Amendment to Final Remedial Action Plan Oakland Army Base Oakland, California for Former Parcel 18 and Subparcels 19 and 21 Oakl

FINAL

Amendment to Final Remedial Action Plan Oakland Army Base Oakland, California for Former Parcel 18 and Subparcels 19 and 21 Oakland United States Army Reserve Center #2

Prepared for

California Environmental Protection Agency Department of Toxic Substances Control

Prepared by

U.S. Army Reserve 63D Regional Readiness Command 4235 Yorktown Avenue Los Alamitos, California 90720-5002

December 2006 TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY...... 1-1 1.1 PURPOSE...... 1-1 1.2 RATIONALE FOR AN AMENDMENT ...... 1-1 1.3 SITE LOCATION, CONDITION, AND INTENDED REUSE...... 1-1 1.3.1 Site Use History ...... 1-1 1.3.2 Nature and Extent of Chemical Impacts ...... 1-1 1.3.3 Intended Reuse...... 1-2 1.4 IDENTIFICATION, SCREENING, AND SELECTION OF REMEDIAL ALTERNATIVES...... 1-2 1.5 SELECTED REMEDY...... 1-2 1.5.1 Environmental Restrictions...... 1-3 1.5.2 Implementation and Enforcement Plan...... 1-3 1.6 DECLARATION / STATUTORY DETERMINATION ...... 1-4 2.0 INTRODUCTION ...... 2-5 2.1 PURPOSE...... 2-5 2.2 RATIONALE FOR AN AMENDMENT ...... 2-5 2.3 SITE LOCATION AND DESCRIPTION...... 2-5 2.4 INTENDED REUSE...... 2-5 2.5 APPROACH TO ENVIRONMENTAL REMEDIATION OF THE SITE ...... 2-5 3.0 SITE BACKGROUND...... 3-1 3.1 SITE SETTING AND FEATURES...... 3-1 3.1.1 Parcel 18...... 3-1 3.1.2 Subparcel 19...... 3-2 3.1.3 Subparcel 21...... 3-2 3.2 SITE GEOLOGY...... 3-3 3.3 SITE HYDROGEOLOGY...... 3-3 3.3.1 Groundwater Quality...... 3-4 3.3.2 Potential for Contaminant Migration to San Francisco Bay Via Groundwater...3-4 3.4 SITE NATURAL RESOURCES...... 3-4 3.5 SITE USE HISTORY...... 3-5 3.5.1 Parcel 18...... 3-5 3.5.2 Subparcel 19...... 3-5 3.5.3 Subparcel 21...... 3-6 4.0 OVERVIEW OF SITE INVESTIGATIONS AND REMEDIAL ACTIVITIES ...... 4-1 4.1 PARCEL 18...... 4-1 4.2 SUBPARCEL 19...... 4-2 4.3 SUBPARCEL 21...... 4-3 4.4 SUMMARY OF CHEMICAL RELEASE SITES AND LOCATIONS ...... 4-4 5.0 CHEMICAL OF CONCERN IDENTIFICATION ...... 5-1 6.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ...... 6-1 7.0 REMEDIAL ACTION OBJECTIVES AND RISK-BASED REMEDIATION GOALS7-1 8.0 IDENTIFICATION, SCREENING, AND SELECTION OF REMEDIAL ALTERNATIVES...... 8-1 8.1 IDENTIFICATION AND SCREENING OF ALTERNATIVES ...... 8-1 i

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 8.1.1 No Action Alternative...... 8-1 8.1.2 Action Alternatives...... 8-1 8.2 DETAILED ANALYSIS OF ALTERNATIVES...... 8-1 8.3 SELECTED REMEDY...... 8-3 8.3.1 Environmental Restrictions...... 8-3 8.3.2 Implementation and Enforcement Plan...... 8-3 8.3.3 Justification for the Selected Remedy...... 8-3 9.0 REMEDIAL ACTION IMPLEMENTATION SCHEDULE ...... 9-1 10.0 NONBINDING ALLOCATION OF RESPONSIBILITY ...... 10-2 11.0 REFERENCES ...... 11-1

LIST OF FIGURES

Figure 1. Regional Location Figure 2. Location of USAR Parcels Figure 3. Aerial Photograph Figure 4. Parcel 18, Building 762 Figure 5. Subparcel 19, Building 780 Figure 6. Subparcel 21, Building 778 (tennis courts)

LIST OF TABLES

Table 1. Existing and Former Buildings Table 2. USTs, ASTs, and Other Subsurface Structures Table 3. Chemicals of Concern Table 4. Remediation Goals for Chemicals of Concern in Soil and Groundwater

LIST OF APPENDICES

Appendix A. Survey Maps Appendix B. Correspondence Appendix C. Soil Sampling Locations Appendix D. Responsiveness Summary

AST Above Ground Storage Tank ARARs Applicable or Relevant and Appropriate Requirements Army United States Department of Defense, Department of the Army bgs Below Ground Surface CERCLA Comprehensive Environmental Responsibility, Compensation, and Liability Act C.F.R. Code of Federal Regulations cm/s Centimeters per Second COC Chemical of Concern DTSC California Environmental Protection Agency, Department of Toxic Substances Control EBS/PA Environmental Baseline Survey/Preliminary Assessment EDC Economic Development Conveyance EIR Environmental Impact Report EKI Erler & Kalinowski, Inc. ESL Environmental Screening Levels FOST Finding of Suitability to Transfer mg/kg Milligram per Kilogram mg/L Milligram per Liter NCP National Oil and Hazardous Substances Pollution Contingency Plan NRE Natural Resources Evaluation OARB Oakland Army Base PA/SI Preliminary Assessment/Site Investigation PCBs Polychlorinated Biphenyls PRG Preliminary Remediation Goal Port Port of Oakland RAO Remedial Action Objective RAP Remedial Action Plan RMP Risk Management Plan

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006

LIST OF ABBREVIATIONS AND ACRONYMS (CONT.)

RCRA Resource Conservation and Recovery Act RRC Regional Readiness Command RWQCB Regional Water Quality Control Board, San Francisco Bay Region SPTCo Southern Pacific Transportation Company TPH Total Petroleum Hydrocarbons USAR U.S. Army Reserve UST Underground Storage Tank VA Veterans Administration VOC Volatile Organic Compounds XRF X-ray Fluorescent Spectrum Analyzer

1.1 PURPOSE

This Amendment to Final Remedial Action Plan, Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 (“RAP Amendment”) amends the California Environmental Protection Agency, Department of Toxic Substances Control (“DTSC”)-approved Final Remedial Action Plan, Oakland Army Base, Oakland, California, dated 27 September 2002 (“RAP”) prepared by Erler & Kalinowski, Inc. (“EKI”) (2002a) to include Parcel 18 and Subparcels 19 and 21 (“the Site”) in the area to which the DTSC-approved RAP applies. This RAP Amendment further identifies, evaluates, and selects remedies for Parcel 18 and Subparcels 19 and 21.

1.2 RATIONALE FOR AN AMENDMENT

Parcel 18 and Subparcels 19 and 21 share similar past uses and are contiguous to the Former Oakland Army Base – Economic Development Conveyance Area (“Former OARB – EDC Area”) covered by the DTSC-approved RAP (EKI, 2002a). An Amendment to the RAP is a convenient and efficient method for selecting remedies that are protective of human health and the environment.

1.3 SITE LOCATION, CONDITION, AND INTENDED REUSE

Parcel 18 and Subparcels 19 and 21 currently consist of 6.76 acres of paved parking, buildings, and other improvements on land owned by the United States Army Reserve (“USAR”) located on the former Oakland Army Base (“OARB”) in Oakland, California (Figures 1 and 2).

1.3.1 Site Use History

Much of the former OARB, including the Site, was natural tidal marsh or open water before 1916. During the first half of the 1900s, dredged sand and imported soil were placed to create the land surface. The United States Department of Defense, Department of the Army (“Army”) acquired the land in 1941, and provided additional fill in most portions of the former OARB, including the Site, to achieve the final grade. The Site was then developed into OARB. Parcel 18 and Subparcels 19 and 21 were initially developed in the 1940s for residential barracks, mess halls, recreation and storage, and a loading dock. Several phases of demolition and site redevelopment have occurred at the Site.

1.3.2 Nature and Extent of Chemical Impacts

As described in the DTSC-approved Environmental Baseline Survey / Preliminary Assessment (“EBS/PA”) (Baseline, 2003), areas where chemicals of concern (“COCs”) may have impacted soil or groundwater included the former x-ray photo processing laboratory in Building 762, lead- affected shallow soils adjacent to existing or demolished buildings, sampling of soil and groundwater near the grease trap near the southeastern portion of Building 780, soil and 1-1

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 groundwater investigations as part of former underground storage tank (“UST”) closures, and storm drains and sanitary sewers. These areas are described in the EBS/PA. Based on the DTSC- approved EBS/PA and on review of available historic information, no locations that would be considered RAP Sites or Risk Management Plan (“RMP”) locations by DTSC have been identified on the Site (Baseline, 2003).

1.3.3 Intended Reuse

The Site is proposed for reuse as marine terminals, including a New Intermodal Rail Terminal. The uses would include paving the Site and providing container storage and container transfer facilities.

1.4 IDENTIFICATION, SCREENING, AND SELECTION OF REMEDIAL ALTERNATIVES

The remedial alternatives are identified, screened, and selected in Section 8 of this RAP Amendment. The identified remedial alternatives include:

No Action Alternative:

• No action for soil and groundwater.

Action Alternatives:

• Conduct a Remedial Investigation and prepare a separate RAP including an evaluation of its own remedial action objectives (“RAOs”), remediation goals, and remedial alternatives.

• Amend the existing DTSC-approved RAP and evaluate the remedial alternatives retained for detailed analysis.

Pursuant to the rationale provided in Section 1.2, above, the only alternative retained for detailed analysis was amendment to the existing DTSC-approved RAP. Under this alternative, each individual remedial alternative from the DTSC-approved RAP was subject to the analysis described in Section 8. On the basis of the detailed analysis, use of institutional controls was the selected alternative.

1.5 SELECTED REMEDY

As presented in Section 8, the proposed remedy for the contamination at Parcel 18 and Subparcels 19 and 21 is amending the existing DTSC-approved RAP to include the Site in the RAP, and then selecting an appropriate remedy from among those identified in the DTSC- approved RAP. The appropriate remedy proposed for the Site is institutional controls, which will be in the form of a Covenant to Restrict Use of Property – Environmental Restriction (“Covenant”). The Covenant will include the following environmental restrictions and Implementation and Enforcement Plan requirements: 1-2

• Sensitive land uses, including, but not limited to, residential housing, schools for persons under 18 years of age, day-care facilities for children, hospitals, and hospices are prohibited. Reuse of Site soil outside of the Site boundary for any purpose is permitted only with the written approval of DTSC.

• The construction of groundwater wells and extraction of groundwater from new and/or existing wells for any purpose are permitted only with the written approval of DTSC. Construction dewatering activities are permitted subject to all applicable local and State requirements, including those of the California Regional Water Quality Control Board, for disposing of the liquid from dewatering activities.

1.5.2 Implementation and Enforcement Plan All current and successive property owners shall comply with the Implementation and Enforcement Plan, which includes the following requirements:

• A written report shall be submitted to DTSC annually. The report submittal date shall be within thirty (30) days following the anniversary date of the Site property transfer (by the end of each year). The report shall include: (1) inspection results, (2) a certification attesting to the compliance of the terms and conditions of the Covenant, and (3) a discussion on any dewatering activities and final disposition of the liquid, violations of the Covenant, and any action taken to ensure compliance with the Covenant.

• DTSC shall be provided with reasonable right of entry and access to the Site for periodic inspections to ensure compliance with the Covenant.

The remaining detected maximum COC concentrations in soil and groundwater are below the Remediation Goals established for industrial / commercial land use and discussed in Section 7 of this RAP Amendment; however, some of the remaining detected concentrations may not be protective for unrestricted land use by sensitive populations. By restricting sensitive land uses, prohibiting extraction or use of groundwater, and requiring an Implementation and Enforcement Plan, the institutional controls selected in this RAP Amendment will be protective of human health and the environment under an industrial / commercial land use scenario.

On the basis of the results of the DTSC-approved EBS/PA (Baseline, 2003), implementation of the RMP (EKI, 2002b) which was appended to the DTSC-approved RAP is not part of the selected remedy.

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006

2.0 INTRODUCTION

2.1 PURPOSE

This RAP Amendment amends the DTSC-approved RAP and includes Parcel 18 and Subparcels 19 and 21 in the area to which the DTSC-approved RAP applies. This RAP Amendment further identifies, evaluates, and selects remedies for Parcel 18 and Subparcels 19 and 21.

2.2 RATIONALE FOR AN AMENDMENT

Parcel 18 and Subparcels 19 and 21 share similar past uses and are contiguous to the Former OARB – EDC Area covered by the DTSC-approved RAP. Parcel 18 and Subparcels 19 and 21 also have similar types of COCs as the Former OARB – EDC Area. An Amendment to the RAP is a convenient and efficient method for selecting remedies that are protective of human health and the environment.

2.3 SITE LOCATION AND DESCRIPTION

Parcel 18 and Subparcels 19 and 21 consist of 6.76 acres of improved land in Oakland, California (Figures 1 and 2). The parcels are all located on the former OARB. The former OARB is bounded to the north by the East Bay Municipal Utility District sewage treatment plant, to the east by railroad tracks and the I-880 freeway, to the south by the former Fleet and Industrial Supply Center Oakland (now owed by the City of Oakland, a municipal corporation, acting by and through its Board of Port Commissioners (“Port of Oakland”) as marine terminals, a rail facility, and a park), and to the west by Port of Oakland marine terminals.

2.4 INTENDED REUSE

The Site is proposed for reuse as marine terminals, including a New Intermodal Rail Terminal. The uses would include paving the Site and providing container storage and container transfer facilities.

2.5 APPROACH TO ENVIRONMENTAL REMEDIATION OF THE SITE

Upon approval by DTSC, this RAP Amendment will apply the original remedial alternatives and selected remedies developed in the original RAP (EKI, 2002a) to the Site. This will expand the area subject to the requirements of the DTSC-approved RAP dated 27 September 2002.

Potentially affected media within the area may consist of soil, groundwater, surface water, and air. On the basis of available information presented herein, there are no identified areas requiring additional active remediation on the Site.

As presented in the DTSC-approved RAP dated 27 September 2002, institutional controls may be the only remedies for a site, or may be an integral component of remedial actions. For the Site, DTSC has determined that institutional controls alone are sufficient to protect human health 2-5

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 and the environment. The institutional controls applicable to the Site will consist of the land and groundwater use restrictions described in Section 8.

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This section provides a summary of background information on the Site. A detailed description of the regional setting of the former OARB, which included the Site, is described in the DTSC- approved RAP / RMP (EKI, 2002a; 2002b). The Site is not part of, but are adjacent to, the Former OARB - EDC Area.

3.1 SITE SETTING AND FEATURES

The Site is located within the former OARB near the Outer Harbor of the Port of Oakland, Alameda County (Figure 1). San Francisco Bay is located more than one-half mile west of the Site. Port of Oakland marine terminals are located between the former OARB and the San Francisco Bay. An aerial photograph of the former OARB from 2002 is shown in Figure 3.

The Site is located on the former OARB. The former OARB is bounded to the north by the East Bay Municipal Utility District sewage treatment plant, to the east by railroad tracks and the I-880 freeway, to the south by the former Fleet and Industrial Supply Center Oakland (now owned by the Port of Oakland and operated as marine terminals, a rail facility, and a park), and to the west by Port of Oakland marine terminals.

3.1.1 Parcel 18

Parcel 18 is located along the western central boundary of the former OARB and is 1.682 acres. Parcel 18 was reassigned to the USAR in 1997 (see Figure 2). Appendix A includes a survey map of Parcel 18 (labeled on the map as Building 762 Parcel).

Parcel 18 currently contains Building 762 (Figure 4). Building 762 is leased from the 63D Regional Readiness Command (“RRC”) to the Veterans Administration (“VA”) for mental health rehabilitation (Oakland VA Mental Health Program).

One pole-mounted transformer is located at the northeastern corner of Building 762. This transformer was installed in 1995 (Baseline, 2003) and is labeled as containing less than 1 ppm polychlorinated biphenyls (“PCBs”).

There is a 15-inch storm drain north of Building 762 in 14th Street carrying stormwater from the southern portion of 14th Street westerly to Maritime Street and which may be located on this parcel. Two catch basins are located along the western boundary and are connected to the 15- inch storm drain. A 10-inch sanitary sewer serving Building 762 is located east of the building and carries flows south along Midway Street.

Parcel 18 is bordered by Parcel 16 to the north, Parcel 19 to the east, Parcel 20 to the south, and Maritime Street and Port marine terminals to the west.

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 3.1.2 Subparcel 19

Parcel 19 consists of 11.4 acres in the east-central portion of the former OARB (see Figure 2). About 3.94 acres of the parcel (“Subparcel 19”) in the southwestern portion of Parcel 19 were reassigned to the USAR in 1998. Appendix A includes a survey map of Subparcel 19 (labeled on the map as the northern portion of the Building 780 Parcel)

The USAR portion of Parcel 19 is partially paved and contains Building 780 and a grass field (Figure 5). Building 780 is currently occupied by the Oakland VA Mental Health Program, and the 63D RRC's medical unit (352D Combat Support Hospital).

The Preliminary Assessment/Site Investigation (“PA/SI”) (Kleinfelder, 1998a) identified a 550- gallon aboveground storage tank (“AST”) east of Building 780. According to a field inspection on 21 July 2003 by Mr. Roger Caswell (Caswell, 2003) this AST is a 350-gallon empty diesel tank formerly servicing a generator. There was no evidence of releases near the AST during the field inspection.

There are three pad-mounted transformers on the south side of Building 780 inside a vault within the building on a concrete pad. These transformers have been tested for PCBs by the Army (MTMCWA, 1998). There were no PCBs detected above the laboratory reporting limits.

Storm sewers are located along the north, south, and western portions of Building 780. The railroad tracks east of Parcel 19 do not drain into these storm drains. The stormwater is conveyed westward to Maritime Street for ultimate disposal to the Bay. Sanitary sewers are located south and west of Building 780.

Subparcel 19 is bordered by Parcel 19 to the north, Parcel 21 to the east and south, and Parcel 20 to the west.

3.1.3 Subparcel 21

Parcel 21 consists of about 14.8 acres along the central southeastern boundary of the former OARB (see Figure 2). About 1.14 acres of the northwestern portion of the parcel (“Subparcel 21”) were reassigned to the USAR in 1997. A survey map of the subparcel is included in Appendix A (labeled on the map as the southern portion of the Building 780 Parcel).

Subparcel 21 is currently occupied by tennis courts (Building 778) built in 1974 and a grass field (Figure 6). Storm drains are located north, south, and west of Building 778. There are no sanitary sewers servicing this Subparcel. Adjacent catch basins were cleaned in conjunction with 400 catch basins cleaned at the former OARB (Foster Wheeler, 1998). The debris from these two catch basins was combined with the debris from all other catch basins; the debris was sampled and disposed of as non-Resource Conservation and Recovery Act (“RCRA”) waste. During cleaning of the catch basins, the pipes leading into the catch basins were inspected to determine their integrity.

There are no reported ASTs on Subparcel 21. There have been no radon, radiological, asbestos, lead-based paint or PCB evaluations performed, since the tennis courts are not a building and

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 there are no transformers on this Subparcel. It is possible that the asphaltic coating for the tennis courts contains PCBs, mercury, or asbestos (SCA, 2003); intrusive testing (coring) was not conducted.

Subparcel 21 is bordered by Subparcel 19 to the north, Parcel 21 to the east and south, and Parcel 20 to the west.

3.2 SITE GEOLOGY

Much of the area encompassing the Former OARB – EDC Area was natural tidal marsh or shallow open water before 1916 (Kleinfelder, 1998a). Filling occurred in subsequent years to construct land for manufacturing buildings that predate the former OARB and to create the former OARB. The soil encountered beneath the Site generally consists of silty to clayey gravel and sandy clay from the ground surface to a depth of approximately 6 feet below ground surface (“bgs”) (Industrial Compliance, 1993; EKI, 2003). The gravel and clay in the upper 6 feet is most likely fill imported by the Army during construction of the former OARB in 1941 and 1942 that was used to cover the former mud flats on the margin of the San Francisco Bay. The soils below 6 feet bgs generally consist of a gray to brown sand unit, locally known as bay sand, interbedded with a highly organic, dark gray to black clay, locally known as bay mud (Industrial Compliance, 1993).

3.3 SITE HYDROGEOLOGY

The Site is located approximately 0.5 miles east of the San Francisco Bay. Groundwater is generally encountered at depths ranging from 4 to 7 feet bgs (Industrial Compliance, 1993; EKI, 2003). Groundwater flow direction is expected to be generally toward San Francisco Bay, but may be affected locally by heterogeneous conditions and tidal influence. The local hydraulic gradient, as measured in August 1993 by consultants for Southern Pacific Transportation Company (“SPTCo”), was approximately 0.003 feet per foot in the southerly direction (Industrial Compliance, 1993).

Groundwater occurs in the artificial fill and in the Merritt Sand. Shallow groundwater in the artificial fill is generally encountered at depths of 4 to 13 feet bgs under unconfined conditions in the former OARB. Subsurface investigations performed at Parcels 18 and 19, as part of the PA/SI (Kleinfelder, 1998a) identified groundwater occurring at depths of 7 and 8 feet bgs. Groundwater in the Merritt Sand is locally confined or semi-confined with water levels generally below the groundwater levels in the shallow artificial fill. Groundwater discharges to the Oakland Outer Harbor.

Beginning at a depth of approximately 15 feet bgs, a sequence of clay on the order of 10 feet thick, referred to as Young Bay Mud, underlies the shallow water-bearing zone at the former OARB (IT, 2000b). The Young Bay Mud is not very permeable. The U.S. Army Corps of Engineers and Port (2000) stated in the Environmental Impact Report for proposed dredging of Oakland Harbor that the Young Bay Mud is an aquitard with a low permeability of 1 x 10-7 centimeters per second (“cm/s”). The Young Bay Mud restricts downward movement of groundwater to the next deeper water-bearing zone that is located at a depth of approximately 25 feet bgs. This deeper water-bearing zone is referred to as the Merritt Sand, which is the 3-3

3.3.1 Groundwater Quality

As discussed in more detail in the RAP / RMP prepared for the Former OARB – EDC Area, groundwater at the former OARB in both the shallow water-bearing zone and Merritt Sand is of poor quality due to the proximity to San Francisco Bay. The Regional Water Quality Control Board, San Francisco Bay Region (“RWQCB”) recognizes the poor quality of groundwater near the former OARB and has proposed a formal determination that groundwater along the Oakland shoreline, including the former OARB, cannot be used for drinking water supply (RWQCB, 1999; 2000).

3.3.2 Potential for Contaminant Migration to San Francisco Bay Via Groundwater

COCs in groundwater, if present, are most likely not migrating to San Francisco Bay because the groundwater velocity at the former OARB is low compared with the rate of absorption and degradation mechanisms (Industrial Compliance, 1993). Seawalls constructed along portions of the Port harbor facilities affect movement of groundwater and serve as barriers to lateral groundwater flow, and tidal influence studies indicate that the actual exchange of water from the shallow water-bearing zone and San Francisco Bay is minimal (Industrial Compliance, 1993).

Although the movement of contaminants in groundwater through the shallow water-bearing zone appears restricted and subject to natural attenuation, it is possible that groundwater migrates to San Francisco Bay through the sand or gravel bedding that surrounds storm drains or through storm drain piping.

Based on the available information reviewed by Vernadero Group, Inc., no known inspections of the storm drain system on Parcel 18 and Subparcels 19 and 21 have been conducted. However, storm drain piping on the former OARB – EDC property is documented to have breaks and cracks, and it is reasonable to assume that the storm drain system on the Site may be similarly compromised.

Storm drain piping at the former OARB is often situated in the saturated zone, and groundwater may enter the cracked or otherwise breached storm drain piping. However, groundwater from the Site that may enter the storm drains is not likely to be contaminated.

3.4 SITE NATURAL RESOURCES

Two Natural Resources Evaluations (“NREs”) were conducted by the USAR on 23 September 2002, and 24 September 2002 to document available natural resources at the Site (see USAR 2002a,b).

Grass and landscape plants dominate the Site. Landscaping surrounds Building 780 on Subparcel 19 and Building 762 on Parcel 18. Landscape plants include eucalyptus (Eucalyptus sp.), pine (Pinus sp.), periwinkle (Vinca sp.), ivy (Hedera sp.), bougainvillea (Bougainvillea sp.), rosemary (Rosmarinus officinalis), iceplant (Carpobrotus sp), lily-of-the valley (Agapanthus sp.), oleander

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 (Nerium oleander), and lantana (Lantana sp.) (USAR 2002a,b). There is a large expanse of lawn to the south of Building 780 extending around to the south of Building 778 (tennis courts). There is also an area of lawn to the east of Building 780. There are two strips of dirt along the south- central fence line and along the north-central fence line near Building 780 with a few herbaceous plants growing in these areas. There are essentially no other areas of bare ground or other non- landscaped areas on the Site.

A total of 33 federal and state sensitive species have been recorded within a few miles of the three subject parcels (CNDDB, 2004) or in the Oakland West U.S. Geological Survey 7.5 minute quad map (USFWS, 2002). There is essentially no habitat on the Site to support any of these species (USAR 2002a,b).

3.5 SITE USE HISTORY

Much of the former OARB, including the Site, was natural tidal marsh or open water before 1916. During the first half of the 1900s, dredged sand and imported soil were placed to create the land surface. The Army acquired the land in 1941, and provided additional fill in most portions of the former OARB, including the Site, to achieve the final grade. The Site was then developed into OARB. The Site was developed in the 1940s for residential barracks, mess halls, recreation and storage, and a loading dock. Several phases of demolition and site redevelopment have occurred at the Site.

3.5.1 Parcel 18

Building 761 was the only structure formerly located in Parcel 18 from 1942 to 1963; the building historically housed a chlorinator for drinking water (Baseline, 2003). The chlorinator included a sump; the location of the sump is unknown, but would likely be within the 60-square foot building. The chlorinator was a Wallace and Tiernan, model E5851. According to Wallace and Tiernan (Baseline, 2003), the chlorinators installed by Wallace and Tiernan for the Army during World War II were typically gas-fed (Baseline, 2003).

Building 762 was used as the Army-Navy medical clinic when constructed in 1965. Table 1 provides information on the demolished buildings, including Building 761 in this parcel.

There have been no known oil/water separators, ASTs, or USTs on this Parcel (Baseline, 2003).

3.5.2 Subparcel 19

Building 780 was formerly used as a barracks for enlisted men. The property card for Building 780 indicates that a can washer and sterilizer area were constructed outside the mess area of the building in 1958 (on a four-inch concrete slab); that area was not deemed a potential source area, thus no sampling was conducted by the Army as part of the PA/SI (Kleinfelder, 1998a). A grease trap is located near the southeast corner of Building 780 (Baseline, 2003).

Two USTs were formerly located in Subparcel 19: UST-16 and UST-780. UST 16 was a 6,000- gallon fuel oil tank removed in 1990 (Baseline, 2003). The RWQCB granted case closure in

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 1997. UST-780 was a 1,000-gallon fuel oil tank removed after 1954 (Table 2), reportedly following installation of UST-722 and UST-723 in Parcel 21 (IT Corporation, 2002).

Eight buildings were formerly located on Subparcel 19. Property cards for former Buildings 723 and 733 indicate oil use for building heat and hot water heat, respectively (Baseline, 2003). All former buildings and their uses on this Subparcel are listed in Table 1. The eight demolished buildings were used for barracks, mess halls, recreation and storage, and a loading dock.

3.5.3 Subparcel 21

Buildings 721, 722, and 728 were formerly located in Subparcel 21 and used for barracks (Table 1) while former Buildings 725 and 726 were used as mess halls. These structures were removed and replaced by tennis courts (referred to as Building 778); the time of demolition of the former buildings is not known precisely.

Six USTs are reported to have been located in Subparcel 21 (IT Corporation, 2002). IT Corporation (2002) made the following determinations regarding these USTs:

o Tank E (1,000 gallons, unknown fuel) was supposedly abandoned in-place in 1972. Appears to be the same as UST-722. No further investigation required.

o UST-721 may not have existed. No further investigation required.

o UST-722 (unknown size and contents) was the same as Tank E; i.e., there was only one UST. No further investigation required.

o UST-723 (1,000 gallons oil) was removed after 1954. No further investigation required.

o UST-742 (1,000 gallons fuel oil); no record of removal. No further investigation required (see discussion in Section 4.3, below).

o UST-743 (1,000 gallons fuel oil); no record of removal. No further investigation required (see discussion in Section 4.3, below).

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The Site use history and descriptions of the nature and extent of potential chemical impacts to soil and groundwater at the Site are based upon the results of record reviews, and previous remedial activities conducted. In particular, these findings are based on the DTSC-approved EBS/PA for Parcel 18 and Portions of Parcels 19 and 21 prepared by Baseline Environmental Consultants (2003). A copy of the DTSC acceptance letter and other related official correspondence are provided in Appendix B. Identified investigations and remediation activities for the Site are summarized below.

4.1 PARCEL 18

The Army-Navy Medical Clinic operated an x-ray photo processing laboratory in Building 762. X-ray photo processing waste, in the form of silver, was reportedly washed down the sanitary sewer in the past. This practice was reportedly discontinued and the waste was collected for processing. Medical and infectious waste generated by the clinic was picked up once a week by an outside contractor (Kleinfelder, 1998a). The PA/SI (Kleinfelder, 1998a) recommended soil sampling for silver along the sewer line alignment from Building 762. Four soil samples were collected from two locations from 3 to 7.5 feet bgs and analyzed for silver; no silver was detected above the laboratory reporting limits of 1 milligram per kilogram (“mg/kg”).

The Army conducted an asbestos survey of Building 762 (U.S. Army Engineer District, Sacramento, 1999). The results of the survey indicated that the floor tiles throughout the building contained asbestos, ranging from two to six percent and that the laboratory counter tops also contained asbestos. The potential exposure to asbestos is minimal because it is not friable; therefore resurveying or abatement is not recommended until demolition (Baseline, 2003).

A lead-based paint survey was conducted by the Army in 1997 at Building 762. The survey was conducted using an x-ray fluorescent spectrum analyzer (“XRF”), which penetrates through all layers of paint to the substrate. The results of the survey indicated that no suspect paint was present (U.S. Army Corps of Engineers, 1997).

The Army has removed four transformers at Building 762 (MTMCWA, 1997). Two of the transformers had PCB-containing fluids at 3 and 35 milligram per liter (“mg/L”), respectively, while the remaining two transformers did not contain PCBs. During a 1996 site inspection (Foster Wheeler, 1996), no soil stains were identified on Parcel 18. Army protocol for visual inspections includes inspection of the ground near and under transformers (Caswell, 2003).

Storm drain catch basins have been cleaned out regularly at the former OARB. In 1998, the two catch basins at Parcel 18 were cleaned in conjunction with 400 catch basins cleaned at the former OARB (Foster Wheeler, 1998). The debris from these two catch basins was combined with the debris from all other catch basins; the debris was sampled and disposed of as non-RCRA waste (Baseline, 2003). During cleaning of the catch basins, the pipes leading into the catch basins were inspected to determine their integrity (Baseline, 2003).

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 A radon survey was conducted in 1989 of Building 762 (Foster Wheeler, 1996). All levels detected (up to 0.6 Pico curie per liter) were below action levels and the Army determined that no further testing was to be conducted (Foster Wheeler, 1996). Sampling results were below 4 Pico curies/liter. The Army determined that such levels were below action levels, and no further testing was required (Baseline, 2003).

The Army conducted an Industrial Radiation Historical Data Review of Building 762 in 1997. The building had a General Electric Model MST 625-II medical x-ray system; no radioactive materials were used for medical diagnostic procedures (MTMCWA, 1997).

Radiation-containing materials were shipped via former OARB facilities. Portions of Buildings 161, 806, and 807 were used as storage areas for the shipments. None of the existing or demolished buildings on Parcel 18 were used for storage of radiation-containing materials (Foster Wheeler, 1996).

4.2 SUBPARCEL 19

The PA/SI (Kleinfelder, 1998a) documented soil and groundwater sampling near the grease trap near the southeastern portion of Building 780 near the sanitary sewer. Two soil samples were collected from one location and one grab groundwater sample was also collected; the soil samples were collected from 3.5 to 6 feet bgs. The samples were analyzed for Total Petroleum Hydrocarbons (“TPH”) as diesel and motor oil, Volatile Organic Compounds (“VOCs”), and metals. In addition, two additional soil samples were collected from depths of 2.5 and 15.5 feet; those samples were only analyzed for metals. No VOCs were identified in the soil or grab groundwater samples above the laboratory reporting limit. Only one sample contained TPH (460 mg/kg) above the laboratory reporting limit but less than the TPH Remediation Goal (Baseline 2003). The metal concentrations were all below the ambient former OARB concentrations (IT Corporation, 2000a).

A soil and groundwater investigation was conducted by the Army (SCS Engineers, 1997) after removal of UST 16. The soil and groundwater investigation did not reveal soil and/or groundwater concentrations above laboratory reporting limits and/or regulatory thresholds, and UST 16 received closure from the RWQCB in 1997.

No subsurface investigations have been conducted for the former UST-780 beneath Building 780. A geophysical investigation was performed in 1993 near UST-780 (Johnson, 1993); no anomaly indicating the presence of a UST was identified (Baseline, 2003).

The Army conducted an asbestos survey of Building 780 (U.S. Army Engineer District, Sacramento, 1999). The results of the survey indicated that all vinyl floor tiles, including those under the carpet, contained asbestos, ranging from three to nine percent. The potential exposure to asbestos is minimal because it is not friable; therefore, resurveying or abatement was not recommended until demolition (Baseline, 2003).

A lead-based paint survey was conducted by the Army in 1997 at Building 780. The survey was conducted using an XRF, which penetrates through all layers of paint to the substrate. The results of the survey indicated that the ladder leading to the roof tested positive for lead-based paint, 4-2

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 while all interior surfaces tested negative for lead-based paint (U.S. Army Engineer District, Sacramento, 1999). No sampling occurred in the shallow soil adjacent to the building.

The three pad-mounted transformers inside Building 780 have been tested for PCBs by the Army (MTMCWA, 1998) and PCBs were not found to be present above laboratory reporting limits. Storm drain catch basins are cleaned out regularly at the former OARB. In 1998, the catch basins at Subparcel 19 were cleaned in conjunction with 400 catch basins cleaned at the former OARB (Foster Wheeler, 1998). The debris from these catch basins was combined with the debris from all other catch basins; the debris was sampled and disposed of as non-RCRA waste (Baseline, 2003). During cleaning of the catch basins, the pipes leading into the catch basins were inspected to determine their integrity (Baseline, 2003).

An Industrial Radiation Historical Data Review was performed in 1997. There was no evidence of previous handling or storage of radioactive materials in or adjacent to Building 780 (MTMCWA, 1998). Radiation-containing materials were shipped via the former OARB facilities. Portions of Buildings 161, 806, and 807 were used as storage areas for the shipments. None of the existing or demolished buildings on Subparcel 19 were used for storage of radiation- containing materials (Foster Wheeler, 1996).

Radon surveys were conducted at the former OARB in 1989. In that survey, the Army tested buildings 1, 6, 70, 647, 650, 655, 690, and 762. The Army determined that all levels detected (up to 0.6 Pico curie per liter) were below action levels and that no further testing was to be conducted (Foster Wheeler, 1996). Therefore, no survey was conducted for Building 780.

4.3 SUBPARCEL 21

Jacobs Engineering Group (1986) identified a UST, Tank E, as being a 1,000-gallon fuel oil tank near Building 778 (tennis courts). The UST was supposedly abandoned in-place in 1972. The Army performed geophysical investigations in 1993 to locate this 1,000-gallon fuel oil UST (Johnson, 1993). The UST was not located. A soil and groundwater investigation was undertaken by the Army to determine the chemical quality of subsurface materials in the area that was thought to contain Tank E (refer to Appendix C-4 for sampling locations). No significant contamination was identified (up to 38.3 mg/kg of diesel in soil and up to 1 µg/L of toluene in a grab groundwater sample) and the UST site was closed by the RWQCB in 1997. No further investigation was recommended by the Army Corps of Engineers (IT Corporation, 2002); the UST is believed (IT Corporation, 2002) to be the same as UST-722.

A geophysical investigation was performed in 2002 on behalf of the Corps of Engineers (IT Corporation, 2002) at the UST-722 location. In addition, soil and groundwater samples were collected from two locations within the area of the suspected UST-722 location (refer to Appendix C-4 for sampling locations); the soil and groundwater samples were analyzed for extractable hydrocarbons and VOCs. No geophysical anomaly was identified and no compounds were detected in the soil samples above the laboratory reporting limit; grab groundwater samples contained up to 0.20 mg/L of diesel, which is below the Army cleanup goal for diesel in groundwater (9.6 mg/L) (IT Corporation, 2000a). 1,1,1-trichloroethane (which is not a Chemical of Concern at the former OARB and has no remediation goal) was identified at a concentration of 0.00028 mg/L. 4-3

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 The RWQCB has assembled risk-based environmental screening levels (“ESL”) for various organic and inorganic compounds (RWQCB, 2003). Compounds in soil and/or groundwater at concentrations below the ESLs are not considered a risk to human health or the environment. The ESL for 1,1,1-trichloroethane in groundwater, for sites where groundwater is not considered a potential source of drinking water, is 0.062 mg/L, or about two orders or magnitude greater than the concentration identified in the grab groundwater sample from the UST-722 location.

The U.S. Environmental Protection Agency, Region 9’s preliminary remediation goal (“PRG”) for 1,1,1-trichloroethane for tap water is 3.2 mg/L. The grab groundwater concentration is about four orders of magnitude below the PRG. The presence of 1,1,1-trichloroethane in the grab groundwater sample is not an environmental concern because it is orders or magnitudes below ESLs and PRGs. Furthermore, grab groundwater samples collected at the grease trap in Subparcel 19 (see Appendix C-4 for sampling locations) did not contain 1,1,1-trichloroethane above the laboratory reporting limit (IT Corporation, 2000a). IT Corporation (2002) indicates that UST-723 supplied fuel for Building 721; therefore, UST-721 may not have existed.

The geophysical investigation conducted in 2002 (IT Corporation, 2002) also included the locations for UST-742 and UST-743. No geophysical anomalies were identified. Two soil borings were installed at each of the UST locations and one soil sample was collected from each soil boring at a depth of 3.5 feet bgs; one grab groundwater sample was also collected from each boring (refer to Appendix C-4 for sampling locations). The samples were analyzed for TPH diesel and motor oil and VOCs. At UST-742, 0.003 mg/L of diesel was identified and at UST- 743 up to 0.019 mg/L of diesel was identified in the grab groundwater samples. The soil samples from both locations had up to 5 mg/kg of diesel. All the identified concentrations were below Army cleanup goals.

4.4 SUMMARY OF CHEMICAL RELEASE SITES AND LOCATIONS

As described in the DTSC-approved EBS/PA (Baseline, 2003), areas where COCs may have impacted soil or groundwater include the former x-ray photo processing laboratory in Building 762, lead-affected shallow soils adjacent to existing or demolished buildings, sampling of soil and groundwater near the grease trap near the southeastern portion of Building 780, soil and groundwater investigations as part of former UST closures, and storm drains and sanitary sewers. These areas are described in the EBS/PA. Based on the DTSC-approved EBS/PA and on review of available historic information, no locations that would be considered RAP Sites or RMP Locations by DTSC have been identified at the Site (Baseline, 2003).

In the event that the nature and extent of encountered COC releases, if any, are found to differ significantly from the conditions described in this RAP Amendment and Baseline’s EBS/PA, the appropriateness of selected remedial actions adopted for the Site will be re-evaluated in consultation with DTSC. If the response measures contained in this RAP Amendment are judged to be inappropriate for any newly identified COC release locations, the Site owner will consult with DTSC to determine appropriate response actions. Newly identified COC releases would be identified through visual or olfactory observations. Additionally, although no additional soil or groundwater sampling is required, chemical data may be collected by the Site owner as may be necessary for off-site disposal purposes, or as directed by DTSC. If such new data indicate that

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 COCs at concentrations greater than Remediation Goals are present in soil or groundwater at the Site, then the Site owner will consult with DTSC to determine appropriate response actions.

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The DTSC-approved EBS/PA was evaluated to identify COCs for the Site. All chemicals detected above laboratory reporting limits on the Site that currently posses Remediation Goals as discussed in Section 7 of this RAP Amendment were retained as COCs. Table 3 provides available historic environmental sampling data for the Site. No new COCs were identified for the Site that were not already identified on the Former OARB - EDC Area.

5-1

The purpose of this RAP Amendment is to adopt the technology evaluations, remedial alternatives, and selected remedies developed in the RAP to the Site. The remedial alternatives and selected remedies developed in the RAP are protective of human health and the environment, cost-effective, and consistent with planned reuse of the Site. The process of developing remedial alternatives and remedies is described in Sections 8, 9, and 10 of the RAP (EKI, 2002a).

Part of the process in developing remedial alternatives and protocols includes an evaluation of Applicable or Relevant and Appropriate Requirements (“ARARs”), as was done in the RAP (EKI, 2002a). The ARARs that apply to the Former OARB – EDC Area, as evaluated in Section 6 of the DTSC-approved RAP, also apply to the Site. Table 6-1 of the DTSC-approved RAP summarizes the ARARs relevant to the former OARB and to the Site (EKI, 2002a). In addition, the requirement for the land use covenant, California Code of Regulations, Title 22, section 67391.1, will be satisfied by the execution and recording of the Covenant in conjunction with transfer of the Site.

6-1

The RAOs and risk-based remediation goals established for the Former OARB – EDC Area in the RAP are adopted for the Site. These RAOs and remediation goals were developed with consideration of potentially complete exposure pathways, as well as chemical-specific ARARs. The RAOs for soil and groundwater are described in detail in Section 7 of the RAP (EKI, 2002a). Risk-based remediation goals to achieve the specified RAOs were also developed in the RAP. The calculations of the risk-based remediation goals, including equations used and input parameters, are described in Sections 7.3 to 7.5 of the RAP (EKI, 2002a). Remediation goals for all COCs at the former OARB including the Site are listed in Table 4.

Remediation goals for most COCs identified at the Site are risk-based remediation goals that are the lowest calculated values of the non-carcinogenic or carcinogenic risk goal for each COC that are protective of all potentially exposed populations as identified previously in the RAP. The individual remediation goals in Table 4 represent the maximum allowable concentrations for the respective COCs, as described in the RAP.

7-1

Following Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) methodologies in U.S. Environmental Protection Agency (1998) Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, a range of remedial technologies and alternatives were identified and screened, pursuant to NCP regulation, 40 C.F.R. part 300.430(e)(7), against the following three criteria: effectiveness, implementability, and cost. Once the remedial alternatives were screened, a detailed analysis consisting of an assessment of individual alternatives against each of the nine NCP evaluation criteria was performed, as described in detail in Section 10 of the RAP (EKI, 2002a). Selected remedial alternatives are discussed below.

8.1 IDENTIFICATION AND SCREENING OF ALTERNATIVES

8.1.1 No Action Alternative

• No action for soil and groundwater: The no action alternative for soil and groundwater is not retained for further analysis because it will not protect human health and the environment and maintain protection over time.

8.1.2 Action Alternatives

• Conduct a Remedial Investigation and prepare a separate RAP including an evaluation of its own RAOs, remediation goals, and remedial alternatives: This alternative is not retained for further analysis because the contiguous property was evaluated in a DTSC-approved RAP and the contiguous property shares similar past uses as well as types and concentrations of potential COCs with the Site. The DTSC-approved RAP evaluated RAOs, remediation goals, and remedial alternatives in a site-specific, robust manner that is applicable to the Site. Amending the DTSC-approved RAP is convenient and efficient for selecting remedies for the Site that are protective of human health and the environment due to the similarities of past land uses and planned future land uses between the Site and the Former OARB – EDC Area.

• Amend the existing DTSC-approved RAP and evaluate the remedial alternatives retained for detailed analysis in the RAP: This alternative is retained for further detailed analysis.

8.2 DETAILED ANALYSIS OF ALTERNATIVES

The following individual remedial alternatives were retained from the original, DTSC-approved RAP for a detailed analysis. For this RAP Amendment, an analysis was performed consisting of an assessment against each of the nine NCP evaluation criteria, as described in detail in Section 10 of the RAP (EKI, 2002a). The following is a summary of the results of the detailed analysis:

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 • Excavate, conduct ex-situ immobilization, dispose of soil off-site, and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in soil and groundwater at the Site are less than Remediation Goals.

• Excavate and dispose of soil off-site and perform in-situ treatment of shallow waterbearing zone and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in soil and groundwater at the Site are less than Remediation Goals.

• Excavate and dispose of soil off-site, and monitor groundwater as needed: This alternative is retained but not selected because identified COCs concentrations in soil and groundwater at the Site are less than Remediation Goals.

• Install vapor barrier with sub-slab depressurization system beneath new buildings and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in groundwater at the Site are less than Remediation Goals.

• Install vapor barrier beneath new buildings and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in groundwater at the Site are less than Remediation Goals.

• Perform in-situ bioremediation in shallow water-bearing zone and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in groundwater at the Site are less than Remediation Goals.

• Perform chemical oxidation / reduction in shallow water-bearing zone and monitor groundwater: This alternative is retained but not selected because identified COCs concentrations in groundwater at the Site are less than Remediation Goals.

• Monitored natural attenuation: This alternative is retained but not selected because identified COCs concentrations in groundwater at the Site are less than Remediation Goals.

• Institutional controls: This is the selected alternative for the Site because, although no COCs have been identified at concentrations in soil and groundwater at the Site above Remediation Goals, the Remediation Goals are not suitable for unrestricted land use. The Remediation Goals were developed considering a set of potentially complete exposure pathways recognizing that all remedial actions would include institutional controls alone to limit land use and groundwater extraction and use, or in combination with engineering controls, to ensure that exposure of Site occupants and workers under planned commercial and industrial land uses does not take place above the risk-based objectives, as established in the RAP (EKI, 2002a).

8-2

The proposed remedy for the contamination at the Site is amending the existing DTSC-approved RAP to include the Site in the RAP, and then selecting an appropriate remedy from among those identified in the DTSC-approved RAP. The appropriate remedy proposed for the Site is institutional controls, which would be promulgated in a Covenant to Restrict Use of Property. The institutional controls would include the following environmental restrictions and an Implementation and Enforcement Plan:

8.3.1 Environmental Restrictions

8.3.2 Implementation and Enforcement Plan

All current and successive property owners shall comply with the Implementation and Enforcement Plan, which includes the following requirements:

• DTSC shall be provided with reasonable right of entry and access to the property for periodic inspections to ensure compliance with the Covenant.

8.3.3 Justification for the Selected Remedy

The remaining detected maximum COC concentrations in soil and groundwater are below the Remediation Goals established for industrial / commercial land use; however, remaining detected concentrations may not be protective for unrestricted land use by sensitive populations. By restricting sensitive land uses, prohibiting extraction or use of groundwater, and requiring an Implementation and Enforcement Plan, the institutional controls selected in this RAP Amendment will be protective of human health and the environment under an industrial / commercial land use scenario.

8-3

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 On the basis of consultation with DTSC, implementation of the RMP (EKI, 2002b), which was appended to the DTSC-approved RAP, is not part of the selected remedy. However, in the event that the nature and extent of encountered COC releases at the Site are found to differ significantly from the conditions described in this RAP Amendment and in Baseline’s 2003 EBS/PA, the appropriateness of selected remedial alternatives will be reevaluated by the Site owner in consultation with DTSC. If the response measures contained in the DTSC-approved RAP are believed to be inappropriate for newly identified releases, the Site owner will consult with DTSC to determine appropriate actions.

8-4

Once DTSC approves this RAP Amendment, the USAR will implement the remedy selected in this RAP Amendment through execution and recordation of the Covenant identified in Section 8. The Covenant will be executed and recorded as part of the transfer of the Site. It is intended that the selected remedy, institutional controls in the form of the Covenant, be the final remedy for the Site. Upon implementation of the final remedy, DTSC will determine whether all necessary remediation at the Site has been completed. Once that determination is made, DTSC will issue a letter to the USAR certifying that the USAR has completed all remediation on the Site necessary to protect human health and the environment. At that time, DTSC anticipates being able to concur with the FOST. The USAR uses the FOST to document that all required remediation or other remedies necessary to protect human health and the environment have been implemented prior to transfer.

The Covenant will be recorded in the Alameda County Assessor’s Office, run with the land, bind all owners of the land, their heirs, successors, and assignees, and the agents, employees, lessees, or renters of the owners, heirs, successors, and assignees. The Covenant will continue in perpetuity unless modified or terminated in accordance with applicable law.

9-1

On the basis of available information presented herein, there are no identified areas requiring additional active remediation on the Site. However, the imposition of institutional controls consisting of the land and groundwater use restrictions described in Section 8 is the selected remedial action for the Site. As required by the California Health and Safety Code section 25356.1(e), which calls for a nonbinding preliminary allocation of responsibility, this section finds that the USAR is responsible for putting these institutional controls in place.

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 11.0 REFERENCES

Baseline Environmental Consultants. 2003. Environmental Baseline Survey/ Preliminary Assessment U.S. Army Reserve Parcel 18 And Portions of Parcels 7, 19, and 21, Former Oakland Army Base, Oakland, California, December.

Caswell, Roger. 2003. OARB Base Environmental Coordinator, personal communication with Diane Heinze, Port of Oakland, EH & SC, July.

CNDDB (California Natural Diversity Data Base). 2004. Rare Find 2, Version 2.1.2. California Department of Fish and Game, Sacramento California.

EKI (Erler and Kalinowski, Inc). 2002a. Final Remedial Action Plan, Oakland Army Base, Oakland, California, 27 September.

EKI (Erler and Kalinowski, Inc). 2002b. Final Risk Management Plan, Oakland Army Base, Oakland, California (Appendix E to Final RAP), 27 September.

EKI (Erler and Kalinowski, Inc). 2003. Phase II Investigation Report, Former Parcels 6 and 7, Former Oakland Army Base, Oakland, California, 12 September.

Foster Wheeler. 1998. Contract DACA05-97-D-0013, Task Order 0021 Final Catch Basin Cleaning Report, 16 October.

Foster Wheeler. 1996. Basewide Environmental Baseline Survey for Oakland Army Base, Oakland, California, prepared for U.S. Army Corps of Engineers, Sacramento District, September.

ICF Kaiser. 1999. Draft Pipeline Investigation Report, Storm Drain and Sanitary Pipeline Systems, Oakland Army Base, September.

Industrial Compliance. 1993. Supplemental Soil and Ground Water Investigation Report, Southern Pacific Transportation Company, Oakland Army Base, Oakland, California, 16 June.

IT Corporation. 2002. Draft Phase II Supplemental Investigation Report Oakland Army Base, Oakland, California, for Sacramento TERC II, 24 June.

IT Corporation. 2000a. Corrective Action Plan for Petroleum Tank Sites for the Oakland Army Base, Oakland, California, 25 February.

IT Corporation. 2000b. Technical Memorandum for Evaluation of Beneficial Uses of Groundwater, Oakland Army Base, Oakland, California. Revision C, 9 March.

Jacobs Engineering Group. 1986. Underground Fuel Storage Tanks Master Plan for Oakland Army Base Oakland California, December.

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Kleinfelder. 1998a. Final Report Basewide Preliminary Assessment/Site Inspection (PA/SI) Oakland Army Base Oakland California, 24 February.

Kleinfelder. 1998b. Basewide Hydrogeologic Study, Oakland Army Base, Oakland, California. Final Report, December.

MTMCWA (Military Traffic Management Command Western Area). 1998. Environmental Condition of Property, Building 780, Oakland Army Base, November.

MTMCWA (Military Traffic Management Command Western Area). 1997. Environmental Condition of Property, Building 762, Oakland Army Base, November.

Port (Port of Oakland). 2000. Oakland Harbor Navigation Improvement (-50 Foot) Project, Final Environmental Impact Statement/Report, January.

RWQCB (Regional Water Quality Control Board). 2003. San Francisco Bay Region, Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater, Volume 1, Summary of Tier 1 Lookup Tables, July (Table B).

RWQCB (Regional Water Quality Control Board). 2000. Proposed Groundwater Amendments to the Water Quality Control Plan (Basin Plan). Final. Functional Equivalent Document, April.

RWQCB (Regional Water Quality Control Board). 1999. East Bay Plan Groundwater Basin Beneficial Use Evaluation Report, Alameda and Contra Costa Counties, CA. Groundwater Committee, June.

SCA. 2003. Summary Report Assessment of Polychlorinated Biphenyls (PCBs) in Ballasts and Mercury-Containing Fluorescent Lamps, West, Oakland Army Deport, Buildings 762 and 780, Oakland, California, for the Port of Oakland, September.

SCS Engineers. 1997. Underground Storage Tank Closure Reports for Tank Sites TK1, TK2, TK3, TK14, TK16, TK17, TK18, and TKN, Oakland Army Base, 11 April.

U.S. Army Corps of Engineers. 1997. Lead-Based Paint Oakland Army Base, October.

U.S. Army Engineer District, Sacramento. 1999. Annual Asbestos Survey, Oakland Army Base, October.

USAR (U.S. Army Reserve). 2002a. Natural Resources Evaluation - U.S. Army Reserve Center CA 125, Oakland USAR Center # 2. 23 September.

USAR (U.S. Army Reserve). 2002b. Natural Resources Evaluation - U.S. Army Reserve Center CA 036, Oakland Heroic War Dead USAR Center and AMSA 85 (G). 24 September.

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Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006 USEPA (U.S. Environmental Protection Agency). 1998. Guidance for Conducting Remedial Investigations and Feasibility Under CERCLA, Interim Final. Office of Solid Waste and Emergency Response. EPA 540/G-89/004. October.

USFWS (U.S. Fish and Wildlife Service). 2002. Jan C. Knight, Chief, Endangered Species Division, U.S. Fish and Wildlife Service, Sacramento Fish and Wildlife Office, Sacramento California, personnel communication with Michael Collins, Project Manager, Vernadero Consulting, Scottsdale, Arizona, Dated 20 May 2002.

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Subparcel 21

Regional Location

Feet [ Figure 1 0 1,000 2,000 3,000 4,000 Source: Baseline, 2004 Location of USAR Parcels [ Not to Scale

Figure 2 Parcel 18

Subparcel 19

Subparcel 21

Aerial Photograph

Feet [ Figure 3 0 500 1,000 1,500 Source: Baseline, 2004 Parcel 18 Building 762

Figure 4 Source: Baseline, 2004 Subparcel 19 Building 780

Figure 5

Table 3 Constituents of Concern in Soil and Groundwater

Sample Depth Feet Location Parcel Sample ID Type bgs Collection Date Constituent Concentration Source of Data 19 19SP104 Soil 3.0 and 6 June 1997 TPH - Diesel Fuel <1.2 mg/kg PA/SI Bldg 780 grease trap 19SP104 Grab gw 7 June 1997 TPH - Diesel Fuel <50 ug/1 PA/SI UST 16 19 SB-16A Soil May 1989 TPH - Diesel Fuel ND SCS April 1997 S-16B Soil May 1989 TPH - Diesel Fuel ND SCS April 1997 307-7 Soil S. Sidewall March 1990 TPH - Diesel Fuel 18 SCS April 1997 307-8 Soil N. Sidewall March 1990 TPH - Diesel Fuel 11 SCS April 1997 307-6 Soil Pit March 1990 TPH - Diesel Fuel 410 SCS April 1997 SB6 Soil 5 August 1991 TPH - Diesel Fuel <10 SCS April 1997 SB7 Soil 7 August 1991 TPH - Diesel Fuel <10 SCS April 1997 SB8 Soil 5.5 August 1991 TPH - Diesel Fuel <10 SCS April 1997 SB9 Soil 5.5 August 1991 TPH - Diesel Fuel <10 SCS April 1997 SB10 Soil 5.5 August 1991 TPH - Diesel Fuel <10 SCS April 1997 MW06 GW @SB6 September 1991 TPH - Diesel Fuel <500 SCS April 1997 April 1992 TPH - Diesel Fuel <50 SCS April 1997 Jaunuary 1993 TPH - Diesel Fuel 0.100 SCS April 1997 MW07 GW @SB7 September 1991 TPH - Diesel Fuel <500 SCS April 1997 MW08 GW @SB8 September 1991 TPH - Diesel Fuel <500 SCS April 1997 September 1992 TPH - Diesel Fuel <50 SCS April 1997 UST E 21 ? Soil 7 1989 TPH - Diesel Fuel ND SCS May 1997 SB-13 Soil 6 December 1996 TPH - Diesel Fuel 38.3 mg/kg SCS May 1997 SB-13 Grab gw 4.35 December 1996 TPH - Diesel Fuel <0.05 mg/1 SCS May 1997 SB-14 Soil 5.5 December 1996 TPH - Diesel Fuel <1 mg/kg SCS May 1997 SB-14 Grab gw 4.22 December 1996 TPH - Diesel Fuel <0.05 mg/1 SCS May 1997 SB-15 Soil 6 December 1996 TPH - Diesel Fuel <1 mg/kg SCS May 1997 SB-15 Grab gw 5.1 December 1996 TPH - Diesel Fuel <0.05 mg/1 SCS May 1997 <1 mg/kg (<1 mg/kg SB-16 Soil 6 December 1996 TPH - Diesel Fuel duplicate) SCS May 1997 <0.05 mg/1 (<0.05 SB-16 Grab gw 4.29 December 1996 TPH - Diesel Fuel mg/1 duplicate) SCS May 1997

UST 722 21 ITT722SO1 Soil 3.5-4 April 2002 TPH - Diesel Fuel <1.2 mg/kg IT Phase II ITT722SO1 Grab gw 5-10 April 2002 TPH - Diesel Fuel <0.09 mg/1 IT Phase II ITT722SO2 Soil 3.5-4 April 2002 TPH - Diesel Fuel <1.1 mg/kg IT Phase II 0.20 mg/1 (0.30 ITT722SO2 Grab gw 5-10 April 2002 TPH - Diesel Fuel mg/1 duplicate) IT Phase II UST 742 21 ITT742SO1 Soil 3.5-4 April 2002 TPH - Diesel Fuel 3 mg/kg IT Phase II ITT742SO1 Grab gw 5-10 April 2002 TPH - Diesel Fuel 0.044 mg/1 IT Phase II ITT742SO2 Soil 3.5-4 April 2002 TPH - Diesel Fuel 5 mg/kg IT Phase II ITT742SO2 Grab gw 5-10 April 2002 TPH - Diesel Fuel 0.015 mg/1 IT Phase II UST 743 21 ITT743SO1 Soil 3.5-4 April 2002 TPH - Diesel Fuel <0.73 mg/kg IT Phase II ITT743SO1 Grab gw 5-10 April 2002 TPH - Diesel Fuel 0.019 mg/1 IT Phase II ITT743SO2 Soil 3.5-4 April 2002 TPH - Diesel Fuel <0.73 mg/kg IT Phase II ITT743SO2 Grab gw 5-10 April 2002 TPH - Diesel Fuel 0.013 mg/1 IT Phase II

Amendment to Final Remedial Action Plan Oakland Army Base, Oakland, California for Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 04 December 2006

Appendix A – Survey Map of Properties to be Conveyed to the Port of Oakland INTENTIONAL BLANK PAGE

Appendix B – Correspondence

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Appendix C – Soil Sampling Locations INTENTIONAL BLANK PAGE

CHECKED BY: S. Walker Date: 9-12-97 Project Number 23-900018-A31

Appendix D – Responsiveness Summary INTENTIONAL BLANK PAGE

Department of Toxic Substances Control

Maureen F. Gorsen, Director Linda S. Adams 8800700 Cal Hein Cenz Avenueter Drive Arnold Schwarzenegger Secretary for Sacramento,Berkeley, Cal Californiaifornia 94 95710826-320-2721 0 Governor Environmental Pr otection

Responsiveness Summary

Amendment to Final Remedial Action Plan Oakland Army Base Oakland, California for Former Parcel 18 and Subparcels 19 and 21 Oakland United States Army Reserve Center #2

December 2006

The Department of Toxic Substances Control (DTSC) is making a decision on the Amendment to Final Remedial Action Plan, Oakland Army Base, Oakland, California, for Former Parcel 18 and Subparcels 19 and 21, Oakland United States Army Reserve Center #2 (RAP Amendment). Parcel 18 and Subparcels 19 and 21 were parts of the former Oakland Army Base. The United States Army Reserve is the current property owner. The draft RAP Amendment proposes institutional controls as the final remedy for the parcels.

DTSC provided a 30-day public comment period, and convened a public meeting on the draft RAP Amendment. DTSC opened the comment period on October 23, 2006, held a public meeting on November 9, 2006, and closed the comment period on November 21, 2006.

On October 23, 2006, DTSC mailed the RAP Amendment fact sheets to people on the project mailing list. The project mailing list consists of 418 addresses, which include recipients from the DTSC Mandatory Mailing List, elected and city officials, government agencies, community groups, former Oakland Army Base’s Restoration Advisory Board members, neighboring residences, and West Oakland Pilot Mailing List. The fact sheet includes a written Spanish statement that a Spanish speaking DTSC staff person is available to answer questions.

On October 23, 2006, DTSC published public notices as display advertisements on the Oakland Tribune and Oakland Post announcing the public comment period and inviting comments on the draft RAP Amendment. The public notice and fact sheet include 1

Printed on Recycled Paper written Spanish statements that a Spanish speaking DTSC staff person is available to answer questions.

DTSC placed copies of the draft RAP Amendment at three repositories: Oakland Main Library, West Oakland Public Library, and DTSC’s Berkeley Office. In addition, the draft RAP Amendment was available for download at DTSC’s website.

On November 9, 2006, DTSC held a public meeting at the West Oakland Multipurpose Senior Center. During the public meeting, DTSC presented the proposed remedy and offered opportunity for public inputs.

DTSC received neither verbal nor written comment on the draft RAP Amendment during the 30-day public comment period.