged ACM on south endpipeline insulation repairedand/or removed.2-45 42-1 Air compressor (384) No Good condition. No No2-46 41 Warehouse (90,527) Transite—valve houses, office,doors, roof trussesFloor tile and masticOnly paint is on floor—some paint is chipped/worn.No YesbStains from drippedoil/engine fluids noted onconcrete floor at time ofvisual survey.Loose ACM transiteremoved from doors, valvehouses, and office; edgesencapsulated with paint.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-4ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-46 41-1 Outbuilding – 41 (180) No Generally good inside (paintchipped in isolated spots),poor condition outside.300-gal AST-HO Yes2-46 51-2 Bus shelter Not suspected Poor condition No No2-47 247 Office (2,946) Suspected transite—walls in boilerroomPipe insulation/fittings—electrical/tool roomFloor tile and masticCeiling tile—men's restroomTar wrap—restroomSpackle/joint compound—throughout buildingPeeling paint in severalareas (storage room, windowsills, etc.).500-gal AST-HO YesbACM pipe insulation jointrepaired in electrical room;loose ACM transite removedin boiler room; edgesencapsulated with paint.2-48 N/A Golf course [facilitynumber 439]N/A N/A No No2-49 502 Base guest house (384) Floor tile and mastic Good condition. No No2-49 503 Base housing (1,456) Tape on heating ducts Good condition; somechipped paint at isolatedlocations on porches and inbasement.2 x 275-gal ASTHONo Radon detected abovecriteria.aACM tape on heating ductsrepaired/replaced.2-49 504 Garage (240) Not suspected Window sills and garagedoor chipped/peeling.No No2-49 508 Lift station (87) Not suspected Poor condition(chipped/peeling) onwooden door.No NoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-5ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-50 18 Alkaline storage (12,000) Transite—pump houseFloor tile and masticGood condition. No No2-51 N/A Golf course N/A N/A No No2-52 N/A Golf course N/A N/A No No2-53 N/A Golf course N/A N/A No No2-54 531 Lift station—sanitarysewer (148)Not suspected Good condition. No No2-55 436 Maintenance (4,436) No Generally good; paintpeeling/chipped in men'sroom/walls, outdoor windowsills, and trim.No No2-56 426 Maintenance (18,928) Floor tile and mastic—majorityremoved or not accessible.Spackle/joint compound—office(likely removed when buildingrefurbished in 1994/1995).Good condition. No YesbRadon detected abovecriteria.a2-57 424 Maintenance—woodwork,upholstery, cable (18,928)Transite—window area in west shopFloor tilePoor condition. No No ACM pipe insulation nearwindow in wood shoprepaired; loose ACM transiteremoved in west shop area;edges encapsulated withpaint.2-57 425 Former barber shop (400) Floor tile and mastic Poor condition in somelocations.No No2-58 475 Storage (1,152) Not suspected N/A No No2-58 476 Storage (1,152) Not suspected N/A No NoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-6ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-58 477 Storage (320) Not suspected N/A No Yesb2-58 478 Storage (1,229) Not suspected Good condition (paint onlyon beams).No No2-58 479 Storage (1,152) Not suspected N/A No No2-58 480 Storage (1,152) Not suspected Good condition (paint onlyon concrete floor andbeams).No No2-59 N/A Open area N/A N/A No No2-60 441 Radioactive materialwarehouse (13,601)Transite—doors, walls Good condition. No YesbLoose ACM transiteremoved from inside andoutside doors/walls; edgesencapsulated with paint.2-61 431 Instrument maintenance—testing (13,601)Transite—outside north wall at airconditioner, back doorFloor tile and masticPipe insulation—restroom, ceilinglength of building.Generally good conditioninside, isolated chippedareas; some outside areaspeeling.No YesbDamaged ACM pipeinsulation in men's restroom(and other damaged areas)re-wrapped.2-61 3335 Bus shelter Not suspected Poor condition (peeling andchipped).No No2-61 431-1 Lift station Not suspected No paint on structure. No No2-62 421 Administration (7,911) Floor tile and masticGood condition. No No Radon detected abovecriteria.a2-63 N/A Open area N/A N/A No No No buildings exist on parcel.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-7ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-64 N/A Open area N/A N/A No No Building 59 previouslylocated on this parcel wasdemolished.2-65 N/A Open area (former sheds) N/A N/A No No No buildings exist on parcel.2-66 N/A Open area (former sheds) N/A N/A No No No buildings exist on parcel.2-67 56 Industrial (92,222) No Good condition; isolatedchipped areas on brick.3 x 2,500-gal ASTHONo2-68 55 Warehouse (90,180) Transite—doors, valve boxes, rooftrussesGenerally good condition;some wear on floor andsome chipped areas onbrick.No No Loose ACM transiteremoved from inside andoutside doors/walls andvalve box; edgesencapsulated with paint.2-68 1-55 Office (384) Floor tile and masticRefractory cementPoor condition (peeling andchipped).275-gal AST-HO No2-69 N/A Open area N/A N/A No No2-70 521 Fire station (11,336) Floor tile and masticSuspected ACM—vent in basementboiler roomOverall good condition;some isolated locations withchipped paint.2,000-gal UST-HO(1996)Yesb2-71 N/A Open area N/A N/A No No2-72 664 Administration office(9,917)Transite—wall boardFloor tile and masticGenerally good conditioninside with somedeteriorated areas; poorcondition outside.300-gal AST inparking lot—gasolineNoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-8ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-72 686 Storage (1,080) Not suspected Generally deterioratedcondition (peeling andchipped).No Yesb2-74B 600 Housing—Kenny Gardens(3,593)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 601 Housing—Kenny Gardens(3,605)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 602 Housing—Kenny Gardens(3,452)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 603 Housing—Kenny Gardens(4,241)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 NoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-9ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-74B 604 Housing—Kenny Gardens(3,790)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.6,000-gal UST-HO No2-74B 605 Housing–Kenny Gardens(3,605)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 606 Housing–Kenny Gardens(3,605)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 607 Housing—Kenny Gardens(3,593)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 No2-74B 608 Housing—Kenny Gardens(3,593)Baseboard trimWallboardVinyl flooringFloor tile/mastic—some unitsGenerally good conditioninside (isolated damaged ordeteriorated areas); somechipped/peeling paintoutside.See Building 604 NoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-10ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-74B 610 Storage—Kenny Gardens(1,777)Not suspected Generally good to faircondition.No No2-74B 612 Storage–Kenny Gardens(1,475)Not suspected Generally fair condition;some chipped paint outside.No No2-74B 616 Former police station(3,360)Transite—Several locationsthroughout buildingFair to poor condition(peeling inside and outside).500-gal UST-HO(not in service)550-gal AST-HONo UST contents removed 3/01.2-74B 618 Environmental offices(6,136)Transite—boiler roomSpackle/joint compound—throughout buildingGood condition. 500-gal AST-HO Yesb2-74B 619 Daycare facility/formerenlisted men's club (5,454)Floor tile and mastic Good condition. 275-gal AST-HO No2-74B 621 Storage shed (140) Not suspected Generally poor condition(peeling).No No2-74B 623 Storage for housing (80) N/A N/A No No2-74B 625 Concession stand—softballfield (144)N/A N/A No No2-74B 627 Post Exchange (PX)(4,135)Suspected floor tile and mastic Generally good condition. 500-gal AST-HO No Radon detected abovecriteria.a2-74B 628 Former security office(5,130)Suspected transite—boiler roomFloor tile and masticSpackle/joint compound—throughout buildingGenerally good condition. 500-gal AST-HO NoLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-11ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2-74B 629 Office (1,040) Floor tile and masticSpackle/joint compoundGenerally good condition. No No2-74B 638 Gate 17 guardhouse (144) Suspected floor tile and mastic Poor condition (peeling). No No2-76 2279 Family housing (2,160) Gasket—basement Good condition inside;generally fair conditionoutside with isolated areaschipped and/or peeling.2 x 275-gal ASTHONo Radon detected abovecriteria.aOld well in yard.2-76 2280 Garage (384) Not suspected Generally fair conditionwith some chipped/peelingpaint.No No2-77 N/A Railroad tracks betweenPhase I Parcels 1 and 2N/A N/A No No No buildings exist on parcel.2R-80 301 Gate 6 – gatehouse (270) –Coffey Ave.Floor tile and mastic Generally fair to poorcondition with somepeeling/chipped paint.No No2R-80 511 Gate 1—gatehouse (462) –Coffey Ave.Floor tile and mastic Generally fair to poorcondition with some areaschipped/peeling inside andoutside.300-gal AST -HO(removed)Size of tankunknown, UST-HONo2R-81 245 Gate 5—sentry station(48)—Michigan(Technology) AvenueNot suspected Generally fair condition. No No2R-82 N/A California (Advantage)AvenueN/A N/A No No Road2R-83 N/A Overcash Avenue N/A N/A No No RoadLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)Table 6-1Summary of Current Building and Parcel Conditions and Results of Final Visual Surveys, Phase II Transfer,Letterkenny Army Depot,Chambersburg, PA(Continued)FINALO:\02281016.008\PHIIFOST_F_ENC6-9.DOC4/30/20026-12ParcelNo.BuildingNo.Description(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills Comments2R-84 N/A Texas (Innovation)AvenueN/A N/A No No Road2R-85 N/A Oregon (Opportunity)AvenueN/A N/A No No Road2R-86 N/A Carbaugh Avenue N/A N/A No No Road2R-87 N/A Pennsylvania Avenue(Letterkenny West)N/A N/A No No Road2R-88 N/A Vehicle Road(Development)N/A N/A No No RoadaRadon was detected above 4 pCi/L, which is an EPA residential action level; there is no industrial/commercial EPA action level.bThese spills incidents are documented in the building discussions. This column includes some spills that are not listed in Table 2 or 3. These spills do not meet the requirement asreportable under CERCLA (see note in Table 2) or are less than 55 gal for petroleum substances (AMC policy). However, these spills have been provided to the grantee for additionalinformation purposes.N/A - Not applicable or none present.TANKSAST - Aboveground storage tank.gal - GallonsHO - Heating oil.UST - Underground storage tank.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 4/30/2002 

## ENCLOSURE 7

ENVIRONMENTAL PROTECTION PROVISIONSLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-1 1. CERCLA COVENANTS AND NOTICE

Pursuant to Section 120(h)(3) of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42 U.S.C. Section 9601 et seq. ("CERCLA"):

A. Notification and Covenants

1. The GRANTOR hereby notifies the GRANTEE of the storage, release, and disposal of hazardous substances on the Property. The release or disposal of these hazardous substances was remedied at the time of the release or, where required, was subsequently addressed under the Installation Restoration Program. For the purpose of this Deed, "hazardous substances" shall have the same meaning attributed to such term under Section 101(14) of CERCLA, 42 U.S.C. §9601(14). Available information regarding the type, quantity, and location of such hazardous substances and action taken to address such hazardous

substances is described in Exhibit D herein [Exhibit D of the Deed is the FOST Table 2- Notification of Hazardous Substances Storage, Release, or Disposal] . More detailed information regarding the storage, release, and disposal of hazardous substances on the Property has been provided to the GRANTEE in the Environmental Baseline Survey for Letterkenny Army Depot dated August 1996, amended May 1999, and as supplemented in November 2000 (collectively the “EBS”) and the Finding of Suitability to Transfer (FOST) for the Property dated November 2001, the receipt of which the GRANTEE hereby acknowledges.

2. The GRANTOR hereby covenants that:

a. All remedial action necessary to protect human health and the environment with respect to any such hazardous substances remaining on the Property has been taken before the date of conveyance hereunder; and

b. Any additional remedial action found to be necessary with regard to such hazardous substances remaining on the Property after the date of this conveyance shall be conducted by the GRANTOR. This covenant in this Subsection 1(A)(2) shall not apply in any case in which the person or entity to whom the Property is transferred is a potentially responsible party under CERCLA with respect to the Property.

2. CERCLA REMEDIATION

The GRANTOR acknowledges that Letterkenny Army Depot (LEAD) has been identified as a National Priorities List (NPL) site under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended. The GRANTEE acknowledges that the GRANTOR has provided it with a copy of the LEAD Federal Facility Agreement (FFA) dated February 3, 1989 and will provide the GRANTEE with a copy of any amendments thereto.

A. The GRANTEE, its successors and assigns, agrees that should any conflict arise between the terms of the FFA as they presently exist or may be amended, and the provisions of this property transfer, the terms of the FFA will take precedence. The GRANTEE, its successors and assigns, further agrees that notwithstanding any other provisions of this Deed, the GRANTOR assumes no liability to the GRANTEE, its successors and assigns, should implementation of the FFA interfere with their use of the Property; and said parties shall have no claim against the United States or any officer, agent, employee, or contractor thereof on account of any such interference, provided the GRANTOR complies with the requirements of Section 2(D).

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

and the FFA for the LEAD site:Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-2 1. The GRANTEE, its successors and assigns, shall not undertake activities on the Property that would interfere with or impede the completion of the CERCLA cleanup at the LEAD NPL site. Activities required to avoid interference with the completion of the CERCLA cleanup at LEAD include, but are not limited to, the GRANTEE, its successors and assigns, taking appropriate action to ensure stormwater is directed into existing or future stormwater sewer systems or drainage ditches; and

2. The GRANTEE, its successors and assigns, shall comply with any institutional controls established or put in place by the GRANTOR relating to the Property that are required by any Record of Decision ("ROD") or amendments thereto issued before or after the date of this Deed. Additionally, the GRANTEE, its successors and assigns, shall ensure that any leasehold it grants in the Property or any fee interest conveyance of any portion of the Property provides for legally binding compliance with the institutional controls required by any such ROD.

C. All subsequent conveyances of the Property or any interests therein by GRANTEE, its successors and assigns, shall be expressly subject to the rights and duties of the United States to continue operation of any monitoring wells, treatment facilities, or other response activities undertaken pursuant to CERCLA or the FFA on said portion of the Property. The GRANTEE, its successors and assigns, shall provide:

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

2. Deed/Lease—Within 14 days after the effective date of the transaction, GRANTEE, its successors and assigns, will provide to the GRANTOR, EPA, and PADEP, copies of the deed, lease, or other conveying instrument evidencing such transaction.

D. The GRANTOR reserves a perpetual easement over and through and a right of access to the Property to perform any additional environmental investigation, monitoring, sampling, testing, remedial action, corrective action, or any other action necessary for the GRANTOR to meet its environmental responsibilities under applicable laws and as provided for in the Deed. This easement and right of access shall be binding on the GRANTEE, its successors and assigns, and shall run with the land. This reservation includes the right to access and use utilities on the Property at reasonable cost to the United States. In exercising this right of access, except in case of imminent endangerment to human health or the environment, the GRANTOR shall give the GRANTEE, or the then record owner, reasonable notice of actions to be taken on the Property and shall use reasonable means, without significant additional cost to the GRANTOR, to avoid and/or minimize interference with the use of the Property.

E. The GRANTOR shall not incur liability for additional response action or corrective action found to be necessary after the date of transfer unless the GRANTEE, its successors or assigns, is able to demonstrate that such release or such newly discovered substance was due to GRANTOR's activities, ownership, use or occupation of the Property, or the activities of GRANTOR's contractors and/or agents.

F. All subsequent leases, transfers, or conveyances shall be made expressly subject to this easement. Upon a determination by the United States that all remedial action is complete at the LEAD NPL site, the

GRANTOR shall execute and record a release of easement.

3. LAND USE RESTRICTIONS

The Department of the Army has undertaken careful environmental study of the Property and concluded that the covenants and restrictions set forth here are required to ensure that the use of the Property is consistent with its environmental condition. In order to protect human health and the environment, promote community objectives, and further the common environmental objectives and land use plans ofLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-3 the GRANTOR, the Commonwealth of Pennsylvania, and the GRANTEE, the covenants and restrictions shall be included to ensure 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, with the

exce p ti o n of P a r ce l s 2

- 74A and 2

- 74B, and the po r t i on of t h e Pr o p e r ty re f e r

r ed to a s the G ate 1

Guardho u se, B u il d ing 511 (“Ga t e 1 Gu a r dho u se a r e a ” ) , sh a l l be u sed s o l ely for c o m m ercial, ind u s t ri a l

, and agricultural purposes and not for residential purposes. The portion of the Property referred to as the

Gate 1 G u ard h ouse ar e a s h all be u s ed s o l e ly for co mm er c ial and ind u s t ri a l p u rp o s es and not for residential purposes. 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, daycare 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 EPA and 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. The GRANTEE shall bear the cost of recording and reasonable administrative fees.

B. Groundwater Restrictions

The GRANTEE covenants for itself, its successors and assigns, not to access the groundwater, except as provided in Subsection 3.C, or use groundwater underlying the property for any purpose without the prior written approval of the GRANTOR, PADEP, and 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, "groundwater" shall have the same meaning as in Section 101(12) of 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 depth of 3 feet (ft) 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 EPA. If the GRANTEE, its successors or assigns, encounters groundwater 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 3.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 and Safety Plan dated October 1998 and any amendments thereto, and other applicable requirements to protectLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-4 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. These 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 the GRANTOR, with a copy to EPA and PADEP, by first class mail, postage prepaid,

addressed as follows:

a. To GRANTOR: Commander Letterkenny Army Depot

1 Overcash Avenue Chambersburg, Pennsylvania 17201-4150

b. To EPA: U.S. Environmental Protection Agency Region III 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. The GRANTEE shall submit all requests for excavation approval as required by Section 3.C to the GRANTOR at the mailing address set forth in Subsection 3.E(1)(a) above.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-5 4. NOTICE OF THE PRESENCE OF LEAD-BASED PAINT AND COVENANT AGAINST THE

USE OF THE PROPERTY FOR RESIDENTIAL PURPOSES

A. The GRANTEE is hereby informed and does acknowledge that all buildings on the Property that were constructed or rehabilitated prior to 1978 are presumed to contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Every purchaser of any interest in Residential Real Property on which a residential dwelling was built prior to 1978 is notified that such property may present exposure to lead from lead-based paint that may place young children at risk of developing lead poisoning. Lead poisoning in young children may produce permanent neurological damage, including learning disabilities, reduced intelligence quotient, behavioral problems, and impaired memory. Lead poisoning also poses a particular risk to pregnant women. The seller of any interest in Residential Real Property is required to provide the buyer with any information on lead-based paint hazards from risk assessments or inspections in the seller's possession and notify the buyer of any known lead-based paint hazards. "Residential Real Property" means any housing constructed prior to 1978, except housing for the elderly (households reserved for and composed of one or more persons 62 years of age or more at the time of initial occupancy) or persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside in such housing) or any 0-bedroom dwelling. For the purpose of this deed, child-occupied facilities are included in the definition of "residential Real Property" and means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, less than 6 years of age, on at least two different days within any week (Sunday through Saturday), provided that each day's visit lasts at least 3 hours, that the combined weekly visits last at least 6 hours, and that the combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited to, day-care centers, pre-schools, and kindergarten classrooms.

B. Available information concerning known lead-based paint and/or lead-based paint hazards, the location of lead-based paint and/or lead-based paint hazards, and the condition of painted surfaces is contained in the EBS documents, the FOST, and (for residential properties) the lead-based paint riskassessment, which have been provided to the GRANTEE. All purchasers must receive the Federallyapproved pamphlet on lead poisoning prevention. The GRANTEE hereby acknowledges receipt of all of the information described in this subparagraph. Additionally, the report entitled Lead-Based Paint Survey, Letterkenny Army Depot prepared by Dames and Moore, Inc. in 1996 pertaining to lead-based paint and/or lead-based paint hazards has been provided to the GRANTEE.

C. The GRANTEE acknowledges that it has received the opportunity to conduct its own risk assessment or inspection for the presence of lead-based paint and/or lead-based paint hazards prior to execution of

this document.

D. The GRANTEE covenants and agrees that it shall not permit the occupancy or use of any buildings or structures on the Property as Residential Real Property without complying with this section and all applicable Federal, state, and local laws and regulations pertaining to lead-based paint and/or lead-based paint hazards. Prior to permitting the occupancy of the Property where its use subsequent to sale is intended for residential habitation, the GRANTEE specifically agrees to perform, at its sole expense, the Army's abatement requirements under Title X of the Housing and Community Development Act of 1992 (Residential Lead-Based Paint Hazard Reduction Act of 1992) (hereinafter Title X).

The GRANTEE shall, after consideration of the guidelines and regulations established pursuant to Title X: (1) perform a risk assessment if more than 12 months have elapsed since the date of the last risk assessment; (2) comply with the joint U.S. Department of Housing and Urban Development (HUD) and EPA Disclosure Rule (24 CFR 35, Subpart H; 40 CFR 745, Subpart F), when applicable, by disclosing to prospective purchasers the known presence of lead-based paint and/or lead-based paint hazards as determined by previous risk assessments; (3) abate lead dust and lead-based paint hazards in pre-1960 Residential Real Property, as defined in paragraph A, above, in accordance with the procedures in 24 CFR 35; (4) abate soil-lead hazards in pre-1978 Residential Real Property, as defined in paragraph A,Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-6 above, in accordance with the procedures in 24 CFR 35; (5) abate lead-soil hazards following demolition and redevelopment of structures in areas that will be developed as Residential Real Property; (6) comply with the EPA lead-based paint work standards when conducting lead-based paint activities (40 CFR 745,Subpart L); (7) perform the activities described in this paragraph within 12 months of the date of the leadbased paint risk assessment and prior to occupancy or use of the Residential Real Property; and (8) send a copy of the clearance documentation to the GRANTOR.

In complying with these requirements, the GRANTEE covenants and agrees to be responsible for any abatement or remediation of lead-based paint or lead-based paint hazards on the Property found to be necessary as a result of the subsequent use of the property for residential purposes. The GRANTEE covenants and agrees to comply with solid or hazardous waste laws that may apply to any waste that may be generated during the course of lead-based paint abatement activities.

E. The covenants, restrictions, and requirements of this Section 4 shall be binding upon the GRANTEE, its successors and assigns, and all future owners, and shall be deemed to run with the land. The GRANTEE on behalf of itself, its successors and assigns, covenants that it will include and make legally binding, this Section 4 in all subsequent transfers, leases, or conveyance documents.

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 EBS documents. To the best of the GRANTOR's knowledge, the ACM in buildings and structures on the Property does not currently pose a threat to human health or the environment, and all friable asbestos that posed a risk to human health has either been removed or encapsulated.

B. The GRANTEE covenants and agrees that its use and occupancy of the Property will be in compliance with all applicable laws relating to asbestos; and that the Army assumes no liability for future remediation of asbestos or damages for personal injury, illness, disability, or death, to the GRANTEE, its successors or assigns, or to any other person, including members of the general public, arising from or incident to the purchase, transportation, removal, handling, use, disposition, or other activity causing or leading to contact of any kind whatsoever with asbestos on the Property, whether the GRANTEE, its successors or assigns, have properly warned or failed to properly warn the individual(s) injured. The GRANTEE agrees to be responsible for any future remediation of asbestos in buildings and structures found to be necessary on the Property.

C. The following buildings were constructed prior to 1981 and have not had an ACM survey completed and may contain ACM:

Buildings 49, 51-2, 245, 431-1, 475, 476, 477, 478, 479, 480, 504, 508, 531, 610, 612, 621, 627, 638, 686, 2280, and 3335.

In accordance with the Occupational Safety and Health Administration (OSHA) guidelines, the following materials, if present in these structures, must be considered as asbestos-containing and handled as such unless tested negative through a certified EPA asbestos building inspector:

!" Thermal system insulation (e.g., pipe insulation, pipe wrap, mudded fittings, or other material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other structural components to prevent heat loss or gain).

!" Spray-on texture surfacing/fireproofing (i.e., material that is sprayed, troweled-on, or otherwise applied to surfaces [such as acoustical plaster on ceilings and fireproofingLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-7 materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes]).

!" Asphalt and vinyl floor tile installed no later than 1980.

The buildings listed here may contain none, some, or all of the above building materials. The GRANTEE acknowledges that these materials shall not be disturbed, and that any maintenance that directly or indirectly disturbs these materials shall need to be performed by appropriately trained personnel, according to the requirements of OSHA.

D. Unprotected or unregulated exposures to asbestos in product manufacturing, shipyard, and building construction workplaces have been associated with asbestos-related diseases. Both OSHA and EPA regulate asbestos because of the potential hazards associated with exposure to airborne asbestos fibers. Both OSHA and EPA have determined that such exposure increases the risk of asbestos-related diseases, which include certain cancers, and which can result in disability or death.

E. The GRANTEE acknowledges that it has inspected the Property as to its asbestos content and condition and any hazardous or environmental conditions relating thereto. The GRANTEE shall be deemed to have relied solely on its own judgment in assessing the overall condition of all or any portion of the Property, including, without limitation, any asbestos hazards or concerns.

F. Notwithstanding the provisions of Section 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 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. NOTIFICATION OF THE PRESENCE OF RADON AND COVENANT

Available and relevant radon assessment data pertaining to the Property is located in the "Environmental Baseline Survey" (EBS)” dated August 1996, in the “Addendum to the EBS” dated May 1999, and in “Supplement 1 to the EBS” dated November 2000. According to said radon assessment data, those structures known as Buildings 5, 7, 8, 33, 421, 426, 503, 627, and 2279 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 5, 7, 8, 33, 421, 426, 503, 627, and 2279 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.

7. STATUTORY INDEMNIFICATION

Subject to the availability of appropriated funds, the GRANTOR recognizes its obligation to hold harmless, defend, and indemnify the GRANTEE and any successor, assignee, transferee, lender, or lessee of the GRANTEE or its successors and assigns as required and limited by Section 330 of the U.S. Department of Defense Authorization Act of 1993, as amended, and to otherwise meet its obligations

under law.

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 inclusionLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 7-8 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.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 

## ENCLOSURE 8

REGULATORY AGENCY CONCURRENCE LETTERSUNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103-2029

Date: March 29,2002

Mr. Bryan Hoke Letterkenny Anny Depot

1 Overcash Avenue
AMSAM-LE-CO-SP; Bldg 10 Chambersburg, PA 17201-4150

Re: Finding of Suitability to Transfer

Phase II Parcels Letterkenny Anny Depot, Chambersburg, P A

Dear Mr. Hoke:

This letter is in response to the Anny's request for EPA comments on the revised Finding

of Suitability to Transfer (FOST) for the Phase II Parcels of property located in Chambersburg, PA,

dated February 2002.

Regarding EPA's comments on the FOST, as has been stated several times in the past,

EPA's preference for transferring the Phase II Parcels is under CERCLA Section 120 (h)(3)(C). Notwithstanding this, previously submitted comments have been adequately addressed and EPA

has no additional comments on the subject FOST at this time. Based on EPA's review and

without any independent verification of the information contained or referenced therein, EPA

fmds that the FOST is sufficient to support the transfer of the subject property under the terms

described therein.

EPA reserves all rights and authorities relating to infonnation 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 concludes EPA's review. Please feel free to contact Stacie Driscoll or me if you have any questions or concerns.

Sincerely,

# /lli.~**~fu.das** Director

Hazardous Site Cleanup Division

cc: Noreen Wagner (PADEP)

### Pennsylvania Department of Environmental Protection

909 Elmerton Avenue Harrisburg, Pennsylvania 17110-8200

March 8, 2002

717-705-4705

FAX 717-705-4830

South central Regional Office

Mr. Bryan Hoke

BRAC Environmental Coordinator
AMSAM-LE-CO-T, Building 10 Letterkenny Army Depot

One Overcash Avenue Chambersburg, PA 17201-4150

Re: Final FaST

Phase II BRAC Parcels

Dear Mr. Hoke:

The purpose of this letter is to provide the Pennsylvania Department of Environmental

Protection's (Department's) acceptance, with comment, of the Phase II Finding of Suitability to

Transfer (FaST) for the Phase II BRAC Parcels at Letterkenny Army Depot, dated February 2002. The

Phase II property consists of approximately 358 acres, including 70 buildings on 298 acres and approximately 60 acres of roads. With the exception of the portions of the property referred to as Parcel
2-74A, 2-74B and the Gate 1 Guardhouse/Building 511, the property will be used for industrial,
commercial, and agricultural purposes and not for residential purposes. The Gate 1 Guardhouse area
will be used solely for commercial and industrial purposes.

Although the Department concurs with the transfer of property for commercial and industrial use

at this time, we do not agree with the remediation standards as stated in Enclosure 7 of the FaST should

the property be used for residential purposes in the future. The Department also does not agree with

your letter dated November 1,2001 statjngthat Pennsylvania's Land Recycling and Environmental

Remediation Standards Act (Act 2) speaks only to industrial and commercial sites at Letterkenny

..

It has consistently been the Department's position that Act 2 is an ARAR for CERCLA sites. Nothing in the Land Recycling and Environmental Remediation Standards Act exempts soils that have

been contaminated as a result of lead-based paint, as opposed to any other source of contamination. In general, lead in the soil presents the same risks regardless of the source of that lead. In addition, there is

no such exemption in any other state environmental statute, such as the Clean Streams Law or the Solid

Waste Management Act. It is the Department's position that soils that exceed a relevant statewide

health standard, whether residential or industrial, promulgated pursuant to Act 2 is a release or potential

release of a hazardous substance that should be addressed. It should be noted, however, that the

An Equal Opportunity Employer www.dep.state.pa.us**i'C;;;~,.** Printed on Recycled Paper**\~(-'-7'** --.----..:

__ __ .. _. . ,-- '.r

.

### "

Mr. Bryan Hoke - 2 - March 8, 2002

Department is not seeking to**~mpose** Act 2 or other state standards to the lead-based paint in the buildings themselves or to dictate how those buildings should be addressed.

If you have any questions or need additional information, you can contact Noreen Wagner at

717-705-4832.

Sincerely,

# ~-r~ mes T. Flesher, Manager·

nvironmental Cleanup Program

cc: Stacie Driscoll, USEPA (3HS13)

Stacie Popp Young, Weston V

John Van Horn, LIDA

'. 1

- '_" " .• :., •

'."; '.'

; "J-I'-.REPl.Y TO
"TTetmoN Of' DEPARTMENT OF THE ARMY

LETTERKENNY ARMY DEPOT

1 OVERCASH AVENUE CHAMBERSBURG, PA 17201

November 1, 2001

Strategic Planning Office

Ms. Noreen K. Wagner, Project Manager

Environmental Cleanup Program Pennsylvania Department of Environmental Protection

909 Elmerton Avenue Harrisburg, Pennsylvania 17110-8200

Dear Ms. Wagner:

This is in response to your letter of October 26, 2001, in which you provided the Pennsylvania Department of Environmental Protection's (PADEP) final comment on the Finding of Suitability to Transfer (FOST) for the Phase II Parcels at Letterkenny Army Depot, dated October 2001. P ADEP is requesting that the requirements of the Land Recycling and Environmental Standards Act (Land Recycling Act) and its implementing regulations be added to the Grantee's abatement responsibility, as noted in Enclosure 7,

Section 4.D of the FOST. In keeping with Department of Defense policy, the Army respectfully declines to do this.

The structures on the Phase II parcels at Letterkenny Army Depot to be used for future

non-residential redevelopment were erected prior to 1978. At that time, the use of leadbased paint was common throughout the United States, including at military installations.

The age of the structures on this site suggests that there is a likelihood that lead-based paint is present on many, ifnot all, of the structures in the Phase II parcels. This, in tum,
makes it likely that there is lead from lead-based paint in the soil in these areas, through

the action of normal weathering and maintenance (e.g., scraping and repainting) over the

years, just as it is likely that there would be lead from lead-based paint in the soil at all

other non-residential sites in the United States with similarly aged structures.

To date, as a matter of law and of national policy, efforts to limit' exposure to lead

from lead-based paint have been focused on residential areas, where, because of exposure patterns and the presence of a peculiarly susceptible population, the risks are likely to be

far more significant. While there have also been significant efforts to limit the dosages of

lead received in the workplace, those efforts to date have not identified the historical use of lead-based paint as requiring special measures. Therefore, the Army has not
conducted soil sampling for lead from lead-based paint in non-residential areas at this

installation. It is the Army's position that assessment and sampling to determine leadbased paint contamination is not required to transfer Army property.-2-

We understand PADEP's position that the Land Recycling Act is an ARAR for

CERCLA sites in accordance with 35 P.S.6026.106. Under regulations implementing

the Act, a clean up standard of 500 ppm is established for lead in residential soils and
1,000 ppm for lead in non-residential soils. 25 Pa. Code Chapter 250, Table 

### 4.
However, the Land Recycling Act does not specifically address lead resulting from flaking or chipping lead-based paint. In the absence of a more specific requirement the Army believes that lead-based paint that chips or flakes off structures due to natural weathering or normal maintenance is not actionable under CERCLA or the Land Recycling Act. The Land Recycling Act also says its standards shall be used when

remediation is required under a variety of Pennsylvania environmental statutes, none of

which mentions contamination from flaking lead-based paint in residential use areas.

The Army has identified the 

### ARAR for its actions in cases such as Letterkenny's, and

it is not the Land Recycling Act. The applicable requirements for addressing lead-based paint are found in the Residential Lead Based Paint Hazard Reduction Act of 1992 (Title X). The standards and other substantive requirements contained there specifically

address lead-based paint contamination in soils and elsewhere. Title X addresses the

residential use scenario at Letterkenny; the Land Recycling Act speaks to cleanup of

industrial and commercial sites.

The Army's policy of addressing chipping or flaking lead-based paint due to natural weathering or normal maintenance of target housing residential dwellings in accordance

with Title 

### X ensures that property is transferred in a manner that is protective of human

health and the environment. The restriction pertaining to lead-based paint contained in

the Environmental Protection Provisions located in Enclosure 7 to the FOST is consistent

with DOD policy and legally sufficient.

A copy of this letter is being furnished to Ms. Stacie Driscoll at the US Environmental

Protection Agency. If there are any questions regarding this matter, please contact me at (717) 267 -9836.

Sincerely,

# I\-~ Bryan Hoke

BRAC Environmental Coordinator

## Pennsylvania Department of**Environmen~** 

## Protec£on

909 Elmerton Avenue Harrisburg, Pennsylvania 17110-8200

October 26, 2001

717-705·4705

FAX 717-705-4830

Southcentral Regional Office



### Mr. Bryan Hoke

BRAC Environmental Coordinator

SIOLE-CO, Building 522 Letterkenny Anny Depot

One Overcash Avenue Chambersburg, PA 17201-4150

Re: Draft-Final Phase II FOST

Dear 

### Mr. Hoke:

The purpose of this letter is to provide the Department's comments on the Finding of Suitability

to Transfer (FOST) for the Phase II Parcels at Letterkenny Anny Depot, dated October 2001. Our

comments on the main text of the document were adequately addressed in this latest version of the

FOST. Our remaining comment pertains to Enclosure 7, Environmental Protection Provisions, of the

document. The Department's position is as follows.

The first paragraph of Section 4.D. states that the Grantee agrees to perform abatement requirements in accordance with Title X of the Housing and Community Development Act of 1992

before buildings and structures can be used as Residential Real Property. Please add the requirements

of the Land Recycling and Environmental Standards Act (Land Recycling Act), Act of July 18, 1995, P.L. No. 1995-2,35 P.S. Sections 6026.101 et. seq., and the regulations that implement

the act, 25 Pa. Code Chapter 250, Administration of the Land Recycling Program (Act 2), which provides standards for site remediation under Pennsylvania law.

The Record of Decision for the Phase II Parcels, issued in July 2001, states that the selected final remedy with regard to soils will be in full compliance with all ARARs. The ARARs list provided in the

ROD specifically mentions the medium-specific concentrations contained in Table 4A of Act 2 for the

contaminants of concern at the Phase II Parcels. Lead is one of those contaminants of concern specifically mentioned in the ROD.

It has consistently been the Department's position that the Land Recycling Act is an ARAR for

CERCLA sites. Nothing in the Land Recycling Act exempts soils that have been contaminated as a
result oflead-based paint, as opposed to any other source of contamination. In general, lead 

### in th,e soil

presents the same risks regardless of the source of that lead. In addition, there is no such exemption in

any other state environmental statute, such as the Clean Streams Law or the Solid Waste Management

An Equal Opportunity Employer www.dep.state.pa.us Printed on Ree.'Cied PaperMr. Bryan Hoke
Page 2

October 26, 2001

Act. 

### It is the Department's position that soils that exceed a relevant statewide health standard promulgated pursuant to the Land Recycling Act is a release or potential release of a hazardous

substance that should be addressed. It should be noted, however, that the Department is not seeking to impose Land Recycling Act or other state standards to the lead-based paint in the buildings themselves

or to dictate how those buildings should be addressed.



### If you have any questions or need additional information, you can contact me at 717-705-4832.

Sincerely,

### '{\~Ln 

### \( 

## l-Uo.-rwv

Noreen K. Wagner Project Manager

Environmental Cleanup Program

NKM:dms

cc: Stacie Driscoll, EPA (3HS13)

John Van Horn, LillALetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 

## ENCLOSURE 9

REFERENCES AND BIBLIOGRAPHYLetterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 9-1 

### REFERENCES AND BIBLIOGRAPHY

Acker, R.C. 1955. Water Supply from Wells for Letterkenny Ordnance. Letter Report to District Engineer, U.S. Army Corps of Engineers, Baltimore District.

Archaeological & Historical Consultants, Inc. December 1996. Phase I Archaeological Survey, Letterkenny Army Depot. Franklin County, Pennsylvania.

Army Materiel Command (AMC). 2000. FOST/FOSL Guidance. Environmental Quality Division. Office of the Command Counsel, AMC BRAC Office. February 1998, updated January 2000.

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

.

Brooks (Brooks Petroleum Contracting Company). February 1991. Findings Report for Site Investigation of Tank Removals at Letterkenny Army Depot, Chambersburg, Pennsylvania, Buildings 425, 435, and 350.

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.

Dragun, J. and A. Chiasson. 1991. Elements in North American Soils. Hazardous Materials Control Resources Institute, Greenbelt, Maryland.

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

EMC (Environmental Management Consultants). July 1988a. Asbestos Survey, Building 663, Letterkenny Army Depot.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 9-2 EMC (Environmental Management Consultants). 1988b. Asbestos Survey—Building 1, Letterkenny Army Depot.

EMS (Environmental Management Systems). 1989. Asbestos Assessment Survey for Letterkenny Army Depot.

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 1987a. Remedial Investigation of the Property Disposal Office Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). December 1987b. Remedial Investigation of the Southeastern Area at LEAD.

ESE (Environmental Science & Engineering, Inc.). 1988a. Feasibility Study of the Property Disposal Office Area at Letterkenny Army Depot

.

ESE (Environmental Science & Engineering, Inc.). 1988b. Feasibility Study of the Southeastern Area of Letterkenny Army Depot, First Operable Unit.

ESE (Environmental Science & Engineering, Inc.). 1989. Feasibility Study of the Southeastern Area of Letterkenny Army Depot, Second Operable Unit.

ESE (Environmental Science & Engineering, Inc.). January 1993a. Remedial Investigation of the Property Disposal Office Area at Letterkenny Army Depot. Final Report.

ESE (Environmental Science & Engineering, Inc.). June 1993b. Risk Assessment of the Property Disposal Office Area at Letterkenny Army Depot, Operable Units 1 and 2. Final Report.

ESE (Environmental Science & Engineering, Inc.). June 1993c. Remedial Investigation of the Southeastern Area at Letterkenny Army Depot. Final Report.

ESE (Environmental Science & Engineering, Inc.). August 1993d. 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.). July 1994. Risk Assessment of the Southeastern Area at Letterkenny Army Depot, Operable Units One and Three. Final Report.

ESE (Environmental Science & Engineering, Inc.). September 1995. PDO New OU #5 Site Investigation, PCBs in Rocky Spring Lake. Draft Report.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 9-3 Fluor Daniel, Inc. 1977. Final Site Inspection Report, Southeastern Area Operable Unit 7 Truck Open Storage Area and Waste Oil Sump, Letterkenny Army Depot, Chambersburg, Pennsylvania.

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

Data Book.

FCRC (Franklin County Reuse Committee, now known as the Letterkenny Industrial Development Authority [LIDA]). May 1997. Letterkenny Army Depot Reuse Strategy Summary Report.

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.

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

Kearney, A.T. and The Earth 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.

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

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

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

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

Radon Recommendations.

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

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 9-4 Shacklette, H.J. and J.G. Boerngen, 1984. “Element Concentrations in Soils and Other

Surficial Materials of the Conterminous United States.” U.S. Geological Survey Professional Paper 1270. U.S. Department of the Interior.

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

.

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

USAMC (U.S. Army Materiel Command). March 1998. Finding of No Significant Impact

, BRAC 1995 Disposal and Reuse of Property at Letterkenny Army Depot, Chambersburg, PA. 11 March 1998.

USATHAMA (U.S. Army Toxic and Hazardous Materials Agency). 1980. Installation Assessment of Letterkenny Army Depot, 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.

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

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

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

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

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

WESTON (Roy F. Weston, Inc.). October 1998c. Finding of Suitability to Transfer (FOST) for Phase I Parcels, Letterkenny Army Depot. Final Report.

WESTON (Roy F. Weston, Inc.). November 1998d. Final Termination Survey Report for Building 8, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). November 1998e. Final Termination Survey Report for Building 7, Letterkenny Army Depot.Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST)

FINAL

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 04/30/02 9-5 WESTON (Roy F. Weston, Inc.). December 1998f. Finding of Suitability to Lease (FOSL) for Buildings 7, 8, and 42, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). May 1999a. Addendum to the Environmental Baseline Survey for Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). May 1999b. Final Termination Survey Report for Building 5, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). June 1999c. Historical Assessment of Radiological Activity at Letterkenny Army Depot

 Revision 1.

WESTON (Roy F. Weston, Inc.). November 1999d. Final Termination Survey Report for Building 33, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). November 1999e. Final Termination Survey Report for Building 441, Letterkenny Army Depot.

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

WESTON (Roy F. Weston, Inc.). October 2000b. Final Decision Document for PCB Transformer Sites in the Southeastern (SE) Area, Operable Unit (OU) 8 (DSERTS Site LEAD-125), Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). May 2000c. Final Termination Survey Report for Building 32, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). February 2001a. Final Proposed Plan for the Phase II Parcels, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). February 2001b. Final Groundwater Vapor Intrusion Risk Assessment Report, Letterkenny Army Depot.

WESTON (Roy F. Weston, Inc.). February 2001c. Final Remedial Investigation and Risk Assessment Report for the Gate 1 Guardhouse, Building 511 Southeastern (SE) Area, Operable Unit (OU) 8 (DSERTS Site LEAD-126), Letterkenny Army Depot.

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

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

Weston Services, Inc. 1989. EPRDA Soil Gas Investigation Report.