DRAFT FINDING OF SUITABILITY TO TRANSFER (FOST) Fort Monmouth, New Jersey. Squier Hall. September 2017

Transcription

1 DRAFT FINDING OF SITABILITY TO TRANSFER (FOST) Fort Monmouth, New Jersey Squier Hall September 2017

2 TABLE OF CONTENTS 1. PRPOSE PROPERTY DESCRIPTION ENVIRONMENTAL DOCMENTATION ENVIRONMENTAL CONDITION OF PROPERTY Environmental Remediation Sites Installation Restoration Program Storage, Release, or Disposal of Hazardous Substances Petroleum and Petroleum Products nderground and Aboveground Storage Tanks Polychlorinated Biphenyls Asbestos Lead-Based Paint Radiological Materials Radon Munitions and Explosives of Concern Other Property Conditions ADJACENT PROPERTY CONDITIONS Environmental Conditions on Surrounding Properties ENVIRONMENTAL REMEDIATION AGREEMENTS REGLATORY/PBLIC COORDINATION NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE FINDING OF SITABILITY TO TRANSFER... 9 i

3 LIST OF ACRONYMS AND ABBREVIATIONS mg/kg µg/m 3 µg/l AAFES ACM AOC AST ASTM BEE bgs B/N BRAC C4ISR CECOM CERCLA CFR COC COPEC CY DCSCC DICAR DMM DOD DPW ECP EDR EPP ESC EL FIFRA FMERA FOST FTMM GWQC GWQS HR HS IA IRP ISCP LBP MEC NEPA milligram per kilogram microgram per cubic meter microgram per liter Army/Air Force Exchange Service Asbestos-Containing Material Area of Concern Aboveground Storage Tank American Society of Testing and Materials Baseline Ecological Evaluation below ground surface Base/Neutral Base Realignment and Closure Command and Control, Communications, Computers, Intelligence, Sensors and Reconnaissance Communications-Electronics Command Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Constituent of Concern Contaminant of Potential Ecological Concern cubic yard Direct Contact Soil Cleanup Criteria Discharge Investigation and Corrective Action Report Discarded Military Munitions Department of Defense Directorate of Public Works Environmental Condition of Property Environmental Data Report Environmental Protection Provision Ecological Screening Criteria Enhanced se Lease Federal Insecticide, Fungicide, and Rodenticide Act Fort Monmouth Economic Revitalization Authority Finding of Suitability to Transfer Fort Monmouth Groundwater Quality Criteria Groundwater Quality Standards Hazardous Release Hazardous Storage Installation Assessment Installation Restoration Program Installation Spill Contingency Plan Lead-Based Paint Munitions and Explosives of Concern National Environmental Policy Act ii

4 NFA NFA-A NJDEP NRDCSCC OSHA P PA PACM PCB PCE ppm PR PS RA RAR RCI RDCSCC RDX RI RIR SI SPCCP STP SVOC TAL TCE TCL TNT TPH TPHC TRPH TSCA HOT SATHAMA.S.C. ST XO VOC No Further Action No Further Action-nrestricted se New Jersey Department of Environmental Protection Non-Residential Direct Contact Soil Cleanup Criteria Occupational Safety and Health Administration Potential Preliminary Assessment Potential Asbestos-Containing Material Polychlorinated Biphenyl Tetrachloroethene part per million Petroleum Release Petroleum Storage Remedial Action Remedial Action Report Residential Communities Initiative Residential Direct Contact Soil Cleanup Criteria Hexahydro-1,3,5-trinitro-1,3,5-triazine Remedial Investigation Remedial Investigation Report Site Investigation Spill Prevention, Control and Countermeasures Plan Sanitary Treatment Plant Semi-Volatile Organic Compound Target Analyte List Trichloroethene Target Compound List 2,4,6-Trinitrotoluene Total Petroleum Hydrocarbon Total Petroleum Hydrocarbon Content Total Recoverable Petroleum Hydrocarbon Toxic Substance Control Act nregulated Heating Oil Tank nited States Army Toxic and Hazardous Materials Agency nited States Code nderground Storage Tank nexploded Ordnance Volatile Organic Compound iii

5 FINAL FINDING OF SITABILITY TO TRANSFER (FOST) Fort Monmouth, New Jersey Squier Hall (Buildings 283 and 288) September PRPOSE The purpose of this Finding of Suitability to Transfer (FOST) is to document the environmental suitability of the property at Squier Hall, Fort Monmouth, New Jersey for transfer to the Fort Monmouth Economic Revitalization Authority (FMERA) consistent with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120(h) and Department of Defense (DOD) policy. In addition, the FOST includes the CERCLA Notice, Covenant, and Access Provisions and other Deed Provisions and the Environmental Protection Provisions (EPPs) necessary to protect human health or the environment after such transfer. 2. PROPERTY DESCRIPTION The property to be transferred to FMERA under the Economic Development Conveyance authority consists of approximately 4.5 acres of land and improvements. The property includes Buildings 283 and 288 and open areas situated on the Main Post of Fort Monmouth, hereinafter referred to as the Property. The Property is located in the Borough of Oceanport, Monmouth County, New Jersey. The Facility Location Map is provided on Figure 1 (Enclosure 1). A map of the Main Post Portion of Fort Monmouth (with Environmental Condition of Property (ECP) categories is provided on Figure 2 (Enclosure 1). A detail of the property to be transferred is provided on Figure 3 and the Adjacent Land se Map is provided on Figure 4 (Enclosure 1). Fort Monmouth is located in the central-eastern portion of New Jersey, approximately 45 miles south of New York City, 70 miles northeast of Philadelphia and 40 miles east of Trenton. The Atlantic Ocean is located approximately 2.5 miles to the east of Fort Monmouth. Fort Monmouth consists of the Main Post, Charles Wood Area and Evans Area. The Main Post encompasses an area of approximately 637 acres and is bounded by State Highway 35 to the west, Parkers Creek and Lafetra Creek to the north, New Jersey Transit Railroad to the east and residential neighborhoods to the south. The Charles Wood Area is comprised of approximately 489 acres and is located one mile west of the Main Post. The Evans Area consisted of approximately 219 acres and was transferred under the Base Realignment and Closure (BRAC) 1993 Program. The Main Post and Charles Wood Area are included in BRAC The majority of the Charles Wood Area and Main Post were previously transferred to FMERA as the Phase 1 and Phase 2 Parcels. The primary mission of Fort Monmouth was to provide command, administrative and logistical support for the Headquarters, nited States Army Communications-Electronics Command (CECOM). CECOM is a major subordinate command of the nited States Army 1

6 Materiel Command and was the host activity. Fort Monmouth served as the center for the development of the Army s Command and Control, Communications, Computers, Intelligence, Sensors and Reconnaissance (C4ISR) systems. In 2005, the nited States Congress approved the BRAC Commission s recommendation to close Fort Monmouth by September The installation closed on September 15, ENVIRONMENTAL DOCMENTATION the: A determination of the environmental condition of the Property was made based upon.s. Army BRAC 2005 Environmental Condition of Property Report Fort Monmouth, Monmouth County, New Jersey, Final, 29 January 2007 Final Historical Site Assessment and Addendum to Environmental Condition of Property Report, Fort Monmouth, Eatontown, New Jersey, January 2007.S. Army BRAC 2005 Site Investigation Report Fort Monmouth, Final, 21 July 2008 Fort Monmouth Reuse and Redevelopment Plan, Final Plan, 22 August 2008 Final Environmental Assessment of the Implementation of Base Realignment and Closure at Fort Monmouth, New Jersey, March 2009 Final Finding of No Significant Impact Environmental Assessment of the Disposal and Reuse of Fort Monmouth, New Jersey, February 2010.S. Army Environmental Condition of Property pdate Report for Phase 2 Property, Fort Monmouth, Monmouth County, New Jersey, March S. Army 2005 BRAC Environmental Condition of Property pdate Report, Fort Monmouth, Monmouth County New Jersey, Final, 18 August S. Army Additional Information on ST 283A and Work Plan Addendum, Fort Monmouth New Jersey, 6 June S. Army Action Memorandum For Building 283 Squier Hall, Fort Monmouth, Oceanport, Monmouth County, New Jersey, August Summary Remedial Investigation Report and NFA Request for FTMM-61, Building 283 Former Gasoline ST Fort Monmouth, New Jersey, 4 April NJDEP No Further Action (NFA) letter for FTMM-61, 4 May NJDEP No Further Action (NFA) letter for FTMM-54, FTMM-55 and FTMM-61 (Area of Concern: Parcel 50), Fort Monmouth, New Jersey, 22 May Additional Information on ST 283A and Work Plan Addendum, Fort Monmouth New Jersey, 6 June Request for No Further Action Determination at Building 283 Squier Hall, Fort Monmouth, New Jersey, 12 June NJDEP No Further Action (NFA) letter for Areas of Concern: Building 283 Squier Hall, 15 June Tetra Tech, Final Asbestos Assessment, Asbestos Abatement, and Lead-Based Paint Assessment at Fort Monmouth, New Jersey (December 2016) 2

7 The information provided is a result of a complete search of agency files during the development of these environmental surveys. A complete list of documents providing information on environmental conditions of the property is attached (Enclosure 2). 4. ENVIRONMENTAL CONDITION OF PROPERTY The DOD Environmental Condition of Property (ECP) categories for the Squier Hall Property is as follows: ECP Category 4: Parcel 49: Portions of Parcel 49 surrounding Buildings 283 and 288 Parcel 50: Portions of Parcel 50 surrounding Buildings 283 and 288. A summary of the ECP categories for parcels and the ECP category definitions are provided in Table 1 Description of Property (Enclosure 3) Environmental Remediation Sites Installation Restoration Program The Army s program for performing remedial actions (RAs) is known as the Installation Restoration Program (IRP). There is one IRP site (FTMM-61) associated with the Property: FTMM-61 is located on the northern side of the central portion of the Main Post (MP) at FTMM at the intersection of Sherrill Avenue and Brewer Avenue, and approximately 200 feet south of Parkers Creek, as shown on Figure 3. It is associated with Building 283 which is adjacent to existing Buildings 145, 288, 291, and 295. Building 283 functioned as the Squier Laboratory from1934 to 1954 and then as administrative offices until FTMM closure in FTMM-61 was identified as an IRP site due to the presence of contaminated soil and groundwater resulting from gasoline leakage from former underground storage tank (ST) 283C. Three historical STs have been removed as part of the FTMM-61 IRP site actions, designated as ST 283A (NJDEP registration ID ), ST 283B (NJDEP registration ID ), and ST 283C (NJDEP registration ID ). ST 283B was a 10,000-gallon ST used for #2 fuel oil storage and received New Jersey Department of Environmental Protection (NJDEP) approval for No Further Action (NFA) on 24 February ST 283C was a 3,000- gallon ST used for gasoline storage and received NJDEP approval for NFA on 10 January ST 283A was a 1,000-gallon ST used for #2 fuel oil storage and received NJDEP NFA approval on 4 May Groundwater monitoring was conducted from 1999 through late 2011 when FTMM was closed. Groundwater sampling resumed in August 2013 to re-establish baseline groundwater conditions for the constituents of potential concern (COPCs). A final groundwater sampling event was performed in The following presents a summary of groundwater remediation and performance monitoring. 3

8 An ORC Advanced injection program was recommended in the 2005 RIR/RAWP (Versar, 2005) to reduce the concentrations of benzene, ethylbenzene and total xylenes in groundwater. In May through July of 2009, ORC was injected into the subsurface, and the program successfully reduced concentrations of benzene by an order of magnitude. Injections were performed on 8 through 10 December 2010, 27 April through 2 May 2011, and 28 June through 1 July Subsequent groundwater monitoring was performed in August 2013 (VOCs and lead) and October 2014 (VOCs only). Benzene and lead concentrations decreased to non-detectable levels and the Army recommended the discontinuation of groundwater sampling. The NJDEP approved this recommendation in a letter dated 26 January NJDEP approved NFA for both soil and groundwater at FTMM-61 (letter dated 04 May 2017) Removal Action As part of the on-going efforts to address open issues with various parcels of property at Fort Monmouth, an investigation was performed at Parcels 49 and 50 and a Time Critical Removal Action (TCRA) was performed for the soils outside of and adjacent to Building 283 to address PCBs and PAHs. This work was covered by the following two documents: ECP Supplemental Phase II Site investigation Work Plan Addendum for Parcels 28, 38, 39, 49, 57, 61, and 69 For Remedial Investigation/Feasibility Study/Decision Documents, Fort Monmouth Oceanport, Monmouth County, New Jersey (dated February 2016) and Revised Letter Work Plan Addendum for Parcel 49, Former Squire Laboratory and Other Facilities, Fort Monmouth, NJ (letter dated August 8, 2016). The Army s decision to undertake a removal action and completion of the TCRA was documented in the Action Memorandum For Building 283 Squier Hall, Fort Monmouth, Oceanport, Monmouth County, New Jersey, August The Army also submitted the Request for No Further Action Determination at Building 283 Squier Hall, Fort Monmouth, New Jersey, 12 June 2017 to NJDEP to request concurrence with Army s no further action determination. NJDEP subsequently issued a NFA letter, dated 15 June 2017, for site restoration work STORAGE, RELEASE, OR DISPOSAL OF HAZARDOS SBSTANCES Hazardous substances were not released or disposed of on the Property in excess of reportable quantities specified in 40 Code of Federal Regulations (CFR) Part 373. Hazardous substances were not released in excess of the 40 CFR 373 reportable quantities. Various hazardous substances were used in small quantities as part of the former laboratory operations at the Property. All hazardous substance storage operations have been terminated on the Property. A summary of the buildings or areas in which hazardous substance activities occurred is provided in Table 2 Notification of Hazardous Substance Storage, Release or Disposal (Enclosure 4). The CERCLA 120(h)(3) Notice, Description, and Covenant at Enclosure 8 will be included in the deed. 4

9 4.3. PETROLEM AND PETROLEM PRODCTS NDERGROND AND ABOVEGROND STORAGE TANKS The primary fuels used throughout the history of Fort Monmouth have been coal, fuel oil, diesel and gasoline. ntil the early 1990s, the primary method of heating for Fort Monmouth was through the use of heating oil. The majority of structures at Fort Monmouth were heated by oil burners fired by oil stored in a ST designated for that individual building. From the 1940s through the 1980s, Fort Monmouth utilized STs/aboveground storage tanks (ASTs) as the primary fuel storage method. Fuels were brought in by rail and staged in large ASTs prior to being transported by truck to individual STs. The large ASTs used to stage fuel were located at the Main Post. In the early 1990s, the Fort Monmouth DPW developed a ST program for managing approximately 474 STs throughout the installation (Main Post and Charles Wood Area). This program was created to work toward replacing the use of heating oil as a major energy source and to convert to natural gas. The DPW s approach involved installing new gas lines and new gas-fed boilers and removing the out of service STs. All buildings at the Main Post and Charles Wood Area are heated by natural gas with the exception of several buildings that are heated and cooled through geothermal heating and cooling systems. Current ST/AST Sites There are no STs or ASTs on the Property. Former ST/AST Sites Table 3 (Enclosure 5) presents a summary of the former STs at the Property. There were four STs that have been removed from the Property, each of which have received NFA approval from NJDEP POLYCHLORINATED BIPHENYLS PCB-Class oils are defined by TSCA as oils containing 500 ppm PCBs or greater. PCBcontaminated oils are defined by TSCA as oils containing between 50 ppm and 499 ppm of PCBs. Non-PCB oils are defined by TSCA as oils containing less than 50 ppm PCBs. Electrical oil having PCB concentrations at or less than 49 ppm is considered a Class D recyclable material in the State of New Jersey. The Main Post has approximately 312 oil-filled pieces of electrical equipment of which 185 units are pole-mounted and 127 units are pad-mounted. Three electrical substations are located on the Main Post at Buildings 288, 978 and The substations have secondary containment structures designed to contain the liquid contents of the largest transformer plus sufficient freeboard to accommodate rainwater accumulation. According to the 2007 ECP, the electrical substation located northeast of Building 288 contained a transformer with Non-PCB oil. According to the 2008 SI, this facility is a modern electrical substation that was constructed after the use of PCB-contaminated electrical equipment was discontinued. No releases from the Building 288 transformer pad were identified. 5

10 During the ECP Phase 2 SI conducted in 2007, PCBs above residential criteria were identified within the courtyard of Building 283. A removal action in 2016 addressed the PCB contamination in soils in the courtyard. The Army s decision and completion of removal activities were documented in the Action Memorandum For Building 283 Squier Hall, Fort Monmouth, Oceanport, Monmouth County, New Jersey, August The Army sought NJDEP s concurrence of its NFA determination in the letter report dated June 12, 2017, Request for No Further Action Determination at Building 283 Squire Hall, Fort Monmouth, New Jersey. The NJDEP concurred with the No Further Action (NFA) determination for the Property (letter dated ). No other potential PCB releases were identified on the Property ASBESTOS Historically, four phases of asbestos surveys were completed for Fort Monmouth. The majority of surveys took place from 1989 to 1992 and from 1997 to Walkthrough surveys were conducted for the purpose of establishing whether the walkthrough building was similar to the reference building with respect to construction and suspect materials (the reference building was used to represent conditions in other similar buildings that may not have received an ACM survey). The data presented on the walkthrough and similar buildings provided a general guideline on the type and quantity of ACM that could be found in these buildings. The data was used as a management tool. See: Appendix H,.S. Army BRAC 2005 Environmental Condition of Property Report, Fort Monmouth, Monmouth County, New Jersey, January 29, The ACM identified during these asbestos surveys generally included floor tile, mastic, linoleum, ceiling tile, pipe fittings, pipe runs, transite panel board, various types of insulation, joint compound, flex connectors and debris. An ACM survey was also conducted from February through August 2015 to evaluate non-residential buildings on the Property that had not been previously inspected or were previously identified as containing ACM. See: Final Environmental Contamination Assessment Report at Fort Monmouth, New Jersey, October 2015, Final Asbestos Survey and Assessment,.S. Army Fort Monmouth. Re-inspections of the buildings on the property were conducted on 28 October, The asbestos survey information is summarized in a portion of Table 2-6 from the Final Asbestos Assessment, Asbestos Abatement, and Lead-Based Paint Assessment at Fort Monmouth, New Jersey (December 2016), see Enclosure 6. Friable ACM was identified in Building 283 and friable ACM in poor condition was abated by the Army in August of Documentation of the abatement is contained in Final Asbestos Assessment, Asbestos Abatement, and Lead-Based Paint Assessment at Fort Monmouth, New Jersey (December 2016). Non-friable ACM was identified in Building 288 during an inspection performed in February 2015 and included floor tile. Building 288 was reinspected in October of 2016 and no changes were noted to the ACM conditions. The deed will include an asbestos warning and covenant (Enclosure 8) LEAD-BASED PAINT Most facilities and buildings at Fort Monmouth were constructed before the DOD ban on the use of lead-based paint (LBP) in 1978 and are likely to contain one or more coats of such 6

11 paint. In addition, some facilities constructed immediately after the ban may also contain LBP because inventories of such paints that were in the supply network were likely to have been used up at these facilities. All buildings on the Property were constructed prior to 1978 and are presumed to contain LBP. These buildings are not intended to be used for residential purposes. The deed will include a LPB warning and covenant (Enclosure 9) RADIOLOGICAL MATERIALS The Historical Site Assessment and Addendum to Environmental Condition of Property Report, Fort Monmouth, Eatontown, New Jersey, Cabrera Services, January 2007, indicated potential storage and use of radiological materials in Building 283 on the Property. Building 283 was identified as potentially impacted. A further evaluation of Building 283 was performed and documented in the Final Status Survey Report, Fort Monmouth, Eatontown, New Jersey, SACE, August 2012; it was determined that Building 283 was suitable for unrestricted use. The Nuclear Regulatory Commission (NRC) concurred on this determination in a letter dated 10 October RADON Radon surveys were conducted in 1991 by the Directorate of Engineering and Housing s Environmental Office as part of the Army s Radon Reduction Program. The survey was conducted for all of Fort Monmouth. Radon detectors were deployed in all structures designated as priority one buildings (daycare centers, hospitals, schools and living areas). Radon was not detected above the.s. Environmental Protection Agency residential action level of 4 picocuries per liter in these buildings MNITIONS AND EXPLOSIVES OF CONCERN Based on a review of existing records and available information, there is no evidence that Munitions and Explosives of Concern (MEC) are present on the Property. The term MEC means military munitions that may pose unique explosives safety risks, including: (A) unexploded ordnance (XO), as defined in 10 nited States Code (.S.C.) 101(e)(5); (B) discarded military munitions (DMM), as defined in 10.S.C. 2710(e)(2); or (C) munitions constituents (e.g., 2,4,6-Trinitrotoluene (TNT), Hexahydro-1,3,5-trinitro-1,3,5- triazine (RDX)), as defined in 10.S.C. 2710(e)(3), present in high enough concentrations to pose an explosive hazard. 7

12 4.10. OTHER PROPERTY CONDITIONS There are no other conditions on the Property that present an unacceptable risk to human health and the environment. 5. ADJACENT PROPERTY CONDITIONS A portion of Landfill FTMM-18 is north of and directly adjacent to the Property. This landfill has a soil cover and is generally contained. Groundwater under FTMM-18 has been impacted and is currently being monitored. Based on sampling done on the Property, it does not appear that this adjacent landfill has affected the Property. However, a groundwater use restriction will be placed in the deed to ensure that groundwater use or access on the Property does not influence adjacent groundwater contamination or interfere with the Army s monitoring. Additionally, the deed will contain provision restricting interference with groundwater monitoring wells on the Property. The adjacent property directly to the west of the Property consists Buildings 291, 292, 293, 295 and 296 and includes paved roads and general open areas. In a portion of these areas, PAHs have been identified slightly above NJDEP non-residential criteria and have not yet been addressed. Since there are buildings between the affected areas and the Property and PAHs are not mobile, impacts from these areas are not anticipated. The property south and east and adjacent to the Property consists of open space paved roads and some limited buildings. This property is classified as a Category 2 due to potential petroleum releases on parts of the property that are not directly adjacent to the Property and no impacts are expected from these adjacent areas. 5.1 Environmental Conditions on Surrounding Properties A regulatory database summary acquired from Environmental Data Resources, Inc. (EDR) on July 29, 2014 as part of the ECP pdate process listed private properties with documented contaminant releases. The EDR Report consolidated standard federal, state, local and tribal environmental record sources based on American Society for Testing and Materials (ASTM) D (2005) recommended minimum search distances from the Property. The majority of the listed properties are residential and the sources of contamination are primarily petroleum releases from HOTs. The Army does not consider that contaminants from these properties have adversely impacted the Property based on their distances/directions from the Property, incomplete hydraulic pathways to the Property, limited contaminant sources and RAs taken. 6. ENVIRONMENTAL REMEDIATION AGREEMENTS The following environmental agreement is applicable to Fort Monmouth generally: Voluntary Cleanup Agreement among New Jersey Department of Environmental Protection,.S. Department of the Army,.S. Department of the Navy,.S. Department of the Air Force and the.s. Defense Logistics Agency dated August 30, However, the Voluntary Cleanup Agreement does not require any remedial action on the Property that is the subject of 8

13 this FOST. The deed will include a provision reserving the Army s right to conduct remediation activities if necessary in the future (Enclosure 8). 7. REGLATORY/PBLIC COORDINATION The NJDEP and the public are being notified of the initiation of this FOST via publication in a local paper. The FOST is being made available for review and comment on the Army website ( and at the FTMM IRP Repository located at the Monmouth County Library Eastern Branch (1001 Route 35, Shrewsbury, NJ, 07701). Regulatory/public comments received during the comment period will be reviewed and incorporated, as appropriate. A copy of the regulatory/public comments and the Army response will be included in the Final FOST. 8. NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE The environmental impacts associated with the proposed transfer of the Phase 2 Property have been analyzed in accordance with the National Environmental Policy Act (NEPA). The results of this analysis are documented in the Final Environmental Assessment of the Implementation of the Base Realignment and Closure at Fort Monmouth, New Jersey, March 2009 and the Finding of No Significant Impact Environmental Assessment of the Disposal and Reuse of Fort Monmouth, New Jersey, February There were no encumbrances or conditions identified in the NEPA analysis as necessary to protect human health or the environment. The deed will contain the applicable preservation covenants as set forth in the Programmatic Agreement among the nited States Army and the New Jersey State Historic Preservation Officer for the Closure and Disposal of Fort Monmouth, New Jersey, October FINDING OF SITABILITY TO TRANSFER Based on the above information, I conclude that all removal or remedial actions necessary to protect human health and the environment have been taken and the Property is transferable under CERCLA Section 120(h)(3). In addition, all DOD requirements to reach a finding of suitability to transfer have been met, subject to the terms and conditions set forth in the attached EPPs that shall be included in the deed for the Property. The deed will also include the CERCLA 120(h)(3) Notice, Covenant, and Access Provisions and Other Deed Provisions. Finally, the hazardous substance notification (Table 2) shall be included in the deed as required under CERCLA Section 120(h) and DOD FOST guidance. Mr. James E. Briggs Chief, Consolidated Branch BRAC Division Date 9

14 9 Enclosures Encl 1 -- Figures Encl 2 -- Environmental Documentation Encl 3 -- Table 1 -- Description of Property Encl 4 -- Table 2 -- Notification of Hazardous Substance Storage, Release, or Disposal Encl 5 -- Table 3 -- Notification of Petroleum Product Storage, Release, or Disposal Encl 6 -- Asbestos Assessment Summary Encl 7 -- CERCLA Notice, Covenant, and Access Provisions and Other Deed Provisions Encl 8 -- Environmental Protection Provisions Encl 9 -- Regulatory/Public Comments and Responses 11

15 ENCLOSRE 1 FIGRES

16 John F Kennedy Intl Gateway National Rec Area LEGEND Installation Boundary Six Mile Run Park Main Post ArcGIS File: FTMON_018_Fig01_Facility.mxd Date: 1/25/07 64 Hightstown 130 Trenton Browns Mills 130 Fort DIX Military Reservation 537 New York--Newark Turkey Swamp County Park Charles Wood Area Allaire State Park P e n n s y l v a n i a M a r y l a n d D e l a w a r e N e w J e r s e y N e w Y o r k Scale: Base Realignment and Closure 2005 FIGRE 1 FACILITY LOCATION MAP FORT MONMOTH NEW JERSEY Miles.S. Army Corps of Engineers

17

18 Environmental Carve-Out Parcels 49 & 50

19 LEGEND Monmouth County 51 Road Centerline Water Feature PINE BROOK Monmouth County 13A NORTH BRANCH PARKERS CREEK N. BRANCH PARKERS CK NT TO 1.10 Monmouth County 13 PARKERS CREEK Sherrill Avenue PARKERS CREEK Saltzman Avenue Monmouth County 11 Hildreth Avenue Oceanport Avenue Leonard Avenue Building Water Body Installation Boundary Land se Industrial/Commercial Residential/Recreational ndeveloped PARKERS CREEK BRANCH Monmouth County 51 LAFETRA CREEK NJ 35 MILL CREEK Avenue of Memories Wilson Avenue HSKYBROOK LAKE Saltzman Avenue Nicodemus Avenue Alexander Avenue Murphy Drive Main St OCEANPORT CREEK Port Au Peck Ave Route 537 ArcGIS File: FTMON_022_Fig23_Land_se.mxd Date: 1/25/07 Garden State Parkway Pearl Harbor Avenue Corregidor Road Pinebrook Road Tinton Avenue/Route 537 SHREWSBRY (PARKERS CREEK) Hope Road Hope Road NJ 36 Megill Drive WAMPM BROOK Pinebrook Road NJ 35 HSKYBROOK CREEK Monmouth County 32 Route 547 BRANCHPORT CREEK (TRTLE MILL CK) NJ 71 Scale: ,500 3,000 Base Realignment and Closure 2005 FIGRE 3.S. Army Corps of Engineers ADJACENT LAND SE MAP FORT MONMOTH NEW JERSEY Feet Note: Schematic representation of prevalent surrounding land use only. Boundaries of surrounding land use designations are not exact.

20 ENCLOSRE 2 ENVIRONMENTAL DOCMENTATION Brinkerhoff Environmental Services, Inc nited States Army Fort Monmouth, New Jersey, Building 283 (FTMM-62), Building 290 (FTMM-55), Building 296 (FTMM-54), Landfill MP-18 (FTMM-18), Classification Exception Area,.S. Army Garrison Fort Monmouth, Main Post, Fort Monmouth, New Jersey. June. Cabrera Services Final Historical Site Assessment and Addendum to Environmental Condition of Property Report, Fort Monmouth, Eatontown, New Jersey. January. CALIBRE Systems, Inc Environmental Condition of Property pdate Report, Fort Monmouth, New Jersey Phase 2 Parcels. March. EDAW, Inc Fort Monmouth Reuse and Redevelopment Plan, Final Plan. 22 August. Environmental Data Resources, Inc EDR Data Map Environmental Atlas, Phase 2 Property, Fort Monmouth, NJ. Inquiry Number s. 29 July. Fort Monmouth Finding of No Significant Impact Environmental Assessment of the Disposal and Reuse of Fort Monmouth, New Jersey. February. Fort Monmouth, Directorate of Public Works Asbestos Database.mdb. March. NJDEP No Further Action (NFA) letter for FTMM-61, 4 May NJDEP No Further Action (NFA) letter for FTMM-54, FTMM-55 and FTMM-61 (Area of Concern: Parcel 50), Fort Monmouth, New Jersey, 22 May NJDEP No Further Action (NFA) letter for Areas of Concern: Building 283 Squier Hall, 15 June Parsons Final August 2013 Baseline Groundwater Sampling Report, Fort Monmouth, Oceanport, Monmouth County, New Jersey. Rev. No. 0. March. Parsons Final Addendum 1 Environmental Condition of Property Report, nregulated Heating Oil Tank (HOT) Investigation Report, Fort Monmouth, Oceanport, Monmouth County, New Jersey. Rev. No. 0. May. Shaw Environmental, Inc. (Shaw) S. Army BRAC 2005 Environmental Condition of Property Report Fort Monmouth, Monmouth County, New Jersey, Final, 29 January. Shaw S. Army BRAC 2005 Site Investigation Report Fort Monmouth, Final. 1

21 21 July. Shaw Fort Monmouth Main Post and Charles Wood Area, Baseline Ecological Evaluation Report,.S. Army Garrison Fort Monmouth, Fort Monmouth, New Jersey. May. Tetra Tech, Inc Final Environmental Contamination Assessment Report at Fort Monmouth, New Jersey. June. Tetra Tech, Final Asbestos Assessment, Asbestos Abatement, and Lead-Based Paint Assessment at Fort Monmouth, New Jersey (December 2016).S. Army BRAC 2005 Environmental Condition of Property Report Fort Monmouth, Monmouth County, New Jersey, Final, 29 January 2007.S. Army Environmental Condition of Property pdate Report for Phase 2 Property, Fort Monmouth, Monmouth County, New Jersey, March S. Army 2005 BRAC Environmental Condition of Property pdate Report, Fort Monmouth, Monmouth County New Jersey, Final, 18 August S. Army Additional Information on ST 283A and Work Plan Addendum, Fort Monmouth New Jersey, 6 June S. Army Action Memorandum For Building 283 Squier Hall, Fort Monmouth, Oceanport, Monmouth County, New Jersey, August S. Army Summary Remedial Investigation Report and NFA Request for FTMM-61, Building 283 Former Gasoline ST Fort Monmouth, New Jersey, 4 April S. Army Additional Information on ST 283A and Work Plan Addendum, Fort Monmouth New Jersey, 6 June S. Army Request for No Further Action Determination at Building 283 Squier Hall, Fort Monmouth, New Jersey, 12 June S. Army Corps of Engineers, Mobile District Final Environmental Assessment of the Implementation of Base Realignment and Closure at Fort Monmouth, New Jersey. March..S. Army Corps of Engineers, New York District Final Status Survey Report, Fort Monmouth, Eatontown, New Jersey. Final. 15 August. 2

22 ENCLOSRE 3 TABLE 1 DESCRIPTION OF PROPERTY Building Number and Property Description Building 283 Bldg 283 is currently administrative space. Previous use included the Squier laboratory - primary R&D laboratory until 1954 (when the laboratory operations were transferred to Bldg 2700). Former repair/experimental work within this parcel included photographic equipment, a battery test facility (which was destroyed by fire in the 1980s and subsequently rebuilt), climatic testing lab, plastics research and development. Numerous former buildings existed in this parcel that were associated with Squier laboratory operations in the 1950s. Building 283 (former STs) ECP Parcel Designation Part of Parcel 49 Part of Parcel 50 Condition Category Remedial Actions 1 4* Limited PCB and PAH removals were performed in 2016 and NJDEP concurred with Army s NFA determination (letter dated June 15, 2017). 4* This parcel number was designated to contain IRP sites FTMM- 54, FTMM-55 and FTMM-61. Only FTMM-61 is within the Property to be transferred. Former STs have been removed, soil and groundwater have been remediated, and NFAs have been received from NJDEP (letter dated May 4, 2017). Parcel 50 essentially overlaps with Parcel 49; discussion of remedial actions are covered above under Parcel 49. * Category 4: Areas where release, disposal, and/or migration of hazardous substances has occurred, and all removal or remedial actions to protect human health and the environment have been taken. 1

23 ENCLOSRE 4 TABLE 2 NOTIFICATION OF HAZARDOS SBSTANCE RELEASE, STORAGE, OR DISPOSAL Name of Hazardous Building Number Substance(s) 283 CT, Chromic acid, TCE, HCL, sulfuric acid, paint thinner, hydrogen sulfide, hydrogen selenide, benzol, cadmium, mercury, silver cyanide, copper cyanide, zinc cyanide, sodium cyanide, nickel sulfate, copper sulfate, photographic reagents 283 Polychlorinated Biphenyls (PCBs) and Polycyclic Aromatic Hydrocarbons (PAHs) 288 CT, acetone, ammonia, methanol, photographic reagents, mercury, lead, sulfuric acid, Date of Storage, Release, or Disposal se and storage in 1950 s as part of laboratory operations but quantities were below the CERCLA reporting limits. PCBs were used in transformers throughout the base history specific release date unknown. Specific release date of PAHs is unknown. se and storage in the 1950s as part of the laboratory operations but quantities were below CERCLA reporting limits. 288 Lead and sulfuric acid se and storage in 2006 through closure in 2011 as part of generator batteries but quantities were below CERCLA reporting limits. Remedial Actions There were no releases of these compounds identified. PAHs and PCBs were addressed via a removal action which was documented in a letter report dated June 12, 2017 to the NJDEP requesting for no further action. The NJDEP concurred on the NFA in a letter dated June 15, The Army further documented the action in an Action Memorandum dated August 1, There were no releases of these compounds identified. There were no releases of these compounds identified. 1

24 ENCLOSRE 5 TABLE 3 NOTIFICATION OF PETROLEM PRODCT STORAGE, RELEASE, OR DISPOSAL Building Number Name of Petroleum Product(s) Date of Storage, Release, or Disposal Building 283 (ST 283C) Gasoline Removed NJDEP closure approved Building 283 (ST 283A) #2 Fuel Oil Removed NJDEP closure approved Building 283 (ST 283B) #2 Fuel Oil Removed NJDEP closure approved on Building 288 (ST 288) #2 Fuel Oil Removed NJDEP closure approved Remedial Action Description ST had numerous holes; sheen observed on groundwater. Highest soil TRPH=4,351 mg/kg. All soil sample results were less than NJDEP NRDCSCC. Closure report submitted to NJDEP , and NJDEP closure approval letter received Benzene and toluene were above NJDEP GWQC. Three monitoring wells were installed in 2000, and three additional wells in Groundwater monitoring was conducted quarterly from 1999 through 2011, and annually from 2013 to Oxygen Release Compound (ORC) injections were performed in 2010 to Groundwater was addressed under FTMM-61 and NFA received May 4, ST removed on ; no contamination observed and no closure samples were initially taken. Additional sampling was performed at the identified location of the tank in 2016 and NFA received May 4, ST removed on Site is clean; TPHC <1000 mg/kg. Soil and groundwater assessment completed. Closure report submitted to NJDEP on NJDEP closure approval letters dated and ST and 185 cubic yards of contaminated soil were removed on Highest soil TPHC =30,004 mg/kg next to structures. Groundwater samples were all clean. Closure report submitted to NJDEP on NJDEP closure approval letter dated

25 ENCLOSRE 6 ASBESTOS ASSESSMENT SMMARY INSPECTIONS 1

26 Asbestos Assessment, Asbestos Abatement, and Lead-Based Paint Assessment Fort Monmouth, New Jersey December 2016 Facility Number Date Re-Inspection Y/N Previously Identified Friable ACM Y/N Additional Suspect Friable ACM Y/N Friable PACM Bulk Samples Collected Y/N 283 b 8/29/2016 N Y Y Y Material (Detected in Bold) Pipe insulation, Fire door, Ceiling tile, Debris, Wall board Condition of PACM Result Pos./Neg. Previously Identified Non- Friable ACM Y/N Additional Non-Friable ACM Y/N Non-Friable PACM Bulk Samples Collected Y/N Sample Location Fair to Good, Fair, Fair to Good, Poor, Fair POS/NEG Throughout Material (Detected in Bold) Various. Detected in Plaster, Joint compound, Glue dots, Floor tile, Mastic, Transite wall panels /28/2016 Y N N N N/A N/A N/A N N N N/A N/A N/A Various. Detected in Poor to Fair, Poor Various /20/2015 N Y Y Y Pipe to Good, Detected in POS/NEG Throughout insulation Poor Glue and dots, Mastic. Mastic /1/2016 Y Y Y Y Pipe insulation Fair POS Y N N Throughout /28/2016 Y Y N N Ceiling tile Poor NEG Y N N Throughout /28/2016 Y Y N N N/A N/A N/A N N N Throughout /28/2016 Y Y Y Y N/A N/A N/A Y N N Throughout /28/2016 Y N N N N/A N/A N/A Y N N Throughout /28/2016 Y N N N N/A N/A N/A Y N N Throughout /28/2016 Y N N N Breeching insulation, Ceiling tile Poor, Poor NEG Y N N Throughout Various. Detected in Plaster, Floor tile, Mastic. Various. Detected in Mastic. Various. Detected in Floor tile, Mastic. Various. Detected in Floor tile, Mastic. Various. Detected in Floor tile, Mastic. Various. Detected in Floor tile, Mastic. Various. Detected in Floor tile, Mastic, Joint compound. Result Pos./Neg. POS/NEG POS/NEG POS/NEG POS/NEG POS/NEG POS/NEG POS/NEG POS/NEG POS/NEG Table 2-6.5

27 ENCLOSRE 7 CERCLA NOTICE, COVENANT, AND ACCESS PROVISIONS AND OTHER DEED PROVISIONS The following CERCLA Covenant and Access Provisions, along with the Other Deed Provisions, will be placed in the deed in a substantially similar form to ensure protection of human health and the environment and to preclude any interference with ongoing or completed remediation activities. 1. Property Covered by Notice, Description, Access Rights, and Covenants Made Pursuant to Section 120(h)(3)(A) of the Comprehensive Environmental Response Compensation, and Liability Act of 1980 (42.S.C. Section 9620(h)(3)(A)): For the Property, the Grantor provides the following notice, description, and covenants and retains the following access rights: A. Notices Pursuant to Section 120(h)(3)(A)(i)(I) and (II)) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. Section 9620(h)(3)(A)(i)(I) and (II): Pursuant to section 120(h)(3)(A)(i)(I) and (II) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(i)(I) and (II)), available information regarding the type, quantity, and location of hazardous substances and the time at which such substances were stored, released, or disposed of, as defined in section 120(h) is provided in Enclosure, attached hereto and made a part hereof. B. Description of Remedial Action Taken, if Any, Pursuant to Section 120(h)(3)(A)(i)(III) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(i)(III)): Pursuant to section 120(h)(3)(A)(i)(III) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(i)(III)), a description of the remedial action taken, if any, on the property is provided in Enclosure 4, attached hereto and made a part hereof. C. Covenant Pursuant to Section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(ii) and (B)): Pursuant to section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(ii) and (B)), the nited States warrants that (1) All remedial action necessary to protect human health and the environment with respect to any hazardous substances identified pursuant to section 120(h)(3)(A)(i)(I) of the 1

28 Comprehensive Environmental Response, Compensation, and Liability Act of 1980 remaining on the property has been taken before the date of this deed, and (2) Any additional remedial action found to be necessary after the date of this deed shall be conducted by the nited States. D. Access Rights Pursuant to Section 120(h)(3)(A)(iii) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(iii)): A. Pursuant to section 120(h)(3)(A)(iii) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(iii)), the nited States retains and reserves a perpetual and assignable easement and right of access on, over, and through the Property, to enter upon the Property in any case in which an environmental response action or corrective action is found to be necessary on the part of the nited States, without regard to whether such environmental response action or corrective action is on the Property or on adjoining or nearby lands. Such easement and right of access includes, without limitation, the right to perform any environmental investigation, survey, monitoring, sampling, testing, drilling, boring, coring, test-pitting, installing monitoring or pumping wells or other treatment facilities, response action, corrective action, or any other action necessary for the nited States to meet its responsibilities under applicable laws and as provided for in this instrument. Such easement and right of access shall be binding on the Grantee and its successors and assigns, and shall run with the land. B. In exercising such easement and right of access, the nited States shall provide the Grantee or its successors or assigns, as the case may be, with reasonable notice of its intent to enter upon the Property and exercise its rights under this clause, which notice may be severely curtailed or even eliminated in emergency situations. The nited States shall use reasonable means, but without significant additional costs to the nited States, to avoid and to minimize interference with the Grantee s and the Grantee s successors and assigns quiet enjoyment of the Property. At the completion of any work, the work site shall be reasonably restored. Such easement and right of access includes the right to obtain and use utility services, including water, gas, electricity, sewer, and communications services available on the Property at a reasonable charge to the nited States. Excluding the reasonable charges for such utility services, no fee, charge, or compensation will be due the Grantee, nor its successors and assigns, for the exercise of the easement and right of access hereby retained and reserved by the nited States. C. In exercising such easement and right of access, neither the Grantee nor its successors and assigns, as the case may be, shall have any claim at law or equity against the nited States or any officer, employee, agent, contractor of any tier, or servant of the nited States based on actions taken by the nited States or its officers, employees, agents, contractors of any tier, or servants pursuant to and in accordance with this clause. Provided, however, that nothing in this paragraph shall be considered a waiver by the Grantee, its successors and assigns, of any remedy available to them under the Federal Tort Claims Act. In addition, the Grantee, its successors and assigns, shall not interfere with any response action or corrective action conducted by the Grantor on the Property. 2

29 2. AS IS CONDITION OF PROPERTY A. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the Property and accepts the condition and state of repair of the Property. The Grantee understands and agrees that the Property is conveyed AS IS without any representation, warranty, or guaranty by the Grantor as to the quantity, quality, title, character, condition, size, or kind, or that the same is in a suitable condition or fit to be used for the purpose(s) intended by the Grantee, and no claim for allowance or deduction upon such grounds will be considered. B. No warranties, either express or implied, are given with regard to the condition of the Property including, without limitation, whether the Property does or does not contain asbestos or lead-based paint. 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, lead-based paint, or other conditions on the Property. The failure of the Grantee to inspect or to exercise due diligence to be fully informed as to the condition of all or any portion of the Property will not constitute grounds for any claim or demand against the Grantor. C. Nothing in this As Is provision shall be construed to modify or negate the Grantor s obligation under the Covenant Pursuant to Section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(ii) and (B)) or any other statutory obligations. 3. INDEMNIFY AND HOLD HARMLESS A. To the extent authorized by New Jersey law, the Grantee, for itself, its successors and assigns, covenants and agrees to indemnify and hold harmless the Grantor, its officers, agents, and employees from (1) any and all claims, damages, judgments, losses, and costs, including fines and penalties, arising out of the violation of the notices, covenants, conditions, and restrictions in this deed by the Grantee, its successors and assigns, and (2) any and all claims, damages, judgments, losses, and costs arising out of, or in any manner predicated upon, exposure to asbestos, lead-based paint, or other condition on any portion of the Property after the date of the conveyance. B. The Grantee, for itself, its successors and assigns, covenants and agrees that the Grantor shall not be responsible for any costs associated with modification or termination of the notices, covenants, conditions, and restrictions in this deed including, without limitation, any costs associated with additional investigation or remediation of asbestos, lead-based paint, or other condition on any portion of the Property. C. Nothing in this Indemnify and Hold Harmless provision shall be construed to modify or negate the Grantor s obligations under the Covenant Pursuant to Section 120(h)(3)(A)(ii) and (B) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42.S.C. 9620(h)(3)(A)(ii) and (B)) or any other statutory obligations. 4. POST-TRANSFER DISCOVERY OF CONTAMINATION AND RELEASE 3