UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105

September 30, 2010

Guy Romine Army Environmental Command 19932 S.E. Foster Road Damascus, OR 97089

Re: U.S. EPA Review of MOTCO Draft Five-Year Review for Site 1 Landfill

Dear Mr. Romine:

The U.S. Environmental Protection Agency (U.S. EPA) appreciates the opportunity to receive and review the Department of the Army's (Army) document entitled, “Draft First Five- Year Review for Site 1 Tidal Area Landfill” (Five-Year Review) for Military Ocean Terminal Concord (MOTCO), dated September 22, 2010. The Five-Year Review was submitted pursuant to the November 20, 2009, Amended Federal Facilities Agreement for the Army portion of the Concord Naval Weapons Station Superfund Site.

Based on our review of the Five-Year Review, U.S. EPA concurs with the Army on the Protectiveness determination for the Site 1 remedy. The Protectiveness Statement indicates the following:

“Although the remedy is incomplete, there have been substantial improvements in protection to human health and the environment since the start of construction. The potential for direct exposure to landfill waste has been substantially reduced by the thick layer of fill which covers nearly the entire landfill. In addition, infiltration of rainwater has been reduced substantially over preconstruction conditions because the site is now sloped to drain and because it is now covered with compacted fill.

The remedy at the Site 1 Landfill is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.”

Additional information and recommendations are provided to improve the overall quality of the Five-Year Review and to address some long-term protectiveness issues (see Enclosure).

u.s. EPA looks forward to continued coordination with the Army on cleanup activities at MOTCO. If you have any questions concerning this matter, please contact Phillip Ramsey of my staff at (415) 972-3006.

Michael Montgomery Assistant Director Federal Facilities and Site Cleanup Branch

Enclosure cc: Ms Cynthia Burris, USACE Mr. Jim Pinasco, DTSC Mr. Alan Friedman, RWQCB

2 ENCLOSURE September 30, 2010

U.S. EPA Review of MOTCO Draft Five-Year Review for Site 1 Landfill

Based upon the U.S. Environmental Protection Agency (U.S. EPA) review of the Department of the Army’s (Army) “Draft First Five-Year Review for Site 1 Tidal Area Landfill” (Five-Year Review) for Military Ocean Terminal Concord (MOTCO), dated September 22, 2010, the following comments apply:

General Comment:

1. Issues, Recommendations, and Follow-Up Actions: The Five-Year review details issues, recommendations, and follow-up actions related to long-term protectiveness. Issues cited include: need for redesign of the Site 1 cap; development of an Explanation of Significant Difference (ESD) to document the design change; and, completion of the landfill remedy. From the three issues, the report identifies two recommendations and follow-up actions: complete the ESD; and complete the cap. While U.S. EPA does not have concerns with the specific issues, recommendations, and follow-up actions described, U.S. EPA requests that the Army expand the issues to include other aspects of the overall remedy for the Site 1 Landfill, including Groundwater and Land Use Controls (LUCs).

Groundwater: U.S. EPA requests that the Army acknowledge in the Five-Year Review that groundwater is an issue that potentially impacts the long-term protectiveness of the existing remedy for Site 1. The Recommendations and Follow-Up Actions should include that the Ar m y will conduct and complete the Groundwater Remedial Investigation/Feasibility Study for Site 1, as well as develop documents associated with remedy selection (i.e., Proposed Plan and Record of Decision or ROD) and implementation (Remedial Design/ Remedial Action). The schedule for these primary deliverables that is established in the Final July 2010 Site Management Plan, should also be included in the Five-Year Review.

LUCs: Similar to U.S. EPA’s concern with Site 1 Groundwater, U.S. EPA requests that the Army detail in the Five-Year Review the specific LUC requirements that exist pursuant to the 2004 ROD. The 2004 Site 1 ROD, Section 2.1, the Selected Remedy, indicates that, “[t]he Navy has selected Alternative 2 (soil cap, surface controls, institutional controls, landfill gas monitoring, and maintenance) as the preferred alternative…”. On page 52, the ROD provides the detailed description of this component of the remedy:

“Institutional controls to safeguard the integrity of the soil cap and associated monitoring systems. Institutional controls would prohibit construction of any habitable structures, or other land-disturbing activity into or onto the surface of the landfill or adjacent to the landfill, planting of vegetation that could threaten the integrity of the landfill cap, removal of or tampering with posted signs, irrigation of the surface of the landfill, and extraction of groundwater from beneath the landfill. The Navy will develop a LUC-RD as part of the post-closure maintenance and monitoring plan to ensure that institutional controls are maintained in the long-term.”

3

Based upon a review of the ROD and the LUC requirements, the Army is requested to review the N a v y ’ s Site 1 LUC-RD for specific LUC requirements and to determine if the existing L U C requirements are consistent with the 2003 DoD-EPA Guidance, “Principles and Procedures for Specifying, Monitoring, and Enforcing Land Use Controls…”. If the LUC requirements are not complete or inconsistent with guidance, the Army should identify it as an “Issue” and propose recommendations and follow-up actions.

Specific Comments:

1. Executive Summary, page ES-1: In the third paragraph, third sentence add, “fundamentally” to the statement “…that are considered significant but that do not fundamentally change the selected remedy.”

2. Section 1.0, Introduction: Text in the second paragraph indicates that “[i]mplementation of the remedy at the Site 1 Landfill has not been completed but is scheduled for completion in 2011.” This statement appears in conflict with the 2004 ROD remedy, which is, per the 2004 Site 1 ROD, a “soil cap, surface controls, institutional controls, landfill gas monitoring, and maintenance”. U.S. EPA recommends that the Army revise this statement to clarify what components of the remedy have not been implemented. While U.S. EPA understands that the landfill cap has not been completed, other aspects including leachate and landfill gas monitoring should now be implemented.

3. Section 1.0: Text in the third paragraph indicates, “[d]ata collected to date do not suggest that groundwater contamination is present that necessitates remedial action, although the assessment is ongoing.” As indicated in the General Comment above, U.S. EPA believes that groundwater is an ” issue” for the Site 1 Landfill that needs to be documented, along with Recommendations and Follow-Up Actions. Rather than providing generalizations regarding an ongoing RI, the Five-Year Review should document that groundwater is an issue and it will be addressed through the development of the RI/FS, Proposed Plan/ROD and RD/RA, which have been planned and scheduled in the Final 2010 SMP. This comment also applies to text in Section 3.4, History of Contamination, where the Army provides an unnecessary groundwater summary.

4. Section 4.1.2, Selected Remedy: The description of the landfill cap provided at the top of page 9 is not consistent with the 2004 Final Site 1 ROD. However, it is recommended that a detailed description of the current landfill cap (as modified by the 2008 ESD) be provided instead. The current cap design, is best presented (as a cross-section) in ESD, Drawing C-102.

5. Section 4.3, Design Changes to Reduce the Weight of the Cap: U.S. EPA found the first paragraph at the top of page 11 to be difficult to follow. Given that this proposed design change description is not an essential component of the Five-Year Review, U.S. EPA requests that that paragraph be deleted.

* * *

4

Draft

First Five-Year Review for Site 1 Tidal Area Landfill Military Ocean Terminal Concord Concord, California

September 30, 2010

Prepared for: U.S. Army Corps of Engineers Sacramento District Sacramento, California

Prepared by: Tetra Tech EM Inc. 1999 Harrison Street, Suite 500 Oakland, California 94612

Prepared under: Naval Facilities Engineering Command Tetra Tech NUS Contract Number N62467-04-D-0055 Contract Task Order 310

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS...... iii EXECUTIVE SUMMARY ...... 1 1.0 INTRODUCTION ...... 1 2.0 SITE CHRONOLOGY ...... 2 3.0 BACKGROUND ...... 2 3.1 INSTALLATION HISTORY ...... 3 3.2 SITE 1 HISTORY ...... 3 3.3 PHYSICAL CHARACTERISTICS ...... 3 3.3.1 Geology and Topography ...... 4 3.3.2 Hydrology ...... 4 3.3.3 Ecology ...... 6 3.4 HISTORY OF CONTAMINATION ...... 6 3.5 SOURCES OF CONTAMINATION...... 7 4.0 REMEDIAL ACTIONS...... 8 4.1 REMEDY SELECTION ...... 8 4.1.1 Remedial Action Objectives ...... 8 4.1.2 Selected Remedy...... 8 4.2 REMEDY IMPLEMENTATION ...... 9 4.3 DESIGN CHANGES TO REDUCE THE WEIGHT OF THE CAP...... 10 4.4 REMEDIAL ACTION COSTS ...... 11 5.0 PROGRESS SINCE THE LAST REVIEW ...... 11 6.0 FIVE-YEAR REVIEW PROCESS...... 12 6.1 ADMINISTRATIVE COMPONENTS OF THE FIVE-YEAR REVIEW PROCESS...... 12 6.2 COMMUNITY NOTIFICATION AND INVOLVEMENT...... 12 6.3 DOCUMENT REVIEW ...... 12 6.4 DATA REVIEW ...... 13 6.4.1 Landfill Gas ...... 14 6.4.2 `Groundwater ...... 14 6.5 SITE INSPECTION...... 15 6.6 INTERVIEWS ...... 15

First Five-Year Review Report for i Site 1 Tidal Area Landfill Military Ocean Terminal Concord TABLE OF CONTENTS (CONTINUED)

7.0 TECHNICAL ASSESSMENT ...... 17 7.1 QUESTION A ...... 17 7.2 QUESTION B...... 17 7.2.1 Exposure Assumptions, Toxicity, and Cleanup Levels ...... 18 7.2.2 Applicable or Relevant and Appropriate Requirements ...... 18 7.2.3 Validity of RAOs ...... 18 7.3 QUESTION C...... 18 8.0 ISSUES ...... 18 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS...... 19 10.0 PROTECTIVENESS STATEMENTS ...... 19 11.0 NEXT REVIEW ...... 19 12.0 REFERENCES ...... 20

FIGURES

Figure 1: Site Vicinity

Figure 2: Site 1 Landfill and Surrounding Sites

Figure 3: 2004 and 2008 Landfill Cap Design Footprint

Figure 4: 2010 Landfill Cap Design Footprint

Figure 5: Site 1 Landfill Perimeter Monitoring Well Locations

ATTACHMENTS

A Site 1 Landfill Chronology of Events

B Site Inspection (Photos Documenting Site Conditions and Check List)

C Interview Reports

First Five-Year Review Report for ii Site 1 Tidal Area Landfill Military Ocean Terminal Concord

ACRONYMS AND ABBREVIATIONS

µg/kg Micrograms per kilogram

Army U.S. Department of the Army ARAR Applicable or relevant and appropriate requirement

CCR California Code of Regulations CDFG California Department of Fish and Game CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations

DoD Department of Defense DTSC Department of Toxic Substances Control

EPA U.S. Environmental Protection Agency EOD Explosives Ordnance Disposal EPA U.S. Environmental Protection Agency ESD Explanation of Significant Differences

IAS Initial assessment study IR Installation Restoration IRP Installation Restoration Program

MEC Munitions and Explosives of Concern mg/kg Milligrams per kilogram mg/L Milligram per liter MOTCO Military Ocean Terminal-Concord msl Mean sea level

NCP National Contingency Plan NOSSA Naval Ordnance Safety and Security Activity NWS SBD Naval Weapons Station Seal Beach Detachment ppm Parts per million ppmv Parts per million by volume PRG Preliminary Remediation Goal

RAB Restoration Advisory Board RAO Remedial action objective RI Remedial investigation ROD Record of decision RPM Remedial project manager

First Five-Year Review Report for iii Site 1 Tidal Area Landfill Military Ocean Terminal Concord ACRONYMS AND ABBREVIATIONS (CONTINUED)

SARA Superfund Amendments and Reauthorization Act SI Site investigation SMP Site management plan SVOC Semivolatile organic compound

TCE Trichloroethene TDS Total dissolved solids TSS Total suspended solids

USACE U.S. Army Corps of Engineers

VOC Volatile organic compound

Water Board San Francisco Bay Regional Water Quality Control Board

First Five-Year Review Report for iv Site 1 Tidal Area Landfill Military Ocean Terminal Concord

EXECUTIVE SUMMARY

This report provides the results of the first Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Five-Year Review conducted for the Site 1 Landfill at Military Ocean Terminal Concord (MOTCO). The review was conducted in accordance with the Comprehensive Five-Year Review Guidance (U.S. Environmental Protection Agency [EPA] 2001). The purpose of this 5-year review is to evaluate whether the remedy at the Site 1 Landfill is protective of human health and the environment. The remedy at the Site 1 Landfill includes construction of a cap to prevent human and animal contact with the waste and to reduce infiltration of rainwater runoff into and through the landfill mass. This statutory review is required by and conducted according to the applicable laws because this remedy does not result in site conditions suitable for unlimited use and unrestricted exposure.

The remedy at the Site 1 Landfill is not complete at this time. Although the remedy is not complete, a 5-year review has been performed at the request of EPA and as required by CERCLA.

The remedy at the Site 1 Landfill will be redesigned to reduce landfill subsidence, cost, and the overall footprint of the cap so that it does not encroach on the surrounding aquatic environment. The basic remedy is unchanged and still complies with EPA presumptive remedy guidance for landfills. However, the changes will be significant to the degree that the Army plans to issue an Explanation of Significant Differences as required under CERCLA for record of decision (ROD) modifications that are considered significant but that do not change the selected remedy. The Army plans to issue the Explanation of Significant Differences on December 31, 2010, in accordance with the MOTCO site management plan (SMP).

The remedy described in this document applies to the waste at the Site 1 Landfill and does not address groundwater conditions at the Site 1 Landfill. Data collected to date do not suggest that groundwater contamination is present that necessitates remedial action, although the assessment is ongoing. A ROD will be completed to document the appropriate remedy selected for groundwater at the Site 1 Landfill. The appropriate remedy for the groundwater at the Site 1 Landfill might be (1) no action, (2) land use controls, (3) some active form of remediation, (4) monitored natural attenuation, or some combination of these remedies. Per the MOTCO SMP, the ROD for Site 1 groundwater is to be completed on September 1, 2013.

PURPOSE AND SCOPE

The purpose of this 5-year review is to evaluate whether the remedy at Site 1 Landfill is protective of human health and the environment. As such, the scope of this evaluation is to review the actions taken since Phase I landfill construction was initiated on September 29, 2005, to provide protectiveness statements for the remedy and, if needed, to recommend actions to be taken before the next 5-year review. The contents of this first 5-year review include community notification, a site inspection, interviews, and document and data review.

First Five-Year Review Report for ES-1 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

COMMUNITY NOTIFICATION

Naval Weapons Station Seal Beach Detachment (NWS SBC) Concord personnel and the adjacent communities were notified of the first 5-year review through a legal notice in the Contra Costa Times on September 13, 2010. The notice stated the purpose of the first 5-year review at the Site 1 Landfill, described the remedial actions completed, and identified the types of contamination.

SITE INSPECTION

The site inspection was conducted on September 14, 2010, and offered the opportunity to observe the site’s remedial efforts to date and to review the site ecology. No conditions were observed at the site that suggest impacts to human health or the environment different from those previously understood.

INTERVIEWS

The interviews with knowledgeable personnel associated with the Site 1 Landfill, including regulatory agency staff and the restoration advisory board (RAB), were conducted the week of September 6, 2010. Interviews were conducted via telephone to ascertain the status of the remedial effort to date. None of the personnel knew of significant changes to site conditions that would alter protectiveness.

DOCUMENT AND DATA REVIEW

Data collected after the ROD was implemented were reviewed in September 2010. Groundwater is being investigated as a separate IR site and is therefore not part of this 5-year review; however, groundwater data collected from monitoring wells around the perimeter of the landfill were evaluated to determine if contaminants from the landfill are migrating to the adjacent Tidal Area sites.

ISSUES AND RECOMMENDATIONS

The issues for the Site 1 Landfill include:

• The landfill cap is currently being redesigned to reduce the quantity of imported fill, landfill subsidence, cost, and the overall footprint of the cap so that it does not encroach on the surrounding aquatic environment. • An Explanation of Significant Differences document will be prepared. • The landfill cap is under construction and will not function as designed until construction is complete. The work is funded and scheduled for completion on November 30, 2011.

Recommendations for the Site 1 Landfill include:

First Five-Year Review Report for ES-2 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

• Complete the Explanation of Significant Differences and the redesign work. • Complete the construction.

EVALUATION OF PROTECTIVENESS

Although the remedy is incomplete, there have been substantial improvements in protection to human health and the environment since the start of construction. The potential for direct exposure to landfill waste has been substantially reduced by the thick layer of fill which covers nearly the entire landfill. In addition, infiltration of rainwater has been reduced substantially over preconstruction conditions because the site is now sloped to drain and because it is now covered with compacted fill.

The remedy at the Site 1 Landfill is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

First Five-Year Review Report for ES-3 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

SITE IDENTIFICATION

Site name (from WasteLAN): Site 1 Landfill; Military Ocean Terminal Concord

EPA ID (from WasteLAN): CA 7170024528

Region: 9 State: CA City/County: Contra Costa County

SITE STATUS

NPL status: 7 Final Deleted Other (specify)

Remediation status (choose all that apply): Under Construction 7

Multiple OUs YES NO 7 Construction completion date: Fiscal Year 2011

Has site been put into reuse? YES NO 7

REVIEW STATUS

Lead agency: EPA State Tribe 7 Other Federal Agency ______US Army_____ Author name: US Army Author title: Author affiliation:

Review period:** 08 / 31 / 2010 to 09 / 24 / 2010

Date(s) of site inspection: 09 / 14 / 2010 Type of review: 7 Post-SARA Pre-SARA NPL-Removal only Non-NPL Remedial Action Site NPL State/Tribe-lead Regional Discretion

Review number: 7 1 (first) 2 (second) 3 (third) Other (specify) ______Triggering action: Actual RA Onsite Construction at OU #____ 7 Actual RA Start at OU#_1___ Construction Completion Previous Five-Year Review Report Other (specify)

Triggering action date: 09 / 29 / 2005

Due date (five years after triggering action date): 09 / 29 / 2010

First Five-Year Review Report for ES-4 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

Five-Year Review Summary Form, continued

Issues:

The issues for the Site 1 Landfill include:

1) The landfill cap is currently being redesigned to reduce the quantity of imported fill, landfill subsidence, cost, and the overall footprint of the cap so that it does not encroach on the surrounding aquatic environment.

2) An Explanation of Significant Differences document will be prepared.

3) The landfill cap is under construction and will not function as designed until construction is complete. The work is funded and scheduled for completion on November 30, 2011.

Recommendations and Follow-up Actions:

The recommendations for the Site 1 Landfill:

• Complete the Explanation of Significant Differences and the redesign work.

• Complete construction of the cap.

Protectiveness Statement(s):

Although the remedy is incomplete, there have been substantial improvements in protection to human health and the environment since the start of construction. The potential for direct exposure to landfill waste has been substantially reduced by the thick layer of fill which covers nearly the entire landfill. In addition, infiltration of rainwater has been reduced substantially over preconstruction conditions because the site is now sloped to drain and because it is now covered with compacted fill.

The remedy at the Site 1 Landfill is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

Other Comments:

None.

First Five-Year Review Report for ES-5 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

1.0 INTRODUCTION

This report provides the results of the first Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Five-Year Review conducted for the Site 1 Landfill at Military Ocean Terminal Concord (MOTCO). The purpose of this 5-year review is to evaluate whether the remedy at the Site Landfill is protective of human health and the environment. The report identifies the methods used in the review and key issues on implementation and performance of the remedy and gives recommendations on how the issues can be addressed. The triggering mechanism for this 5-year review of the Site 1 Landfill was the start of on-site construction associated with the remedy, which was September 29, 2005.

Implementation of the remedy at the Site 1 Landfill has not been completed but is scheduled for completion in 2011. This 5-year review is being conducted at the request of the U.S. Environmental Protection Agency (EPA) in accordance with the CERCLA requirements described in this document.

The remedy described in this document applies to the waste at the Site 1 Landfill and does not address groundwater conditions at the Site 1 Landfill. Data collected to date do not suggest that groundwater contamination is present that necessitates remedial action, although the assessment is ongoing. A record of decision (ROD) will be completed to document the appropriate remedy selected for groundwater at the Site 1 Landfill. The appropriate remedy for the groundwater at the Site 1 Landfill might be (1) no action, (2) land use controls, (3) some active form of remediation, (4) monitored natural attenuation, or some combination of these remedies. Per the MOTCO site management plan (SMP), the ROD for Site 1 groundwater is to be completed on September 1, 2013.

Consistent with Executive Order 12580, the Secretary of Defense is responsible for ensuring that 5-year reviews are conducted at all qualifying Department of Defense (DoD) remediation sites. The U.S. Department of the Army is authorized to conduct the 5-year review of the Site 1 Landfill pursuant to CERCLA § 121 and the National Contingency Plan (NCP). CERCLA § 121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.

First Five-Year Review Report for 1 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

EPA and the Army interpret this requirement further in the NCP, Title 40 Code of Federal Regulations (CFR) Section §300.430(f)(4)(ii), which states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.

This 5-year review was conducted in accordance with the following guidance document:

• Comprehensive Five-Year Review Guidance (EPA, 2001). (This document includes the report template used for preparing this 5-year review report.)

The 5-year review of the remedial action taken for the Site 1 Landfill is a statutory review because the remedies were selected after the effective date (October 17, 1986) of the Superfund Amendments and Reauthorization Act (SARA), and the remedies do not result in site conditions suitable for unlimited use and unrestricted exposure (such as residential land use).

2.0 SITE CHRONOLOGY

The site was first investigated during an initial assessment study (IAS) in 1983. The initial assessment study consisted of a search of historical records, a visual inspection of the site, and interviews with personnel at Naval Weapons Station Seal Beach Detachment (NWS SBD) Concord. Based on the historical information, the site was recommended for further study. A site inspection (SI) of the Site 1 Landfill was subsequently conducted from April 1988 to January 1991. Groundwater, surface water, soil, and sediment samples were collected within the Site 1 Landfill. Results revealed volatile organic compounds (VOC), semivolatile organic compounds (SVOC), polynuclear aromatic hydrocarbons, the pesticide dieldrin, the polychlorinated biphenyl Aroclor-1260, metals, and the nitroaromatic explosive compound nitrobenzene. The Navy documented its intent to use a presumptive remedy approach in December 1994 in the Remedial Investigation/Feasibility Study Tidal Area Sites Draft Final Work Plan. Based upon EPA’s Presumptive Remedy for CERCLA Municipal Landfill Sites (1993), a multi-layer municipal solid waste prescriptive soil cap was proposed and selected.

Events related to the Site 1 Landfill from discovery until the present are summarized in Attachment A.

3.0 BACKGROUND

This section describes the fundamental aspects of the site and site characteristics and identifies the threat posed to the public and the environment at the time of the ROD so that the performance of the remedy can be easily compared with the site conditions the remedy was intended to address.

First Five-Year Review Report for 2 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3.1 INSTALLATION HISTORY

MOTCO (formerly NWS SBD Concord) is the major Army munitions transshipment facility on the West Coast and is located in the north-central portion of Contra Costa County, California, 30 miles northeast of San Francisco (Figure 1). On October 1, 2008, the 6,800-acre Tidal Area of the former NWS SBC Concord was transferred from the Navy to the Army pursuant to the Defense Base Closure and Realignment Act of 1990, as amended by the Defense Authorization Act of 2005. The Army has assumed responsibility as the lead agency for environmental cleanup at MOTCO. Before the Army became involved, the U.S. EPA, the California EPA Department of Toxic Substances Control (DTSC), the California Department of Fish and Game (CDFG), and the San Francisco Bay Regional Water Quality Control Board (Water Board) worked with the Navy on the Installation Restoration Program (IRP) for the installation. The Army has worked closely with the regulatory agencies since it became responsible for environmental cleanup at MOTCO. The Site 1 Landfill is one of 19 installation restoration (IR) sites the Army investigated under the IRP.

3.2 SITE 1 HISTORY

The Tidal Area at MOTCO — which includes the Site 1 Landfill, the R Area (Site 2), the Froid and Taylor Roads (Site 9), and the Wood Hogger (Site 11) — is located on a site originally occupied in part by a copper smelting operation from 1901 to 1908 and later by the Pacific Coast Shipbuilding Company. At that time, the area was known as “Bay Point.” The copper smelting and ship building operations occurred in the area north of the Site 1 Landfill. The distance from the landfill to the former smelting and shipbuilding operations is estimated to be more than 1,000 feet. Otter Slough was constructed to drain surface water and groundwater from the Tidal Area to Suisun Bay. The slough is believed to have passed through the current location of the Site 1 Landfill. During construction of NWS SBD Concord in 1942, the portion of this slough that passed through the present location of Site 1 Landfill was backfilled and the slough was rerouted around the landfill.

The Site 1 Landfill covers 12.5 acres and contains an estimated 125,000 to 135,000 cubic yards of waste and cover soil. The landfill served as the primary disposal area for NWS SBD Concord from 1944 to 1979. During that time, the landfill received household refuse from the base and surrounding communities, as well as facility waste and construction debris. Site 2, a wetland area, is adjacent to the landfill along its western and southern boundaries (Figure 2). The closest civilian population to the landfill is 1.3 miles away.

3.3 PHYSICAL CHARACTERISTICS

The physical characteristics, including geology, topography, hydrology, and ecology of the Site 1 Landfill, are discussed in the following sections.

First Five-Year Review Report for 3 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3.3.1 Geology and Topography

The Tidal Area of MOTCO, which includes the Site 1 Landfill, is characterized by artificial fill material that overlies fine-grained Bay Mud sediments. Artificial fill material has been used in the Tidal Area to construct road and railroad beds, channel levees, structural pads, and protective revetments. The fill material was used to elevate portions of the base above the marsh plain, which is generally at or near mean sea level (msl) in the Tidal Area. The artificial fill used outside the area of the landfill is typically a mixed lithology that contains varying proportions of clay, silt, sand, and gravel. The refuse that makes up the landfill is also considered artificial fill. Household refuse, facility waste, construction debris, metal debris, and soil were deposited directly on the surface of the marsh to form the landfill. Aerial photographs show no evidence of excavation at the landfill. Topographic maps indicate that the landfill extends approximately 10 feet above the marsh plain.

Bay Mud underlies the fill material and the landfill and consists chiefly of silty clay with local horizons of peat. Because the Bay Mud is not consolidated, the weight of the refuse and cap material placed to date has compressed the underlying Bay Mud to some extent. Silty clay is the predominant lithology of the Bay Mud, although peat lenses are present beneath the landfill and a sand body is found in the area east of the landfill.

Before construction, the landfill formed an asymmetric mound that reached a maximum elevation of more than 10 feet above msl near its eastern edge along Johnson Road. The western half of the landfill is at an elevation of 3 to 5 feet above msl. The area adjacent to the Tidal Area Landfill consists of low-lying wetlands, including the R Area (Site 2), the Froid and Taylor Roads site (Site 9), and the Wood Hogger site (Site 11). The elevation of the wetlands west of the landfill is generally between 2 and 4 feet msl.

After munitions were discovered in the landfill during construction, the Navy at the time decided to prohibit all further landfill excavation to mitigate the risk of potential undiscovered buried munitions in the waste. The landfill redesign therefore required placement of additional fill. Most of that fill was imported to the site, and the top surface of the landfill currently extends to an elevation nearing approximately 16 feet.

The extent of the Site 1 Landfill depicted in Figure 2 encompasses the entire area where landfill debris and surface cover fill exist. The boundary between the landfill and Site 2 is sharply defined by the toe of the landfill fill slope.

3.3.2 Hydrology

MOTCO lies within the boundaries of the Clayton Valley Groundwater Basin, as defined in the San Francisco Bay Water Quality Control Plan (Basin Plan). The existing and potential beneficial uses identified for this groundwater basin, which lies between 50 to 300 feet below ground surface, include the following: municipal and domestic supply, industrial process supply, industrial service supply, and agricultural supply. Groundwater at the Tidal Area Sites occurs in a shallow unconfined water-bearing zone predominantly composed of silty clays.

First Five-Year Review Report for 4 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

Shallow groundwater in the Tidal Area contains total dissolved solids (TDS) at levels that are, on average, significantly higher than the 3,000-miligrams per liter (mg/L) level State Water Resources Control Board Resolution 88-63 sets as a maximum for a municipal or domestic water supply and the 10,000 mg/L level set forth in EPA’s groundwater classification guidelines (EPA 1998). TDS concentrations in the four Tidal Area Sites are generally very high, ranging from 3,930 mg/L to 65,600 mg/L. An average TDS concentration of more than 23,000 mg/L was detected in samples collected from 1990 to 1997 from the 23 wells in the Tidal Area. For comparison, the concentration of TDS in sea water typically is 35,000 mg/L.

Groundwater is not considered potable because of high TDS in samples from the monitoring wells. There is no historical, existing, or planned use of the shallow groundwater in the Tidal Area as a source of drinking water.

Data obtained from groundwater monitoring wells surrounding the Site 1 Landfill indicate that groundwater elevations in the eastern, elevated portion of the landfill are consistently higher than in the western edge of the landfill and the adjacent Site 2. Groundwater consistently flows west or southwest beneath the landfill during both the wet and dry seasons, except in the northern portion of the landfill, where groundwater locally flows northward toward Suisun Bay. The available data do not indicate that groundwater mounds beneath the landfill. However, the refuse in the landfill extends down to and below the groundwater table. Groundwater flow rates in the area are extremely low because the silty clay that makes up the bulk of the Bay Mud does not readily transmit water.

Groundwater flow velocities up to 2.2 feet per year were estimated from hydraulic parameters measured in 1998. Specific yields of the monitoring wells have not been measured, principally because of the difficulty in carrying out pumping tests in wells screened in Bay Mud. Sampling records indicate that wells at the landfill typically experienced significant drawdown at a pumping rate of 0.1 liter per minute, suggesting that well yields would be below 200 gallons per day. Groundwater elevations at the Site 1 Landfill measured from December 1989 to January 1998 ranged from 3.20 feet below msl to 3.54 feet above msl. Except for a few wells or measurement periods, water levels in the wells at the site were highest near the end of the wet season and lowest near the end of the dry season. The response of water levels in landfill wells to seasonal rainfall indicates that groundwater is recharged by infiltration of precipitation.

A confined sand body is present in the area east of the landfill. The sand body occurs about 16 feet below grade, is approximately 3.5 feet thick, and appears to terminate in the vicinity of the landfill. Groundwater flows to the northwest within the sand body and was not sampled during the confirmation study because the sand body is not downgradient of the landfill (Tetra Tech 1998). Surface water is not present at the landfill. Open surface water exists year round at adjacent Site 2, however. Otter Slough is a manmade drainage canal that runs along the southwestern perimeter of Site 2. At its closest point, Otter Slough is about 750 feet from the Site 1 Landfill. Tidal fluctuations in Otter Slough cause localized reversals in the direction of groundwater flow in the area immediately adjacent to the slough, but groundwater flow in the vicinity of the landfill is not affected by tidal fluctuations in Otter Slough. In general, groundwater at the site flows toward Site 2 during both the dry and wet seasons.

First Five-Year Review Report for 5 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3.3.3 Ecology

The eastern half of the landfill extends into the upland area of the site and is bordered by Johnson Road. The landfill is bordered on the northern, southern, and western perimeters by Tidal Area wetlands. The landfill currently exists as a bare soil cap that does not provide the necessary plant life to support native animals. After the cap is constructed and the surface is revegetated, the waste will be isolated from contact with animals and the plant life may provide a source of food for animals. As such, the landfill is expected to become better habitat for animals than it is now or before the waste was covered. The landfill will not, however, match the ecologically sensitive, high-quality marshland habitat at adjacent Site 2, which borders the landfill to the south and west.

The ecology of Site 2 is characteristic of estuarine ecology. Suisun Bay is influenced by both fresh water from the Sacramento and San Joaquin Rivers and the partly marine waters of San Francisco Bay. Site 2 is characterized by a large area of open water and marsh habitat and vegetation that tolerates brackish water. The threatened and endangered species present in the adjacent areas include salt marsh harvest mice (Reithrodontomys megalotis) (federally- and state-listed endangered species) and California black rails (state-listed threatened species).

3.4 HISTORY OF CONTAMINATION

The SI completed in 1991 revealed that VOCs, SVOCs, polynuclear aromatic hydrocarbons, polychlorinated biphenyls, and metals are present within the landfill itself. As a result of the SI, a remedial investigation (RI) was conducted to assess whether contaminants were migrating outward from the landfill.

During the RI, surface and subsurface soil and groundwater samples were collected around the perimeter of the landfill to assess potential migration of chemicals. Surface water samples were not collected at the Site 1 Landfill during the RI because no surface water was present at the landfill. The RI did not attempt to fully characterize the contents of the landfill because of the heterogeneous nature of the landfill contents. In addition, because based on the EPA guidance document Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA 1993), capping was considered the most likely remedy. Instead, samples were collected at eight locations around the perimeter of the landfill, and 24 samples were collected, analyzed, and compared with 1996 EPA Region IX and California-modified residential preliminary remediation goals (PRG) (EPA 1996) and ambient concentrations for metals. The risk assessment was limited to a focused review and is not required under the presumptive remedy guidance.

Only one organic compound was detected in soil samples at a concentration greater than its residential PRG. The polynuclear aromatic hydrocarbon benzo(a)pyrene was detected in surface soil samples from the western edge of the landfill at a concentration of 68 micrograms per kilogram (µg/kg), and the 1996 PRG was 56 µg/kg (Tetra Tech 1999). The EPA PRGs have been updated, and the current residential PRG for benzo(a)pyrene has been increased to 62 µg/kg (EPA 2002). Two metals, arsenic and lead, were detected in soil at concentrations greater than the residential PRGs (0.38 milligrams per kilogram [mg/kg] for arsenic and 130 mg/kg for lead)

First Five-Year Review Report for 6 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

and the estimated ambient concentrations (24 mg/kg arsenic and 61 mg/kg lead). Arsenic was detected in surface and subsurface soil samples at concentrations up to 57.6 mg/kg. Lead was detected in surface soil samples at concentrations ranging from 5.3 to 156 mg/kg. Arsenic was the only compound considered a chemical of concern for the landfill during the focused human health risk assessment.

Results for groundwater samples, including results from the 1998 confirmation groundwater sampling event, indicate that organic compounds are not present in groundwater near the Site 1 Landfill. Metals (arsenic, chromium, iron, nickel, and zinc) were detected in groundwater, but at concentrations that were comparable to concentrations detected in other wells both upgradient and downgradient of the landfill. Isolated areas of comparatively high concentrations characterize the geographic distribution of metals in groundwater. Most of the higher metals concentrations were detected in samples from Site 2, which is hydraulically downgradient of the landfill, but relatively high concentrations of metals were also detected in samples from upgradient wells at the eastern edge of the landfill. The data for metals did not show evident plumes of groundwater contaminated by metals emanating from the landfill. Instead, the distribution suggests that concentrations of metals at Site 2 are caused by evaporative processes that concentrate metals already present in groundwater throughout the site (Tetra Tech 1998).

The Navy collected additional groundwater samples from wells located near the landfill in July 2003. Aluminum, arsenic, copper, mercury, nickel, and zinc were all detected above groundwater screening criteria at one or more locations. Detected metals were compared with ambient water quality criteria or Bay Basin Plan objectives (Water Board 1995). A statistical comparison between the 1997 and 2003 groundwater sampling events showed no significant change in the concentrations of arsenic, mercury, and nickel at the Site 1 monitoring wells. A statistically significant difference existed between groundwater concentrations of aluminum, copper, iron, thallium, and zinc in samples collected during 1997 and 2003. However, the higher concentrations of these metals, collected in 2003, were determined to be an artifact of total suspended solids (TSS) in samples. While groundwater was not analyzed for TSS during the 2003 investigation, elevated concentrations of aluminum in the 2003 samples is an indicator that suspended solids were present in the samples (Tetra Tech 2004b).

3.5 SOURCES OF CONTAMINATION

Historical aerial photographs indicate, based on the expansion of the landfill perimeter, that most of the waste was deposited in the landfill between 1959 and 1974. Household garbage from NWS SBD Concord and surrounding civilian communities, as well as shipboard waste, was disposed of at the landfill. The landfill reportedly received solvents, acids, paint cans, creosote-treated timbers, asphalt, concrete, asbestos, and ordnance materials, including inert munitions.

Historical photographs indicate that the Site 1 Landfill was created by the progressive disposal of debris placed directly on native soil outward from Johnson Road. Apparently, the area was not excavated before waste was discarded there. A waste thickness of up to 10 feet was estimated

First Five-Year Review Report for 7 Site 1 Tidal Area Landfill Military Ocean Terminal Concord from topographic evaluation; however, the waste may be unevenly distributed, and the ratio of waste to soil cover in the fill may be variable. There is no record of the degree of landfill subsidence that resulted from consolidation of the underlying Bay Mud.

Groundwater levels in the vicinity of the Site 1 Landfill have been measured up to 3.54 feet above msl. It is therefore clear that at least a portion of the landfill waste is inundated because the waste has been measured at up to 10 feet thick at the landfill.

The horizontal extent of the landfill has been established with a high degree of certainty based on historical aerial photographs and visual site inspections. The boundary of the landfill on the east side is delineated by a road, and on the north, south, and west sides, the boundary is visually apparent as a sudden change in slope from the flat wetland to the raised mound of the landfill.

4.0 REMEDIAL ACTIONS

This section provides the results of events identified in the chronology of site events (Section 2.0) that define the remedy for Site 1 from the signing of the ROD through the first 5-year review. Specifically, the initial plans, implementation history, and performance of the remedy are discussed, as well as changes to or problems with components of the remedy.

4.1 REMEDY SELECTION

A final ROD dated July 2004 for the Site 1 Landfill was signed by the Navy, EPA Region 9, and DTSC (Tetra Tech 2004a).

4.1.1 Remedial Action Objectives

The remedial action objectives (RAOs) for Site 1 were developed using the following EPA guidance documents: “Conducting RI/FS Studies for CERCLA Municipal Landfill Sites” (EPA 1991) and “Presumptive Remedy for CERCLA Municipal Landfill Sites” (EPA 1993). Alternatives were developed with the goal of attaining these RAOs:

• Protect human health and environmental receptors from contact with landfill contents. • Protect human health and the environment from exposure to leachate.

• Protect human health and the environment from subsurface landfill gas migration.

4.1.2 Selected Remedy

A soil cap was selected based on extensive discussions with the Navy, EPA, DTSC, Water Board, and the Integrated Waste Management Board. Based on the agencies’ comments and meetings, the Navy concluded that the soil cap should consist of a prescriptive standard cap described in Title 27 California Code of Regulations (CCR), Division 2, 21090.

First Five-Year Review Report for 8 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

The cap consisted of a multilayer municipal solid waste prescriptive soil cap constructed to isolate and eliminate direct contact with refuse in the landfill and to reduce soil erosion, infiltration, and potential contamination migration and included from top to bottom:

• A 12-inch-thick vegetative layer • A 12-inch-thick low-permeability clay barrier • A biotic (drainage) barrier • A 24-inch foundation layer

The selected remedy included waste consolidation. The intent of the waste consolidation was to minimize the volume of imported soil while creating grades that promote surface drainage. In addition, the waste consolidation effort minimized the surface area and successfully held the new footprint of the landfill to the same dimensions as the existing landfill. The landfill consolidation thus prevented any enlargement of the landfill footprint. The proposed waste consolidation included dewatering the excavation area; excavating waste on the perimeter of the landfill; relocating the waste to the central portions of the landfill; and constructing a perimeter containment dike for the landfill waste, the foundation layer of soil, and the landfill cap itself.

After the ROD was signed, the Navy and EPA decided to substitute a linear low-density polyethylene synthetic membrane cover for the 1-foot–thick low-permeability clay layer to further limit infiltration of rainwater (Tetra Tech 2006a, 2006b). This substitution was based on subsequent testing of the hydraulic conductivity of the underlying Bay Mud. In addition, another 6 inches of fill was specified for the vegetative soil cover. The original design included a low-permeability clay dike that was eliminated in favor of the linear low-density polyethylene membrane cover. These changes were considered minor and insignificant, with little to no impact on the overall scope, performance, or cost of the selected remedy (EPA 2006). Figure 2 shows the footprint of the original design.

4.2 REMEDY IMPLEMENTATION

Phase I of the remedy was implemented in September 2005 with installation of gas monitoring probes around the perimeter of the landfill. The cap construction was initiated during summer 2006. When construction began, the surface of the landfill was stripped of vegetation for preliminary grading. On June 15, 2006, and again on July 6, 2006, munitions and explosives of concern (MEC) were found in soil excavated as part of construction for the landfill cap. Subsequently, Travis Air Force Base Explosives Ordnance Disposal (EOD) personnel were called for an emergency response. Travis EOD personnel identified objects as World War II-era “Hedgehog” antisubmarine bombs. They found one part of a broken-open Hedgehog bomb and an intact Hedgehog bomb. According to experts from the Naval Ordnance Safety and Security Activity (NOSSA), a fully intact Hedgehog bomb has 33 pounds of C-2 high explosives. Travis EOD personnel exploded the partial bomb in place and X-rayed the intact bomb, but were unable to verify whether it contained high explosives. They subsequently transported the intact bomb off site for disposal. The discovery of these objects led to a stop

First Five-Year Review Report for 9 Site 1 Tidal Area Landfill Military Ocean Terminal Concord work order from the Navy. On October 5, 2006, during winterization activities, additional MEC consisting of an MK 29 point-detonating nose fuze for a 5-inch projectile and various munitions debris, including unfired and fired flash and burster tubes and flare cartridges, were discovered by the on-site unexploded ordnance technician.

The discovery of MEC within the Site 1 Landfill resulted in a reevaluation of the original design. To avoid the risks and risk reduction costs associated with excavating in areas with potential MEC, the Navy prepared a revised design detailed in the 2008 Explanation of Significant Differences (ESD) (Tetra Tech 2008) that avoided relocation of existing waste. However, this revised design included a 2.5-acre increase in the area of the landfill cap to maintain coverage of the waste mass. This increase resulted in the need for placing fill in the wetland and to import additional fill when compared with the original design. Figure 3 shows the footprint of the 2008 revised design.

Construction of the revised landfill cap began in 2009. Waste subsidence caused by consolidation of the Bay Mud led to an increase of the volume of fill required on site. Soil imports were interrupted in March 2009 and the site was graded to an elevation near the revised design foundation level over the central portion of the landfill. Approximately 10 acres out of the 12.5 are covered with fill. The fill is probably thickest in the middle of the landfill and may be up to 10 to 12 feet thick. Construction work had not yet been initiated along a narrow band of the landfill at the north, south, and west landfill perimeter at the tidal fluctuation zone when the work was stopped in March 2009. This strip varies in width from approximately 40 feet to 120 feet; a portion of it is within the tidal fluctuation zone and is therefore submerged. The revised landfill cap was to cover the footprint of the waste, including the submerged portion, provide a low-permeability geomembrane layer, limit infiltration, and promote flow of rainwater off of the landfill surface.

In 2010, the U.S. Army Corps of Engineers (USACE), Sacramento District, conducted a review to evaluate subsidence at the Site 1 Landfill and the impact of encroaching on the Site 2 wetland before completion of the landfill cap would move forward (USACE 2010a, 2010b, 2010c). The USACE recommended:

• Design changes to reduce the weight and cost of the cap. • Reduce or eliminate extension of the cap into the Site 2 wetland.

4.3 DESIGN CHANGES TO REDUCE THE WEIGHT OF THE CAP

As part of the redesign, the Army will conduct a geotechnical investigation and prepare an engineering analysis to support the design changes for the landfill cap. The Army is proposing a hybrid multilayer cap that will cover the full footprint of the waste mass while avoiding placement of fill in Site 2. The cap will consist of a partially exposed geomembrane in the tidal fluctuation area. In general, the cap will include a foundation layer, geosynthetic layers, and a vegetative layer over the central part of the landfill.

First Five-Year Review Report for 10 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

The geomembrane will be anchored at the edge of the landfill, laid over the zone of tidal fluctuation, and anchored in the landfill at a distance such that there is no influence from tidal fluctuation or sea level rise. At that point, the cap will be a layered cover, including a foundation layer, a geomembrane layer, the biotic layer, a drainage layer, and the vegetative soil layer. The existing imported fill will be used for foundation fill and vegetative cover. Some of the fill will be collected and stored for vegetative cover, and the balance of the fill will be land-formed to provide a finished, undulating surface for the foundation layer and the geosynthetics. The final cover will present an aesthetic look with multiple drainage swales. The undulations will have an inclination of up to 3 percent while the drainage swales will follow an inclination of 2 percent. Figure 4 shows the 2010 redesigned cap.

In compliance with paragraph 117(c) of CERCLA and Title 40 of the CFR, the Army and its contractors have engaged with the regulatory agencies on how to address the changes to the final cover. The initial presentation to the agencies was held on August 31, 2010.

It is anticipated that, in accordance with paragraph 300.435 (c) (2) of Title 40, the agencies will agree that an ESD rather than an amendment to the ROD will be sufficient because the proposed cover is not significantly different and is an improvement of the currently approved cover. The ESD will describe the cover proposed for the Site 1 Landfill and will provide the technical information to demonstrate that the cover proposed meets all regulatory requirements and is technically sound. The ESD will:

• Report the findings of the geotechnical investigation. • Present a summary of the engineering analysis in support of the stability and integrity of the cover (an analysis of settlement, drainage, slope stability, and soil loss). • Present the revised design (including technical specifications and construction drawings) and the construction quality assurance plan.

The schedule for completion of landfill cap is November 2011. Institutional land use controls will be included as part of the remedy to maintain the effectiveness of the landfill cap in preventing exposure to debris, contaminated soil, and groundwater within the landfill.

4.4 REMEDIAL ACTION COSTS

The cost to the Navy of implementing the remediation remedy up to the first 5-year review is approximately $5.5 million and included funding for oversight, unexploded ordnance support, and construction. The Army currently has about $4.8 million under contract to complete construction of the Site 1 Landfill cap.

5.0 PROGRESS SINCE THE LAST REVIEW

This 5-year review is the first for the site.

First Five-Year Review Report for 11 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

6.0 FIVE-YEAR REVIEW PROCESS

This section provides a description of the activities performed during the 5-year review process for the Site 1 Landfill and summarizes the findings for each step when appropriate.

6.1 ADMINISTRATIVE COMPONENTS OF THE FIVE-YEAR REVIEW PROCESS

The 5-year review team consisted of Cindi Rose (project manager), John Bosche (senior engineer), and Carolyn Hunter (community involvement specialist).

6.2 COMMUNITY NOTIFICATION AND INVOLVEMENT

MOTCO personnel and residents in the adjacent communities of Contra Costa County were notified of the start of the 5-year review for Site 1 on September 1, 2010. The public notice was published as a legal notice in the Contra Costa Times on Monday September 13, 2010. The notice stated the purpose of the 5-year review at Site 1 under CERCLA and described the remedial actions completed since the 2004 ROD was signed.

A second public notice and a fact sheet will be released in December 2010 to notify the community of that the 5-year review report is complete. A fact sheet will also be sent to the current Restoration Advisory Board (RAB) members and regulatory agency personnel who have indicated interest concerning the environmental restoration at the Site 1 Landfill. In addition, the 5-year review report will be available for interested members of the community at the MOTCO Information Repository located at the Concord Public Library, 2900 Salvio Street, Concord, California 94519.

The local community was not directly involved in the 5-year review process for the Site 1 Landfill. As the public had the opportunity to become involved in the environmental restoration process at the Site 1 Landfill during the earlier phases, the RAB was viewed as the forum for exchange of information among the interested parties (for example, the Army, regulatory agencies, and the community).

6.3 DOCUMENT REVIEW

The 5-year review drew on the documents listed below. Documents 3 to 12 are provided on the CD included with this report.

1) Comprehensive Five-Year Review Guidance (EPA 2001) 2) Five-Year Review Process in the Superfund Program (EPA 2003) 3) Final Record of Decision, Tidal Area Landfill Site 1, Naval Weapons Station Seal Beach Detachment Concord, Concord, California (Tetra Tech 2004a)

First Five-Year Review Report for 12 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

4) Groundwater Sampling Summary Report for the Tidal Area Landfill (Site 1) Naval Weapons Station Seal Beach Detachment Concord, Concord, California (Tetra Tech 2004b) 5) Landfill Gas Characterization, Site 1 Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California (Tetra Tech 2005) 6) Groundwater Investigation Data Submittal Tidal Area Landfill, Site 1 Naval Weapons Station Seal Beach, Detachment Concord, Concord, California (SulTech 2006) 7) Final Explanation of Significant Differences, Landfill Cap Redesign, IR Site 1, Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California (Tetra Tech 2008) 8) Memorandum for; Project Manager, Military Ocean Terminal Concord (Cynthia Burris), Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Remedial Approach. CESPK-ED-EE. Dated 22 January, 2010. (USACE 2010a) 9) Memorandum for PM, Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Geotechnical Evaluation. CESPK-ED-EE. Dated 19 February, 2010 (USACE 2010b) 10) Memorandum for PM, Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Review Summary. CESPK-ED-EE. Dated 22 February, 2010 (USACE 2010c) 11) Interim Remedial Action Completion Report for IR Site 1 Landfill Cover Construction. Naval Weapons Station Seal Beach Detachment Concord, Concord, California. Dated August 30, 2010 (Oneida Total Integrated Enterprises 2010) 12) MOTCO Environmental Restoration Services: Site 1 Landfill, Concord, California. Technical Approach Meeting Presentation. Dated 31 August, 2010 (American Integrated Services 2010)

6.4 DATA REVIEW

Data collected after the ROD was implemented are summarized below. Groundwater is being investigated as a separate IR site and is therefore not part of this 5-year review; however, groundwater data collected from monitoring wells around the perimeter of the landfill were evaluated to determine if contaminants from the landfill are migrating to the adjacent Tidal Area sites.

First Five-Year Review Report for 13 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

6.4.1 Landfill Gas

On February 2, 2005, field personnel collected 33 field screening readings at the Site 1 Landfill and collected 10 Summa canisters for laboratory analysis (Tetra Tech 2005). These 10 Summa canisters included eight samples, one duplicate sample, and one upwind sample of ambient air.

Field screening results indicated that methane concentrations vary at the site from 0 to 280 parts per million (ppm). The average of all methane readings was 67 ppm. Carbon monoxide was not detected at any field screening location, and oxygen was consistently read at concentrations of 20.7 to 20.9 percent. All readings of the lower explosive limit were zero, as were all readings of hydrogen sulfide. These results varied widely and were not confirmed by the more accurate laboratory analytical methods. Since this landfill is located near heavily industrialized areas, the field screening results may have been influenced by contaminants in the air that blow onto the site.

Laboratory analytical results for methane were lower than the concentrations detected using field screening equipment. Methane detected in the ambient air sample was 3.0 parts per million by volume (ppmv) and concentrations in the samples collected varied from 2.5 to 3.1 ppmv (Tetra Tech 2005). The difference between field screening concentrations and concentrations measured in the laboratory can arise from two factors. First, the laboratory instrumentation is generally more accurate than the field methods. Second, the laboratory protocol detects and quantifies only the methane present in the sample, whereas the field screening adds other organic vapors to the reported concentration of methane.

Laboratory analytical results for non-methane VOCs indicated that 14 of the 43 target compounds were detected in at least one of the 10 samples collected (Tetra Tech 2005). Of the 14 compounds that were detected, seven were detected from only one sample. One compound, acetone, was detected in the ambient air sample at levels consistent with concentrations found in two other samples and should be regarded as a background gas in these samples. Therefore, only five of the detected compounds were found in more than one location in the landfill at levels above concentrations in ambient air.

All values measured in the field and in the laboratory suggest that the landfill is producing very low concentrations of methane. The remedial design includes installation and future monitoring of gas monitoring probes to evaluate potential landfill gas migration, as required under Title 27 CCR.

6.4.2 `Groundwater

In July and August 2005, a groundwater sample at each of the following wells was collected around the perimeter of the landfill, as shown on Figure 5:

TLSMW001, TLSMW002, TLSMW003, TLSMW004, TLSMW005, TLSMW006, TLSMW007, TLSMW008, TLSMW009, TLSMW010, TLSMW012, RADPZ003, RADPZ004, and RADPZ006.

First Five-Year Review Report for 14 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

On October 20, 2005, a second round of groundwater samples was collected from wells TLSMW005 and TLSMW012. Second-round groundwater samples could not be collected from wells TLSMW008, TLSMW009, and TLSMW010 because the annular bentonite seals in those wells failed when aquifer tests were conducted.

In general, organic constituents were not detected at concentrations that appear significant. One exception is the groundwater sample from well TLSMW009, where 20 micrograms per liter of 1,1,1-trichloroethene (TCE) was detected (SulTech 2006). The presence of 1,1,1,-TCE in groundwater in well TLSMW009 was detected on one occasion. Testing was not conducted because the bentonite seal failed and well TLSMW009 was subsequently abandoned, so it is uncertain whether 1,1,1-TCE in groundwater will be consistently detected during future rounds of groundwater sampling and analysis.

Aluminum, arsenic, copper, mercury, nickel, and zinc were all detected above groundwater screening criteria at one or more locations. Data collected to date for metals show that concentrations in groundwater are static and exhibit no long-term trend.

6.5 SITE INSPECTION

The site inspection for this first 5-year review was conducted on September 14, 2010, by two representatives of Tetra Tech (Cindi Rose and Kevin Bricknell). The purpose of the site inspection was to review and document current site conditions

Overall, the site walk offered the opportunity to observe the remedial efforts conducted to date and to review the site’s ecology. Pictures accompanying the locations discussed above are included in Attachment B. At this point, the landfill cap is under construction and will not function as designed until construction is complete.

Items observed during the 5-year review site inspection walk included:

• With the exception of an erosional area along the southeast boundary of the landfill, storm water controls (drainage channels and silt fencing) are in good repair. The Army will repair this erosional area in September 2010. • With a few exceptions, such as exposed rebar, the waste is completely covered • Evidence of burrowing into the top cover and side slopes by small mammals • Monitoring wells and gas monitoring well are locked and secure

6.6 INTERVIEWS

Personnel responsible for the Site 1 Landfill at MOTCO include the Army and regulatory agency personnel. Interviews were conducted via telephone to ascertain the status of the remedial effort to date. The interviews were conducted during the week of September 6, 2010. An interview documentation form listing the name, title, and organization of each interviewee,

First Five-Year Review Report for 15 Site 1 Tidal Area Landfill Military Ocean Terminal Concord along with the date and location where the interviews took place, is provided in Attachment C; the interview record documenting the interviews is provided in Attachment C as well.

A summary of the interviews is given below.

Phillip Ramsey: Mr. Ramsey is a lead remedial project manager (RPM) for EPA assigned to MOTCO. Mr. Ramsey’s overall impression of remediation of the Site 1 Landfill is that it is taking a long time to be completed. The Navy completed the ROD for the Site 1 Landfill in 2004. EPA acknowledges that the discovery of munitions caused another delay in completion of the cap. Mr. Ramsey stated he is optimistic that the Army’s revised design will resolve the issues and complete the last phase of the remedial design of the landfill cap per the 2011 SMP milestone date of November 30, 2011.

Alan Friedman: Mr. Friedman is a lead RPM for the Water Board assigned to MOTCO. Overall, Mr. Friedman said he has been disappointed in the project. He feels the transition of MOTCO from the Navy to the Army was badly handled and that there were a lot of delays associated with the Army on getting contractors on board to complete the work. The Water Board appreciates the Army Commander’s participation in recent meetings and feels the Army has made the commitment to properly close the landfill within a reasonable timeframe. Mr. Friedman requested the Army be forthcoming with the regulatory agencies and the public on the progress of the landfill closure and delays.

Jim Pinasco: Mr. Pinasco is a lead RPM for DTSC assigned to MOTCO. Mr. Pinasco’s overall impression is there have been significant delays in completing the landfill cap; however, he is confident in the Army’s present landfill team and thinks the current schedule for completion will be met.

Igor Skaredoff: Mr. Skaredoff is the community co-chair for the MOTCO RAB. Mr. Skaredoff stated that “nothing much” happened at Site 1 before the Army took over the base and that the delay in the transition between the Navy and Army was disappointing. He is optimistic about the Army’s new plan to cap the landfill. He said more work has been completed on the landfill in the last 3 years than the past 10 years. He feels that the Army’s redesign is the correct way to cap the landfill.

Cindy Welles: Ms. Welles is a member of the MOTCO RAB and a Clyde resident. Ms. Welles stated that too much time and money have been wasted on the Site 1 Landfill cap. She said the cap should have been constructed long ago. She hopes that the Army’s redesign will resolve the problems.

First Five-Year Review Report for 16 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

7.0 TECHNICAL ASSESSMENT

The technical assessment for the Site 1 Landfill is presented in this section by addressing each of the three key assessment questions. The three key questions are as follows:

• Is the remedy functioning as intended by the decision documents? • Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of remedy selection still valid? • Has any other information come to light that could call into question the protectiveness of the remedy?

Each of these key questions is answered and references to the information used to answer the questions are cited in the following sections. This discussion provides a framework for the protectiveness determination (Section 10.0) that supports the conclusions of the review.

7.1 QUESTION A

QUESTION: Is the remedy functioning as intended by the decision documents? ANSWER: Yes. Per the 5-year review process, the focus of the review when the remedy is under construction is to evaluate whether the remedy is being constructed in accordance with the requirements of the decision documents and design specifications and whether the remedy is expected to be protective when it is completed.

The remedy that was being constructed was functioning as designed; however, subsidence and encroachment into the Site 2 wetland were an issue. The Army has identified opportunities to improve the design by reducing the overall importation of fill and footprint of the landfill. The Army’s redesign will reduce the weight of the landfill cap and so reduce future settlement as well as avoid costs associated with wetland mitigation. The redesigned cap is expected to be protective when it is completed in November 2011.

7.2 QUESTION B

QUESTION: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of remedy selection still valid? ANSWER: Yes. The following subsections discuss the information evaluated in answering this question on the basis of human-health and ecological risk assessment, federal and state regulations evaluated as potential applicable or relevant and appropriate requirement (ARAR) for the remedial actions, and achievement of the RAOs.

First Five-Year Review Report for 17 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

7.2.1 Exposure Assumptions, Toxicity, and Cleanup Levels

Characterization of the landfill contents is not required to select and construct EPA’s presumptive remedy, a landfill cap. In accordance with the EPA’s presumptive remedy guidance for landfills, chemicals of concern and their concentrations have not been evaluated, and human health and ecological risk assessments have not been completed for the landfill because the waste has not been characterized. The presumptive remedy is a containment solution and does not include cleanup of the debris within the landfill. Cleanup levels were therefore not included in the ROD. Capping addresses the threats of potential contact with waste and off-site contaminant migration by windborne or surface water erosion of soils and waste.

7.2.2 Applicable or Relevant and Appropriate Requirements

No new ARARs have been identified other than those already incorporated in the ROD (Tetra Tech 2004a) or the ESD (Tetra Tech 2008).

It is the determination of the Army that the revised design currently being developed will continue to satisfy the statutory requirements of cleanup under CERCLA § 121. Considering the information that has been developed during implementation of the remedy and the proposed changes to the selected remedy, the Army believes that the remedy will remain protective of human health and the environment, will comply with federal and state requirements that are applicable or relevant and appropriate to the revised remedial action, and will be cost effective. The Army further intends the project will not require mitigation for loss of wetland habitat at the perimeter of the landfill because the new design will not encroach upon the Site 2 wetlands.

7.2.3 Validity of RAOs

Overall, the RAOs are still considered valid for the Site 1 landfill; however, RAOs will not be achieved until the landfill cap is completed in November 2011.

7.3 QUESTION C

QUESTION: Has any other information come to light that could call into question the protectiveness of the remedy? ANSWER: No. The cap as currently designed would have been protective of the human health and the environment. However, the Army’s redesign will reduce total settlement, the landfill footprint, and total cost. When the cap is complete, it will be protective of human health and the environment.

8.0 ISSUES

The selected remedy has not been fully implemented. Currently, the waste over the majority of the landfill is covered with 2 to 10 feet of foundation soil. A narrow band of potentially contaminated soil or waste materials could be exposed to the environment at the existing landfill perimeter.

First Five-Year Review Report for 18 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Recommendations for the issues for completion of the landfill cap include:

1. Complete the geotechnical investigation and redesign of the landfill cap. 2. Complete the ESD. 3. Complete the construction of the landfill cover.

10.0 PROTECTIVENESS STATEMENTS

Although the remedy is incomplete, there have been substantial improvements in protection to human health and the environment since the start of construction. The potential for direct exposure to landfill waste has been substantially reduced by the thick layer of fill which covers nearly the entire landfill. In addition, infiltration of rainwater has been reduced substantially over preconstruction conditions because the site is now sloped to drain and because it is now covered with compacted fill.

The remedy at the Site 1 Landfill is expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risks are being controlled.

11.0 NEXT REVIEW

The next 5-year review for the Site 1 Landfill will be due 5 years from the date this document is signed. Consecutive 5-year reviews will be required for the Site 1 Landfill as long as site conditions remain that do not allow for unlimited use and unrestricted exposure.

First Five-Year Review Report for 19 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

12.0 REFERENCES

American Integrated Services, Inc. 2010. “MOTCO Environmental Restoration Services: Site 1 Landfill, Concord, California. Technical Approach Meeting Presentation.” August 31.

Oneida Total Integrated Enterprises. 2010. “Interim Remedial Action Completion Report for IR Site 1 Landfill Cover Construction. Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” August 30.

Regional Water Quality Control Board. 1995. “San Francisco Bay Basin (Region 2), Water Quality Control Plan.” June 21, 1995.

SulTech. 2006. “Groundwater Investigation Data Submittal Tidal Area Landfill, Site 1 Naval Weapons Station Seal Beach, Detachment Concord, Concord, California.” November 15.

Tetra Tech EM Inc. (Tetra Tech). 1998. “Technical Memorandum: Confirmation Groundwater Sampling in the Tidal Area Sites – Naval Weapons Station, Concord, California.” March 19.

Tetra Tech. 1999. “Draft Final Remedial Investigation Tidal Area Sites 1, 2, 9, and 11 Report - NWSSB Detachment Concord, California.” June.

Tetra Tech. 2004a. “Final Record of Decision, Tidal Area Landfill Site 1, Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” April 13.

Tetra Tech. 2004b. “Groundwater Sampling Summary Report for the Tidal Area Landfill (Site 1) Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” June 24.

Tetra Tech. 2005. “Landfill Gas Characterization, Site 1 Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” April 14.

Tetra Tech. 2006a. “Naval Weapons Station Seal Beach Detachment Concord, Concord, California, IR Site 1 – Tidal Area Landfill Cover Final Remedial Design Drawings.” April 28.

Tetra Tech. 2006b. “Revised Final (100%) Remedial Construction Specifications, Landfill Cover, Tidal Area Landfill, Site 1, Naval Weapons Station Seal Beach, Detachment Concord, Concord, California.” February 22.

Tetra Tech. 2007. “Draft Technical Memorandum Landfill Cap Redesign, Site 1 Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” March 5.

Tetra Tech. 2008. “Final Explanation of Significant Differences, Landfill Cap Redesign, IR Site 1, Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California.” May 22.

First Five-Year Review Report for 20 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

U.S. Army Corps of Engineers (USACE). 2010a. “Memorandum for; Project Manager, Military Ocean Terminal Concord (Cynthia Burris), Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Remedial Approach. CESPK-ED-EE.” January 22.

USACE. 2010b. “Memorandum for PM, Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Geotechnical Evaluation. CESPK-ED-EE.” February 19.

USACE. 2010c. “Memorandum for PM, Military Ocean Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Review Summary. CESPK-ED-EE.” February 22.

U.S. Environmental Protection Agency (EPA). 1991. “Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill Sites.” EPA/540/P-91/001, OSWER Directive 9355.3-11. February.

EPA. 1993. “Presumptive Remedy for CERCLA Municipal Landfill Sites.” EPA 540/F-93/035. September.

EPA. 1996. “Region IX Preliminary Remediation Goals.” August 1.

EPA. 2001. “Comprehensive Five-Year Review Guidance.

EPA. 2002. “Region IX Preliminary Remediation Goals.” October 1.

EPA. 2006. Letter Regarding Review of Tidal Area Landfill Design Change Determination (w/ *enclosures). From Phillip Ramsey. To L. Chung, Naval Facilities Engineering Command Southwest, Desert Integrated Product Team. May 22.

First Five-Year Review Report for 21 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

FIGURES

Suisun BBayay 680 Ryer ¨¦§ Island SITE 1 Freeman (Tidal Area Landfill) Island Snag Island Roe Island Benicia Seal Middle Islands Ground Island

Bay Point ST4

UV242 UV4 Pittsburg

Martinez

UV24 Concord Antioch

Pleasant Hill

Site 1 Landfill MILITARY OCEAN TERMINAL CONCORD Military Ocean Terminal Concord (MOTCO) 0 2 4 Concord Former Naval Weapons Station FIGURE 1 Miles SITE VICINITY

Site 1 Five-Year Report

2010-09-10 12:00 :\concord\projects\site_01\5_year_plan_2010\site_1_regional_location.mxd TtEMI-OAK drew.bley v an Site 2 Wetland

Site 1 Landfill

Site 9

Site 11

Site 1 Landfill - Active from 1959-1974 - 125,000 to 135,000 CY of waste - 12.5 acres MILITARY OCEAN TERMINAL CONCORD

Other Site Boundary FIGURE 2

0 700 SITE 1 LANDFILL

Feet AND SURROUNDING SITES Aerial Photo referenced as June 19, 2009, USDA Site 1 Five-Year Plan 2010-09-13 10:27 v:\concord\projects\site_01\5_year_plan_2010\landfill_and_surrounding_sites.mxd TtEMI-OAK andrew.bley 0 250 500

Feet Estimated Limit of Waste

2004 Design Footprint MILITARY OCEAN TERMINAL CONCORD 2008 Revised Design Footprint FIGURE 3 Encroachment of Landfill Cap on Site 2 Wetland 2004 AND 2008 LANDFILL CAP DESIGN FOOTPRINT Aerial Photo referenced as June 19, 2009, USDA Site 1 Five-Year Report 2010-09-09 12:36 v:\concord\projects\site_01\5_year_plan_2010\design_footprint.mxd TtEMI-OAK andrew.bley 0 250 500

Feet Estimated Limit of Waste MILITARY OCEAN TERMINAL CONCORD 2010 Design Footprint FIGURE 4 2008 Revised Design Footprint 2010 LANDFILL CAP DESIGN FOOTPRINT Aerial Photo referenced as June 19, 2009, USDA Site 1 Five-Year Report 2010-09-09 12:53 v:\concord\projects\site_01\5_year_plan_2010\2010_design_footprint.mxd TtEMI-OAK andrew.bley Site 2 Wetland TLSMW012 TLSMW003 !A !A

TLSMW004 TLSMW008 !A TLSMW002 !A !A

Site 1 Landfill

TLSMW009 TLSMW005 !A !A

TLSMW001 !A TLSMW010 !A

TLSMW006 !A TLSMW007 !A

!A Monitoring Well

Site 1 Landfill MILITARY OCEAN TERMINAL CONCORD

FIGURE 5 0 250 500 SITE 1 LANDFILL PERIMETER Feet MONITORING WELL LOCATIONS

Aerial Photo was taken within the last two years Site 1 Five-Year Report 2010-09-13 13:44 v:\concord\projects\site_01\5_year_plan_2010\landfill_and_monitoring_wells.mxd TtEMI-OAK andrew.bley

ATTACHMENTS

ATTACHMENT A SITE 1 LANDFILL CHRONOLOGY

TABLE A-1. SITE 1 LANDFILL CHRONOLOGY First Five-Year Review for Site 1 Tidal Area Landfill, Military Ocean Terminal Concord, Concord, California

Author/Responsible Date Event Party Navy purchase of land from Pacific Coast Shipbuilding March 12, 1942 Navy Company. Initial Assessment Study conducted under Navy 1981 to 1983 Assessment and Control of Installation Pollutants Ecology and Environment Program identified six sites for further study. Final Work Plan for Remedial Investigation at Naval 10/01/90 Weapons Station, Concord, California: Work Plan, IT Corporation Tidal Area Sites. Technical Memorandum: Preliminary Results of Remedial Investigation, Phase I Site Characterization 07/01/91 IT Corporation Activities, Tidal Area Sites, Naval Weapons Station, Concord, California. Draft Site Investigation Report, Tidal Area Sites, Naval 07/01/92 IT Corporation Weapons Station, Concord, California. Draft Preliminary Risk Evaluation, Tidal Area Sites, 08/01/92 IT Corporation Naval Weapons Station, Concord, California. NWS SBD Concord was included on the National 12/16/94 EPA Priorities List The Navy documents its intent to use a presumptive remedy approach for Site 1 in December 1994 in the PRC and Montgomery December 1994 Remedial Investigation/Feasibility Study Tidal Area Watson Sites Draft Final Work Plan. PRC Environmental Draft Remedial Investigation Tidal Area Sites 1, 2, 9, 04/16/97 Management, Inc. and and 11, Naval Weapons Station Concord. Montgomery Watson Draft Summary Report, Radiological Survey, Tidal Area PRC Environmental 07/28/97 Landfill, Naval Weapons Station Concord, California. Management, Inc. Draft Tidal Area Landfill Feasibility Study Report, Naval Tetra Tech EM Inc. and 09/15/97 Weapons Station, Concord, California. Levine-Fricke-Recon, Inc. Draft Final Feasibility Study Tidal Area Landfill, Site 1, Tetra Tech EM Inc. and 06/01/98 Weapons Support Facility Seal Beach Detachment Levine-Fricke-Recon, Inc. Concord, Concord California. Draft Proposed Plan and Record of Decision for Tidal 09/28/98 Area Landfill, Site 1, Weapons Support Facility, Seal Tetra Tech EM Inc. Beach, Detachment Concord, Concord, California. Draft Final Remedial Investigation Tidal Area Sites 1, 2, 06/06/99 9, and 11, Naval Weapons Station, Seal Beach Tetra Tech EM Inc. Detachment, Concord, California. 09/01/01 Draft Final Record of Decision, Tidal Area Landfill. Tetra Tech EM Inc.

Attachment A, First Five-Year Review Report for A-1 Site 1 Tidal Area Landfill Military Ocean Terminal Concord TABLE A-1. SITE 1 LANDFILL CHRONOLOGY (CONTINUED) First Five-Year Review for Site 1 Tidal Area Landfill, Military Ocean Terminal Concord, Concord, California

Author/Responsible Date Event Party Revised Draft Final Tidal Area Landfill Record of 06/26/03 Tetra Tech EM Inc. Decision. Final Record of Decision, Tidal Area Landfill Site 1, 04/13/04 Naval Weapons Station Seal Beach Detachment Tetra Tech EM Inc. Concord, Concord, California. Groundwater Sampling Summary Report for the Tidal 06/24/04 Area Landfill (Site 1) Naval Weapons Station Seal Tetra Tech EM Inc. Beach Detachment Concord, Concord, California. Final Record of Decision, Tidal Area Landfill Site 1, 07/01/04 Naval Weapons Station Seal Beach Detachment Tetra Tech EM Inc. Concord, Concord, California. 75% Construction Specifications Landfill Cover Tidal 07/21/04 Area Landfill, Site 1, Naval Weapons Station Seal Tetra Tech EM Inc. Beach, Detachment Concord, Concord, California. Pre-Final (95%) Remedial Construction Specifications Landfill Cover Tidal Area Landfill, Site 1, Naval 12/23/04 Tetra Tech EM Inc. Weapons Station Seal Beach, Detachment Concord, Concord, California. Final Landfill Gas Sampling and Analysis Plan (Field Sampling Plan/Quality Assurance Project Plan) Site 1 01/17/05 Tetra Tech EM Inc. Tidal Area Landfill, Naval Weapons Station Seal Beach Detachment Concord, Concord, California. Landfill Gas Characterization, Site 1 Tidal Area Landfill, 04/14/05 Naval Weapons Station Seal Beach Detachment Tetra Tech EM Inc. Concord, Concord, California. Liquefaction Study, Site 1 Tidal Area Landfill, Naval 04/15/05 Weapons Station Seal Beach Detachment Concord, Tetra Tech EM Inc. Concord, California. Final (100%) Remedial Construction Specifications Landfill Cover, Tidal Area Landfill, Site 1, Naval 05/13/05 Tetra Tech EM Inc. Weapons Station Seal Beach, Detachment Concord, Concord, California. Draft Final Closure Plan and Post-Closure Maintenance 05/13/05 Plan, Site 1 Tidal Area Landfill, Naval Weapons Station Tetra Tech EM Inc. Seal Beach, Detachment Concord, Concord, California. Phase I of landfill construction initiated with installation 09/29/05 of gas monitoring probes around the perimeter of the Navy landfill Revised Final (100%) Remedial Construction Specifications, Landfill Cover, Tidal Area Landfill, 02/26/06 Tetra Tech EM Inc. Site 1, Naval Weapons Station Seal Beach, Detachment Concord, Concord, California.

Attachment A, First Five-Year Review Report for A-2 Site 1 Tidal Area Landfill Military Ocean Terminal Concord TABLE A-1. SITE 1 LANDFILL CHRONOLOGY (CONTINUED) First Five-Year Review for Site 1 Tidal Area Landfill, Military Ocean Terminal Concord, Concord, California

Author/Responsible Date Event Party Naval Weapons Station Seal Beach Detachment 04/28/06 Concord, Concord, California, IR Site 1 – Tidal Area Tetra Tech EM Inc. Landfill Cover Final Remedial Design Drawings. Letter Regarding Review of Tidal Area Landfill Design Change Determination (w/ enclosures). From Phillip 05/22/06 EPA Ramsey. To L. Chung, Naval Facilities Engineering Command Southwest, Desert Integrated Product Team. Munitions of explosive concern (MEC) discovered 06/15/06, within the landfill (broken open Hedgehog bomb, and Navy 07/06/06 the other an intact Hedgehog bomb). During winterization activities, additional MEC consisting of an MK 29 point-detonating nose fuze for a 10/05/06 5-inch projectile and various munitions debris, including Navy unfired and fired flash and burster tubes, and flare cartridges discovered. Groundwater Investigation Data Submittal Tidal Area 11/15/06 Landfill, Site 1 Naval Weapons Station Seal Beach, SulTech Detachment Concord, Concord, California. Draft Technical Memorandum Landfill Cap Redesign, 03/05/07 Site 1 Tidal Area Landfill, Naval Weapons Station Seal Tetra Tech EM Inc Beach Detachment Concord, Concord, California. Delineation of Wetlands at Site 1 Tidal Area Landfill (Landfill Remediation Project pursuant to the Comprehensive Environmental Response, 09/25/07 Tetra Tech EM Inc. Compensation, and Liability Act), Naval Weapons Station Seal Beach Detachment Concord, Concord, California. Final Explanation of Significant Differences, Landfill Cap Redesign, IR Site 1, Tidal Area Landfill, Naval 05/22/08 Tetra Tech EM Inc. Weapons Station Seal Beach Detachment Concord, Concord, California Navy holds a public meeting to address public concern 06/26/08 about the haul route for importing fill to the Site 1 Navy Landfill The Navy transfers the tidal area portion of the former Naval Weapons Seal Beach Detachment Concord to 01/10/08 Navy/Army the Army. The Army installation is designated Military Ocean Terminal Concord

Attachment A, First Five-Year Review Report for A-3 Site 1 Tidal Area Landfill Military Ocean Terminal Concord TABLE A-1. SITE 1 LANDFILL CHRONOLOGY (CONTINUED) First Five-Year Review for Site 1 Tidal Area Landfill, Military Ocean Terminal Concord, Concord, California

Author/Responsible Date Event Party Navy construction activities of the revised landfill cap began. Unexpected increase in foundation material quantities; attributed to subsidence. Soil imports were March 2009 Navy interrupted in March 2009 and the site was graded to an elevation near the revised design foundation level over the central portion of the landfill. Army requests that no additional soil be imported to June 2009 the Site 1 Landfill until the subsidence issue is fully Army evaluated. Memorandum for; Project Manager, Military Ocean Terminal Concord (Cynthia Burris), Military Ocean 01/22/10 USACE Terminal Concord (MOTCO) Site 1 Tidal Area Landfill Remedial Approach. CESPK-ED-EE. Memorandum for PM, Military Ocean Terminal Concord 02/19/10 (MOTCO) Site 1 Tidal Area Landfill Geotechnical USACE Evaluation. CESPK-ED-EE. Memorandum for PM, Military Ocean Terminal Concord 02/22/10 (MOTCO) Site 1 Tidal Area Landfill Review Summary. USACE CESPK-ED-EE. Interim Remedial Action Completion Report for IR Site 1 Oneida Total Integrated 08/30/10 Landfill Cover Construction. Naval Weapons Station Enterprises Seal Beach Detachment Concord, Concord, California. MOTCO Environmental Restoration Services: Site 1 08/31/10, Landfill Redesign, Concord, California. Technical American Integrated 09/01/10 Approach Meeting Presentation to the agencies and Services, Inc. Restoration Advisory Board.

Attachment A, First Five-Year Review Report for A-4 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

ATTACHMENT B SITE INSPECTION

Site 1 Landfill – September 14, 2010

Figure 1: Silt Fence ‐ north east Figure 2: Top of landfill –facing north boundary

B‐1 Site 1 Landfill – September 14, 2010

Figure 3: Burrowing on side slope Figure 4: Burrowing on top of cover

B‐2 Site 1 Landfill – September 14, 2010

Figure 5: Silt fence –facing northwest Figure 6: Silt fence, exposed waste (rebar)

B‐3 Site 1 Landfill – September 14, 2010

Figure 7: Erosion control –northern Figure 8: Erosion control –northern boundary looking up (south facing) boundary looking down (north facing)

B‐4 Site 1 Landfill – September 14, 2010

Figure 9: Silt fence –toe of landfill Figure 10: Erosion control facing facing west north west

B‐5 Site 1 Landfill – September 14, 2010 Figure 11: Erosion control south side Figure 12: Erosion control south side of landfill of landfill

B‐6 Site 1 Landfill – September 14, 2010

Figure 13: Piezometer – along Figure 14: Monitoring well southeast boundary TLSMW006

B‐7 Site 1 Landfill – September 14, 2010

Figure 15: Erosion southeast side of Figure 16: Erosion southeast side of landfill, side slope landfill, top of cover

B‐8 Site 1 Landfill – September 14, 2010

Figure 17: Gas monitoring probe 2 Figure 18: Gas monitoring probe 3

B‐9

Site Inspection Checklist

I. SITE INFORMATION Site name: Site 1 Landfill Date of inspection: September 14, 2010 Location and Region: EPA ID: CA7170024528 Military Ocean Terminal Concord Owner/Operator: Port of Chicago Highway United States Department of the Navy Concord, CA 94520 Agency, office, or company leading the Five-Year Review: Weather/temperature: Breezy/approx. 78º F Army Environmental Command supported by Tetra Tech Remedy Includes: (Check all that apply) 7 Landfill cover/containment Monitored natural attenuation 7Access controls Groundwater containment Institutional controls Vertical barrier walls Groundwater pump and treatment Surface water collection and treatment Other Evacuation of

Although the remedy is incomplete, there have been substantial improvements in protection to human health and the environment since the start of construction. The potential for direct exposure to landfill waste has been substantially reduced due to the thick layer of fill which covers nearly the entire landfill. Also, because the site is now sloped to drain and because it is now covered with compacted fill, the infiltration of rainwater has been reduced substantially over the preconstruction conditions. ______Attachments: Inspection team roster attached (See Section 6.5) Site map attached (See Figure 1) II. INTERVIEWS (Check all that apply) 1. O&M site manager ______Not Applicable N/A______Name Title Date Interviewed at site at office by phone Phone no. ______Problems, suggestions; Report attached ______

2. O&M staff ______Not Applicable N/A ______Name Title Date Interviewed at site at office by phone Phone no. ______Problems, suggestions; Report attached ______

Attachment B, First Five-Year Review Report for B-10 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.

Agency MOTCO Environmental Coordinator Contact __Sunny Sea ______14 September, 2010 Name Title Date Phone no. Problems; suggestions; Report attached 7 No problems associated with the site______

Agency ______Contact ______Name Title Date Phone no. Problems; suggestions; Report attached ____No Problems associated with the site______

Agency ______Contact ______Name Title Date Phone no. Problems; suggestions; Report attached ______

Agency ______Contact ______Name Title Date Phone no. Problems; suggestions; Report attached ______

4. Other interviews (optional) Report attached. Not Applicable.

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 1. O&M Documents O&M manual Readily available Up to date 7 N/A As-built drawings Readily available Up to date 7 N/A Maintenance logs Readily available Up to date 7 N/A Remarks______

Attachment B, First Five-Year Review Report for B-11 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

2. Site-Specific Health and Safety Plan Readily available Up to date 7 N/A Contingency plan/emergency response plan Readily available Up to date 7 N/A Remarks______3. O&M and OSHA Training Records Readily available Up to date 7 N/A Remarks______4. Permits and Service Agreements Air discharge permit Readily available Up to date 7 N/A Effluent discharge Readily available Up to date 7 N/A Waste disposal, POTW Readily available Up to date 7 N/A Other permits______Readily available Up to date 7 N/A Remarks______5. Gas Generation Records Readily available Up to date 7 N/A Remarks______6. Settlement Monument Records Readily available Up to date 7 N/A Remarks______7. Groundwater Monitoring Records Readily available Up to date 7 N/A Remarks______8. Leachate Extraction Records Readily available Up to date 7 N/A Remarks______9. Discharge Compliance Records Air Readily available Up to date 7 N/A Water (effluent) Readily available Up to date 7 N/A Remarks______10. Daily Access/Security Logs Readily available Up to date 7 N/A Remarks______

IV. O&M COSTS 1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house 7 Contractor for Federal Facility Other______

Attachment B, First Five-Year Review Report for B-12 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

2. O&M Cost Records Readily available 7 Up to date Funding mechanism/agreement in place Original O&M cost estimate N/A Breakdown attached

Cost breakdown provided in Section 5 of the Five-Year Review Assessment report.

Total annual cost by year for review period if available

From______To______Breakdown attached Date Date Total cost From______To______Breakdown attached Date Date Total cost From______To______Breakdown attached Date Date Total cost From______To______Breakdown attached Date Date Total cost From______To______Breakdown attached Date Date Total cost

3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: ______V. ACCESS AND INSTITUTIONAL CONTROLS 7 Applicable N/A A. Access Restrictions 1. Signs and other security measures Location shown on site map N/A Remarks: Operating base with no public access. U.S. Army security patrols the area to provide added security measures. ______B. Institutional Controls (ICs)

Attachment B, First Five-Year Review Report for B-13 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

1. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No 7 N/A Site conditions imply ICs not being fully enforced Yes No 7 N/A

Type of monitoring (e.g., self-reporting, drive by) ______Frequency ______Responsible party/agency ______Contact ______Name Title Date Phone no.

Reporting is up-to-date Yes No 7 N/A Reports are verified by the lead agency Yes No 7 N/A

Specific requirements in deed or decision documents have been met Yes No 7 N/A Violations have been reported Yes No 7N/A Other problems or suggestions: Report attached ______2. Adequacy ICs are adequate ICs are inadequate 7 N/A Remarks______D. General 1. Vandalism/trespassing 7Location shown on site map 7 No vandalism evident Remarks______2. Land use changes on site 7 N/A Remarks______3. Land use changes off site N/A Remarks______VI. GENERAL SITE CONDITIONS A. Roads Applicable 7 N/A 1. Roads damaged Location shown on site map Roads adequate 7 N/A Remarks______B. Other Site Conditions

Attachment B, First Five-Year Review Report for B-14 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

Remarks __See notes on the site tour in “Other Observations”.______

Interim cover on waste, Final cover not installed. Inspected cover surface, gas probes, and monitoring wells. ______

VII. LANDFILL COVERS Applicable 7 N/A – landfill cover still under construction A. Landfill Surface 1. Settlement (Low spots) Location shown on site map 7 Settlement not evident Areal extent______Depth______

Remarks: No noticeable differential settlement 2. Cracks Location shown on site map 7 Cracking not evident Lengths______Widths______Depths______Remarks None evident ______3. Erosion Location shown on site map Erosion not evident Areal extent______Depth______Remarks Erosion along the south east side of landfill about 2-foot deep into the existing cover soil.. Erosion is occurring where perimeter berm around the cover ends, an sheet flow from the cover accumulates and discharges down the slope ______4. Holes Location shown on site map Holes not evident Areal extent______Depth______Remarks Miscellaneous small holes around the perimeter of the cover from small burrowing animals ______5. Vegetative Cover Grass Cover properly established No signs of stress G Trees/Shrubs (indicate size and locations on a diagram) Remarks: None on top, Existing brush around slope seems in place ______6. Alternative Cover (armored rock, concrete, etc.) 7 N/A Remarks______7. Bulges Location shown on site map 7 Bulges not evident Areal extent______Height______Remarks Not Evident ______8. Wet Areas/Water Damage 7 Wet areas/water damage not evident Wet areas Location shown on site map Areal extent______Ponding Location shown on site map Areal extent______Seeps Location shown on site map Areal extent______Soft subgrade Location shown on site map Areal extent______Remarks______

Attachment B, First Five-Year Review Report for B-15 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

9. Slope Instability Slides Location shown on site map 7 No evidence of slope instability Areal extent______Remarks______B. Benches Applicable 7 N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) 1. Flows Bypass Bench Location shown on site map 7 N/A or okay Remarks______2. Bench Breached Location shown on site map 7 N/A or okay Remarks______3. Bench Overtopped Location shown on site map 7 N/A or okay Remarks______C. Letdown Channels 7 Applicable N/A (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

[Temporary channels are in place at 4 locations. Each channel is traversed by straw rolls anchored in place with fence posts. A 5th channel is needed at the southeastern end of the cover where sheet flow discharges from the cover down the slope and is creating a gulley. See erosion, item A3, above

A silt fence has been installed around the toe of the slope. It is intact and in good shape. 1. Settlement Location shown on site map 7No evidence of settlement Areal extent______Depth______Remarks No evidence of differential settlement ______2. Material Degradation Location shown on site map 7 No evidence of degradation Material type______Areal extent______Remarks Straw rolls are in good shape ______3. Erosion Location shown on site map No evidence of erosion Areal extent______Depth______Remarks None evident, except the need for a 5th channel ______4. Undercutting Location shown on site map 7 No evidence of undercutting Areal extent______Depth______Remarks______

Attachment B, First Five-Year Review Report for B-16 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

5. Obstructions Type______7 No obstructions Location shown on site map Areal extent______Size______Remarks______6. Excessive Vegetative Growth Type______7 No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on site map Areal extent______Remarks______D. Cover Penetrations Applicable N/A 1. Gas Vents Active 7 Passive Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks______2. Gas Monitoring Probes 7 Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks Three probe protective covers in good shape ______3. Monitoring Wells (within surface area of landfill) 7 Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance N/A Remarks Wells at Site 2 were observed. No MWs within the surface of the landfill. MWs 12, 4, 5, 6, and 7 appear properly locked and sealed. Unable to observe MWs in water – MW 1, 2, 8, and 3

4. Leachate Extraction Wells Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs Maintenance 7 N/A Remarks______5. Settlement Monuments Located Routinely surveyed 7 N/A Remarks______None______E. Gas Collection and Treatment Applicable 7 N/A 1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs Maintenance Remarks______2. Gas Collection Wells, Manifolds and Piping Good condition Needs Maintenance Remarks______

Attachment B, First Five-Year Review Report for B-17 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs Maintenance N/A Remarks______F. Cover Drainage Layer Applicable 7 N/A 1. Outlet Pipes Inspected Functioning N/A Remarks______2. Outlet Rock Inspected Functioning N/A Remarks______G. Detention/Sedimentation Ponds Applicable 7 N/A 1. Siltation Areal extent______Depth______N/A Siltation not evident Remarks______2. Erosion Areal extent______Depth______Erosion not evident Remarks______3. Outlet Works Functioning N/A Remarks______4. Dam Functioning N/A Remarks______H. Retaining Walls Applicable 7 N/A 1. Deformations Location shown on site map Deformation not evident Horizontal displacement______Vertical displacement______Rotational displacement______Remarks______2. Degradation Location shown on site map Degradation not evident Remarks______I. Perimeter Ditches/Offsite Discharge Applicable 7 N/A 1. Siltation Location shown on site map Siltation not evident Areal extent______Depth______Remarks______2. Vegetative Growth Location shown on site map N/A Vegetation does not impede flow Areal extent______Type______Remarks______

Attachment B, First Five-Year Review Report for B-18 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

3. Erosion Location shown on site map Erosion not evident Areal extent______Depth______Remarks______4. Discharge Structure Functioning N/A Remarks______VIII. VERTICAL BARRIER WALLS Applicable 7 N/A 1. Settlement Location shown on site map Settlement not evident Areal extent______Depth______Remarks______2. Performance Monitoring Type of monitoring______Performance not monitored Frequency______Evidence of breaching Head differential______Remarks______IX. GROUNDWATER/SURFACE WATER REMEDIES Applicable 7 N/A A. Groundwater Extraction Wells, Pumps, and Pipelines Applicable N/A 1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells located Needs O&M N/A Remarks______

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M Remarks______3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided Remarks______B. Surface Water Collection Structures, Pumps, and Pipelines Applicable N/A 1. Collection Structures, Pumps, and Electrical Good condition Needs O&M Remarks______2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M Remarks______3. Spare Parts and Equipment Readily available Good condition Requires upgrade Needs to be provided Remarks______

Attachment B, First Five-Year Review Report for B-19 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

C. Treatment System Applicable 7 N/A 1. Treatment Train (Check components that apply) Metals removal Oil/water separation Bioremediation Air stripping Carbon adsorbers Filters______Additive (e.g., chelation agent, flocculent)______Others______Good condition Needs Maintenance Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually______Quantity of surface water treated annually______Remarks______

2. Electrical Enclosures and Panels (properly rated and functional) N/A Good condition Needs Maintenance Remarks______3. Tanks, Vaults, Storage Vessels N/A Good condition Proper secondary containment Needs Maintenance Remarks______4. Discharge Structure and Appurtenances N/A Good condition Needs Maintenance Remarks______5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Needs repair Chemicals and equipment properly stored Remarks______6. Monitoring Wells (pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks______

Attachment B, First Five-Year Review Report for B-20 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

D. Monitoring Data 1. Monitoring Data Is routinely submitted on time Is of acceptable quality 2. Monitoring data suggests: Groundwater plume is effectively contained Contaminant concentrations are declining

D. Monitored Natural Attenuation 1. Monitoring Wells (natural attenuation remedy) Properly secured/locked Functioning 7 Routinely sampled Good condition All required wells located Needs Maintenance N/A Remarks______

X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). ______B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy. ______

C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future. ______D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. ______

Attachment B, First Five-Year Review Report for B-21 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

ATTACHMENT C INTERVIEW REPORTS

INTERVIEW DOCUMENTATION FORM The following is a list of individual interviewed for this Five-Year Review. See the attached contact record(s) for a detailed summary of the interviews.

Phillip Ramsey Lead RPM EPA 9/8/10 14:30 Name Title/Position Organization Date

Alan Friedman Lead RPM Water Board 9/9/10 8:30 Name Title/Position Organization Date

Lead RPM 9/9/10 10:00 Title/Position Jim Pinasco DTSC Date Name Organization

Igor Skaredoff RAB Co-Chair Community Member 9/12/10 17:15 Name Title/Position Organization Date

Cindy Welles RAB Community Member 9/8/10 16:30 Name Title/Position Organization Date

Attachment C, First Five-Year Review Report for C-1 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

INTERVIEW RECORD

Site Name: Site 1 Landfill Military Ocean Terminal Concord EPA ID No.: CA7170024528 Subject: Site 1 Remedial Efforts Time: PDT Date: Type: 7Telephone Visit Other Incoming 7Outgoing Location of Visit: Contact Made By: Name: Carolyn Hunter Title: Community Relations Organization: Tetra Tech Specialist Individual Contacted: Name: Mr. Phillip Ramsey Title: Lead RPM Organization: US EPA Telephone No: 415-972-3006 Street Address: 75 Hawthorne Street, Floor SFD 8-3 Fax No: City, State, Zip: San Francisco, CA 94105

E-Mail Address: [email protected] Summary Of Conversation

1) What is your overall impression of the project? (general sentiment): EPA Remedial Project Manager (RPM’s) impression of the remediation of Site 1 is that it is taking a long time to be completed. The Navy completed the Record of Decision (ROD) for Site 1 in 2004. The Site 1 ROD took a few years to be signed by all of the regulatory agencies. EPA acknowledges that the landfill closure laws were agreed on in 2004 for Site 1. The discovery of munitions caused another delay in the completion of the cap. EPA understood the implications of finding munitions on the landfill and the surrounding sites. EPA is optimistic that the Army’s new plan will resolve the issues and complete the last phase of the remedial design of the landfill cap. The Army’s plan looks like the landfill cap will be completed within the next year.

2) Have there been routine communications or activities (site visits, inspections, report activities, etc.) conducted by your office regarding the site? If so please give purpose and results: EPA has been intimately involved in the all of the events at Site 1. EPA has been fairly engaged with the Army in getting the project completed. The Army just gave EPA a revised plan to complete the landfill design which seems workable. There could have been better communication on Site 1 from the Army to EPA. It would have been helpful for the Army to call EPA to get more of the historical background on the Site 1 landfill when preparing the path forward. EPA has a lot of the site history that would have been useful to the Army.

3) Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the responses: There was considerable interest from the community on the haul route for the landfill cap soil with the Navy in 2007. Recently, a community member from Bay Point contacted EPA regarding noise and vibration late at night coming from MOTCO. EPA spoke with the Army and no overnight work was being completed at the time of the Bay Point community member’s complaint. There have been no violations at Site 1. The Army is in compliance with the Federal Facilities Agreement and Site Management Plan for MOTCO.

4) Do you feel well informed about the site’s activities and progress: Yes.

5) Do you have any comments, suggestions, or recommendations regarding the site’s management or operation: EPA wants to work cooperatively with the Army to get the Site 1 Landfill completed.

Attachment C, First Five-Year Review Report for C-2 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

INTERVIEW RECORD

Site Name: Site 1 Landfill Military Ocean Terminal Concord EPA ID No.: CA7170024528 Subject: Site 1 Remedial Efforts Time: PDT Date: Type: 7Telephone Visit Other Incoming 7Outgoing Location of Visit: Contact Made By: Name: Carolyn Hunter Title: Community Relations Specialist Organization: Tetra Tech Individual Contacted: Name: Mr. Jim Pinasco Title: Lead Remedial Project Organization: Department of Toxics Manager Substances Control Telephone No: 916-255-3719 Street Address: 8800 Cal Center Drive Fax No: 916-255-3697 City, State, Zip: Sacramento, CA 95826 E-Mail Address: [email protected] Summary Of Conversation

1) What is your overall impression of the project? (general sentiment): This landfill cap was supposed to have been fast tracked in the 1990’s. The Army’s current proposal is the most sound design so far. The Army has a real landfill design team on board with experience.

2) Have there been routine communications or activities (site visits, inspections, report activities, etc.) conducted by your office regarding the site? If so please give purpose and results: Nothing independent of what the Navy or Army has done. Department of Toxic Substances Control Board (DTSC) has participated as part of the team.

3) Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the responses: Nothing outside of group speak.

4) Do you feel well informed about the site’s activities and progress: Yes, as well as can be expected.

5) Do you have any comments, suggestions, or recommendations regarding the site’s management or operation: DTSC thinks the new landfill design team will get the Site 1 Landfill cap completed. No one expected the tide gate to fail and complicate the project as well as the other unforeseen circumstances to cause the project delays.

Attachment C, First Five-Year Review Report for C-3 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

INTERVIEW RECORD

Site Name: Site 1 Landfill Military Ocean Terminal Concord EPA ID No.: CA7170024528 Subject: Site 1 Remedial Efforts Time: PDT Date: Type: 7Telephone Visit Other Incoming 7Outgoing Location of Visit: Contact Made By: Name: Carolyn Hunter Title: Community Relations Specialist Organization: Tetra Tech Individual Contacted: Name: Mr. Alan Friedman Title: Lead Remedial Project Organization: San Francisco Bay Regional Manager Water Quality Control Board Telephone No: 510-622-2347 Street Address: 1515 Clay Street, Suite 1400 Fax No: 510-622-2458 City, State, Zip: Oakland, CA 94612 E-Mail Address: [email protected] Summary Of Conversation

1) What is your overall impression of the project? (general sentiment): San Francisco Bay Regional Water Quality Control Board (Water Board) has been disappointed in the project. The transition of MOTCO from the Navy to the Army was badly handled. There were enormous delays getting the Army on track with handling the work and to get their contractors on board and up to speed. There should have been enough lead time between the Navy and Army to make a seamless transition. There were delays in putting the landfill cap on. There are many landfills in the area that have installed and completed a cap without these problems.

2) Have there been routine communications or activities (site visits, inspections, report activities, etc.) conducted by your office regarding the site? If so please give purpose and results: Yes. The Water Board has not seen Site 1 in a long time. There has been regular communication on the project between the Army and the Water Board. There have been delays in the Site 1 reports but the Water Board has been kept well informed.

3) Have there been any complaints, violations, or other incidents related to the site requiring a response by your office? If so, please give details of the events and results of the responses: No complaints or violations. No order has been issued to compel the completion of the landfill cap.

4) Do you feel well informed about the site’s activities and progress: Yes. Both the Navy and Army have kept the regulatory agencies well informed.

5) Do you have any comments, suggestions, or recommendations regarding the site’s management or operation: The Army needs to practice full disclosure on the project. The Water Board appreciates the Army Commander’s participation in recent meetings. The Army has made the commitment to properly close the landfill. The Army should be honest with the regulatory agencies and public on the progress of the landfill closure and delays.

Attachment C, First Five-Year Review Report for C-4 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

INTERVIEW RECORD

Site Name: Site 1 Landfill Military Ocean Terminal Concord EPA ID No.: CA7170024528 Subject: Site 1 Remedial Efforts Time: PDT Date: Type: 7Telephone Visit Other Incoming 7Outgoing Location of Visit: Contact Made By: Name: Carolyn Hunter Title: Community Relations Specialist Organization: Tetra Tech Individual Contacted: Name: Mr. Igor Skaredoff Title: RAB Co-Chair Organization: MOTCO RAB

Telephone No: 925-229-1371 Street Address: 411 Isabel Drive Fax No: City, State, Zip: Martinez, CA 94553 E-Mail Address: [email protected] Summary Of Conversation 1) What is your overall impression of the project? (general sentiment): Nothing much has happened at Site 1 in a long time before the Army took over the base. The delay in the transition between the Navy and Army was disappointing. I am optimistic with the Army’s new plan to cap the landfill. There has been more work completed on the landfill in the last 3 years than the past 10 years. The Army has seemed to have settled on the right way to cap the landfill. 2) What effects have site operations had on the surrounding community: Not sure. The Clyde community would be impacted more than the rest of the community. The revised truck hauling plan the Navy prepared after hearing the communities concerns made it so the landfill capping soil being hauled onto the base did not impact the community. 3) Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details: I do not think the community has any issues or is really aware of Site 1 at all. The community is more concerned with the Inland Area and the transfer to the City of Concord. The community is more aware that MOTCO is an active munitions’ hauling base. Very few community members know what Site 1 is. 4) Do you feel well informed about the site’s activities and progress: I feel fairly well informed. The military has given me information on Site 1. The Army Commander being involved recently has good intentions with informing the community. The Commander of the base being more involved creates an opportunity to more effectively convey information to the community. The MOTCO remedial team and military personnel are very straight forward with the community. 5) Do you have any comments, suggestions, or recommendations regarding the site’s management or operation: I am surprised that the military and regulatory agencies are not open to participation of Restoration Advisory Board (RAB) members in the technical cleanup meetings. I am sad that the Army and regulatory agencies do not have confidence in the community and will let RAB members listen in on their technical meetings. The RAB can help with providing the Army and regulatory agencies with good information and perspective to move forward with the cleanup program. Involving the RAB in the technical meetings will make them better advocates to the community. The relationship with the Army and the RAB is much better now than in the past.

Attachment C, First Five-Year Review Report for C-5 Site 1 Tidal Area Landfill Military Ocean Terminal Concord

INTERVIEW RECORD

Site Name: Site 1 Landfill Military Ocean Terminal Concord EPA ID No.: CA7170024528 Subject: Site 1 Remedial Efforts Time: PDT Date: Type: 7Telephone Visit Other Incoming 7Outgoing Location of Visit: Contact Made By: Name: Carolyn Hunter Title: Community Relations Specialist Organization: Tetra Tech Individual Contacted: Name: Ms. Cindy Welles Title: RAB Member Organization: MOTCO RAB

Telephone No: 925-685-2698 Street Address: 339 Wellington Ave Fax No: City, State, Zip: Clyde, CA 94520-1116 E-Mail Address: [email protected] mailto:[email protected] Summary Of Conversation

1) What is your overall impression of the project? (general sentiment): Capping the Site 1 Landfill has been a huge boondoggle waste of money. Too much time was wasted on this project. The Site 1 Landfill should have been capped and closed a long time ago. I hope the Army’s last plan will fix it.

2) What effects have site operations had on the surrounding community: Truck traffic and hedge hog found in the landfill and exploded on site were community concerns. The Navy did a good job finding an alternative truck haul route. The proposed alternative haul route was a success and there was no impact on the Town of Clyde.

3) Are you aware of any community concerns regarding the site or its operation and administration? If so, please give details: No. Nobody thinks of Site 1 being there. The community is unaware of Site 1.

4) Do you feel well informed about the site’s activities and progress: Yes.

5) Do you have any comments, suggestions, or recommendations regarding the site’s management or operation: No. It sounds like the Army’s proposed fix was well thought out. I am glad there is no more soil that needs to be hauled through the community onto the site to complete the cap. I am cautiously enthusiastic and hope it the landfill cap will be completed soon.

Attachment C, First Five-Year Review Report for C-6 Site 1 Tidal Area Landfill Military Ocean Terminal Concord