®

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

LETTERKENNY

PENNSYLVANIA

CHAMBERSBURG,

ARMY DEPOT

BALTIMORE DISTRICT

Proud Past

 Dynamic Future

 Final
O:\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. 02281.016.008.3100 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

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TABLE OF CONTENTS 

Section Page 

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

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

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

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

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

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

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

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

3.4 POLYCHLORINATED BIPHENYLS (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 HAZARDOUS CONDITIONS.................................................................. 9

5. REMEDIATION ............................................................................................................. 10

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

7. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE

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

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

ENCLOSURE 1—SITE MAPS OF PROPOSED TRANSFER AREAS

(FIGURES 1 AND 2) 

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

PARCELS FOR THE FOST 

ENCLOSURE 3—TABLE 2, NOTIFICATION OF HAZARDOUS SUBSTANCE 

STORAGE, RELEASE, AND/OR DISPOSAL 

ENCLOSURE 4—TABLE 3, NOTIFICATION OF PETROLEUM PRODUCT 

STORAGE, RELEASE, AND/OR DISPOSAL 

ENCLOSURE 5—APPENDIX A—SUMMARY OF PARCEL AND BUILDING

CONDITIONS, FOST FOR THE PHASE II BRAC PARCELS
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TABLE OF CONTENTS 

(Continued) 

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

PROPERTY TRANSFER, RESULTS OF FINAL VISUAL SURVEYS

ENCLOSURE 7—ENVIRONMENTAL PROTECTION PROVISIONS

ENCLOSURE 8—REGULATORY AGENCY CONCURRENCE LETTERS 

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

AA Ammunition Area 

ACM asbestos-containing material 

AMC Army Materiel Command 

AST aboveground storage tank 

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 

ft2

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

LIST OF ACRONYMS 

(Continued) 

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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.
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1. PURPOSE 

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

document environmental conditions at selected parcels and buildings 

(Phase 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 (Enclosure 7), necessary to protect human health and 

the environment after such transfer. 
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2. PROPERTY DESCRIPTION 

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

north of the Borough of Chambersburg, PA. The Depot 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 Figure 1 (land parcels) and 

Figure 2 (road parcels), which are included in Enclosure 1. Information 

about these parcels and buildings is summarized in Enclosure 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). 
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3. ENVIRONMENTAL CONDITION OF THE PROPERTY 

The Army has determined the environmental condition of the proposed 

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

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

LEAD EBS (WESTON, 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 

Enclosure 9, References and Bibliography. The review of documents, the 

EBS visual site inspections (1996, 1999, and 2000) and the final site 

inspections constitute an EBS specific to the transfer parcels. The conditions 

noted during the final site inspections are provided in Enclosure 6. 

In 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. 
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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). 

Enclosure 2, Table 1, provides a description of the property and a summary 

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 

occurred is provided in Enclosure 3, Table 2, Notification of Hazardous 

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. 
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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 

Enclosure 4, Table 3, Notification of Petroleum Products 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). 
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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 survey 
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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 (Enclosure 2), and Table

A-1 (Enclosure 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. 
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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.
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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.
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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 surface 
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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. 
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6. REGULATORY AND PUBLIC COORDINATION 

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

the FOST. Regulatory/public comments received during the FOST 

development were reviewed and incorporated as appropriate. All 

regulatory agency comments were resolved. Copies of the regulatory 

agency concurrence letters are included in Enclosure 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. 
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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). 
environmental protection provisions, which &hall be 

for the property. The environmental protection prov

the CERCLA section l2O(h)(3) covenant and access p

the hauadous substance notification (Table 2) will b

deed as required under CERCLA Section 120(h) and 

guidance.

- Col., as

Deputy Chiefof Stafffor .ODS

Enclosure!

Enclosure 2

End.osure4

EnclosureS

Enclosure 6

Enc:losure 7

EnclosureS

Enclosure 9

ENUOSURES

Sib! Maps of Proposed Transfer Areas 

Table 1,Property Desaiption of Phase 

theFOST 

Table 2, Notification of Hazarci011S Sub

Release, and!or Disposal

Table 3, Notification of Petroleum Prod

and!or DispOsal

Appendix A, Summary ofParcel and B

FC5l"for the Phase II BRAC Parcels

Summaty of Building and Puce! Cond

Property Transfer, Results of Final Visu

Environment:al Protection Provisions

Regulatory Agency Con.cur:rence Letter

References and Bibliography

14
Letterkenny 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 Roadway Parcels

t

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

Jo,I1;I••r. DIslrl 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 NIIJIlS )

Legend:

Building 301

GATE 6

2R-:84 TEXAS/WASmNGTON (INNOVATION)

Letterkenny Township Roads
Letterkenny 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 FOST 
MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-1 

Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2-35 N/A Open Area 1.5 – 12(5) HR 2-36 N/A Railroad Yard 27 – 12(5) HR 

2-36 211 Patriot Project Office (1,232) 27 1943 12(5) HR 2-37 49 Lift Station – Sanitary (142) 5 1972 12(5) HR 2-37 N/A Two temporary sheds in Electrical Distribution Area 5 1988/ 

1990s 

12(5) HR 

2-38 7 Warehouse (90,000) 5.5 1943 12(5) HR 2-38 1-7 Restrooms (384) 5.5 1943 12(5) HR 2-39 5 Shipping Warehouse (90,000) 5.5 1943 12(5) HR 2-39 5-2 Outbuilding – 5 (384) 5.5 1943 12(5) HR 

2-40 8 Warehouse (90,000) 5.7 1943 12(5) HR 2-40 1-8 Restrooms (384) 5.7 1943 12(5) HR 2-41 N/A Open Area 2.6 – 12(5) HR 2-42 33 Warehouse (90,527) 5.4 1943 12(5) HR 2-43 32 Warehouse (90,180) 5.3 1943 12(5) HR 2-44 31 Warehouse (90,180) 5.4 1943 12(5) HR 2-45 42 Warehouse/Shipping Packaging (90,000) 5.3 1943 12(5) HR 2-45 42-1 Air Compressor (384) 5.3 1943 12(5) HR 2-46 41 Warehouse (90,527) 5.3 1943 12(5) HR 2-46 41-1 Outbuilding – 41 (180) 5.3 1943 12(5) HR 
Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-2 

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2-46 51-2 Bus Shelter 5.3 – 12(5) HR 2-47 247 Office (2,946) 3 1943 12(5) HR 2-48 N/A Golf Course 14.9 1963 12(5) HR 2-49 502 Base Guest House (384) 5.9 – 12(5) HR 2-49 503 Base Housing (1,456) 5.9 – 12(5) HR 2-49 504 Garage (240) 5.9 – 12(5) HR 2-49 508 Lift Station (87) 5.9 1960 12(5) HR 2-50 18 Alkaline Storage (12,000) 2.9 1943 12(5) HR 2-51 N/A Golf Course 4.7 1963 12(5) HR 2-52 N/A Golf Course 6 1963 12(5) HR 2-53 N/A Golf Course 10 1963 12(5) HR 2-54 531 Lift Station – Sanitary Sewer (148) 6.6 1945 12(5) HR 2-55 436 Filter Apparatus Testing Building (4,436) 0.7 1943 12(5) HR 2-56 426 Maintenance (18,928) 1.4 1942 12(5) HR 2-57 424 Maintenance – Woodwork, Upholstery, Cable 

(18,928) 

1.4 1942 12(5) HR 

2-57 425 Former Barber Shop (400) 1.4 1942 12(5) HR 2-58 475 Storage (1,152) 4.4 1962 12(5) HR 2-58 476 Storage (1,152) 4.4 1962 12(5) HR 
Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-3 

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2-58 477 Storage (320) 4.4 1962 12(5) HR 2-58 478 Storage (1,229) 4.4 1971 12(5) HR 2-58 479 Storage (1,152) 4.4 1971 12(5) HR 2-58 480 Storage (1,152) 4.4 1971 12(5) HR 2-59 N/A Open Area 3.8 – 12(5) HR 2-60 441 Radioactive Material Warehouse (13,601) 1.4 1942 12(5) HR 2-61 431 Instrument Maintenance – Testing (13,601) 1.5 1943 12(5) HR 2-61 431-1 Lift Station 1.5 1960 12(5) HR 2-61 3335 Bus Shelter 1.5 – 12(5) HR 2-62 421 Administration (7,911) 1.4 1942 12(5) HR 2-63 N/A Open Area 8.1 – 12(5) HR 2-64 N/A Open Area (Former Building 59 Storage) 7.2 1961 12(5) HR 2-65 N/A Open Area (Former Sheds) 1.8 – 12(5) HR 2-66 N/A Open Area (Former Sheds) 1.2 – 12(5) HR 2-67 56 Industrial (92,222) 4.8 1943 12(5) HR 2-68 55 Warehouse (90,180) 5.4 1943 12(5) HR 2-68 1-55 Office (384) 5.4 1943 12(5) HR 2-69 N/A Open Area 10.9 – 12(5) HR 2-70 521 Fire Station (11,336) 2.3 1942 12(5) HR 
Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-4 

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2-71 N/A Open Area 7.8 – 19(5) HR 2-72 664 Administration Office (9,917) 4.2 1943 19(5) HR 2-72 686 Storage (1,080) 4.2 1949 19(5) HR 

2-74A N/A Open Area 40.8 – 19(5) HR 

2-74B 600 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 2-74B 601 Housing - Kenny Gardens (3,605) 30.6 1954 19(5) HR 2-74B 602 Housing - Kenny Gardens (3,452) 30.6 1954 19(5) HR 2-74B 603 Housing - Kenny Gardens (4,241) 30.6 1954 19(5) HR 2-74B 604 Housing – Kenny Gardens (3,790) 30.6 1954 19(5) HR 2-74B 605 Housing – Kenny Gardens (3,605) 30.6 1954 19(5) HR 2-74B 606 Housing – Kenny Gardens (3,605) 30.6 1954 19(5) HR 2-74B 607 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 2-74B 608 Housing - Kenny Gardens (3,593) 30.6 1954 19(5) HR 2-74B 610 Storage - Kenny Gardens (1,777) 30.6 1968 19(5) HR 2-74B 612 Storage - Kenny Gardens (1,475) 30.6 1973 19(5) HR 2-74B 616 Police Station (3,360) 30.6 1944 19(5) HR 2-74B 618 Environmental Offices (6,136) 30.6 1943 19(5) HR 2-74B 619 Former Enlisted Men’s Club (5,454) 30.6 1943 19(5) HR 2-74B 621 Storage Shed (140) 30.6 1966 19(5) HR 
Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-5 

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2-74B 623 Storage Housing (80) 30.6 1988 19(5) HR 2-74B 625 Concession Stand—Softball Field (144) 30.6 1990 19(5) HR 2-74B 627 Post Exchange (PX) (4,135) 30.6 1944 19(5) HR 2-74B 628 Security Office (5,130) 30.6 1943 19(5) HR 2-74B 629 Office (empty) (1,040) 30.6 1944 19(5) HR 2-74B 638 Gate 17 Guardhouse (144) 30.6 1942 19(5) HR 

2-76 2279 Family Housing (2,160) 22 – 19(5) HR 2-76 2280 Garage (384) 22 1980 19(5) HR 2-77 N/A Railroad track area between Phase I Parcels 1 and 2 1.1 – 12(5) HR 

2R-80 511 Gate 1 – Gatehouse (462) – Coffey Avenue 15.3 1942 12(5) HR 2R-80 301 Gate 6 – Gatehouse (270) – Coffey Avenue 15.3 1973 12(5) HR 2R-81 245 Sentry Station – Gate 5 (48) 27 – 12(5) HR 2R-81 N/A Michigan Avenue (Technology) 5.8 – 12(5) HR 2R-82 N/A California Avenue (Advantage) 5.7 – 12(5) HR 2R-83 N/A Overcash Avenue 3.6 – 12(5) HR 2R-84 N/A Texas Avenue (Innovation) 11.4 – 12(5) HR 2R-85 N/A Oregon Avenue (Opportunity) 4.5 – 12(5) HR 2R-86 N/A Carbaugh Avenue 5.9 – 12(5) HR/ 

19(5) HR 
Table 1

Property Description of Phase II BRAC Parcels for the FOST, 

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01|O:\02281016.008\PHIIFOST_T1_F.DOC 

2-6 

Parcel No. 

Building 

No. 

Description 

(Square Footage of Facility) 

Area 

(acres) 

Year Built 

EBS 

Parcel 

I.D. 

N

2R-87 N/A Pennsylvania Avenue (Letterkenny West) 4.2 – 19(5) HR 2R-88 N/A Vehicle Road (Development) 3.8 – 19(5) HR 

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 the

areas). 

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 

originate at any of the Phase II parcels. Also note that release of petroleum products is defined as greater than 55 gal (AMC polic

(1) Groundwater below parcel known to be contaminated or potentially contaminated with VOCs. This building is not a source 

groundwater. 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 

groundwater. 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 DISPOSAL 
Letterkenny 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 required 
Letterkenny 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 

aThe 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. 

bHazardous 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 DISPOSAL 
Letterkenny 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/Disposala

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/Disposala

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. Dieselc

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/Disposala

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. 

aAMC’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 PARCELS
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-1 4/30/2002 

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 Figures A-1 through 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 further 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-2 4/30/2002 

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 (Figures A-1 and A-2) is approximately 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. 
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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 

(ft2), 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. 
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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-ft2 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. 
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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-ft2 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-ft2 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 reportedly 
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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-ft2 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. Hazardous 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. 
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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). 
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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 a 
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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-ft2 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. 
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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 showed 

that 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 (Figure A-3) is approximately 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. 
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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. The 
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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 (Figure A-4) is approximately 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 PARCEL 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 (Figure A-5) is approximately 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. 
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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 (Figure A-6) is approximately 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 was 

not 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 of 
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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 evaluated 

at 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 a 
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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, 
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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 was 

found 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 to 
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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. 
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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 (Figure A-7) is approximately 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 of 
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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-ft2 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). LIDA 
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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 tank 
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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 (Figure A-8) is approximately 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 (Figure A-9) is approximately 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. 
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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, 
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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 (μg/g). 

Building 627 serves as LEAD’s post exchange (PX), where active and 

retired military personnel can purchase food and sundries. The building 
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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 μg/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 628 

indicated 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. 
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A.42 PARCEL 2-76 (Buildings 2279 and 2280—Housing and 

Outbuildings) 

Parcel 2-76 (Figure A-10) is approximately 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 (Figure A-11) is approximately 1.1 acres in size and consists of

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

FINAL

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-26 4/30/2002 

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 A-27 4/30/2002 

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 A-28 4/30/2002 

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. 
MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-29 

Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

5 2-39 

2 

PINS, SPAC, TILE, TRAN, ROOF, MAST, DCTM, DCTC 

TILE, PINS No 1.0-5.6 NE No No 

5-2 2-39 

2 

ROOF No No NE NE No No 

7 2-38 

1 

TRAN, PINS TRAN Yes 

(removed 

4/93) 

4.4-12.4 NE No No 

1-7 2-38 

1 

No No No NE NE No 300-ga
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-30 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

8 2-40 

1 

TRAN, TILE, GASK GASK, TRAN No 2.7-5.3 NE 20,000-gal 

HO 

No 

1-8 2-40 

1 

REFC No No NE NE No 300-ga

18 2-50 

1 

TILE, TRAN, MAST No Yes 

(removed 

11/86 and 

1/88) 

1.6 NE No No 

31 2-44 

1 

TRAN No No 0.73-1.0 NE No No 

32 2-43 

1 

TRAN No No 0.9-2.1 NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-31 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

33 2-42 

2 

TRAN TRAN No 7.2 NE 7,500-gal 

HO 

No 

41 2-46 

2 

TRAN No No 1.4-2.2 NE No No 

41-1 2-46 

2 

No No No NE NE No 300-ga

42 2-45 

1 

TRAN, TILE, SPAC, PINS 

TRAN, PINS Yes 

(removed 

4/95) 

0.4-1.6 NE 7,500-gal 

HO 

No 

42-1 2-45 

1 

No No No NE NE No No 

49 2-37 

1 

NE No No NE NE No No 

51-2 2-46 

2 

NE No No NE NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-32 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

55 2-68 

1 

TRAN, TILE, MAST No No NE NE No No 

1-55 2-68 

1 

TILE, MAST, REFC No No NE NE No 275-ga

56 2-67 

1 

TRAN TRAN No 1.2-2.0 NE No 3 x 2,50

HO 

211 2-36 

1 

REFC, TRAN No Yes (removed 

1/94) 

0.8 NE No 300-ga

245 2R-81 

1 

NE No No NE NE No No 

247 2-47 

1 

CT, TILE, MAST, TAR, PFIT, PINS 

PINS, CT No NE NE No 500-ga

301 2R-80 

1 

TILE, MAST No No 0.9 NE No No 

421 2-62 

1 

PINS, PFIT, TILE, MAST 

PINS No 2.7-4.6 NE No No 

424 2-57 

1 

PINS, PFIT, TRAN, TILE, MAST 

PINS No 0.6-1.5 NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-33 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

425 2-57 

1 

TILE, MAST No No NE NE No No 

426 2-56 

1 

PINS, SPAC, TILE, MAST 

PINS, SPAC, 

TILE, MAST 

No 4.2 NE No No 

431 2-61 

1 

PINS, TRAN, TILE, MAST 

PINS, TRANS No 1.9-2.0 NE No No 

431-1 2-61 

1 

NE No No NE NE No No 

436 2-55 

1 

No No Yes 

(removed 

1/95) 

2.1 NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-34 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

441 2-60 

1 

TILE, TRAN No No 2.8-3.2 NE No No 

475 2-58 

1 

NE No No NE NE No No 

476 2-58 

1 

NE No No NE NE No No 

477 2-58 

1 

NE No No NE NE No No 

478 2-58 

1 

NE No No NE NE No No 

479 2-58 

1 

NE No No NE NE No No 

480 2-58 

1 

NE No No NE NE No No 

502 2-49 

1 

TILE No No NE NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-35 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

503 2-49 

1 

TILE, MAST, REFC, TAPE 

TRAN No 1.9-5.6 Yes – GC No 2 x 275

HO 

504 2-49 

1 

NE No No NE NE No No 

508 2-49 

1 

NE No No NE NE No No 

511 2R-80 

1 

MAST, TILE No No 0.4 NE Size of tank 

unknown – 

HO (not in 

service) 

300-ga

(REM

521 2-70 

1 

CINS, PINS, TILE, TRAN, MAST 

TILE, PINS, 

TRAN 

No 0.5-1.8 NE 2,000-gal 

HO 

T (2000) 

550-gal D 

T (1996)g 

No 

531 2-54 

1 

NE No No NE NE No No 

600 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.1-1.9 Yes – GC See 604 No 

601 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.4-2.0 Yes – GC See 604 No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-36 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

602 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 0.5-1.3 Yes – GC See 604 No 

603 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.1-1.4 Yes – GC See 604 No 

604 2-74B 

1 

VINYL, TILE, MAST, BB, WALL, PINS 

PINS No 1.1-1.7 Yes – GC 6,000-gal 

HO 

T (1996) 

No 

605 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.6-1.8 Yes – GC See 604 No 

606 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.0-1.3 Yes – GC See 604 No 

607 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 0.9-1.3 Yes – GC See 604 No 

608 2-74B 

1 

VINYL, TILE, MAST, BB, WALL 

No No 1.0-1.1 Yes – GC See 604 No 

610 2-74B 

1 

NE No No NE NE No No 

612 2-74B 

1 

NE No No NE NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-37 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

616 2-74B 

1 

TILE, MAST, TRAN No No NE Yes – GC 500-gal HO 

(not in 

service) 

500-ga

618 2-74B 

1 

SPAC, TILE, TRAN No No 0.7-0.8 NE No 500-ga

619 2-74B 

1 

TILE, MAST No No 1.3 Yes – GC No 275-ga

621 2-74B 

1 

NE No No NE NE No No 

623 2-74B 

1 

NE No No NE NE No No 

625 2-74B 

1 

NE No No NE NE No No 

627 2-74B 

1 

NE; TILE - Visual No No 2.3-11.2 Yes – GC No 500-ga

628 2-74B 

1 

PINS, SPAC, TILE, MAST 

PINS, SPAC, 

TILE, MAST 

No 1.2-2.3 NE No 500-ga

629 2-74B 

1 

SPAC, TILE, MAST No No 1.0-1.2 NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-38 

Asbestos (ACM) 

Building 

Parcel 

and 

ECP 

Categorya

ACM 

Identified 

Documented 

Removals 

PCBContaining 

Transformer Radon (pCi/L) 

LBP Survey 

(1993/1994/ 

1996) UST AST 

638 2-74B 

1 

NE No No NE NE No No 

664 2-72 

2 

PINS, TILE, TRAN, MAST 

TILE, PINS No 1.6-3.1 NE No 300-gal 

parkin

686 2-72 

2 

NE No No NE NE No No 

2279 2-76 

1 

TILE, CT (debris), MAST, GASK, PINS 

No No 1.4-7.5 Yes – GC No 2 x 275

HO 

2280 2-76 

1 

NE No No NE NE No No 

3335 2-61 

1 

NE No No NE NE No No 
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-39 

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

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

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 

Phase 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 psubstances 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 

gal for petroleum substances (AMC policy). However, these spills have been provided to the grantee for additional information purposes.

c Buildings 7, 8, 32, and 431 were classified as unaffected (WESTON, 1999c). NRC defines unaffected as any area in which radioactive material

low potential for residual contamination. The Final Termination Reports for Buildings 7 (WESTON, 1998e), 8 (WESTON, 1998d), and 32 (Ware suitable for unrestricted use. Building 431 has ongoing operations and reuse will remain the same; therefore, a Final Termination Survey is n

d Buildings 33 and 441 contained areas that were classified as affected, which NRC defines as any area that has the potential for radioactive cont

significant fraction of release limits. Final Termination Reports for Buildings 33 (WESTON, 1999d) and 441 (WESTON, 1999e) indicate that tunrestricted use. 

e Building 56 was classified as nonimpacted, which NRC defines as any area for which there is no reasonable potential for residual contamination

Final Termination Survey and is suitable for unrestricted use (WESTON, 1999c). 

f Sampling completed in 1999 and a risk assessment (RA) performed in 2000 for Building 511 indicated that no remedial action is necessary to p

environment based on the intended future industrial use of the site. This evaluation is documented in Final Remedial Investigation (RI)/Risk AssGuardhouse, Building 511 (WESTON, 2001c). 

g The 550-gal UST at Building 521 is currently regulated by the Pennsylvania Department of Environmental Protection (PADEP). The reports de

Buildings 521 and 686 and the correspondence from PADEP approving the remedial measures and investigations completed are in the UST file
Table A-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

MK01\O:\02281016.008\PHIIFOST_F_ENC5.DOC A-40 

KEY:

TANKS

CRDEP = 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 integrity

 test (date of test). 

RADON

NE = Not evaluated/not surveyed. 

ASBESTOS

BB = 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 SURVE

GC = PainNE = Not ppm = PartYes = Surv











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

FINAL 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-1 4/30/2002 

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 summary of the current building conditions, including accessible ACM, radon, 

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) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-2 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-35 N/A Open area N/A N/A No No 2-36 211 Patriot project office 

(1,232) 

Refractory cement—furnace room (separate entrance) 

Good inside, outside paint on trim peeling in isolated spots. 

300-gal AST-HO No 

2-36 N/A Railroad yard N/A N/A No No 2-37 49 Lift station – sanitary 

(142) 

Not suspected Good condition No No 

2-38 7 Warehouse (90,000) Transite—roof trusses ("draft 

board"), valve houses Floor tile and mastic Pipe insulation—north end 

Good; minor chipping of paint on brick. 

No No 

2-38 1-7 Restrooms (384) No Paint in fair to poor 

condition. 

300-gal AST-HO No 

2-39 5 Shipping warehouse 

(90,000) 

Floor tile and mastic Transite—roof trusses, pump house door Duct cloth and duct mastic Spackle/joint compound 

Generally good, paint peeling/chipped in isolated locations. 

No Yesb 

2-39 5-2 Outbuilding – 5 (384) Roofing material Paint chipped and peeling. No No 2-40 8 Warehouse (90,000) Transite—roof trusses, valve house 

Floor tile and mastic Gasket—boiler room 

Generally good; paint peeling/chipped in some locations. 

20,000-gal USTHO Yesb 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-3 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-40 1-8 Restrooms (384) Refractory cement Paint chipped and peeling. 300-gal AST-HO No 2-41 N/A Open area N/A N/A No No 2-42 33 Warehouse (90,527) Transite—roof trusses 

Vinyl flooring—office 

Good except for paint chipped/peeling in some outside areas. 

7,500-gal UST-HO Yesb

2-43 32 Warehouse (90,180) Transite—roof trusses Only paint is on portions of 

floor—good condition. 

No Yesb

2-44 31 Warehouse (90,180) Transite—roof trusses 

Floor tile and mastic 

Only paint is on portions of floor—good condition. 

No No 

2-45 42 Warehouse/shipping 

packaging (90,000) 

Transite—roof trusses and doors Floor tile and mastic Pipe insulation—south end, bathroom, and steamline Spackle/joint compound—southeast office exterior 

Generally good; some wear on floor and brick. 

7,500-gal UST-HO Yes 

2-45 42-1 Air compressor (384) No Good condition. No No 2-46 41 Warehouse (90,527) Transite—valve houses, office, 

doors, roof trusses Floor tile and mastic 

Only paint is on floor—some paint is chipped/worn. 

No Yesb 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-4 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-46 41-1 Outbuilding – 41 (180) No Generally good inside (paint 

chipped in isolated spots), poor condition outside. 

300-gal AST-HO Yes 

2-46 51-2 Bus shelter Not suspected Poor condition No No 2-47 247 Office (2,946) Suspected transite—walls in boiler 

room Pipe insulation/fittings—electrical/tool room Floor tile and mastic Ceiling tile—men's restroom Tar wrap—restroom Spackle/joint compound—throughout building 

Peeling paint in several areas (storage room, window sills, etc.). 

500-gal AST-HO Yesb 

2-48 N/A Golf course [facility 

number 439] 

N/A N/A No No 

2-49 502 Base guest house (384) Floor tile and mastic Good condition. No No 2-49 503 Base housing (1,456) Tape on heating ducts Good condition; some 

chipped paint at isolated locations on porches and in basement. 

2 x 275-gal ASTHO No 

2-49 504 Garage (240) Not suspected Window sills and garage 

door chipped/peeling. 

No No 

2-49 508 Lift station (87) Not suspected Poor condition 

(chipped/peeling) on wooden door. 

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

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-5 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-50 18 Alkaline storage (12,000) Transite—pump house 

Floor tile and mastic 

Good condition. No No 

2-51 N/A Golf course N/A N/A No No 2-52 N/A Golf course N/A N/A No No 2-53 N/A Golf course N/A N/A No No 2-54 531 Lift station—sanitary 

sewer (148) 

Not suspected Good condition. No No 

2-55 436 Maintenance (4,436) No Generally good; paint 

peeling/chipped in men's room/walls, outdoor window sills, and trim. 

No No 

2-56 426 Maintenance (18,928) Floor tile and mastic—majority 

removed or not accessible. Spackle/joint compound—office (likely removed when building refurbished in 1994/1995). 

Good condition. No Yesb 

2-57 424 Maintenance—woodwork, 

upholstery, cable (18,928) 

Transite—window area in west shop Floor tile 

Poor condition. No No 

2-57 425 Former barber shop (400) Floor tile and mastic Poor condition in some 

locations. 

No No 

2-58 475 Storage (1,152) Not suspected N/A No No 2-58 476 Storage (1,152) Not suspected N/A No No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-6 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-58 477 Storage (320) Not suspected N/A No Yesb2-58 478 Storage (1,229) Not suspected Good condition (paint only 

on beams). 

No No 

2-58 479 Storage (1,152) Not suspected N/A No No 2-58 480 Storage (1,152) Not suspected Good condition (paint only 

on concrete floor and beams). 

No No 

2-59 N/A Open area N/A N/A No No 2-60 441 Radioactive material 

warehouse (13,601) 

Transite—doors, walls Good condition. No Yesb 

2-61 431 Instrument maintenance—

testing (13,601) 

Transite—outside north wall at air conditioner, back door Floor tile and mastic Pipe insulation—restroom, ceiling length of building. 

Generally good condition inside, isolated chipped areas; some outside areas peeling. 

No Yesb 

2-61 3335 Bus shelter Not suspected Poor condition (peeling and 

chipped). 

No No 

2-61 431-1 Lift station Not suspected No paint on structure. No No 2-62 421 Administration (7,911) Floor tile and mastic Good condition. No No 2-63 N/A Open area N/A N/A No No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-7 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-64 N/A Open area N/A N/A No No 2-65 N/A Open area (former sheds) N/A N/A No No 2-66 N/A Open area (former sheds) N/A N/A No No 2-67 56 Industrial (92,222) No Good condition; isolated 

chipped areas on brick. 

3 x 2,500-gal ASTHO No 

2-68 55 Warehouse (90,180) Transite—doors, valve boxes, roof 

trusses 

Generally good condition; some wear on floor and some chipped areas on brick. 

No No 

2-68 1-55 Office (384) Floor tile and mastic 

Refractory cement 

Poor condition (peeling and chipped). 

275-gal AST-HO No 

2-69 N/A Open area N/A N/A No No 2-70 521 Fire station (11,336) Floor tile and mastic 

Suspected ACM—vent in basement boiler room 

Overall good condition; some isolated locations with chipped paint. 

2,000-gal UST-HO (1996) 

Yesb

2-71 N/A Open area N/A N/A No No 2-72 664 Administration office 

(9,917) 

Transite—wall board Floor tile and mastic 

Generally good condition inside with some deteriorated areas; poor condition outside. 

300-gal AST in parking lot—gasoline 

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

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-8 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-72 686 Storage (1,080) Not suspected Generally deteriorated 

condition (peeling and chipped). 

No Yesb

2-74B 600 Housing—Kenny Gardens 

(3,593) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 601 Housing—Kenny Gardens 

(3,605) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 602 Housing—Kenny Gardens 

(3,452) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 603 Housing—Kenny Gardens 

(4,241) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-9 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-74B 604 Housing—Kenny Gardens 

(3,790) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

6,000-gal UST-HO No 

2-74B 605 Housing–Kenny Gardens 

(3,605) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 606 Housing–Kenny Gardens 

(3,605) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 607 Housing—Kenny Gardens 

(3,593) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 

2-74B 608 Housing—Kenny Gardens 

(3,593) 

Baseboard trim Wallboard Vinyl flooring Floor tile/mastic—some units 

Generally good condition inside (isolated damaged or deteriorated areas); some chipped/peeling paint outside. 

See Building 604 No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-10 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-74B 610 Storage—Kenny Gardens 

(1,777) 

Not suspected Generally good to fair 

condition. 

No No 

2-74B 612 Storage–Kenny Gardens 

(1,475) 

Not suspected Generally fair condition; 

some chipped paint outside. 

No No 

2-74B 616 Former police station 

(3,360) 

Transite—Several locations throughout building 

Fair to poor condition (peeling inside and outside). 

500-gal UST-HO (not in service) 550-gal AST-HO 

No 

2-74B 618 Environmental offices 

(6,136) 

Transite—boiler room Spackle/joint compound—throughout building 

Good condition. 500-gal AST-HO Yesb

2-74B 619 Daycare facility/former 

enlisted men's club (5,454) 

Floor tile and mastic Good condition. 275-gal AST-HO No 

2-74B 621 Storage shed (140) Not suspected Generally poor condition 

(peeling). 

No No 

2-74B 623 Storage for housing (80) N/A N/A No No 2-74B 625 Concession stand—softball 

field (144) 

N/A N/A No No 

2-74B 627 Post Exchange (PX) 

(4,135) 

Suspected floor tile and mastic Generally good condition. 500-gal AST-HO No 

2-74B 628 Former security office 

(5,130) 

Suspected transite—boiler room Floor tile and mastic Spackle/joint compound—throughout building 

Generally good condition. 500-gal AST-HO No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-11 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2-74B 629 Office (1,040) Floor tile and mastic 

Spackle/joint compound 

Generally good condition. No No 

2-74B 638 Gate 17 guardhouse (144) Suspected floor tile and mastic Poor condition (peeling). No No 

2-76 2279 Family housing (2,160) Gasket—basement Good condition inside; 

generally fair condition outside with isolated areas chipped and/or peeling. 

2 x 275-gal ASTHO No 

2-76 2280 Garage (384) Not suspected Generally fair condition 

with some chipped/peeling paint. 

No No 

2-77 N/A Railroad tracks between 

Phase I Parcels 1 and 2 

N/A N/A No No 

2R-80 301 Gate 6 – gatehouse (270) – 

Coffey Ave. 

Floor tile and mastic Generally fair to poor 

condition with some peeling/chipped paint. 

No No 

2R-80 511 Gate 1—gatehouse (462) – 

Coffey Ave. 

Floor tile and mastic Generally fair to poor 

condition with some areas chipped/peeling inside and outside. 

300-gal AST -HO (removed) Size of tank unknown, UST-HO 

No 

2R-81 245 Gate 5—sentry station 

(48)—Michigan (Technology) Avenue 

Not suspected Generally fair condition. No No 

2R-82 N/A California (Advantage) 

Avenue 

N/A N/A No No 

2R-83 N/A Overcash Avenue N/A N/A No No 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

Table 6-1 

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

Letterkenny Army Depot, 

Chambersburg, PA 

(Continued) 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 6-12 

Parcel 

No. 

Building 

No. 

Description 

(Square Footage) Accessible ACM Condition of LBP Storage Tanks Spills 

2R-84 N/A Texas (Innovation) 

Avenue 

N/A N/A No No 

2R-85 N/A Oregon (Opportunity) 

Avenue 

N/A N/A No No 

2R-86 N/A Carbaugh Avenue N/A N/A No No 2R-87 N/A Pennsylvania Avenue 

(Letterkenny West) 

N/A N/A No No 

2R-88 N/A Vehicle Road 

(Development) 

N/A N/A No No 

a Radon 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 

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

N/A - Not applicable or none present. TANKS

AST - Aboveground storage tank. gal - Gallons HO - 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 PROVISIONS
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

FINAL 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 7-1 04/30/02 

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 7-2 04/30/02 

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

FINAL 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 7-3 04/30/02 

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 

exception of Parcels 2-74A and 2-74B, and the portion of the Property referred to as the Gate 1 

Guardhouse, Building 511 (“Gate 1 Guardhouse area”), shall be used solely for commercial, industrial, 

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

Gate 1 Guardhouse area shall be used solely for commercial and industrial purposes 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 protect 
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

FINAL 

O:\02281016.008\PHIIFOST_F_ENC6-9.DOC 7-4 04/30/02 

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 

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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 risk 

assessment, which have been provided to the GRANTEE. All purchasers must receive the Federallyapproved pamphlet on lead poisoning prevention. The GRANTEE hereby acknowledges receipt of all of 

the information described in this subparagraph. Additionally, the report entitled Lead-Based Paint Survey, 

Letterkenny Army Depot prepared by Dames and Moore, Inc. in 1996 pertaining to lead-based paint 

and/or lead-based paint hazards has been provided to the GRANTEE. 

C. The GRANTEE acknowledges that it has received the opportunity to conduct its own risk assessment 

or inspection for the presence of lead-based paint and/or lead-based paint hazards prior to execution of 

this document. 

D. The GRANTEE covenants and agrees that it shall not permit the occupancy or use of any buildings or 

structures on the Property as Residential Real Property without complying with this section and all 

applicable Federal, state, and local laws and regulations pertaining to lead-based paint and/or lead-based 

paint hazards. Prior to permitting the occupancy of the Property where its use subsequent to sale is 

intended for residential habitation, the GRANTEE specifically agrees to perform, at its sole expense, the 

Army's abatement requirements under Title X of the Housing and Community Development Act of 1992 

(Residential Lead-Based Paint Hazard Reduction Act of 1992) (hereinafter Title X). 

The GRANTEE shall, after consideration of the guidelines and regulations established pursuant to Title 

X: (1) perform a risk assessment if more than 12 months have elapsed since the date of the last risk 

assessment; (2) comply with the joint U.S. Department of Housing and Urban Development (HUD) and 

EPA Disclosure Rule (24 CFR 35, Subpart H; 40 CFR 745, Subpart F), when applicable, by disclosing to 

prospective purchasers the known presence of lead-based paint and/or lead-based paint hazards as 

determined by previous risk assessments; (3) abate lead dust and lead-based paint hazards in pre-1960 

Residential Real Property, as defined in paragraph A, above, in accordance with the procedures in 24 

CFR 35; (4) abate soil-lead hazards in pre-1978 Residential Real Property, as defined in paragraph A, 
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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 fireproofing 
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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 inclusion 
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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 

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ENCLOSURE 8 

REGULATORY AGENCY CONCURRENCE LETTERS
Letterkenny Anny Depot, Chambersburg, PA

Dear Mr. Hoke:

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

of Suitability to Transfer (FOST) for the Phase II Parcels ofproperty located in Cham

dated February 2002.

Regarding EPA's comments on the FOST, as has been stated several time

EPA's preference for transferring the Phase II Parcels is under CERCLA Section 

Notwithstanding this, previously submitted comments have been adequately addr

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

without any independent verification ofthe information contained or referenced t

fmds that the FOST is sufficient to support the transfer ofthe subject property un

described therein.

EPA reserves all rights and authorities relating to infonnation not contain

in this document whether or not such information was known when this documen

discovered after such issuance.

This concludes EPA's review. Please feel free to contact Stacie Driscoll 

have any questions or concerns.

Sincerely,

/lli

~fu.das

Director

Hazardous Site Clean

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

Southcentral 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 ofthis letter is to provide the Pennsylvania Department ofEnvironmental

Protection's (Department's) acceptance, with comment, ofthe 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 ofroads. With the exception ofthe portions ofthe 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 ofthe 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 oflead-based paint, as opposed to any other source of contamination. In

general, lead in the soil presents the same risks regardless ofthe source ofthat 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,

mes

~-r~ 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 ofOctober 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. PADEP is requesting that the requirements ofthe 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 ofthe 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 ofthe structures on this site suggests that there is a likelihood that lead-based

paint is present on many, ifnot all, ofthe 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 oflaw 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 offstructures 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 ofthis letter is being furnished to Ms. Stacie Driscoll at the US Environmental

Protection Agency. Ifthere 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 ofthis letter is to provide the Department's comments on the Finding ofSuitability

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

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

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

document. The Department's position is as follows.

The first paragraph ofSection 4.D. states that the Grantee agrees to perform abatement

requirements in accordance with Title X ofthe Housing and Community Development Act of 1992

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

ofthe 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 ofDecision 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 ofAct 2 for the

contaminants of concern at the Phase II Parcels. Lead is one ofthose contaminants ofconcern

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 ofthe source ofthat 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 Paper
Mr. 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.

Ifyou 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, LillA
Letterkenny Army Depot Phase II Finding of Suitability to Transfer (FOST) 

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ENCLOSURE 9 

REFERENCES AND BIBLIOGRAPHY
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REFERENCES AND BIBLIOGRAPHY 

Acker, R.C. 1955. Water Supply from Wells for Letterkenny Ordnance. Letter Report to 

District Engineer, U.S. Army Corps of Engineers, Baltimore District. 

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

Survey, Letterkenny Army Depot. Franklin County, Pennsylvania. 

Army Materiel Command (AMC). 2000. FOST/FOSL Guidance. Environmental Quality 

Division. Office of the Command Counsel, AMC BRAC Office. February 1998, updated 

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) 

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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) 

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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 

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