Final Dust Control and Air Monitoring Plan IR Site 2 - Alameda Point California

Luis Rivero, Lisa Tolbert, Michele Pribble
2013-04-25
City of Alameda

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RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 23. Inconsistent terminology is used in Attachments 8 and 9. For example, Section 3.3 (Dust Control Measures) of Attachment 9 states that chemical soil stabilizer will be applied to on-site storage piles of soil or sediments while Attachment 8 (Stormwater Pollution Prevention Plan) states that soil tackifier will be used to provide dust control and prevent runoff of stockpiled soils. In addition, Section 5.0 (Mitigation Contingencies) of Attachment 9 indicates that a nontoxic lockdown material will be used to suppress dust. It is unclear if these references are to the same product. In addition, a material safety data sheet (MSDS) should be included for this (these) product(s). Please revise the Draft RD/RA WP to use consistent terminology throughout the document and include a MSDS for the intended dust mitigation media.

Response 23. The terminology in Attachments 8 and 9 has been revised to consistently reference a “soil tackifier (Soiltac® or equivalent)” when discussing stabilization of stockpiled soil/sediments or dust control measures. A MSDS has been included in Attachment 9.

 

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TABLES

 

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Page 1 of 1

 

 

TABLE 4-1

 

DERIVED AIRBORNE CONCENTRATIONS FOR RADIONUCLIDES OF INTEREST

 

 

 

Radionuclide

 

Radiation

DAC

(mCi/mL)

10% DAC

(mCi/mL)

Radium-226

 

Alpha (a)

3.0 × 10-10

3.0 × 10-11

Thorium-232

5.0 × 10-13

5.0 × 10-14

Uranium-238

2.0 × 10-11

2.0 × 10-12

Strontium-90

Beta (b-)

8.0 × 10-9

8.0 × 10-10

Cobalt-60

Beta/gamma (b-, g)

7.0 × 10-8

7.0 × 10-9

Cesium-137

6.0 × 10-8

6.0 × 10-9

Abbreviations and Acronyms:

mCi/mL – microcuries per milliliter CFR – Code of Federal Regulations

DAC – derived air concentration (10 CFR 20 Appendix B)

 

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FIGURES

 

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Figure 2-1. Wind Rose Diagram for Alameda Point

 

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APPENDIX A

MATERIAL SAFETY DATA SHEET

 

 

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Soiltac Material Safety Data Sheet

Formula Placeholder

 

ATTACHMENT 10 WASTE MANAGEMENT PLAN

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

CONTRACT NO. N62473-10-D-0809 CTO NO. 0009

 

ATTACHMENT 10

 

FINAL

WASTE MANAGEMENT PLAN

April 2013

 

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA DCN: RMAC-0809-0009-0004

 
   


Prepared by:

1230 Columbia Street, Suite 750 San Diego, California 92101-8530

 

 

 

Prepared by:                                                                                    Jennifer Dessort

Environmental Compliance Manager

 

Reviewed by:                                                                                                                                                              Hedy Abedi, PhD, PE

Project Manager

 

 

 

PAGE ABBREVIATIONS AND ACRONYMS...................................................................................... iii

1.0        WASTE MANAGEMENT PLAN..................................................................................... 1-1

1.1           PROJECT WASTE DESCRIPTIONS..................................................................... 1-1

1.2           WASTE MANAGEMENT...................................................................................... 1-2

1.2.1           Waste Classification.................................................................................... 1-2

1.2.2           Waste Accumulation and Storage............................................................... 1-4

1.2.3           Soil and Waste Stockpiles and Staging Piles............................................... 1-4

1.2.4           Wastewater and Waste Fluids..................................................................... 1-6

1.2.5           Used Personal Protective Equipment.......................................................... 1-7

1.2.6           Container Labeling...................................................................................... 1-7

1.2.7           Waste Accumulation Areas......................................................................... 1-8

1.2.8           Waste Disposal............................................................................................ 1-8

1.2.9           Waste Transportation................................................................................... 1-9

1.2.10       Waste Minimization..................................................................................... 1-9

1.2.11       Waste Management Inspection and Documentation Program.................. 1-10

1.2.12       Inspections................................................................................................. 1-10

1.2.13       Documentation.......................................................................................... 1-11

1.2.14       Hazardous Waste Manifests and LDR Certification................................. 1-11

1.3           WASTE MANAGEMENT FOR RADIOACTIVE WASTES.............................. 1-12

1.3.1           Waste Classification.................................................................................. 1-12

1.3.2           Waste Accumulation and Storage............................................................. 1-13

1.3.3           Radiological Point Sources....................................................................... 1-13

1.3.4           Soil, Debris, and Materials........................................................................ 1-13

1.3.5           Wastewater and Waste Fluids................................................................... 1-14

1.3.6           Labeling and Posting of Containers Containing Radioactive Waste........ 1-14

1.3.7           Waste Accumulation Areas....................................................................... 1-14

1.3.8           Waste Disposal.......................................................................................... 1-15

1.3.9           Waste Transportation................................................................................. 1-15

1.3.10       Waste Minimization................................................................................... 1-15

1.3.11       Inspections................................................................................................. 1-16

1.3.12       Documentation.......................................................................................... 1-16

1.3.13       Radioactive Waste Manifests.................................................................... 1-17

1.4           HAZARDOUS MATERIAL SECURITY PLAN................................................. 1-17

1.5           UPDATING THE WASTE MANAGEMENT PLAN........................................... 1-17

2.0    REFERENCES................................................................................................................... 2-1

 

 

 

 

 

 

 

 

Attachment 10 Waste Mgmt Plan.docx                                                                                            i                                                 Final Waste Management Plan IR Site 2, Alameda Point, Alameda, California

DCN: RMAC-0809-0009-0004

CTO No. 0009

 

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TABLES

 

Table 1-1         Summary of Waste Management, Transportation, and Disposal Requirements

 

 

 

 

ARAR

applicable or relevant and appropriate requirement

BMP

best management practice

CAMU

Corrective Action Management Unit

CCR

California Code of Regulations

CERCLA

Comprehensive Environmental Response, Compensation, and Liability Act

CFR

Code of Federal Regulations

DoD

Department of Defense

DON

Department of the Navy

DOT

Department of Transportation

EPA

U.S. Environmental Protection Agency

IR

Installation Restoration (Program)

LDR

land disposal restriction

LLCW

low-level contaminated waste

LLMW

low-level mixed waste

LLRW

low-level radioactive waste

mR/hr

milliroentgens per hour

NRC

Nuclear Regulatory Commission

PjM

Project Manager

PPE

personal protective equipment

RASO

Radiological Affairs Support Office

RCRA

Resource Conservation and Recovery Act

RTM

Remedial Technical Manager

STLC

Soluble Threshold Limit Concentration

SWPPP

Stormwater Pollution Prevention Plan

TSDF

treatment, storage, and disposal facility

TtEC

Tetra Tech EC, Inc.

TTLC

Total Threshold Limit Concentration

WET

Waste Extraction Test

WMP

Waste Management Plan

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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The purpose of the Waste Management Plan (WMP) is to present the waste management practices and procedures to be followed for the types and quantities of waste expected to be generated during the field activities at Installation Restoration Program (IR) Site 2. The WMP identifies waste management activities conducted during the storage and the preparation and/or disposal of waste (including waste characterization, packaging, storage, and management while in storage). The transportation and disposition of waste materials at appropriate disposal and recycling facilities are also included. It is the responsibility of the Project Manager (PjM) to verify that all project personnel are aware of the requirements stipulated in this WMP.

 

The WMP provides information on how wastes, including potentially hazardous wastes associated with project activities, will be managed and disposed. In addition, a secondary goal of this section is to ensure that waste minimization practices are followed, to the extent practical, to reduce the volume of waste that will be generated, stored, and removed from the site for disposal.

 

The WMP is also a primary component of the Tetra Tech EC, Inc. (TtEC), Compliance Program, which includes on-site environmental compliance inspections. The WMP will be revised if the scope of this project or the applicable regulations change.

1.1         PROJECT WASTE DESCRIPTIONS

Construction activities will involve the generation, management, and disposal of various waste streams, which may include:

  • Green waste including grass, shrubs, and trees removed prior to grading activities
  • Low-level radioactive waste (LLRW) including soil and point sources
  • RCRA hazardous, non-RCRA hazardous, and nonhazardous soil
  • Nonhazardous solid waste, such as trash, empty calibration gas canisters, and inert construction debris
  • Oversized contaminated debris – rock, wood, piping, concrete, and scrap metal
  • Wastewater, including impacted stormwater runoff, fluids from equipment and personnel decontamination, and groundwater monitoring well development purge water
  • Used oil (including motor oil, hydraulic fluid, greases, antifreeze/coolant, and so forth), oil filters, fuel and air filters from equipment maintenance operations
  • Decontamination pad solids/sludges
  • Used polyethylene liners from soil stockpiles and/or waste storage areas
  • Used personal protective equipment (PPE)

 

 

During these activities, the site will be managed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Area-of-Contamination policy, which allows impacted soil and/or waste to be uncovered, moved, and reconsolidated without triggering the Resource Conservation and Recovery Act (RCRA) land disposal restrictions (LDRs) and minimum technical requirements for a landfill under RCRA.

 

Table 1-1 presents a summary of applicable waste characterization, containment, storage, transportation, and disposal requirements for each of the aforementioned waste streams.

1.2         WASTE MANAGEMENT

In accordance with the applicable or relevant and appropriate requirements (ARARs) for remedial activities, the substantive requirements of the state and federal hazardous waste generation, characterization, storage, treatment, and management regulations of Title 22 California Code of Regulations (CCR), Sections 66261, 66262, and 66264, and 40 Code of Federal Regulations (CFR), Parts 261, 262 and 264, are applicable to the management of hazardous  wastes  generated  during  the  remedial  action  and  associated  project  activities.   A summary of the key aspects of the waste management program is provided below.

1.2.1        Waste Classification

Federal RCRA hazardous waste determination is necessary to determine whether a waste is subject to RCRA requirements at Title 22 CCR, Division 4.5 and other state requirements at  Title 23 CCR, Division 3, Chapter 15. The first step in the RCRA hazardous waste characterization process is to evaluate contaminated media at the site(s) and determine whether it constitutes a “listed” RCRA waste. The preamble to the National Oil and Hazardous Substances Pollution Contingency Plan states that “…it is often necessary to know the origin of the waste to determine whether it is a listed waste and that, if such documentation is lacking, the lead agency may assume it is not a listed waste” (55 Federal Regulation 8666, 8758 [1990]).

 

This approach is confirmed in the U.S. Environmental Protection Agency (EPA) guidance for CERCLA compliance with other laws (EPA 1988), as follows: “To determine whether a waste is a listed waste under RCRA, it is often necessary to know the source. However, at many Superfund sites, no information exists on the source of wastes. The lead agency should use available site information, manifests, storage records, and vouchers in an effort to ascertain the nature of these contaminants. When this documentation is not available, the lead agency may assume that the wastes are not listed RCRA hazardous wastes, unless further analysis or information becomes available that allows the lead agency to determine that the wastes are listed RCRA hazardous wastes.”

 

RCRA hazardous wastes that have been assigned EPA hazardous waste numbers (or codes) are listed in Title 22 CCR, Sections 66261.30 through 66261.33. The lists include hazardous waste codes beginning with the letters “F,” “K,” “P,” and “U.” Knowledge of the exact source of a waste is required for source-specific listed wastes (“K” waste codes). Some knowledge of the nature or source of the waste is required even for listed wastes from non-specific sources, such as spent solvents (“F” waste codes) or commercial chemical products (“P” and “U” waste codes). These listed RCRA hazardous wastes are restricted to commercially pure chemicals used in particular processes such as degreasing. P and U wastes cover only unused and unmixed commercial chemical products, particularly spilled or off-specification products (EPA 1992).  Not every waste containing a P or U chemical is a hazardous waste. To determine whether a CERCLA investigation-derived waste contains a P or U waste, there must be direct evidence of product use. In particular, all the following criteria must be met. The chemicals must be:

  • Discarded (as described in 40 CFR, Section 261.2[a][2])
  • Either off-specification commercial products or a commercially sold grade
  • Not used (soil contaminated with spilled unused wastes is a P or U waste)
  • The sole active ingredient in a formulation

 

Hazardous waste characteristics, as defined in 40 CFR, Sections 261.21 through 261.24, are commonly referred to as ignitable, corrosive, reactive, and toxic. California environmental health standards for the management of hazardous waste set forth in 22 CCR, Division 4.5, were approved by EPA as a component of the federally authorized California RCRA program. Therefore, the characterization of RCRA waste is based on the state requirements.

 

The characteristics of ignitability, corrosivity, reactivity, and toxicity are defined in 22 CCR, Sections 66261.21 through 66261.24. According to 22 CCR, Section 66261.24(a)(1)(A), waste that exhibits the characteristic of toxicity is assigned a hazardous waste code beginning with the letter “D” to wastes that exhibit the characteristic of toxicity; D waste codes are limited to “characteristic” hazardous wastes.

 

According to 22 CCR, Section 66261.10, waste characteristics can be measured by an available standardized test method or be reasonably classified by generators of waste based on their knowledge of the waste, provided that the waste has already been reliably tested or if there is documentation of chemicals used.

 

A waste determined not to be a RCRA hazardous waste may still be considered a state-regulated non-RCRA hazardous waste. The state is broader in scope in its RCRA program in determining hazardous waste. Title 22 CCR, Section 66261.24(a)(2), lists the Total Threshold Limit Concentrations (TTLCs) and the Soluble Threshold Limit Concentrations (STLCs) for non- RCRA hazardous waste. The state applies its own leaching procedure, Waste Extraction Test

 

(WET), which uses a different acid reagent and has a different dilution factor (tenfold). There  are other state requirements that may be broader in scope than federal ARARs for identifying non-RCRA  wastes  regulated  by  the  state.  See  additional   subsections   of   22   CCR, Section 66261.24. A waste is considered hazardous if its total concentrations exceed the TTLCs or if the extract concentrations from the WET exceed the STLCs. A WET is required when the total concentrations exceed the STLC by a factor of ten, but are less than the TTLCs. California also has additional hazardous waste classification criteria (including 96-hour fish bioassays) that may need to be considered on a case-by-case basis. Wastes determined to be hazardous wastes under California regulations and not under federal regulations are referred to as non-RCRA wastes.

 

The waste classification requirements also apply to contents from decontamination water generated from daily decontamination activities, collected stormwater, groundwater monitoring well purge water, construction debris, and waste oils and fluids generated from the on-site project equipment. Wastewater resulting from stormwater runoff and decontamination water will be collected and contained within a portable aboveground tank. When the tank or container is approximately half-full or at least every 60 days, whichever occurs first, the tank will be sampled to determine proper disposition of the wastewater. PPE and soil stockpile liners will be characterized based on generator knowledge and will be disposed of at an off-site landfill. Debris will also be characterized based on generator knowledge to determine if it is a potential hazardous waste. Waste oil and other fluids generated during equipment maintenance activities will be collected, contained, and sent off-site for recycling.

1.2.2        Waste Accumulation and Storage

Title 40 CFR, Part 262, 40, and 22 CCR, Section 66262, consist of regulations applicable to the generation, storage, management, and accumulation of RCRA and non-RCRA hazardous wastes, respectively. Specific requirements apply to the accumulation time for hazardous wastes on site and to the accumulation and labeling of hazardous wastes. This project may result in the temporary accumulation of hazardous wastes in staging piles, containers, and tanks. These wastes will be managed, accumulated, and inspected in accordance with the regulations.

 

Nonhazardous waste is not subject to specific regulatory requirements for accumulation or storage; however, appropriate best management practices (BMPs) will be implemented.

1.2.3        Soil and Waste Stockpiles and Staging Piles

Soil excavated during this project will be stockpiled in inactive areas of the site until such time it is needed for reconsolidation or for use as cover material. During these activities, the soil and refuse will be managed under the CERCLA Area-of-Contamination policy, which allows impacted soil and/or refuse waste to be uncovered, moved, and reconsolidated without triggering the RCRA LDRs and minimum technical requirements for a landfill under RCRA. During

 

construction, excavated materials and drill cuttings requiring temporary stockpiling prior to reconsolidation will be staged on-site and will not require characterization or off-site disposal. While not anticipated, if refuse is excavated and is not reconsolidated and the material is determined to be RCRA hazardous waste based on representative sampling and analysis data, then the new (effective April 22, 2002) RCRA temporary Corrective Action Management Unit (CAMU) regulations are applicable. These regulations consist of the performance and technical standards for staging piles (Sections 264.554[d][1][i–ii] and [d][2]) and closure requirements for staging piles (Section 264.554[j–k]). Under the new regulations, a temporary CAMU may be designated for temporary (up to 2 years) treatment or storage of solid, non-flowing remediation waste. The RCRA LDRs, the landfill minimum technology requirements, and the waste pile permitting requirements are not applicable to temporary CAMUs for RCRA hazardous wastes. The temporary CAMU regulations also require that the unit:

  • The unit will be designed using appropriate measures (for example, liners, soil crusting agents, run-on/runoff controls, groundwater monitoring system) to prevent or minimize releases and cross media transfers of hazardous wastes and constituents (Section 264.554[d][1][ii]).
  • For units located in a previously contaminated area of the facility—All remediation wastes, contaminated containment system components, structures, and equipment that are contaminated with waste or leachate must be removed and decontaminated within

180 days (264.554[j]). In addition, contaminated subsoils must be remediated in accordance with an approved plan and schedule, but the 180-day time limit does not apply.

  • For units located on uncontaminated areas of the facility—Within 180 days following expiration of the operating term, any remaining contamination (such as, containment system components and subsoils) must be removed in accordance with the clean closure standards for waste piles in 22 CCR, Sections 66264.558(a) or 66265.558(a), and the closure performance standards in 22 CCR, Sections 66264.111 or 66265.111, for permitted and interim status facilities, respectively (264.554[k]).

 

For non-RCRA hazardous waste, in accordance with Division 20, Chapter 6.5, Section 25123.3 of the California Health and Safety Code, the material  can be stockpiled at the site for up to     90 days without satisfying all substantive requirements of a hazardous waste facility permit, provided the following conditions are met:

  • The materials do not contain free liquids.
  • The waste is accumulated on an impermeable surface (minimum 20-mil liner).
  • The generator controls against wind dispersion and rain runoff.
  • The generator inspects the site weekly and after storms to ensure the erosion controls are working properly.
  • After final off-site transportation, the accumulation site is inspected and remediated as necessary.
  • The site is certified for compliance with these standards by a registered engineer.

 

 

A log of all hazardous soil and debris stockpiles (or staging piles) will be maintained and updated on a daily basis. The log will include date of accumulation, date of sampling, analytical results obtained or pending, RCRA hazardous or non-RCRA hazardous designation, and so forth.

 

In addition to the aforementioned requirements, the State Water Resources Control Board Policy Number 92-08, which pertains to the control of stormwater discharges from construction activities, may also be relevant and appropriate to the temporary storage of stockpiled materials. Appropriate best management practices (BMPs) will be implemented to protect stockpiles from erosion and from stormwater run-on and runoff. These BMPs include erosion control, stormwater drainage control, secondary containment, fugitive emissions and wind dispersion control, and spill prevention. A site-specific Stormwater Pollution Prevention Plan (SWPPP) has been prepared for the project in accordance with ARARs (See Attachment 8 to the RAWP).

1.2.4        Wastewater and Waste Fluids

Title 22 CCR, Section 66264, and 40 CFR, Part 264, contain applicable requirements for facilities that store hazardous wastes in tanks or containers for over 90 days. Decontamination water and stormwater that comes in contact with the hazardous waste stockpiles will be collected and stored on-site in an approved tank of an appropriate capacity. The tank will be installed, managed, and inspected in accordance with the substantive requirements of 22 CCR, Sections 66264.191, 66264.192, 66264.193, and 66264.194. These regulations require specific engineering and design specifications, daily inspections of the tanks, adequate secondary containment (110 percent of the tank volume, plus the maximum rainfall from a 25-year, 24-hour storm event), and closure standards. The contents of the tank will be characterized based on generator knowledge from the project waste streams and/or per the requirements of 22 CCR, Section 66261, to determine appropriate disposal options. In addition, daily inspections of wastewater tanks will be conducted and logged to ensure the integrity of the tanks and secondary containment to check for leaks or spills, and to ensure that labels and markings are in good condition.

 

Wastewater generated, which may include decontamination water generated from equipment and personnel decontamination and purge water from well development activities, will be collected in 55-gallon drums, or combined in a large temporary storage tank (such as a Baker tank), and labeled as “Potentially Hazardous Decontamination (or Purge) Water.” The drums will be temporarily staged within a pre-designated and secondarily contained on-site waste accumulation area pending characterization and appropriate disposal. When possible, waste fluids generated from heavy equipment maintenance activities will be collected and removed from the site by the maintenance contractor for recycling. If waste fluids are required to be stored on-site, they will

 

be labeled accordingly, contained within Department of Transportation (DOT)-approved 55-gallon drums, and situated within a pre-designated and properly designed hazardous waste container storage area. Containers of hazardous wastes containing free liquids have stringent secondary containment requirements. These requirements include:

  • A base free of cracks or gaps and sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed.
    • The base will be sloped or the containment system will be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation. Alternatively, the containers may be elevated on pallets to prevent contact with accumulated liquids.
    • The containment system will have sufficient capacity to contain 10 percent of the volume of containers or the volume of the largest container, whichever is greater, plus the maximum rainfall from a 25-year 24-hour storm event.
    • Spilled or leaked waste and accumulated precipitation will be removed from the sump or collection area in a timely manner to prevent overflow of the collection system.

 

1.2.5        Used Personal Protective Equipment

Used PPE will be stored in DOT-approved 55-gallons drums or LLRW bins within the designated hazardous waste container storage area or the Radiological Material Area (RMA), respectively. The storage area will be designed and managed in accordance with the substantive requirements of the container management regulations codified in 22 CCR, Sections 66264.170 through 66264.178.

1.2.6        Container Labeling

Containers of potentially hazardous waste will be labeled with indelible ink with the following information: source and location; contents and quantity; potential health, safety, and environmental hazards; accumulation start date; date container sampled; parameters analyzed for; and the words “Analysis Pending – Potentially Hazardous.” If containers are determined to contain nonhazardous waste, they will be labeled accordingly. If containers are determined to contain hazardous waste, they will immediately be labeled with a completed “Hazardous Waste” label, which will include:

  • EPA Identification Number of the generator
  • Name and address of the generator
  • EPA waste code
  • DOT shipping name (prior to off-site shipment)
  • Description of contents
  • Date of generation (date first drop of waste placed in container)

 

An inventory of waste containers will be maintained for later submittal to the Department of the Navy (DON). In addition, weekly inspections of container storage areas will be conducted and logged while wastes remain in these areas to ensure the integrity of the containers and secondary containment, to check for leaks or spills, and to ensure labels and markings are in good condition.

1.2.7        Waste Accumulation Areas

Hazardous waste storage areas require:

 

  • A sign with the legend, “Danger Hazardous Waste Area-Unauthorized Personnel Keep Out” (written in English and Spanish), will be posted at each 90-day accumulation area and stockpile in sufficient numbers to be seen from any approach. The signs will be legible from a distance of at least 25 feet.
  • Aisle space will be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes.
    • The following emergency equipment will be located or available to personnel during active waste management activities at each accumulation area:

-        A device, such as a telephone or a hand-held two-way radio, capable of summoning emergency assistance will be available.

-        Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment will be available.

-        Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems.

-        A spill response kit for minor spills. The kit will include a shovel, adsorbent pads and/or “kitty litter,” and a collection container.

 

Bulk quantities of fuel, oil, or other hazardous materials will not be stored on-site. Equipment fueling and maintenance activities will be performed by an off-site contractor on an as-needed basis.

1.2.8        Waste Disposal

Although not anticipated, soil or refuse that is excavated during this project and that is not reconsolidated will be disposed of off-site at an appropriately permitted waste disposal facility. Non-soil related wastes, which may include wastewater, debris, used PPE, used oil, and impacted stormwater, will be managed in accordance with the regulations and transported off-site for appropriate recycling or disposal. Used PPE will generally be managed as LLRW and disposed of by the LLRW contractor. Each waste stream requiring off-site disposal will be characterized by generator knowledge or sampled and analyzed, as necessary, to ensure that it is properly

 

characterized and profiled and meets the waste acceptance criteria and packaging requirements for the proposed treatment, storage, and disposal facility (TSDF) prior to transport. Hazardous waste debris generated on site, which has been treated using an alternate treatment technology as indicated in 40 CFR, Part 268.45, and 22 CCR, Section 66268, (decontaminated with a water wash and spray), will be disposed of as nonhazardous solid waste. Used PPE and debris (oversized material, polyethylene liners, polyvinyl chloride piping, and so forth) that is determined to be radiological waste or a hazardous waste and is unsuitable for decontamination, will be transferred to the LLRW contractor or sent off-site to a hazardous waste landfill facility respectively. Waste oil and other fluids generated during equipment maintenance activities will be collected, contained, and sent off-site for recycling.

 

Non-radiologically impacted hazardous waste will be disposed only at a hazardous waste disposal facility approved by the DON and permitted for the disposal of the particular type of hazardous waste generated. Wastes disposed off-site will be sent to RCRA Subtitle C or RCRA Subtitle D facilities that meet the requirements of 40 CFR, Part 300.440 (CERCLA Off-site Policy).

1.2.9        Waste Transportation

Hazardous wastes sent off-site for disposal or recycling will be done so in accordance with the DOT Hazardous Material Transportation regulations of 49 CFR, Parts 171 through 177,  and    40 CFR, Part 262, Subpart B, and 22 CCR, Section 66262, which involve packaging, placarding, labeling, and manifesting requirements, and  with  appropriate  LDR  certification  notices  per 40 CFR, Part 268, and 22 CCR, Section 66268. Personnel having the required DOT-training will perform all DOT functions. In addition, all transporter and disposal contractors will be subject to the contractor qualification process. Under no circumstances will TtEC personnel sign hazardous waste manifests.

 

Material that does not exhibit one of the nine DOT hazard class characteristics (explosives, gases, flammable/combustible liquids, flammable solids/spontaneously combustible materials, dangerous when wet materials, oxidizers and organic peroxides, toxic materials and infectious substances, radioactive materials, corrosive materials) is not regulated under DOT rules for hazardous material transportation. If material is suspected to be hazardous, it will be shipped under the appropriate hazard class. All hazardous waste will be transported under DOT hazardous material regulations. Each shipment of a suspected hazardous material will be properly classed using the Hazardous Materials Table in 49 CFR, Part 172.101. DOT-trained personnel will make all determinations.

1.2.10    Waste Minimization

To minimize the volume of waste, the following general guidelines will be followed:

 

  • Waste materials will not be contaminated unnecessarily.
  • Work will be planned ahead.
  • Materials may be stored in large containers, but the smallest reasonable container will be used to transport the material to the location where it is needed.
  • Cleaning and extra sampling supplies will be maintained outside any potentially contaminated area to keep them clean and to minimize additional waste generation.
  • Mixing of detergents or decontamination solutions will be performed outside potentially contaminated areas.
  • Drop cloths or other absorbent material will be used to contain small spills or leaks.
  • Contaminated materials will not be placed with clean materials.
  • Wooden pallets inside the exclusion zone will be covered with plastic.
  • Material and equipment will be decontaminated and reused when practical.
  • Volume reduction techniques will be used when practicable.
  • Waste containers will be verified to ensure they are solidly packed to minimize the number of containers.
  • Only the size waste containers adequate to contain the volume of waste generated will be used.
  • Less hazardous substances will be used whenever possible (only the volume of standard solutions needed for testing will be brought; minimal amounts of decontamination water and solvent rinses will be used).

 

 

1.2.11    Waste Management Inspection and Documentation Program

This section presents the waste inspection procedures and documentation program to be employed during the project field activities.

1.2.12    Inspections

While all waste accumulation areas will be informally inspected on a daily basis, formal inspections of all hazardous container accumulation areas will be conducted and recorded at least weekly in accordance with 40 CFR, Part 264, Subpart I, and 22 CCR, Section 66264. However, daily inspections will be conducted for tanks containing hazardous wastewater. In addition, hazardous soil stockpiles will be inspected daily to ensure that liners are in place and the stockpiles are adequately protected. The Project Quality Control Manager or his designee will conduct inspections. Inspections will be logged in a field notebook, and a weekly (daily for tanks) inspection checklist will be completed. The container storage area(s) will be inspected to ensure the following:

  • Containers are in good condition. If a container is not in good condition or appears to be leaking, the waste will be transferred to another container.
    • Containers are made of materials that will not react with, and are otherwise compatible with, the hazardous waste to be stored.
    • Containers are closed at all times, except when adding or removing waste.

 

 

Tanks used for storage of collected hazardous runoff and decontamination water will be inspected on a daily basis and the inspections will be logged. The inspections will ensure that tanks have adequate secondary containment, are properly labeled, are in good condition (no apparent structural defects or deterioration), and have no visible leaks.

1.2.13    Documentation

Documentation requirements apply to all waste managed during project activities. Field records will be kept of all waste generation activities. All pages of the field data record log will be signed and dated by the supervising field leader who is entering the data. In addition, the following information will be recorded in the log:

  • Description of waste generating activities
  • Location of waste generation (including depth, if applicable)
  • Type and volume of waste
  • Date and time of generation
  • Description of any waste sampling
  • Name of person recording information
  • Name of field manager at time of generation

1.2.14    Hazardous Waste Manifests and LDR Certification

All hazardous waste transported from the site will be accompanied by a Hazardous Waste Manifest. DON personnel will be responsible for reviewing and signing all waste documentation, including waste profiles, manifests, and LDR notifications (manifest packages). Prior to signing the manifest, the designated DON official will ensure that pre-transport requirements of packaging, labeling, marking, and placarding are met according to 40 CFR, Parts 262.30 through 262.33, and 49 CFR, Parts 100 through 178.

 

The DON will receive one copy of the manifest; the remaining copies will be given to the transporter. The manifest will be returned to the DON’s signatory official for the base’s recordkeeping requirements. Copies of all manifests for waste generated at the site will be kept in a compliance file within the project files. (The PjM will provide the DON with the generator’s copies of the manifest.)

 

An LDR form will accompany the shipment of hazardous waste to the TSDF. The TSDF will be notified prior to the waste being sent. The following items must accompany the notification and are included in one of the following facility-specific forms:

  • EPA Hazardous Waste Generator identification number for material flow analysis
  • Manifest number, including state disposal application number
  • Waste analysis data
  • Corresponding concentration-based or technology-based treatment standards will be identified if the waste is also land disposal restricted

 

RCRA recordkeeping requirements per 40 CFR, Parts 262.20 through 262.44, including  retention of signed copies of manifests from the designated facility that received the waste, will be adhered. Additionally, biennial and exception reporting information will be submitted, as necessary, according to 22 CCR, Sections 66262.41 and 66261.42, and 40 CFR, Parts 262.41  and 262.42. Additional reporting may be required in accordance with 22 CCR, Section 66262.43, and 40 CFR, Part 262.43.

1.3         WASTE MANAGEMENT FOR RADIOACTIVE WASTES

The following subsections address specific control and management practices for LLRW and low-level mixed waste (LLMW), hereafter including low-level contaminated waste (LLCW), that should be followed by the certified waste broker contracted by the Department of Defense (DoD) Executive Agency for LLRW. Disposal of all LLRW and LLMW will be handled through the DON’s LLRW Disposal Program. TtEC has no responsibilities in verifying that the DoD broker adheres to these requirements.

 

The certified DoD waste broker should be used for all packaging, storage, shipping, manifesting, and disposal of LLRW and LLMW. The waste broker should coordinate closely with the Radiological Affairs Support Office (RASO).

1.3.1        Waste Classification

Radioactive wastes should be classified as specified in 49 CFR and/or disposal facility requirements. These wastes should be categorized as either LLRW or LLMW. Waste characteristics, including the radionuclides present and their associated specific activity, should be measured by an available standardized test method such as gamma spectroscopy, strontium analyses, and/or alpha spectroscopy. Additionally, for LLMW, chemical waste characteristics can be measured by a standardized test method or be reasonably classified by generators of waste based on their knowledge of the waste, provided that the waste has already been reliably tested for acceptance at the waste disposal facility.

 

A waste determined not to be a RCRA LLMW may still be considered a state-regulated non-RCRA LLCW (low level radioactive and non-RCRA hazardous). The state is broader in scope in its RCRA program in determining hazardous waste.

1.3.2        Waste Accumulation and Storage

As for hazardous waste, specific requirements apply to the accumulation time for LLMW or LLCW on-site and to the accumulation and labeling of LLMW. This project may result in the temporary accumulation of LLMW or LLCW in containers. These wastes should be managed, accumulated, and inspected in accordance with the hazardous waste regulations and may only be stored on-site for less than 90 days. Accumulation time requirements do not apply to LLRW- only waste.

 

All LLRW, LLMW, and LLCW should be packaged per the direction of a waste broker certified by the DoD Executive Agency for LLRW (Army Field Support Command) in accordance with federal directives and disposal facility requirements. Typical containers that may be used for these wastes include bins, 55-gallon drums, B-25 boxes, and/or covered roll-off containers. Containers should be properly lined, and absorbent should be used if it is considered necessary. All containers should be radiologically surveyed and/or swiped by the DoD broker when received. Each container should be properly inventoried and labeled. Inventories should include material description and isotopic identification, and hazardous components if appropriate. The contents of each container should be recorded in the field logbook, and each container should be assigned a unique identification number. Records should be maintained by the DoD broker.

 

Containers should be stored in a designated and posted radiological materials storage area under the authority of the DoD broker’s Nuclear Regulatory Commission (NRC) or California Agreement State radioactive materials license. Storage areas may be at the site where the waste originated. Containers should be secured to prevent unauthorized access to the contents of the container. Once filled, all containers should be surveyed and surface radiation measurements collected by the DoD broker using an ion chamber survey meter or equivalent.

1.3.3        Radiological Point Sources

Radiological point sources (such as radium-containing dials) should be packaged in metal drums in accordance with DOT regulations specified in 49 CFR, Subpart I, and should be stored in a posted radiological materials area. The DON is responsible for the transportation and disposal of radiological point sources.

1.3.4        Soil, Debris, and Materials

Soil, debris, and materials classified as LLRW or LLMW may be generated during excavation. When classified as LLRW or LLMW, these wastes should be placed in bins, 55-gallon drums, B-25 boxes, and/or roll-off containers.

 

1.3.5        Wastewater and Waste Fluids

Wastewater from the radioactive material decontamination area should be maintained separately from hazardous decontamination and dewatering wastewater. If the wastewater chemical characteristics are unknown, wastewater should be managed as LLRW wastewater, until characterized. Known or suspected LLMW or LLCW wastewater should be segregated during accumulation and storage. When decontaminating and dewatering radioactively contaminated material, every effort should be made to minimize the generation of mixed waste.

1.3.6        Labeling and Posting of Containers Containing Radioactive Waste

Each waste container containing LLRW or LLMW should be labeled by the DoD broker. The specific activity contained in each waste container and maximum contact radiation levels should be measured in milliroentgens per hour (mR/hr). Following the surveying and labeling, the waste container should be placed in a designated and posted radioactive material storage area. The waste container should be posted with a “Caution – Radioactive Material” sign. The sign should also note the maximum surface radiation level (measured in mR/hr). An inventory of contents with radionuclide and specific activity (if available) should be posted on the outside of the container or a notice should be posted stating where this information is found. The waste inventories should be managed under DoD NRC or California Agreement State radioactive materials license, including the mixed waste inventory due to the radioactive constituents.

1.3.7        Waste Accumulation Areas

The DoD broker working on this project in conjunction with TtEC should implement, at a minimum, the following requirements for radioactive waste stored on-site within a designated radioactive waste storage area:

  • An industry standard placard and barrier materials should be displayed with wording that includes the following, “Caution, Radioactive Materials Area-Unauthorized Personnel Keep Out” (written in English and Spanish), at each radioactive waste storage area sufficient to be seen from any approach. The signs should be legible and clearly conspicuous for outdoor and indoor locations.
    • Aisle space should be maintained to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes.
    • The areas should be secured to prevent unauthorized access to the material.
    • The following emergency equipment should be located or available to personnel during radioactive waste management activities at each accumulation area:

-        A device, such as a telephone or a hand-held two-way radio, capable of summoning emergency assistance

 

-        Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment

 

Filled containers generated during performance of this remedial action should be stored at the site where they were generated, until the contained material can be characterized for packaging and disposal by the DoD waste broker.

1.3.8        Waste Disposal

A certified waste broker contracted by the DoD Executive Agency for LLRW should be used for all packaging, shipping, manifesting, transportation, and disposal of LLRW, LLMW, and LLCW. The certified waste broker should coordinate closely with RASO. LLRW, LLMW, and LLCW inventories once identified by TtEC will be immediately turned over for management to the waste broker. These materials should be managed under the DoD broker’s NRC license because of the radioactive constituents.

 

The certified waste broker should be responsible for preparing the hazardous waste manifests for the LLMW and the radioactive waste manifests for the LLRW. These manifests should be signed by the certified waste broker. The certified waste broker should also be responsible for coordinating the shipment of LLMW and LLRW and coordinating with the waste disposal facilities.

1.3.9        Waste Transportation

Wastes sent off-site for disposal should be done so in accordance with the DOT Radioactive Material Transportation regulations of 49 CFR, by a certified waste broker contracted by the DoD Executive Agency for LLRW. Personnel having the required DOT training should perform assistance as needed.

 

The certified waste broker should be responsible for surveying and taking radiation measurements on the outside of the container prior to shipment. The certified waste broker should work with the Caretaker Site Office (CSO) representative to ensure that containers leaving the site meet the release limits for equipment and materials as identified in the Radiological Work Plan (Attachment 2 to the RAWP).

1.3.10    Waste Minimization

To minimize the volume of radioactive waste generated during the project, the following general guidelines will be followed:

  • Waste material will not be contaminated unnecessarily.
  • Work will be planned ahead.
  • Cleaning and extra sampling supplies will be maintained outside any potentially contaminated area to keep them clean and to minimize additional waste generation.
  • Mixing of detergents or decontamination solutions will be performed outside potentially contaminated areas.
  • When decontaminating radioactively contaminated material, every effort should be made to minimize the generation of mixed waste.
    • Contaminated material will not be placed with clean material.
    • Wooden pallets inside the exclusion zone will be covered with plastic.
    • Material and equipment will be decontaminated and reused when practicable.
    • Volume reduction techniques will be used when practicable.

 

1.3.11    Inspections

The DoD broker is responsible for LLRW accumulation areas. While all waste accumulation areas should be informally inspected on a daily basis, formal inspections of all container accumulation areas should be conducted and recorded at least weekly in accordance with the DoD broker’s  NRC license requirements. The RTM or designee will conduct inspections. Inspections will be recorded in a dedicated field logbook, and a weekly inspection checklist should be completed. The container storage area(s) should be inspected to ensure the following:

  • The containers should be checked for good condition. If a container is not in good condition the certified waste broker will be informed.
  • The containers should l be checked to ensure that they remain closed and secured at all times, except when adding or removing waste.
  • The container label should be checked to ensure that it is visible and filled out properly.

 

1.3.12    Documentation

Documentation requirements apply to all waste managed during project activities. Field records should be kept of all waste-generation activities. All pages of the field data record log will be signed and dated by the person who is entering the data. In addition, the following information will be recorded in the log:

  • Description of waste-generating activities
  • Location of waste generation (including depth, if applicable)
  • Type and volume of waste
  • Date and time of generation
  • Description of any waste sampling
  • Name of person recording information
  • Name of RTM at time of generation

 

1.3.13    Radioactive Waste Manifests

All radioactive waste transported from the site should be accompanied by a radioactive waste manifest and/or hazardous waste manifest if necessary. The LLRW/LLMW/LLCW manifests are the responsibility of the certified waste broker. LLRW manifests are signed by the broker.

 

The CSO and RASO should each receive one copy of the manifest; the remaining copies should be given to the transporter. The manifest should be returned to the DON’s signatory official for the base’s recordkeeping requirements. Copies of all manifests for waste generated at the site should be kept in a compliance file within the DoD broker’s project files.

1.4         HAZARDOUS MATERIAL SECURITY PLAN

If it is determined that placardable DOT hazardous materials will be generated on-site, a DOT Hazardous Material Security Plan will be prepared as a stand-alone document. The Hazardous Material Security Plan will be prepared in accordance with 49 CFR 172, Subpart H, and will guide the management for security purposes of hazardous materials prior to shipment. All site personnel responsible for hazardous materials security will receive both general awareness and plan-specific training. This training will be documented in the project file.

1.5         UPDATING THE WASTE MANAGEMENT PLAN

The WMP will be updated as changes in site activities or conditions or changes in applicable regulations occur. Revisions to the WMP will be reviewed and approved by the DON. All changes to the WMP associated with radioactive or mixed waste will require approval from the RASO.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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2.0     REFERENCES

 

EPA  (United  States  Environmental  Protection  Agency).    1992.     Guide to Management of Investigation-Derived Wastes. Publication 9345.3-03FS. January 2.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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TABLES

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Excavated soil and/or refuse intended for

off-site disposal

Unless a waste determination (e.g., RCRA hazardous, non- RCRA hazardous or nonhazardous) can be made based on generator knowledge, stockpiled soil and/or refuse will be sampled in accordance with the SAP.

Samples will be run for potential contaminants including: VOCs, SVOCs, TPH, PCBs/Pesticides, total metals analysis and STLC or TCLP, as appropriate.

Contain in within the RMA until characterized.

RCRA hazardous and non-RCRA hazardous soil contain in bermed pad with underlying 20-mil polyethylene liners.

All hazardous excavated soil and/or refuse intended for off-site disposal will be stockpiled on liners or placed bins. Nonhazardous soils may be taken to an unlined area the Navy has designated. All stockpiles will have appropriate erosion, wind, and stormwater run-on and runoff controls and other appropriate BMPs will be employed as required.

Hazardous stockpiles will be identified as RCRA hazardous or non-RCRA hazardous waste.

Hazardous stockpiles will be managed in accordance with the staging pile requirements of 40 CFR, Section 264.554.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

Due to the CERCLA Off- site Rule, all excavated soil will be sent to an appropriate TSDF approved under the CERCLA Off-site Rule.

Prior to transport, the soil will be segregated as RCRA hazardous, non- RCRA hazardous, and/or nonhazardous.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

All LLRW wastes will be turned over to the DoD Waste Broker for transportation and disposal.

Trees and other

Above ground tree and other

Laydown in

For clean vegetation and trees, no

Trees and vegetation may

Green materials will be

above ground

vegetation will be considered

uncontaminated

storage requirements. For vegetation

be transported in open

sent to an off-site

vegetation

to be non-hazardous unless it

area or on a clean

or debris contacting radiological or

rolloff bins as green wastes.

composting facility. Trees

 

has contacted hazardous

surface within the

other contamination materials, the

 

and woody materials may

 

materials

contaminated

materials will be stored in

 

be chipped and dispersed

 

 

area.

accordance with the above

 

in the random fill area of

 

 

 

(Excavated soil or refuse intended for

 

the landfill.

 

 

 

disposal off-site).

 

 

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Used oil (including motor oil, hydraulic fluid, greases

Used oil may be characterized based on process knowledge when solely from heavy equipment. Other oils, or oils without process knowledge will be sampled and tested in accordance with the SAP

Used oil to be stored in 55- gallon containers.

Used oil to be stored in 55-gallon drums labeled “USED OIL” and located within a secondary containment unit.

A contracted waste oil recycler shall pick up used oil for recycling.

Used oil will require a bill of laden for recycled materials.

Used Oil will be Recycled, no disposal.

Used fuel and oil filters

Used oil filters and oil will be handled as a Specified California Hazardous Waste.

“Drained” oil filters may be managed as a nonhazardous solid waste. Recycling of the “empty” filters is an alternate method for removal of this material from site.

Run total analysis and STLC or TCLP, or use process knowledge to make a waste determination.

“Drained” oil filters to be placed into plastic bags within 55 gallon open top drums. Filters to be drained and stored within the secondary containment area.

Spent oil and fuel filters will be completely drained and placed into plastic bags before being placed into nonhazardous solid waste dumpsters or retained for recycling.

Hazardous waste manifest required for disposal.

Hazardous waste manifest to be signed by the DON. Recycled filters will require

a bill of laden for recycled

materials.

Contracted recycler to pick up and recycle used oil Secondary choice would be disposal of the bagged (drained) oil filters at an approved Class III solid waste landfill.

 

Spent fuel filters (drained) will be handled as nonhazardous solid waste.

 

 

 

 

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Wastewater (decontamination water, and collected radiologically impacted stormwater)

Unless a waste determination (e.g., RCRA hazardous, non- RCRA hazardous or nonhazardous) can be made based on generator knowledge, the material will be sampled to determine appropriate management and disposal procedures.

Samples will be run for potential contaminants including: pH, VOCs, SVOCs, TPH,

PCBs/Pesticides, total metals analysis and STLC or TCLP, as appropriate.

DOT-approved 55-gallon (bunghole-type) metal drums (1A1) or

aboveground tank(s).

Ninety-day storage limit applies to tanks and containers containing hazardous waste. Containers and tanks will be marked as “HAZARDOUS WASTE” and

include the accumulation date, composition and physical state of the waste, hazardous properties, and name and address of generator.

Containers and tanks will be sealed when not being filled/unloaded.

Containers will be elevated to prevent contact with any ponded precipitation and/or liquids.

Store in predesignated hazardous waste storage areas with secondary containment.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

The waste will be containerized and sent off- site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

Alternately, radiologically impacted waters may be treated on site, sampled and used for dust control purposes.

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Hazardous contents from buried containers, if encountered.

Unless a definitive nonhazardous waste determination can be made based on generator knowledge, container contents will be presumed hazardous pending analytical results and waste determination (e.g., RCRA hazardous, non-RCRA hazardous or nonhazardous) to determine appropriate management and disposal procedures.

Samples will be run for reactivity, corrosivity, ignitability, and all potential contaminants of concern including: VOCs, SVOCs, PCBs, Pesticides, TPH, and metals.

DOT-approved 55-gallon (bunghole-type) metal drums for liquids (1A1) or over-pack containers. For limited amounts of material, open top 55 gallon drums maybe be used. For bulk wastes, closed top rolloffs can be used, or the materials placed on a lined containment area and covered

Ninety-day storage limit applies to containers containing hazardous waste. Containers will be marked as “HAZARDOUS WASTE” and

include the accumulation date, composition and physical state of the waste, hazardous properties, and name and address of generator.

Containers and tanks will be sealed when not being filled/unloaded.

Containers will be elevated to prevent contact with any ponded precipitation and/or liquids.

Store in predesignated hazardous waste storage areas with secondary containment.

Incompatible materials will be segregated.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

The waste will be containerized and sent off- site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

Used air filters

Air filters will be surveyed for radiological contamination.

Spent air

All filters are to be placed into plastic bags and placed into nonhazardous solid waste dumpsters.

Contracted solid waste management company to collect trash.

Dispose of air filters in site dumpsters or roll-off bins for nonhazardous solid waste and subsequent disposal at an approved Class III Landfill.

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Construction debris (rock, wood, piping, concrete, asphalt, and oversized material)

Unless a waste determination (e.g., RCRA hazardous, non- RCRA hazardous or nonhazardous) can be made based on generator knowledge, the material will be sampled to determine appropriate management and disposal procedures.

Samples will be run for potential contaminants including: VOCs, SVOCs, TPH, total metals analysis, and STLC or TCLP.

Debris not having contact with waste or contaminated soil may be characterized as a nonhazardous solid waste.

Hazardous debris moved from point of generation to the decontamination area.

Hazardous debris stored in bins or managed stockpiles.

Decontaminated debris (debris that meets the debris treatment standard and is not contaminated with a listed waste) and nonhazardous debris may be stored in nonhazardous solid waste roll-offs bins.

Hazardous debris that cannot be decontaminated and does not meet the debris treatment standards will be stored in containers and/or bins and will be marked as follows: “HAZARDOUS WASTE” and

include the accumulation date, composition and physical state of the waste, hazardous properties, and name and address of generator.

Containers and/or bins will be sealed/ covered when not being loaded/unloaded. Containers will be elevated to prevent contact with any ponded precipitation and/or liquids.

No special transporter requirements for debris determined to be nonhazardous. Contracted solid waste management company to collect material.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

Nonhazardous debris or debris treated to meet “Alternate Treatment” standards may be disposed off-site at an approved Class III solid waste landfill.

Hazardous waste will be containerized and sent off- site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

Nonhazardous waste (trash, inert construction debris, calibration canisters, clean polyethylene liners, and so forth)

Materials generated during the remedial action project and not contaminated with any waste or waste residue may be characterized as a nonhazardous solid waste.

Waste to be stored in nonhazardous roll-off bins or stockpiles.

Nonhazardous waste to be stored separate from hazardous waste and labeled accordingly to prevent commingling of hazardous and nonhazardous wastes.

No special transporter requirements for wastes determined to be nonhazardous. Contracted solid waste management company to collect material.

Nonhazardous waste to be disposed off-site at an approved Class III solid waste landfill.

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Polyethylene sheeting or other liner materials (Contaminated)

Liners used for containing hazardous soil will be presumed to be hazardous.

Liners will be stored in roll-off bins or DOT

55-gallon drums.

Labeling should consist of a completed commercial hazardous waste label. Roll-off bins will be marked as “HAZARDOUS WASTE” and include the accumulation date, composition and physical state of the waste, hazardous properties, and name and address of generator.

Roll-off bins will be sealed/covered when not being loaded/unloaded.

Roll-off bins will be elevated to prevent contact with any ponded precipitation and/or liquids.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

The waste will be containerized and sent off- site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

For LLRW, wastes will be turned over to the US Army Waste Broker for transportation and disposal.

Scrap metal

Unless generator knowledge is sufficient to make a nonhazardous determination, metal debris will be decontaminated in accordance with the hazardous debris treatment standards before it can be managed as scrap metal for recycling.

Segregate scrap metal from other construction debris following decontamination.

Store in unique rolloffs outside the contamination area to prevent commingling with hazardous wastes and construction debris.

No special transporter requirements for scrap metal determined to be nonhazardous. Contracted scrap metal recycling company to collect material.

Scrap metal routed thru a portal monitor prior to being sent to an approved scrap metal recycling facility.

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

PPE

Use process knowledge to make a waste determination. Decontaminated PPE can be

managed as a nonhazardous

solid waste.

LLRW PPE will be treated as being LLRW.

Use plastic bags at point of generation to transport to the 90-day accumulation area. (for non-rad

PPE). LLRW PPE

will be placed in DOT-approved 55-gallon metal

drums (1A2).or

placed into LLRW rolloff bins.

Labeling should consist of a completed commercial hazardous waste label. Containers will be sealed/covered when not being loaded/unloaded. Containers and roll-off bins will be elevated to prevent contact with any ponded precipitation and/or liquids.

Store in predesignated hazardous waste storage areas with secondary containment.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

Decontaminated PPE may be placed into nonhazardous solid waste roll-off bin to be picked up by contracted solid waste disposal contractor.

Decontaminated PPE may be disposed at an approved Class III solid waste landfill.

If hazardous the waste will be containerized and sent off-site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal. For LLRW, wastes will be turned over to the DoD Waste Broker for transportation and disposal.

 

Waste Types

Characterization Requirements

Containment Requirements

Storage Requirements

Transportation Requirements

Disposal Requirements

Unidentified waste streams (i.e., waste streams that may be generated during site activities, but have yet to be identified)

Unless a waste determination (e.g., RCRA hazardous, non- RCRA hazardous or nonhazardous) can be made based on generator knowledge, the material will be sampled to determine appropriate management and disposal procedures.

Samples will be run for potential contaminants including VOCs, SVOCs, TPH, PCBs/pesticides, total metals analysis, and STLC or TCLP, as appropriate.

DOT-approved 55-gallon metal drums (1A1 or 1A2) depending on whether a liquid or solid.

If hazardous waste, labeling should consist of a completed commercial hazardous waste label. Containers will be sealed/covered when not being managed. Containers will be elevated to prevent contact with any ponded precipitation and/or liquids.

If a hazardous waste, the storage accumulation clock starts from the date that waste is first put into the container destined for off-site disposal (90-day max. allowed).

Store in predesignated hazardous waste storage areas with secondary containment.

If material is a hazardous waste, a hazardous waste manifest and DOT vehicle placarding are required.

Must use a Cal/EPA- permitted transporter. Must also have LDR certifications as necessary. Hazardous waste manifest to be signed by the DON.

Individuals involved in overseeing or shipping hazardous materials must meet DOT training requirements.

The waste will be containerized and sent off- site for disposal at an appropriate TSDF approved under the CERCLA Off-site Rule.

All disposal facilities will be submitted for preapproval to the CSO prior to off-site transport and disposal.

UXO/MEC

UXO/MEC will be evaluated by a UXO Technician to determine if the item(s) are hazardous or inert.

MEC that is determined to be MEC or MMPEH

Will be inventoried and stored in drums or magazines as determined by the UXO Supervisor.

Will be made inert, demilitarized by the UXO supervisor, or destroyed by EOD.

Disposal at an approved disposal facility as determined by the UXO Supervisor.

 

Abbreviations and Acronyms:

Cal/EPA – California Environmental Protection Agency CFR – Code of Federal Regulations

CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act CSO – Caretaker Site Office

DoD – Department of Defense DON – Department of the Navy

DOT – Department of Transportation LLRW – low-level radioactive waste LDR – land disposal restriction

MEC – munitions and explosives of concern

MPPEH – material potentially presenting an explosive hazard PCB – polychlorinated biphenyl


 

PPE – personal protective equipment

RCRA – Resource Conservation and Recovery Act RMA – Radiological Material Area

SAP – Sampling and Analysis Plan

STLC – Soluble Threshold Limit Concentration SVOC – semivolatile organic compound

TCLP – Toxicity Characteristic Leaching Procedure TPH – total petroleum hydrocarbons

TSDF – treatment, storage, and disposal facility UXO – unexploded ordnance

VOC – volatile organic compound

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ATTACHMENT 11

POST-CLOSURE OPERATIONS, MAINTENANCE, AND MONITORING PLAN

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

 

CONTRACT NO. N62473-10-D-0809 CTO NO. 0009

 

ATTACHMENT 11

 

FINAL

POST-CLOSURE OPERATIONS, MAINTENANCE, AND MONITORING PLAN

Revision 1

November 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA

 

DCN: RMAC-0809-0009-0004.R1

 

Prepared by:

 
   

1230 Columbia Street, Suite 750 San Diego, California 92101-8536

 
   

Pete Everds Technical Lead

 

 

 

Hedy Abedi, PhD, PE Project Manager

 

TABLE OF CONTENTS

 

PAGE ABBREVIATIONS AND ACRONYMS....................................................................................... v

1.0           INTRODUCTION............................................................................................................ 1-1

1.1                 SITE DESCRIPTION.......................................................................................... 1-1

1.2                 SITE HISTORY................................................................................................... 1-1

1.3                 FUTURE USE...................................................................................................... 1-2

1.4                 PREVIOUS ACTIVITIES................................................................................... 1-2

1.4.1             Remedial Investigation/Feasibility Study............................................. 1-2

1.4.2             Record of Decision................................................................................. 1-2

1.4.3             Remedy for Soil..................................................................................... 1-2

1.4.4             Remedy for Groundwater...................................................................... 1-3

1.5                 SELECTED REMEDY COMPONENTS........................................................... 1-3

1.5.1             Gas Venting........................................................................................... 1-3

1.5.2             Subgrade and Foundation Fill................................................................ 1-4

1.5.3             Multilayer Soil Cover............................................................................ 1-4

1.5.4             Settlement Monuments.......................................................................... 1-5

1.6                 DOCUMENT ORGANIZATION....................................................................... 1-5

2.0           OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND

METHANE MONITORING............................................................................................ 2-1

2.1                 LONG-TERM GROUNDWATER MONITORING WELL EVALUATION.... 2-1

2.1.1             Groundwater Monitoring Well Network and Sampling Frequency...... 2-1

2.1.2             Proposed Analysis and Field Parameters............................................... 2-2

2.1.3             Data Analysis......................................................................................... 2-3

2.2                 COMPLIANCE PERIOD.................................................................................... 2-3

2.3                 METHANE MONITORING............................................................................... 2-4

3.0           OPERATIONS AND MAINTENANCE FOR SITE STRUCTURES.............................. 3-1

3.1                 LANDFILL COVER SURFACE WATER MANAGEMENT SYSTEM........... 3-1

3.2                 WETLANDS CULVERT.................................................................................... 3-2

3.3                 GAS COLLECTION........................................................................................... 3-2

3.4                 GAS PROBES..................................................................................................... 3-2

3.5                 MONITORING WELLS..................................................................................... 3-2

3.6                 SETTLEMENT MONUMENTS......................................................................... 3-2

3.7                 ACCESS ROADS................................................................................................ 3-3

3.8                 SIGNAGE............................................................................................................ 3-3

4.0           OPERATIONS AND MAINTENANCE FOR LANDFILL COVER

SETTLEMENT, EROSION, AND VEGETATION........................................................ 4-1

4.1                 DIFFERENTIAL SETTLEMENT AND EROSION.......................................... 4-1

4.1.1             Detection................................................................................................ 4-1

4.1.2             Repairs................................................................................................... 4-1

PAGE 4.2             VEGETATION.................................................................................................... 4-2

4.3                 DOCUMENTATION.......................................................................................... 4-2

4.4                 EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND

SEAWALL.......................................................................................................... 4-2

5.0           MONITORING AND MAINTENANCE OF WETLANDS MITIGATION

AREAS.............................................................................................................................. 5-1

5.1                 SUCCESS CRITERIA FOR VEGETATION..................................................... 5-1

5.2                 SUCCESS CRITERIA FOR WILDLIFE............................................................ 5-2

5.3                 SUCCESS CRITERIA FOR HYDROLOGY..................................................... 5-2

6.0           SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE

ACTIVITIES..................................................................................................................... 6-1

6.1                 SCHEDULED INSPECTION............................................................................. 6-1

6.1.1             Cover Settlement................................................................................... 6-1

6.1.2             Geonet Animal Intrusion Barrier........................................................... 6-1

6.1.3             Methane Monitoring.............................................................................. 6-1

6.1.4             Wetlands Culvert................................................................................... 6-1

6.1.5             Site Structures........................................................................................ 6-2

6.2                 FIELD DOCUMENTATION.............................................................................. 6-2

6.2.1             Document Corrections........................................................................... 6-2

7.0..... REPORT REQUIREMENTS AND DATA MANAGEMENT........................................ 7-1

8.0      POST-CLOSURE FINANCIAL ASSURANCE.............................................................. 8-1

9.0      REFERENCES.................................................................................................................. 9-1

 

 

TABLES

 

Table 2-1            Proposed Groundwater Monitoring Well Network, Analyses, and Sampling Frequency

Table 2-2            Standard Operating Procedures for Post-Closure Monitoring and Maintenance

 

 

 

 

 

FIGURES

 

Figure 1-1          Site Location Map

Figure 2-1          IR Site 2 Groundwater Monitoring Well Locations Figure 2-2                      Analytical Trends Comparison Flow Chart

Figure 6-1          Proposed Schedule

 

APPENDICES

 

Appendix A          Long-term Groundwater Monitoring Evaluation Appendix B           Standard Operating Procedures (on CD only) Appendix C                           Plan Itemized Cost Estimate (on CD only) Appendix D                              Emergency Response Plan (on CD only)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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ABBREVIATIONS AND ACRONYMS

 

 

 

BGMP

Basewide Groundwater Monitoring Program

CCR

California Code of Regulations

CFR

Code of Federal Regulations

COC

contaminant of concern

CTR

California Toxics Rule

DON

Department of the Navy

DTSC

Department of Toxic Substances Control

EC

engineering control

EPA

U.S. Environmental Protection Agency

FS

Feasibility Study

FWBZ

first water-bearing zone

GME

Groundwater Monitoring Evaluation

HCH

hexachlorocyclohexane

IC

institutional control

IR

Installation Restoration (Program)

MNA

monitored natural attenuation

NAS

Naval Air Station

PCGMP

post-closure groundwater monitoring program

RAO

remedial action objective

RAWP

Remedial Action Work Plan

RD

Remedial Design

RI

remedial investigation

ROD

Record of Decision

SAP

Sampling and Analysis Plan

SOP

standard operating procedure

SWBZ

second water-bearing zone

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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1.0          INTRODUCTION

 

 

Tetra Tech EC, Inc., has prepared this Post-Closure Operations, Maintenance, and Monitoring Plan (Plan) for Installation Restoration (IR) Site 2, former Naval Air Station (NAS) Alameda, Alameda Point, Alameda, California. This Plan was prepared for the Department of the Navy (DON), Base Realignment and Closure Program Management Office West under Contract No. N62473-10-D-0809, Contract Task Order 0009. The purpose of this Plan is to describe the operations, maintenance, and monitoring to be implemented after construction of the multilayer soil cover (cover) on the IR Site 2 landfill. The approach set forth in this Plan was developed based on the description of the selected soil remedy in Record of Decision (ROD) (DON 2010), site conditions described in the Remedial Investigation (RI) Report (Battelle and BBL 2006), and the Feasibility Study (FS) Report (Battelle and BBL 2008), and procedures and recommendations presented in the Long-term Groundwater Monitoring Evaluation (Alameda Agencies, 2013).

 

1.1              SITE DESCRIPTION

The site covers approximately 110 acres in the southwest corner of the former Alameda NAS, now referred to as Alameda Point (Figure 1-1). The site consists of the former landfill area  (West Beach Landfill), which occupies approximately 60 acres, and a wetland, which covers approximately 33 acres immediately south and west of the landfill. The wetland area includes two surface water features, the north pond and the south pond. The north pond is connected by a culvert to San Francisco Bay. The remaining 17 acres within the site boundary is known as the interior margin and the coastal margin. The site is bound on the south and west by San Francisco Bay and on the east and north by runways and tarmacs.

 

Additional site background information is presented in Section 2.0 of the Remedial Action Work Plan (RAWP).

 

1.2              SITE HISTORY

The site was formerly part of the San Francisco Bay and was created by construction of a seawall around the perimeter, filling with dredge materials, and subsequent disposal of wastes generated by former NAS Alameda activities from 1956 through early 1978. Historical disposal methods  at the site generally consisted of trench-and-fill operations and placement of cover soil on an intermittent basis. These operations resulted in waste that is in contact with shallow  groundwater. Alameda Point was included on the National Priorities List of Superfund sites in August 1999, U.S. Environmental Protection Agency (EPA) (Identification: CA2170023236).

 

After landfill operations ceased in 1978, an earthen berm was constructed around the perimeter of the landfill. The extent of the landfill, as defined in the ROD (DON 2010) and as modified based on the Intermediate Draft Remedial Design Report (KCH 2011), is shown on Figure 1-1.

 

1.3              FUTURE USE

IR Site 2 has been designated for federal agency (DON) to federal agency (Office of Veterans Affairs) transfer. The proposed future use at IR Site 2 is “undeveloped” with potential for recreational uses such as a perimeter hiking trail.

 

1.4              PREVIOUS ACTIVITIES

IR Site 2 was used as a landfill. There was no land use at the site prior to 1956, when the perimeter sea wall was constructed and the site was first formed by using dredged fill. Due to its historical use solely as a landfill, no persons have resided or currently reside at the site.

1.4.1        Remedial Investigation/Feasibility Study

The Final RI Report (Battelle and BBL 2006), the FS, and Basewide Groundwater Monitoring Program (BGMP) reports describe in detail the nature and extent of groundwater contamination. The most commonly detected organic contaminants in site groundwater are volatile organic compounds, total petroleum hydrocarbons, and other fuel-related compounds (ITSI 2008). Groundwater contamination is characterized by a relatively widespread pattern of low-level contamination. The source of contamination is attributed to the operation of the site as the principal waste disposal facility for Alameda Point between 1956 and 1978.

1.4.2        Record of Decision

The DON conducted an FS (Battelle and BBL 2008) to evaluate potential remedial alternatives for IR  Site 2 and prepared a ROD (DON 2010) to document the selected remedy for the site.  The DON and the Federal Facility Agreement signatories (the EPA, California Environmental Protection Agency, Department of Toxic Substances Control [DTSC], and the San Francisco Bay Regional Water Quality Control Board) concurred on the selected remedy for the site. The decision agreed to in the ROD is based on information contained in the administrative record file as well as on extensive field investigations, laboratory analyses, interpretation of the data, review of current and future conditions, assessment of the potential human health and ecological risks, and an evaluation of potential remedial alternatives.

1.4.3        Remedy for Soil

The selected remedy for soil, as outlined in the ROD, is Alternative 2, a multilayer soil cover, engineering controls (ECs) and institutional controls (ICs), and monitoring. This alternative consists of installation of an engineered soil cover over the former landfill to isolate buried waste and soil contaminants and prevent animal burrowing; implementation of engineering and land use controls to protect human health and soil cover integrity; provision for any necessary

 

wetlands mitigation if impacts to wetlands occurs; monitoring of the soil cleanup action and wetlands mitigation to ensure their proper construction and long-term effectiveness; and conduct of methane gas monitoring as necessary.  The RAWP addresses the design of the soil remedy  and includes more details on the ECs and ICs.

1.4.4        Remedy for Groundwater

The selected remedy for groundwater, as outlined in the ROD, is Alternative 2 – Monitored Natural Attenuation (MNA). This alternative consists of regularly monitoring groundwater quality using shoreline groundwater monitoring wells to ensure that there are continued stable to decreasing trends in contaminant concentrations, and protection of the beneficial uses of surface water in San Francisco Bay; and implementation of engineering controls and ICs to protect human health and the groundwater remedy.

 

The objective of MNA is to verify the occurrence of natural attenuation of groundwater contaminants through monitoring. In accordance with the ROD, contaminants will not be actively remediated, but will be allowed to degrade, adsorb, dilute, or transform according to natural, unaided environmental processes (DON 2010). The groundwater remedy meets the Remedial Action Objective (RAO) described in the ROD to protect beneficial uses of surface water in San Francisco Bay from the potential for discharge of site groundwater (DON 2010).

 

Because groundwater at the site is not used for drinking water and is not considered a potential drinking water source, numerical standards associated with groundwater (such as maximum contaminant levels for drinking water) do not apply. Instead, chemicals identified during the remedial investigation in excess of California Toxics Rule (CTR) surface water quality criteria were summarized in ROD Table 2.7.

 

While the CTR criteria are not directly applicable to groundwater, the criteria are appropriate to provide suitable context for evaluating IR Site 2 groundwater relative to groundwater RAOs. Currently, risk to San Francisco Bay surface water from site groundwater is considered negligible.

 

1.5              SELECTED REMEDY COMPONENTS

1.5.1        Gas Venting

The landfill area was designed with a passive gas venting system to prevent landfill gas buildup which could disrupt the cover. The gas venting trenches are filled with high permeability aggregate and geotextile surrounding a 4-inch perforated pipe. The pipes connect to gas vents open to the atmosphere.

 

Ten existing landfill gas probes will be destroyed during soil cover construction. Nine new perimeter gas probes will be installed at IR Site 2, as shown in the design drawings presented in

 

RAWP Attachment 1. These probes will be designed and located as described in the RAWP and attached 100% Remedial Design (RD).

1.5.2        Subgrade and Foundation Fill

The subgrade and foundation fill will consist of common fill materials or natural ground. The primary requirement for this fill material is that it be compatible and provide stable support for the cover. The primary purpose of the subgrade and foundation fill is to build up the original landfill surface to moderate, uniform slopes. Grades established for the cover system will be approximately 1.5 percent to account for potential settlement and maintain positive drainage over the cover system.

1.5.3        Multilayer Soil Cover

The proposed cover will be 2 feet thick to provide required isolation from the waste, and will consist of three distinct layers:

  • Animal intrusion barrier consisting of minimum 220-mil high-density polyethylene geonet
  • Cover layer of 18 inches of common fill
  • Vegetative layer of 6-inch-thick topsoil amended to help establish vegetation

 

1.5.3.1                 Animal Intrusion Barrier

The animal intrusion barrier will be installed utilizing minimum 220-mil layer of high-density polyethylene geonet. The material will  require  no  specialized  seaming and  will  transverse  the fill.

 

1.5.3.2                 Cover Layer

After the animal intrusion barrier is placed over a portion of the site, a cover layer will be installed consisting of an 18-inch layer of import material meeting geotechnical specifications and conditioned for moisture.

 

1.5.3.3                 Vegetative Layer

The vegetative layer is a 6-inch layer that requires only 85 percent compaction and is amended to help establish vegetation. This fill material is similar to the cover material.

 

1.5.3.4                 Vegetation

The landfill cover will be hydroseeded with a mixture identified in the Specifications in the 100% RD (Attachment 1 to the RAWP).

 

1.5.3.5                 Surface Water Management System (Drainage and Swale Layer)

Two new earthen swales with turf reinforcement mats are integrated into the cover design. The channels slope from 0.5 to 1 percent and have been placed to maximize the efficiency of collection and transfer of sheet flow from the completed cover. An existing concrete channel located on the eastern boundary of the site will be maintained throughout construction and incorporated into the final drainage system.

1.5.4        Settlement Monuments

Four settlement monuments will be installed on the final cover system as specified in the     100% RD (Attachment 1 of the RAWP). Markers will be located where the depth of fill is the greatest and therefore settlement potential the highest. The monuments will be located so that settlement rate and trends can be monitored and assessed.

 

1.6              DOCUMENT ORGANIZATION

This Plan is organized as follows:

 

  • Section 1.0 provides the site description, history, previous activities, site remedy components, and document organization.
  • Section 2.0describes the requirements for post-closure groundwater and methane monitoring.
    • Section 3.0 describes the operation and maintenance requirements for site structures.
    • Section 4.0 describes the operation and maintenance requirements for the landfill cover settlement.
    • Section 5.0describes the monitoring and maintenance requirements for the wetlands mitigation areas.
      • Section 6.0 provides the proposed schedule.
      • Section 7.0 describes reporting requirements.
      • Section 8.0 provides post-closure financial assurance.
      • Section 9.0 provides post-closure certification.
      • Section 10.0 lists the references cited in the text.
      • Tables and figures follow the text.
      • Appendix A presents the Long-term Groundwater Monitoring Evaluation (GME)
      • Appendix B includes the Standard Operating Procedures (SOPs).
      • Appendix Cpresents the estimated annual cost for operations, maintenance, and monitoring.
        • Appendix D presents the required Emergency Response Plan.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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2.0          OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND METHANE MONITORING

 

 

2.1              LONG-TERM GROUNDWATER MONITORING WELL EVALUATION

In accordance with groundwater requirements in the ROD, this section presents the groundwater monitoring methods and criteria for assessing groundwater data trends to confirm that contaminant levels remain within an acceptable range. The monitoring well network, monitoring schedule, analytes, and methods are defined. As part of their technical review and oversight, the regulatory agencies provided recommendations for the long-term groundwater monitoring program for Alameda IR Site 2 (Alameda Agencies, 2013), which are included as Appendix A. These recommendations were based on an evaluation of available historical geologic, hydrogeologic, and analytical data for IR Site 2. Post-closure groundwater monitoring requirements are presented below, incorporating details from the GME (Appendix A).

2.1.1        Groundwater Monitoring Well Network and Sampling Frequency

The long-term monitoring plan has been designed to demonstrate protection of San Francisco Bay (bay) and the North and South Ponds (wetlands) from contamination in groundwater that may migrate beneath IR Site 2 and discharge to these surface water bodies. The long-term groundwater monitoring well network focuses on groundwater potentially influenced by the landfill that is hydraulically connected to the wetlands and the bay. The groundwater monitoring well network includes interior first water-bearing zone (FWBZ) wells that are downgradient of the landfill and upgradient of the wetlands, and shoreline FWBZ wells that are downgradient of the landfill and adjacent to the bay (Figure 2-1). Historical groundwater flow directions support the placement of these monitoring wells. Flow directions will continue to be evaluated to ensure that the monitoring network remains appropriate for its intended purpose.

 

The monitoring well network utilizes existing upper and lower FWBZ wells that were installed in the mid-1990s and have been sampled since that time, yielding a robust historical data set. As shown on Figure 2-1 and discussed in Section 5.8.3 of the RAWP, four new well clusters, completed in the upper and lower FWBZ, will be constructed and added to the program to enhance coverage of the monitoring network. Existing FWBZ wells on the upgradient perimeter of the site will be used for water level information and to monitor quality of groundwater migrating on to the site. Second water-bearing zone (SWBZ) wells (i.e., within and/or below the BSU) are not included in the monitoring program because data from these wells are not representative of the shallow groundwater water discharging to the wetlands and/or bay, and because they are below the depth of the influence of the landfill. SWBZ wells will be abandoned as shown on Figure 2-1. Well destruction methods are described in Section 5.5.1 of the RAWP.

 

Table 2-1 identifies the monitoring well, water-bearing zone, proposed analytical methods, and well sampling frequency. A new Sampling and Analysis Plan (SAP) will be prepared for the long-term monitoring program for IR Site 2, in compliance with California Code of Regulations Title 27, Subchapter 3.  Water Monitoring, and Title 22 Chapter 14, Article 6.  The new SAP  will include a field sampling plan and quality assurance project plan along with a complete listing of analytes. As discussed further in Section 3.5, a well inventory will be performed to evaluate the condition of existing monitoring wells that will remain in the program. Corrective measures (such as redevelopment) will be performed as necessary. Well sampling frequency  will be quarterly for the first year for all newly installed wells. After 1 year of monitoring, the frequency may be reduced to semiannual based on criteria described below. Existing wells at the site will continue to be sampled semiannually. In the event that unusual variability is seen in the groundwater results, the frequency of sampling events will be evaluated and potentially increased.

 

Changes to the sampling frequency will be based on the trend analysis described in Section 2.1.3 and on the Analytical Comparison Flow Chart (Figure 2-2). Decreases to sampling frequency will be considered if:

  • Current concentrations continue to show stable or decreasing trends compared to historical results

 

Increases to sampling frequency will be considered if:

 

  • Concentration trends are found to be increasing (assumption is currently there are none trending upward)
  • Concentration of a constituent is greater than the historical maximum in three successive samples
  • Concentrations become significantly more variable than seen in the historic data set

 

Maximum sample frequency will be quarterly. Trends will be evaluated in the annual report based on the methodology described in Section 2.1.3. If an increasing trend is confirmed, the operations and maintenance contractor will notify the DON who will notify DTSC and the Regional Water Quality Control Board. A corrective action plan may be developed as necessary.

2.1.2        Proposed Analysis and Field Parameters

Proposed analytes include those listed in ROD Table 2-7. The list includes metals (arsenic, copper, and nickel), pesticides (aldrin, alpha chlordane, a-hexachlorocyclohexane [HCH], b-HCH, 4,4-dichlorodiphenyldichloroethene, 4,4-dichlorodiphenyltrichloroethane, dieldrin, endrin, gamma chlordane, heptachlor, and heptachlor epoxide), and the semivolatile organic compound/polynuclear aromatic hydrocarbon diethylexyl phthalate. The list was developed to meet the RAOs described in the ROD to protect beneficial uses of surface water in San Francisco

 

Bay from the potential for discharge of site groundwater (DON 2010). Table 2-1 lists the proposed analyses for each well. A complete list of analytes is included in Worksheet 15A of the Basewide Groundwater Monitoring Program SAP (SES-TECH 2011).

 

Field parameters including depth to groundwater, pH, conductivity, turbidity, temperature, dissolved oxygen, and oxidation reduction potential will be recorded during post-closure sampling events.

2.1.3        Data Analysis

Data from all shoreline and interior wells will be used for the trend analysis, as required by the ROD. Data from future analyses will be evaluated using historical data. New wells will be monitored for at least four quarters before evaluating trends.

 

Analytical results for each well will be evaluated using a graphical representation of the concentrations trends. A time-series plot will be generated for all wells for the analytes listed above. The plots will be examined to identify obvious trends. A minimum of two samples are required for the plots.

 

Non-detect observations will be treated as nil values (i.e., zeros) in the trend plots, which is consistent with the procedure used in the FS Report (Battelle and BBL 2008).

 

A visual, qualitative assessment will be performed on each time-series plot. Professional judgment will be used on the evaluation with an understanding of site conditions and considering inconsistent results and the possible effects of changes in detection limits. A minimum number of two data points are required for the plots.

 

Finally, a Mann-Kendall trend analysis will be performed for each well/analyte. The Mann- Kendall test will determine whether there is an upward, downward, or no trend. The Mann- Kendall test is not affected by large variations in analyte concentration. A minimum of four samples are required.

 

Groundwater data and trends need to be evaluated with the ROD criteria “to confirm that the contaminants remain within an acceptable range” (DON 2010). This operations  and maintenance plan proposes that so long as monitoring results do not trigger a response as defined in Section 2.1.1, the results are within an acceptable range.

 

2.2              COMPLIANCE PERIOD

The post-closure groundwater monitoring program (PCGMP) is configured as a remedial action monitoring program where the purpose of the monitoring is to assess the performance of the remedial action (Title 22 California Code of Regulations [CCR] Section 66264.100). Because the landfill will be in post-closure, the provision of Section 66264.100 for returning a facility to

 

detection monitoring (Section 66264.98) is not applicable. The performance of the PCGMP will be evaluated during the 5 year review process. The protectiveness of the groundwater  monitoring remedy along with the cover system and ICs will also be evaluated as part of 5-Year reviews required by EPA.

 

The first groundwater monitoring event is planned to occur in February 2014 based on the current landfill construction schedule. Groundwater monitoring data will be  reviewed  and results of the trend analyses will be reported coincident with the Basewide Groundwater Program Monitoring Reports and the scheduled 5-Year reviews. If concentration trend data are consistent with pre-closure data or exhibit declining concentrations, groundwater monitoring frequency may be reduced.

 

2.3              METHANE MONITORING

Methane monitoring will be conducted in accordance with Title 27 CCR, Section 20921 (a), to provide for the protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone and that methane levels in ambient air at the landfill perimeter is in compliance. Nine new monitoring probes will be installed around the landfill perimeter. Methane monitoring probe construction details are included in the 100% RD (Attachment 1 to the RAWP, sheet D-2). Probe locations are shown on sheets C-9 through C-11.

Methane monitoring will be conducted quarterly. Methane will be measured at each probe to evaluate subsurface concentrations. An exceedance of the criterion will be considered verified if concentrations are above 5 percent by volume for any two of three consecutive quarters. If methane concentrations are confirmed, the EPA and the San Francisco Bay Regional Water Quality Control Board will be promptly notified and the gas control system design re-evaluated.

In addition, barometric pressure, atmospheric temperatures, and general weather conditions will be reported at the time of gas collection. It is recommended by the Integrated Waste Management Board to collect landfill gas during barometric low pressures. Depending on the weather, this may be late in the morning or early in the afternoon.

 

In addition to monitoring the probes, perimeter  monitoring  locations  spaced  approximately 250 feet apart along the boundary of the landfill cover will be used to monitor ambient air at the point of compliance. Establishing the perimeter monitoring locations will be the responsibility  of the post-closure operations and maintenance contractor. Relevant standard operating procedures for landfill probe and surface perimeter monitoring are listed in Table 2-2 and included in Appendix B.

 

3.0          OPERATIONS AND MAINTENANCE FOR SITE STRUCTURES

 

 

The maintenance and monitoring will begin once the landfill soil cover construction is complete, anticipated to be in January 2014.

 

3.1              LANDFILL COVER SURFACE WATER MANAGEMENT SYSTEM

Existing drainage features include concrete channel, drainage piping and inlets, concrete outfall culverts, and earthen swales. Supplemental drainage in accordance with the final cover design will supplement existing drainage with a total of three turf reinforced mat channels. An existing concrete channel located on the eastern boundary of the site will be maintained throughout construction, and incorporated into the final drainage system.

 

Concrete channels and earthen swales with turf reinforcement mat collect and divert stormwater runoff. Concrete channels prevent erosion in areas where stormwater flow might accumulate. Proper and adequate inspections of the channels are required to prevent sediment build-up and failure of integrity. Inspections will be conducted annually before the rainy season and in the event of heavy precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or

0.25 inch or more within 1 hour. The inspection will be in accordance with  SOP  004  (Appendix B).

Concrete channels associated with the landfill cover drainage system will be visually inspected by walking the length of each channel. Special attention is required to verify sediment and  debris accumulation along the channels, cracking or fractures of the concrete structure, erosion at joints or along edges, and separation or deterioration of joints between concrete sections.

 

Drainage pipe cleanout ports and discharge piping will be visually inspected for damage or blockage. Drainage pipe outlets, discharge piping, and riser pipes will be cleared to allow free flow of water. The pipe outlets will also be inspected for blockage.

 

Nonconcrete drainage channels and swales will be inspected for erosion and proper functioning. Special attention should be directed to areas of no grass or patchy grass; ripples or swells in the soil caused by erosion; and settlement that inhibits or prohibits storm water flow.

 

Stormwater should flow around, off, and away from the landfill cover, with visual flow directly into the concrete channels or other established drainage routes. The perimeter of the cover  should be inspected to check that drainage flows around and away from the cover. The lip and entrance to concrete drainage channels will also be inspected to check for areas where storm water may not readily enter a channel. Inspection should be made by walking the cover perimeters and drainage channels.

 

3.2              WETLANDS CULVERT

The wetlands culvert hydraulically connects the North Pond to San Francisco Bay. The culvert will be inspected quarterly and in the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

 

3.3              GAS COLLECTION

The landfill passive gas collection system consists of a perimeter boundary conveyance trench filled with high permeability sandy soil surrounding a 4-inch perforated pipe. The pipes are connected to gas vents open to the atmosphere at the high end of the trenches.

 

The gas vent pipes will be visually inspected in accordance with SOP 009 (Appendix B) with extra attention centered on cracks or holes in the riser pipe; missing or damaged screens and end caps; and completely destroyed riser pipes. The gas collection system will be decommissioned if results of methane monitoring indicate that the system is not required based on results provided in annual monitoring reports or the 5-Year Reviews.

 

3.4              GAS PROBES

Existing soil gas probes located within the landfill boundary will be destroyed prior to multilayer soil cover installation. A network of nine probes will be installed around the perimeter of the landfill in order to establish a compliance plane. The probes will be monitored in accordance with SOP 008 (Appendix B).

 

3.5              MONITORING WELLS

Existing groundwater monitoring wells located within the landfill boundary will be protected during cover construction, where feasible. At the completion of the soil cover, all existing wells at the site will be inventoried. If an existing well is damaged, a replacement well screened at the same intervals will be installed within a 5-ft radius of the original well. If excess sedimentation  is noted, the wells will be redeveloped prior to sampling. Results of the well inventory will be reported in the RACR.

 

Routine monitoring well inspection and maintenance will be performed during sampling activities. The condition of the well vault lid, lid bolds, well cap, and well ID will be inspected and noted during each sampling event. Observations will be recorded on field monitoring well sampling forms. Well sampling methodology is included in the current Basewide Groundwater Monitoring Program SAP.

 

3.6              SETTLEMENT MONUMENTS

Four settlement monuments will be installed on the final cover system as shown in the100% RD (Attachment 1). Markers will be located where the depth of fill is the greatest and, therefore,

 

settlement potential is the highest. The monuments will be located so that settlement rate and trends can be monitored and assessed.

 

Monuments will be surveyed annually. Additionally, topographic surveys of the entire cover  will be conducted every 5 years to evaluate settlement. Annual surveying will include the following:

  • Inspect each monument with respect to the surrounding surface of the cover, noting whether the station appears to be even with the surrounding surface, if it is in a depressed area, or if the area is higher than the surrounding surface.
  • Record all observations.
  • Survey and record the elevations of all four settlement monitoring stations to an accuracy of 0.01 foot vertically against the benchmark.

 

Survey data will be collected by a California licensed surveyor and the data will be included in the annual reports and 5-Year Review. If significant settlement is found (typically more than

0.75 foot), a professional engineer will evaluate the situation and the site operator/manager will be notified.

 

3.7              ACCESS ROADS

Access roads within IR Site 2 will be constructed to provide easy access to the site for monitoring and maintenance activities. Each road is approximately 24 feet wide, constructed with 12 inches of compacted aggregate over geotextile fabric (100% RD, Attachment 1 to the RAWP, sheet D-4). Inspection of the roads will be conducted in association with other monitoring and maintenance activities. Access road inspection will be in accordance with SOP 003 (Appendix B). Access road maintenance and repair will be conducted in accordance with SOP 006 (Appendix B).

 

3.8              SIGNAGE

Maintenance activities will include inspection of general information placards for the perimeter monitoring locations and signs for the public indicating trail use or restoration areas on a semiannual basis to ensure that they have not been damaged. Signs that have been altered, or affected by natural conditions, will be replaced.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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4.0        OPERATIONS AND MAINTENANCE FOR LANDFILL COVER SETTLEMENT, EROSION, AND VEGETATION

 

 

4.1              DIFFERENTIAL SETTLEMENT AND EROSION

Differential settlement is caused by decomposition and/or consolidation of subsurface material, which may result in adverse grade or depression on the surface of the landfill cover. Since the groundwater remedy is MNA and the cover design does not address groundwater, differential settlement that results in ponding of surface water or affects drainage controls may not require corrective action. Erosion is anticipated to be the most common problem that will affect the landfill cover. Erosion is typically noted at the base of long slopes where water tends to accumulate due to grading and drainage patterns. Settlement or effects to drainage controls that cause erosion and reduce the thickness of the cover will need to be corrected.

4.1.1        Detection

The IR Site 2 landfill cover will be visually inspected quarterly by the Operations Manager or his/her designee and annually by a registered civil engineer or engineering geologist as described in SOP 001 (Appendix B) to ensure the integrity. Landfill cover maintenance activities will include assessment of the landfill cover conditions, vegetation control and restoration, and animal control. The perimeter of the landfill will be evaluated for areas where surface water is impounded, excessive erosion is evident, or sloughing is apparent on a slope. Surface cracks more than 1 inch wide and 12 inches deep, or longer than 20 feet may indicate slope instability, settlement, or internal thermal activity of the landfill. The quarterly inspection will include looking for pieces of geonet material and waste items on the cover surface that indicate the geonet animal intrusion barrier has been breached by burrowing animals. Landfill cover maintenance and repairs will be conducted in accordance with SOP 007 (Appendix B).

4.1.2        Repairs

For areas where the thickness of the cover has been compromised and repair is warranted, the cover will be repaired by excavating and stockpiling the top cover soils in the impacted area down to the animal intrusion barrier, and regrading that portion of the cover with material comparable to that used in the original cover design. Animal burrows that breach the geonet layer will be filled with low-strength concrete slurry. Repairs will need to be inspected by a registered civil engineer.

 

New fill soils would be placed at the locations designated by the registered civil engineer and compacted to 6 inches below the unaffected surrounding cover and compacted to approximately

90 percent  of  the  Modified  Proctor  maximum  dry  density  with  water  content  within  0  to 4 percent of the modified optimum. The area will be re-covered with the removed topsoil cover material, compacted to approximately 85 percent, and scheduled for vegetation restoration.

 

The final grade will be graded with no more than a 1.5 percent slope and reseeded to match the undisturbed surrounding area. Major repair work will be inspected after completion by a registered engineer. The area will be surveyed after repair to obtain a record of the surface elevations of the repaired area.

 

4.2              VEGETATION

The landfill cover will be hydroseeded with a mixture identified in the Specifications (100% RD Attachment 1 to the RAWP, sheet C-12). Once established, the vegetative cover will appear similar to local natural open space areas. The vegetative cover will turn green during the rainy season and is expected to fade to brown during the dry season. Since the landfill cover will be hydroseeded, during the rainy season, supplemental irrigation is not anticipated. The cover vegetation will be inspected as described in SOP 005 (Appendix B).

 

Reseeding may be required to cover repairs, eroded areas, dead areas, and bald spots. Supplemental irrigation may be required to help establish reseeded areas. Water will be applied to re-seeded areas at a sufficient rate to ensure moist soil conditions to a minimum 1 inch depth, while preventing run-off.

 

4.3              DOCUMENTATION

Inspection of cover settlement should be recorded on the standardized form developed for this purpose provided in SOP 001, Multilayer Soil Cover Inspection.

 

Information on the form includes:

  • Settlement location with regard to permanent markers
  • Measurements of settlement or erosion

 

4.4              EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND SEAWALL

If a major seismic event occurs, the operation and maintenance contractor or designated alternate will initiate procedures to inspect all landfill systems, including settlement monuments. Initial repairs will be performed within 72 hours. For the purpose of this plan, a major seismic event is defined as one that equals or exceeds Intensity V (as defined by the Modified Mercalli Scale) at the site.

 

A major earthquake will require implementation of the following SOPs for inspection of all systems:

  • SOP 001      Multilayer Soil Cover Inspection
  • SOP 002      Landfill Gas Surface Monitoring
  • SOP 003      Access Road Inspection
  • SOP 004      Surface Water Management System Inspection and Maintenance
  • SOP 005      Vegetative Cover Inspection and Maintenance
  • SOP 006      Access Road Maintenance and Repair
  • SOP 007      Multilayer Soil Cover Maintenance and Repair
  • SOP 008      Landfill Gas Probe Monitoring
  • SOP 009      Landfill Perimeter Gas Vent Inspection and Maintenance

 

 

If the seawall or the berm is damaged, it will be repaired. SOP 007 has procedures for repairing shallow and deep cracks, vertical cracks, cracks with vertical displacement, depressions, and sloughing/slope failure, which will be used for berm repair. For seawall repairs, inspection of  the damage by a qualified engineer will be required to design the repairs including procedures  for completing these repairs. These repairs could include relocating displaced riprap, and the use of gunite, concrete, or other similar materials to repair cracks and voids. Placement of additional riprap may also be necessary to repair and/or raise the seawall. Surface water that contacts the landfill waste as a result of a major seismic event will be confined and addressed. The PCGMP well network will also be inspected. Resampling of the monitoring wells will be evaluated. If inspection of the systems detects a noncompliance, the operations and maintenance contractor will notify the site management representative, who will notify the EPA, DTSC, and the Regional Water Quality Control Board.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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5.0        MONITORING AND MAINTENANCE OF WETLANDS MITIGATION AREAS

 

 

A baseline vegetation and wildlife survey that will occur immediately prior to construction will establish overall percent cover, document the composition of the vegetative community, and establish average daily use of the reference areas by shorebirds and waterfowl. Hydrologic success will also be considered.

 

5.1                SUCCESS CRITERIA FOR VEGETATION

During the vegetation survey, permanent 1-meter-square reference plots will be established on transects running through the entire mitigation sites. These transects and monitoring plots will  be assessed on a yearly basis using the same criteria as those used to establish baseline conditions. The survey will document mortality, weed invasion, and rate of  colonization. Success criteria for vegetation are as follows:

  • In the tidal marsh area, existing conditions show a pickleweed community cover density of approximately 75 to 100 percent in the wetland areas that will be affected. The 5-year monitoring goal is to attain this same density and the same plant community composition as under existing conditions.  The Year 1 goal  is to show   10 percent pickleweed cover, increasing to 25 percent at Year 2, 50 percent in Year 3, and 75 percent in Year 4. If these goals are not met, the restored area will be assessed to determine if site conditions are not conducive to plant growth. If needed,  corrective actions including planting pickleweed plugs taken from a nearby location will be implemented. Corrective actions would be implemented in Year 2  and beyond if needed.
    • There is no invasive cordgrass or pepperweed in the tidal marsh at this time. Success criteria require that this state be attained and maintained in the mitigation area for the duration of the 5-year monitoring period.
    • In the open water/mudflat habitat, there will be little to no vegetation in the low- marsh (mudflat) areas, and the mid- and high-marsh areas are projected to be vegetated almost exclusively with pickleweed to reflect current conditions. Success criteria are such that the mudflat area will have less than 10 percent vegetation below

-0.2 feet NGVD29, and this vegetation will be a minimum of 80 percent pickleweed. Above -0.2 feet, pickleweed will increase in density to 75 to 100 percent over 5 years. The pickleweed fringe will be maintained by work crews who will remove cordgrass and pepperweed by hand or other approved method to ensure no encroachment of these weed species.

  • If success criteria are not met, corrective action will be taken. For vegetation establishment, this means that pickleweed plugs will be planted in quantities needed to attain goals if goals are not met at Years 2 and beyond. For invasive species, this means that all invasive cordgrass or pepperweed will be removed on a yearly basis, on a date preceding normal seedset.

 

5.2              SUCCESS CRITERIA FOR WILDLIFE

For wildlife, bird counts will occur at the appropriate time of year and will occur over successive tidal cycles. Bird usage of the tidal pond, the mudflats, and freshwater pond will be documented and used to create the baseline conditions against which to measure success. Success criteria for bird use of the mitigation sites is such that bird use would increase incrementally over a 5-year period as the invertebrate community in the substrate increased, and would match the rate of bird use in the reference (adjacent) areas at the end of the 5-year monitoring period.

 

5.3                SUCCESS CRITERIA FOR HYDROLOGY

Although a detailed hydrologic study of the site has not been completed, success criteria are such that hydrological features found at the reference areas (meaning wetlands directly adjacent to the mitigation areas) will be found in the mitigation areas as well. In the tidal areas, this means that the constructed wetlands will be tidally inundated and drained on a diurnal basis on the same intervals as the reference area.

 

In the open water/mudflat/pickleweed freshwater areas near the South Pond, the mitigation wetlands will have been graded to the same elevation as the reference habitat; therefore, success criteria are such that surface water levels and mudflats will mimic conditions found in the surrounding areas that have the same surface elevation. In general, this means that surface water levels will be highest in the period from December through April, and will diminish thereafter.  In dry years, the freshwater open water area and mudflat may dry completely in late summer.

 

Hydrologic features of the site will not be manipulated during construction; however, if after project implementation hydrological features do not appear to be operating as planned, a hydrologic assessment of the area will be performed by a hydrologist and recommendations for further grading will be made.

 

6.0        SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE ACTIVITIES

 

 

The proposed schedule is presented on Figure 6-1. The schedule assumes that construction of  the cover will be complete in January 2014. Adjustments to the schedule may be necessary if there are changes to the construction schedule. Time frames for activities are approximate and correspond with the frequency of tasks discussed in subsequent sections. Severe damage, catastrophic events, and some minor items, such as watering of the cover vegetation, have not been included since these events do not occur on a regular schedule.

 

6.1              SCHEDULED INSPECTION

IR Site 2 will be inspected quarterly and after major weather (any rain event with 0.5 inch of rain occurring in a 24-hour period) or seismic events (Modified Mercalli Intensity V) for damage, and maintenance will be performed as necessary. Inundation due to gradual sea level rise will be monitored and reported as part of the quarterly inspections. Inspection items and corrective actions are described in the following sections. If damage to the cover system is observed during any post-closure inspection, the cause of the damage will be investigated and documented in the inspection log.

6.1.1        Cover Settlement

Inspection of the landfill cover condition and the slopes of the landfill will occur on a quarterly basis and after significant events.

6.1.2        Geonet Animal Intrusion Barrier

The quarterly inspection will include looking for pieces of geonet material and waste items on the cover surface that indicate the geonet animal intrusion barrier has been breached by burrowing animals.

6.1.3        Methane Monitoring

Methane monitoring will be conducted quarterly for the first 5 years following the completion of the cover construction, and will be re-evaluated during the 5-year review. Methane monitoring will consist of both soil gas probe monitoring and ambient air monitoring at the perimeter of the landfill.

6.1.4        Wetlands Culvert

The culvert connecting San Francisco Bay with the IR Site 2 wetlands area will be inspected on a quarterly basis and after significant events. The Navy will make necessary repairs, modifications or replacement to maintain tidal circulation as recommended by the structural assessment of the culvert if warranted. In the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

 

6.1.5        Site Structures

The following structures shall be inspected semiannually:

 

  • Signage
  • Landfill perimeter gas vents
  • Settlement monuments

 

Settlement monuments will be surveyed annually. Access roads and surface water management structures will be inspected annually before the rainy season and in the event of heavy precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour.

 

6.2              FIELD DOCUMENTATION

SOPs have been included in Appendix B with documentation forms for field recording of scheduled routine maintenance and monitoring data collection.

6.2.1        Document Corrections

Changes or corrections on any project documentation will be made by crossing out the erroneous item with a single line and initialing (by the person performing the correction) and dating the correction. The original item, although erroneous, must remain legible beneath the crossed-out line. The new information should be written clearly above the crossed-out item.

 

7.0    REPORT REQUIREMENTS AND DATA MANAGEMENT

 

 

Reporting will occur as a part of this Plan. Reporting will consist of submitting annual reports to the EPA, DTSC, and Regional Water Quality Control Board. The inspection and monitoring program established will be evaluated annually by an independent, qualified engineer registered in California, The inspection will include review of the condition of all surface improvements, drainage facilities, erosion control facilities, vegetative cover, gas control facilities, and monitoring facilities. Specifically, the annual report will present:

  • Survey data
  • Site inspection data:

–        Condition of vegetation

–        Erosion

–        Cracking

–        Seepage

–        Slope stability

–        Subsidence

–        Settlement

–        Condition of run-on and run-off control systems

–        Condition of surveyed benchmarks

  • Groundwater monitoring system and analytical results for samples collected in the previous semiannual and current annual sampling events
    • Perimeter landfill gas probe and ambient air monitoring results
    • Trends analyses results

 

Initially (for the first year at a minimum), stand-alone reports will be submitted. A 5-year review will be completed for the site at the time of the basewide 5-year review cycle in 2017.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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8.0    POST-CLOSURE FINANCIAL ASSURANCE

 

 

A detailed cost estimate for annual operating, maintenance, monitoring, and reporting is included in Appendix C. The estimated annual cost for anticipated activities is $101,715 in 2012 dollars. The DON is fiscally responsible for post-closure related costs until such time as the site is transferred to the Office of Veteran Affairs.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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9.0    REFERENCES

 

Alameda Agencies (Department of Toxic Substance Control, U.S. Environmental Protection Agency, and Regional Water Quality Control Board), 2013. Installation Restoration Site 2, Alameda Point, Long-Term Groundwater Monitoring Evaluation and Recommendations. Email Correspondence dated May 29, 2013, sent to the DON Alameda Lead RPM, William McGinnis

AMEC (AMEC Earth & Environmental, Inc.). 2010. Draft 2009 Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. March.

—————. 2011. Final 2010 Annual Groundwater Monitoring  Report,  Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. June.

Battelle and BBL (Blasland, Bouck, and Lee, Inc.). 2006. Final Remedial Investigation Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. Prepared for Base Realignment and Closure, Program Management Office West, San Diego,  CA. June 23.

—————. 2008. Final Feasibility Study Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. October.

DON (United  States Department of the Navy).   2010.   Final Record of Decision (ROD) for    IR Site 2, Former Naval Air Station Alameda, California. August.

ITSI (Innovative Technical Solutions, Inc.). 2008. Final Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. November.

KCH (CH2M HILL Kleinfelder, A Joint Venture). 2011. Preliminary Draft Remedial Design Report, Installation Restoration Site 2, Alameda Point, Alameda, California. December.

SES-TECH, 2011. Final Alameda Point Basewide Groundwater Monitoring Program Work  Plan, Alameda Point, Alameda, California. September.

SES-TECH. 2012. Draft Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California (December).

TtEMI (Tetra Tech EM, Inc.). 2009. Draft 2008 Final Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. March.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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TABLES

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Well Name

 

 

Water Bearing Zone

Well Screen Interval (ft bgs)

 

 

Pesticides (EPA 8081)

Volatile Organic Compounds (EPA 8260)

Semi-volatile Organic Compounds (EPA 8270)

 

Dissolved Metals (EPA 6020)

442-MW1ac

Upper FWBZ

7-17

-

-

-

-

M010-Aa

Upper FWBZ

5.5-15.5

-

-

-

-

M011- Aa

Upper FWBZ

3.5-13.5

-

-

-

-

M012- Aa

Upper FWBZ

5-15

-

-

-

-

M013- Aa

Upper FWBZ

3.5-13.5

-

-

-

-

M014- Aa

Upper FWBZ

4.5-14.5

-

-

-

-

M016-A

Upper FWBZ

4-14

SA

-

-

SA

M016-E

Lower FWBZ

14-24

SA

-

-

SA

M018-A

Upper FWBZ

4-14

SA

-

-

SA

M018-E

Lower FWBZ

36-46

SA

-

-

SA

M020-A

Upper FWBZ

5-15

SA

-

-

SA

M020-E

Lower FWBZ

30.5-40.5

SA

-

-

SA

M021-A

Upper FWBZ

3.5-13.5

SA

-

-

SA

M021-E

Lower FWBZ

30-37

SA

-

-

SA

M022-A

Upper FWBZ

3.5-13.5

SA

-

-

SA

M022-E

Lower FWBZ

27.5-37.5

SA

-

-

SA

M023-A

Upper FWBZ

3.5-13.5

SA

-

-

SA

M023-E

Lower FWBZ

25-35

SA

-

-

SA

M024-Ac

Upper FWBZ

5-15

SA

SA

SA

SA

M024-Ec

Lower FWBZ

23.5-33.5

SA

SA

SA

SA

M036-Ac

Upper FWBZ

9-19

SA

SA

SA

SA

M036-Ec

Lower FWBZ

24-34

SA

SA

SA

SA

M037-Ac

Upper FWBZ

10-20

SA

SA

SA

SA

M037Ec

Lower FWBZ

17.5-27.5

SA

SA

SA

SA

M038-Ac

Upper FWBZ

7-17

SA

SA

SA

SA

M038-Ec

Lower FWBZ

17-27

SA

SA

SA

SA

M039-Ac

Upper FWBZ

8-18

SA

SA

SA

SA

M040-Ab

Upper FWBZ

5-15

Q/SA

-

-

Q/SA

M040-Eb

Lower FWBZ

25-35

Q/SA

-

-

Q/SA

M041-Ab

Upper FWBZ

5-15

Q/SA

-

-

Q/SA

M041-Eb

Lower FWBZ

25-35

Q/SA

-

-

Q/SA

M042-Ab

Upper FWBZ

8-18

Q/SA

Q/SA

Q/SA

Q/SA

 

 

 

 

 

Well Name

 

 

Water Bearing Zone

Well Screen Interval (ft bgs)

 

 

Pesticides (EPA 8081)

Volatile Organic Compounds (EPA 8260)

Semi-volatile Organic Compounds (EPA 8270)

 

Dissolved Metals (EPA 6020)

M042-Eb

Lower FWBZ

22.5-32.5

Q/SA

Q/SA

Q/SA

Q/SA

M043-Ab

Upper FWBZ

5-15

Q/SA

-

Q/SA

Q/SA

M043-Eb

Lower FWBZ

23.5-33.5

Q/SA

-

Q/SA

Q/SA

Notes:

a - Well to be used for water level measurements only.

b – Screen intervals for new wells are estimated. Final well completion details will be reported in the RACR.

c – Estimated depth from surface of soil cover. Wells within the cover will be resurveyed and revised well screen intervals will be reported in the RACR.

Abbreviations and Acronyms:

bgs – below ground surface ft – feet

FWBZ – first water-bearing zone

Q/SA – quarterly for first year after installation; semiannual thereafter SA – semiannual

 

 

 

TABLE 2-2

 

STANDARD OPERATING PROCEDURES FOR POST-CLOSURE MONITORING AND MAINTENANCE

 

 

Standard Operating Procedure Title

001

Multilayer Soil Cover Inspection

002

Landfill Surface Gas Monitoring

003

Access Road Inspection

004

Surface Water Management System Inspection and Maintenance

005

Vegetative Cover Inspection and Maintenance

006

Access Road Maintenance and Repair

007

Multilayer Soil Cover Maintenance and Repair

008

Landfill Gas Probe Monitoring

009

Landfill Perimeter Gas Vent Inspection and Maintenance

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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FIGURES

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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FIGURE 2-2

ANALYTICAL COMPARISON FLOW CHART

 

 

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APPENDIX A

LONG-TERM GROUNDWATER MONITORING EVALUATION

(Alameda Agencies, 2013)

 

 

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Installation Restoration Site 2, Alameda Point

Long-Term Groundwater Monitoring Evaluation and Recommendations

 

The Purpose of Long-Term Monitoring-Landfill: Detection of any anthropogenic compounds beyond the landfill footprint.

The Purpose of Long-Term Monitoring-Corrective Action Area: 1) Detection of contaminants discharging above applicable regulatory levels to surface water bodies. 2) To meet the needs of a Monitored Natural Attenuation (MNA) remedy.

Definition of Uppermost Aquifer: The uppermost aquifer is defined as the first water- bearing zone (FWBZ) and occurs from the groundwater surface to the low-permeability Bay sediment Unit (BSU). The FWBZ is comprised of artificial fill and landfill waste.

Two intervals are monitored within the FWBZ. “A” wells monitor groundwater at the base of the landfill waste, and “E” wells monitor groundwater just above the BSU. The FWBZ discharges to San Francisco Bay (the Bay). The shallowest interval also discharges to the wetlands (i.e., North and South Ponds).

Groundwater flow directions: Groundwater flow directions in the FWBZ are away from the center of the landfill towards the wetlands and the Bay. In general, a groundwater mound has been found to occur in the vicinity of MW-38A. This feature is particularly pronounced in the 2004 groundwater elevation map, but persists in following years up to the most recent monitoring period. Flow directions are to the northwest, west, west southwest, and south away from this area. Vertical gradients are generally downward from the upper FWBZ to the lower FWBZ. The results of a tidal influence study performed in 2004 show that wells along the shoreline are tidally influenced. Tidal efficiencies are typically greater in the lower FWBZ than in the upper FWBZ.

Historical Detections of COCs: In general, pesticides, volatile organic compounds, (VOCs) and to a lesser extent, metals have been detected above applicable regulatory levels in monitoring wells screened within the uppermost interval of the FWBZ (“A” wells). Higher concentrations of metals and occasionally pesticides have been detected in monitoring wells screened within the lower interval of the FWBZ (“E” wells). However, it is noted that monitoring for organic compounds has not been performed for “E” wells in recent years.

Adequacy of Monitoring Network:

Based on historical flow directions and contaminant distribution in the FWBZ, additional wells are recommended as follows:

  1. Well 17A should be abandoned and replaced with two new well clusters (two “A” and two “E” wells), equally spaced between well clusters MW-16A/E and MW- 18A/E. This will provide a more robust network on the southern landfill perimeter to monitor COCs that may be migrating south and southwestward toward the Bay.
  2. A new well cluster (“A” and “E” wells) midway between well clusters MW-23A/E and MW-24A/E is needed to provide a more robust network on the western

 

landfill perimeter to monitor COCs that may be migrating west and northwestward toward the Bay.

  1. A new well cluster (“A” and “E” wells) midway between well clusters MW-36A/E and MW-37A/E is needed to provide a more robust network on the northeastern edge of the North Pond to monitor COCs that may be migrating west and southwesterly toward the North Pond. With the addition of this well cluster, monitoring well cluster MW-19A/E is no longer needed and may be abandoned.

Because monitoring is intended to detect migration of COCs into surface water bodies, all monitoring wells screened within or below the Bay Mud (i.e., “B” and “C” wells) are no longer needed and may be abandoned.

Upgradient monitoring wells should be retained for water level measurements to provide continued evaluation of flow directions and gradients.

Sampling and Analysis Plan (SAP): A new SAP must be prepared to provide monitoring requirements for IR Site 2 in compliance with California Code of Regulations Title 27, Subchapter 3. Water Monitoring, and Title 22 Chapter 14, Article 6.

The SAP should include the objectives of sampling, including both detection monitoring and MNA.

A well inventory should be performed to evaluate current condition of monitoring wells that will remain in the program. The construction details should be provided and the current conditions of the wells should be evaluated. Corrective measures (such as redevelopment) should be proposed if deemed necessary.

Compounds of Interest and COCs:

Metals, pesticides, and VOCs should be monitored as follows. Wells along the shoreline should be monitored for pesticides and metals. Interior wells (along the landfill/wetland boundary) should be monitored for metals, pesticides, and VOCs. Shoreline well MW-24A should also be analyzed for VOCs due to historical detections. VOCs are the most mobile of these compounds and may affect the transport of pesticides. VOCs should be monitored to evaluate trends that would indicate plume movement or expansion.

Frequency of Monitoring:

Newly installed monitoring wells should be monitored quarterly for at least one year after which monitoring may be reduced to semiannual pending regulatory notification and approval. Older monitoring wells should be sampled semiannually. Changes to monitoring frequency may be considered during future Five-Year Reviews of remedial actions for Alameda Point. There must be concurrence by Federal Facility Agreement signatories for any changes in monitoring frequency.

 

 

 

APPENDIX B

STANDARD OPERATING PROCEDURES

(on CD only)

 

 

 

This page intentionally left blank.

 

SOP 001

MULTILAYER SOIL COVER INSPECTION

 

1.0 GENERAL

 

The multilayer soil cover should remain intact, free of major cracking (defined as cracks 1-inches or wider, deeper than 12-inches, and longer than 20-feet), erosion (deeper than 12-inches) and surface depressions that could cause ponding. The vegetation inspection is described in Standard Operating Procedure (SOP) 005 (Vegetation Cover Inspection and Maintenance).

 

2.0 TASK DESCRIPTION

 

The task covered by this SOP is the visual inspection of the cover which guides maintenance and repair planning and implementation. Regular visual inspections of the cover shall be performed quarterly by the Operations Manager or his designee, and annually by a registered civil engineer.

 

3.0 REQUIRED MATERIALS

 

The following items are needed to perform a visual inspection:

  • A copy of the landfill map (attached)
  • Form SOP 001 (Cover Inspection Form)
  • Survey stakes
  • Measuring tape
  • Clipboard
  • Pen with indelible ink
  • Camera

 

4.0   TASK PERFORMANCE

 

Record inspection observations on Form SOP 001. All areas exhibiting the conditions listed below shall be recorded on the form and flagged or staked in the field. The completed form shall be given to the Operations Manager, who will then refer to SOP 007 (Multilayer Soil Cover Maintenance and Repair). The following are guidelines for conditions to be observed and recorded:

  • Eroded areas (erosion deeper than 6-inches)
  • Landfill cover soil conditions such as sloughing and sliding
  • Cracks, fissures, or other features that may potentially allow gas migration or surface water infiltration. Cracks in the cover longer than 20 feet and deeper than 12 inches and wider than 1 inches shall be examined and evaluated by a registered civil engineer.
  • Areas of subsidence, depressions, or topography where ponding may occur
  • The state of surface water management facilities, failure or malfunction of which could impact cover performance
  • Culvert integrity and blockage which would impede flow to wetlands

 

In addition to regular visual inspections, the landfill cover shall be inspected as soon as it is accessible following the events listed below:

  • Significant rainfall (as defined in SOP 004 – Surface Water Management System Inspection). Note in particular erosion, or areas of slope deformation
  • Major earthquakes. Note in particular cracks, deformation, or zones of slope instability.
  • Failure of the surface water management control system. Note in particular erosion, wet or saturated cover soils, ponding, or areas where there is a potential for increased infiltration.
  • An emergency as defined in the Emergency Response Plan

 

If at any time a condition of cover distress is observed, it shall immediately be reported to the Operations Manager.

 

FORM SOP 001 COVER INSPECTION

 

 

 

 

Type of Inspection:


 

Quarterly Semiannual


 

Inspector:     Name:                          


 

Affiliation:                      

 

 

Date:                                                        Time                                     Weather Condition:                                 

 

 

OBSERVATION TYPE AND DETAILED DESCRIPTION:

Erosion                  Sloughing/Sliding                 Cracks/Fissures                Subsidence/Depression                   Other

 
   

 

 

 

LOCATION OF OBSERVATION (Show on map):                                                                         

 
   

 

 

 

 

ACTION TAKEN:                                                                                                                            

 
   

 

 

 

 

 

REMARKS:                                                                                                                                       

 
   

 

 

 

 

 

Signature

 

Operations Manager                                                                                                      Date                                     

Site Manager

(for annual inspection only)                                                                                         Date                                     

 

STANDARD OPERATING PROCEDURE

Last Revised 11/29/11

 
   

 

 

 

 

 

SOP 104-4

 

SOP 002

 

LANDFILL SURFACE GAS MONITORING

 

 

1.0 GENERAL

 

Landfill surface gas monitoring is performed to evaluate the effectiveness of the landfill cover and the passive gas control system in controlling the movement of methane through the cover. The objective of this Standard Operating Procedure (SOP) is to monitor ambient air at 250 foot intervals around the perimeter of the landfill in order to identify specific locations or areas of the landfill surface with elevated emission rates greater than 50 ppmv. Selection and permanently identifying the monitoring stations will be the responsibility of the Operations and Maintenance contractor.

2.0 TASK DESCRIPTION

 

Surface gas monitoring will be conducted quarterly during landfill gas probe monitoring activities (SOP 008). Surface gas monitoring will be conducted buy a field technician using hand held instruments.

3.0 REQUIRED MATERIALS

 

The following equipment and supplies are needed:

 

  • Methane monitoring instrument capable of measuring methane in the PPM range (such as the GasTech Innova or equivalent)
    • Landfill map with monitoring stations

 

  • Clipboard

 

  • Portable wind speed (anemometer) meter

 

  • Thermometer

 

  • Pen with indelible ink

 

  • Safety vest (orange)

 

  • Surface Emission Data Sheet (Form SOP 002-1)

 

Note: Other safety-related equipment may be required when performing emissions monitoring.

 

4.0    TASK PERFORMANCE

 

4.1                  EQUIPMENT STARTUP PROCEDURES

 

Calibrate instruments in accordance with manufacturer specifications.

 

4.2                  MONITORING CONDITIONS

 

The average wind speed suitable for surface gas monitoring is less than 10 miles per hour (mph). Monitoring is terminated when the average wind speed exceeds 10 mph or the instantaneous wind speed exceeds 15 mph. Average wind speed is determined on 15 minute intervals. Suface gas monitoring is conducted when the landfill is dry and no rain is falling. The landfill is considered dry when there has been no rain (>.10 inches) for the preceding 72 hours prior to monitoring. Any delays due to excessive wind speeds, rainfall, construction activities, etc., should be noted.

4.3                  SAMPLING PROCEDURES

 

At each monitoring locations, the field technician record the temperature, and the average and maximum wind speed. The methane monitoring instrument will be held approximately 3 inches from the landfill surface for 2 to 5 minutes or until methane concentrations (if any) is stabilize. Measurements will be recorded on the Surface Emissions Data Sheet (Form SOP 002-1).

For readings of 50 ppmv or greater description of the suspected cause of the exceedance (i.e., cracking, thin cover, exposed waste) will be recorded on the form.

4.4    EXCEEDANCE ACTION

 

If a location exceeds 50 ppmv, the location will reported to the Operations Manager for appropriate actions including possible cover repair or modifications to the passive gas collection system. Within 1 day after the repair, the area will be re-monitored to determine if additional remediation is required.

4.5                  REPORTING REQUIREMENTS

 

In the event of an exceedance, report of findings will be submitted to the DON six weeks after completion of the survey.

 

Form SOP 002-1 SURFACE EMISSIONS DATA SHEET

 

 

 

 

 

Location ID

 

 

 

Temerature (Degrees F)

 

 

Sampling Time (min)

 

 

 

Methane (PPM)

 

 

Ave/Max Wind Speed (mph)

 

 

Barometric Pressur

(in. Hg)

 

 

 

 

Observations

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Date                                                                   Technician            Initial Calibrated   


Instrument Serial No.:                                          Final Calibrated      

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Notes:

 

 

SOP 003

ACCESS ROAD INSPECTION

1.0 GENERAL

 

The access roads provide all-weather access to the landfill. Each road is approximately 24 feet wide, constructed with 12 inches of compacted aggregate over geotextile fabric.

 

2.0 TASK DESCRIPTION

 

This SOP addresses the visual inspection of the access roads to note conditions that may require road maintenance and repair. Access Roads will be inspected annually by a registered civil engineer before the rainy season and in the event of heavy precipitation resulting in either .50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour.

 

3.0 REQUIRED MATERIALS

 

The following items are needed for a visual inspection:

 

  • Copy of the access road system map
  • Copy of the Access Road Inspection Form (Form SOP 003-1)
  • Pen with indelible ink
  • Clipboard
  • Survey stakes
  • Ribbons and markers
  • Measuring tape
  • Camera

 

4.0 TASK PERFORMANCE

 

Inspection observations are recorded on Form SOP 003-1. Inspection results will be evaluated against SOP 006 (Access Road Maintenance and Repair). The following are guidelines for conditions to be observed and recorded:

  • Adverse grades (that may impede drainage)
  • Cracks wider than ½ inch, and longer than 50 feet (cracks wider than 2 inches and deeper than 12 inches and longer than 50 feet shall be examined by a registered civil engineer)
  • Localized depressions (that may cause ponding)

 

 

  • Sloughing
  • Excessive erosion (greater and 3 inches) of road surface
  • Loss or deterioration of surfacing
  • Debris (soil or vegetation) from upgradient slope
  • Damaged or missing road signs
  • Damaged drainage structures (see SOP 004 - Surface Water Management System Inspection and Maintenance).
    • Deformation of the upgradient or downgradient slope that affects road use (see SOP 001

– Cover Inspection).

 

  • Extensive cracking (deeper than 6 inches)
  • Depressions (causing ponding)
  • Deep erosion (deeper than 6 inches)
  • Adjacent slope instability
  • Exposure of a geotextile material or absence of granular road base material.

 

A registered civil engineer shall establish the need for additional observations, including but not limited to:

  • Test pits
  • Test trenches
  • Settlement or deformation measurements

 

In addition to annual inspections, access roads shall be inspected after the following:

 

  • Significant rainfall (as defined in 004 – Surface Water Management System Inspection). Note in particular erosion.
  • Major earthquakes. Note in particular cracks, deformation, or zones of actual or incipient slope instability.
  • Failure of the surface water management control system. Note in particular erosion, wet or saturated soils, ponding, or areas where there is a potential for increased infiltration.
  • An emergency as defined in the Emergency Response Plan.

 

 

 

FORM SOP 003-1

ACCESS ROAD INSPECTION FORM


 

 

 

 

Page 1 of 2

 

 

 

 

Type of Inspection:


 

Annual


 

Other           Inspector:  Name:                           


 

Affiliation:                    

 

 

Date:                                                       Time                                                        Weather                                                             

 

ROAD/LOCATION

NORMAL

ABNORMAL

STATION

DESCRIPTION *

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

* Use following codes for observed conditions: 1-adverse grades; 2-cracking; 3-depression; 4-sloughing; 5-erosion; 6-loss of surfacing; 7-debris form upgradient slope; 8-damaged/missing road signs;

9-damaged drainage structures; 10-slope deformation.

 

Signatures

 


Operations Manager                                                                                                         Date

Registered Civil Engineer

(for annual inspection only)                                                                                         Date                                     

 

 

SOP 004

SURFACE WATER MANAGEMENT SYSTEM INSPECTION AND MAINTENANCE

1.0  GENERAL

The inspection and maintenance of the Surface Water Management (SWM) system are described in this Standard Operating Procedure (SOP). The SWM system provides for surface water drainage, and controls infiltration into and erosion of the landfill cover. SWM components include the concrete channel and three turf reinforced mat channels.

 

2.0  TASK DESCRIPTION

An annual survey of the SWM system will be conducted prior to the rainy season. The survey will be performed by a registered professional civil engineer or other qualified professional in addition to site personnel. In the event of heavy precipitation resulting in either .50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour, a site inspection will be conducted immediately following the storm event.

 

3.0   TASK PERFORMANCE

As part of the annual survey, complete Form SOP 004-1. Form SOP 004-2 should be completed during the routine inspections and inspections performed after rain events.

 

Any breakdown and subsequent repair of the SWM system shall be documented on Form SOP 004-3 and reported to the Operations Manager immediately. Below is a list of procedures associated with SWM system maintenance:

 

  1. Concrete Channel
  • Clear debris or vegetation having a stem greater than 1 inch in diameter
  • Repair cracks and grout as required to maintain integrity of concrete
  1. Turf Reinforced Mats
  • Clear debris or other drainage obstructions
  • Repair or remove and replace matting as needed due to base soil loss or washouts
  • Replace infill as needed to maintain proper grades and/or soil loss
  • Re seed to maintain vegetation cover
  1. Drop Inlets
  • Adjust inlet riser to remain flush with top of geocell
  • Repair gaps between pipe and surface completion

 

 

  1. Sediment Traps/Erosion Control
  • Remove silt buildup greater than 6 inches
  • Repair as necessary
  • Follow maintenance procedures outlined in the SWPPP for the BMPs for Erosion and Sediment Control
  1. Discharge Outlets
  • Clear debris, vegetation, and other obstructions
  • Repair or replace discharge piping or structure as necessary
  1. Drainage Pipe
  • Clear vegetation and debris
  • Remove silt when buildup exceeds 6 inches
  • Remove and replace pipe if the integrity of the pipe is impacted
  1. Drainage Inlet
  • Clean and regrout areas of cracking or spalling
  • Remove debris and silt buildup inside box and weep holes
  • Clear debris or vegetation from debris rack or grate
  • Remove silt buildup greater than 6 inches

 

 

FORM SOP 004-1

Surface Water Management System Annual Inspection Checklist

Page 1 of 2

Inspection Performed by:                                                                           Date:                              

 

Component to Be Checked

Finding

Comment (Additional space end of form)

Sloping and Grading

Slope of the top cover area > 1%?

Yes    No

 

Longitudinal slope of access and bench roads > 1%?

Yes    No

 

Cross slope of access and bench roads

> 3%?

Yes    No

 

Storm Drain Pipe

Slope of each pipe ³ 3%?

Yes    No

 

Slip joints/joint displacement?

Yes    No

 

Anchor stability adequate?

Yes    No

 

Stress, leaks, or erosion in joints?

Yes    No

 

Cover erosion under pipe?

Yes    No

 

Misalignment, corrosion, loss of protective coating?

Yes    No

 

Blockage?

Yes    No

 

Erosion upstream or downstream of pipe invert?

Yes    No

 

Concrete Channel

Has displacement of concrete occurred?

Yes    No

 

Debris, large bush, or vegetation > 1 inch in diameter present?

Yes    No

 

Grout or concrete integrity adequate?

Yes    No

 

Turf Reinforced Mats

Longitudinal slope > 1%?

Yes    No

 

Integrity of matting walls adequate?

Yes    No

 

Debris or other drainage obstructions present?

Yes    No

 

Exposed liner present?

Yes    No

 

 

 

Have their been any washouts?

Yes    No

 

Drainage Inlets

Debris or vegetation at inlet?

Yes    No

 

Silt buildup or other blockage present?

Yes    No

 

Corrosion?

Yes    No

 

Displacement? (Inlet should remain flush with surface)

Yes    No

 

Gaps between inlet and piping?

Yes    No

 

Culverts (Pipes)

Yes    No

 

Integrity of pipe adequate?

Yes    No

 

Sediment Trap/Erosion Controls

Silt Build-up?

Yes    No

 

Missing or damaged sections?

Yes    No

 

Discharge Outlets/Outfalls

Debris or oversized vegetation at structure?

Yes    No

 

Corrosion at facility?

Yes    No

 

Integrity of facility adequate?

Yes    No

 

Leaks and/or deterioration at piping connections?

Yes    No

 

Any conditions present which may impede flow capacity?

Yes    No

 

 

Comments                                                                                                                                         

 

 
   

 

 
   

 

 
   

 

Surface Water Management System Inspection Checklist

 

Inspection Performed by:                                                                           Date:                              

 

Component to Be Checked

Finding

Comment (Additional space end of form)

Storm Water/Erosion Control

Runoff Inundation?

Yes    No

 

Gully washes, washouts, or overtopping of drainage system?

Yes    No

 

Areas of ponding? If yes, identify where.

Yes    No

 

Debris or clogging of drain inlets?

Yes    No

 

Integrity of double containment structures adequate?

Yes    No

 

Contaminated liquids present in double containment structures? If yes, determine nature of liquid.

Yes    No

 

Erosion along edge of concrete or turf mat channels?

Yes    No

 

 

 

Comments:                                                                                                                                         

 

 

 

 

STORM WATER/EROSION CONTROL BREAKDOWN AND REPAIRS FORM

 

Date:                                                                           Inspector:                                                       

 

Observations                                                                           Personnel Notified:                            

1. Subsidence

5. Slope Condition

                                                           

2. Cracks

6. Damaged Materials

                                                           

3. Obstructions

7. Silt Deposition

                                                           

4. Washouts

8. Vegetation

                                                           

 

 

Type of Breakdown/Failure                                                                                                              

 

 

 

 

 

Location (show on map)                                                                                                                    

 

 

 

 

 

Action Requested                                                                                                                               

 

 

 

 

 

Action Taken                                                                                                                                     

 

 

 

 

 

Comments                                                                                                                                          

 

 

 

 

 

 

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

 
   

 

 

 

 

 

Final Construction As-Built Report,

 

SOP 005 VEGETATIVE COVER

INSPECTION AND MAINTENANCE

1.0  GENERAL

 

The vegetative cover provides moisture penetration control, erosion control, and visual enhancement across the landfill slopes and top deck. The vegetative cover selected to provide these results is comprised of California native plants.

 

Once established the vegetative cover will appear similar to local natural open space areas. The vegetative cover will turn green during the rainy season and is expected to fade to brown during the dry season.

 

2.0   TASK DESCRIPTION

 

The vegetative cover shall be visually inspected at the intervals listed in the Post Closure Operations, Maintenance and Monitoring Plan. The frequency of inspection and maintenance may be varied by the Operations Manager to respond to seasonal variations in precipitation and vegetation establishment and growth.

 

In addition to the landscaping covering the refuse, some areas along the periphery contain native growth areas and wetland that will require inspection which must be inspected and cut back as necessary.

 

3.0  REQUIRED MATERIALS

 

The following items are necessary:

  • Copy of the Wetlands Mitigation Plan (attachment 7- of the Remedial Action Work Plan)
  • Copy of Vegetative Cover Inspection Form (Form SOP 005-1)
  • Copy of Landfill Map

 

4.0  TASK PERFORMANCE

 

Using the following as guidance record observations, on Form SOP 005-1(Vegetative Cover Inspection Form):

  • Weed and fire control - Observe growth of nuisance weeds and plant materials after the end of the rainy season. Nuisance weeds include Mustard, Tumbleweed, Tree Tobacco,

 

Castor Bean, Pompas Grass, Eucalyptus, Elm, and Bermuda Grass. Other plants that may naturalize should be verified for removal when they occur.

  • Reseeding and Soil fertilization program - Determine locations of poor growth for soil analysis in late summer. Evaluate the establishment rate and appearance of the vegetation. Determine areas that require reseeding.
  • Rodent control - Evaluate visible signs of burrowing rodents during routine inspections around the site.
  • Erosion Control – check for soil erosion

 

5.0   MAINTENANCE

 

In cases where an inspection establishes a deficiency in the vegetation that could be repaired by immediate action, such action shall be taken in discussion with the Operations Manager.

 

Inspections recorded on Form SOP 005-1 shall be considered by the Operations Manager. He shall issue plans and instructions for ongoing vegetation maintenance or replacement. Examples are:

 

  • Weed removal – Remove by hand at first signs of growth. If Mustard and Thistle has spread, removal options include mowing. Foliage removal is another option for Mustard.
  • Reseeding and soil fertilization program – Reseed areas of poor growth in late fall or early winter using seed mix specification in Attachment 1 sheet C-12.
  • Soil Erosion – Repair per SOP 004 (Surface Water Management System Inspection, Surveillance, and Maintenance Activities.
    • After the end of the rainy season, and after grasses have produced seed, the crown of the landfill will be mowed to control weeds. Other areas of the landscaped portion of the site will be weeded or mowed if practical.
    • Until coverage of seed mixes approaches design values, probably in the second or third growing season post mechanical completion, a landscape consultant will be used seasonally to recommend mixes, amendments, and reseeding techniques.

 

 

FORM SOP 005-1 VEGETATIVE COVER INSPECTION FORM

AREA:                                                                        DATE AND TIME:                                     

 

BOUNDARY ACCESS ROADS:                              INSPECTOR:                                               

 

 

GENERAL SOIL CONDITION: WET          


DRY           


WEATHER:                                 

 

 

ITEM

COMMENTS

ACTIONS TO BE TAKEN

Grass

 

 

Shrubs

 

 

Weeds

 

 

Soil Erosion

 

 

Non-Native Plants

 

 

Evidence of Burrowing Rodents

 

 

 

 

 

 

 

SOP 006 ACCESS ROAD

MAINTENANCE AND REPAIR

1.0   GENERAL

 

Standard Operating Procedure (SOP) 003 (Access Road Inspection) describes the access and road inspection procedures. The inspection findings are documented on Form SOP 003-1. Based on that information, the Operations Manager will implement maintenance and repair activities as described in this SOP.

 

2.0  TASK DESCRIPTION

 

Maintenance includes ongoing, routine, or regular activities necessary to keep the roads in a safe and functional state and protect the cover design.

Repair includes area specific work that may be required from time to time to restore or improve the state or functioning of the roads and the cover.

 

3.0   TASK PERFORMANCE

 

The Operations Manager shall review relevant inspection observations and monitoring data, and shall establish the need for and extent of maintenance and repair. Repairs will be done in accordance with RD Attachment 1specifications. The Operations Manager may consult with licensed/registered specialists to compile alternate repair plans or specifications.

 

4.0   GUIDELINES FOR MAINTENANCE AND REPAIR

 

Maintenance and repair procedures vary depending on existing conditions such as cracks, adverse grades, depressions, erosion gullies, sloughing or slope failures. Maintenance and repair of the access roads shall be documented on Form SOP 006-1.

 

  1. Cracks
  • Cracks wider than ½-inch and longer than 20-feet shall be repaired. Surface cracks shall be evaluated for evidence of vertical displacement across the crack and depth of crack. If crack extends to full depth of road base, the geotextile layer separating the road base and underlying layer may have to be penetrated or removed to evaluate depth of crack. The location of cracks shall be mapped and documented. An up-to-date crack location map shall be maintained to identify areas of chronic cracking.
  • Minor cracks less than 6 inches in depth shall be scarified to the depth of crack and recompacted.
  • Cracks deeper than 6-inches and with no vertical displacement across the cracks shall be repaired by excavating a 2 to 3 foot wide zone to the depth of crack and replacing the excavated layer with aggregate base to RD Attachment 1 specifications.
  • Major cracks (wider than 1 inches and deeper than 1 foot and longer than 20 feet), or cracks with vertical displacement across the crack may be indicative of slope deformation/sliding and shall be first evaluated by a registered civil engineer prior to implementing repair. The repair may include removal and recompaction of a relatively large section of the roads and adjacent slope to stabilize the area. (See also Section 4.0 of SOP 007 – Multilayer Cover Maintenance and Repair).
  • In areas of chronic cracking (where cracks reappear on a regular basis) more extensive crack repair/control measures should be considered. Such measures may include but are not limited to excavating a wide area straddling the crack, constructing a reinforced foundation consisting of one or more layers of geogrid below the barrier.
  • The designs for repair of major cracks, slope deformations/sliding and areas of chronic cracking as described above shall be prepared by a registered civil engineer. The engineer will develop a number of appropriate standard designs to repair such cracks and will recommend or approve use of same to repair the subject cracks.

 

 

  1. Surface Depressions:

 

  • Localized minor surface depressions, less than 1 foot deep, shall be repaired by backfilling with the compacted aggregate base per RD attachment 1 specifications.
    • Large surface depressions, greater than 1-foot deep, shall be evaluated to determine if the barrier layer below this road subgrade has been impacted. A test pit may be excavated, geotextile removed, and the animal intrusion barrier inspected to determine evidence of excessive cracking or saturation. If the cover layer has been impacted, repair of the depression will include excavation of the area to the subgrade layer, preparation of cover, and replacement and reconstruction of the multilayered cover system to RD Attachment 1 specifications. If the compacted layer beneath the animal intrusion barrier is found to be intact, repair of the depression area shall include backfilling and compacting of the subgrade repair of geotextile fabric compaction of the aggregate base. At the completion of this repair, a survey of the repaired area shall be performed and recorded in the Record Drawings.

 

  1. Erosion Damage:

 

  • Erosion channels penetrating only the road surface materials shall be repaired by removal of material from the channel sides and bottom to competent material surface, and replacing with compacted aggregate The backfilling and compaction shall be performed

 

in maximum 6-inch thick layers using the appropriate compactors for the size of the area being worked.

  • Deep erosion channels extending to the geotextile and cover layer shall be repaired by excavation and replacement of the different layers of materials used in the original access road section. The cover layer, if affected, shall be excavated to its full depth and replaced with compacted material within design specifications.

 

  1. When repairing the layered cover system below access roads, each layer shall be tied into existing layers of the corresponding material and constructed to project specifications. Replacement geotextile or geonet shall be overlapped a minimum of 24 inches over existing geotextile.

 

  1. Adverse access road grades will be restored by placement of additional subgrade material and replacement of roads surfacing material over the reconstructed part.

 

 

FORM SOP 006-1 ACCESS ROAD REPAIR RECORD

Inspector                                                                                          Date:                                         Time:                                 

 

 

DEFICIENCY TYPE AND DETAILED DESCRIPTION:                                                              

Cracking                Depressions                   Erosion                  Sloughing                  Adverse Grades                 Other

 
   

 

 

 

 

LOCATION OF REPAIR ACTIVITY (Show on map):                                                                   

 
   

 

 

 

 

 

ACTION TAKEN (refer to repair detail or design drawings, as appropriate):                                 

 
   

 

 

ATTACHMENTS (As-Built drawings, compaction reports, etc., as appropriate):                          

 
   

 

 

REMARKS:                                                                                                                                       

 
   

 

 

 

Signature

 


Operations Manager                                                                                                         Date

 

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

 
   

 

 

 

 

 

 

 

SOP 007

 

MULTILAYER SOIL COVER MAINTENANCE AND REPAIR

1.0   GENERAL

 

The landfill multilayer soil cover consists of a minimum 6 inch compacted soil layer, an animal intrusion (geonet) barrier, an 18 inch compacted soil cover, and an 6 inch vegetative layer. The functions of the multilayer soil cover are to contain refuse, control infiltration, support vegetation, and control gas emissions. These functions are achieved if the cover is intact, free of significant cracking and erosion, maintains specified grades, and supports vegetation. This Standard Operating Procedure (SOP) describes the procedures to maintain or repair the cover.

 

2.0  TASK DESCRIPTION

 

The tasks covered by this SOP are maintenance and repair of the cover. Maintenance includes ongoing, routine, or regular activities necessary to keep the cover in a functional state. Repair includes area specific work that may be required from time to time to restore or improve the state or functioning of the cover.

 

3.0   TASK PERFORMANCE

 

Maintenance or repair of the landfill cover is undertaken as established pursuant to observations, inspections, or monitoring in accordance with one or more of the following:

  • SOP 001 – Multilayer Soil Cover Inspection
  • SOP 002 - Landfill Surface Gas Monitoring
  • SOP 003 - Access Road Inspection
  • SOP 004 - Surface Water Management System Inspection and Maintenance
  • SOP 005 - Vegetative Cover Inspection and Maintenance
  • SOP 006 - Access Road Maintenance and Repair

 

The Operations Manager shall review relevant inspection observations and monitoring data, and shall establish the need for and extent of maintenance and repair. Repairs will be done in accordance with Record Drawings and specifications. The Operations Manager may consult with licensed/registered specialists to compile alternate repair plans or specifications.

Repair that involves construction should be undertaken in conformance with construction drawings and specifications.

 

4.0   GUIDELINES FOR MAINTENANCE AND REPAIR

 

Maintenance and repair procedures vary depending on existing conditions such as cracks, depressions, erosion gullies, sloughing or slope failures. Maintenance of the cover shall be recorded in daily logs, notebooks, or other reporting formats as may be used on a regular basis.

 

Following repair to the cover, the repaired areas shall be revegetated in accordance with SOP 005 (Vegetative Cover System Inspection and Maintenance). Repair of the cover shall be documented on Form SOP 007-1. The DON will be notified of start and finish of major repair activities (i.e. those necessary to restore compliance with Performance Standards).

 

  1. Vertical and Near-Vertical Cracks:
  • Surface cracks shall be evaluated for length, width, and depth of crack and evidence of any relative vertical displacement (vertical offset) across the crack. Significant cracking (cracks 1 inches or wider, deeper than 12 inches and longer than 20 feet) shall be repaired. Cracks in the cover longer than 20 feet and deeper than 1 foot and wider than 1 inches shall be examined by a registered civil engineer. The engineer will develop a

number of standard designs to repair such cracks and will recommend or approve the use of same to repair the subject cracks. Other cracks, e.g., longer than 20 feet but less than 1 inches wide, will be repaired as necessary by the site forces.

  • For shallow cracks (not greater than 1 foot deep) with no vertical offset, the first response is to apply a small quantity of water (water truck application) to the cracked area and use tracked equipment to squeeze the cover materials into cracks and sufficiently repair them. If the cracks aren’t repaired using this method, excavate a 2 to 3 foot wide area straddling the crack to the depth of cracking and replace with cover materials compacted to project specifications. Compaction may be achieved in horizontal lifts with hand compaction equipment or parallel to slope face with sheepsfoot rollers (winched from bench above or mounted on long-reach backhoe arm).
  • Deeper cracks (deeper than 1 foot) with no vertical offset shall be repaired as follows:

–        The lower portion of the crack below a depth of 1 foot shall be sealed by grouting.

–        The grout shall consist of a mix of fine or silty sand with approximately 5 percent by weight of bentonite mixed with water to mortar-like consistency. Grouting shall be done at 5-foot centers through a grouting pipe inserted into the crack. At each injection point, grouting shall be performed in 2-foot vertical stages proceeding from the bottom up. Grouting shall continue until a pressure of 5 psi is reached, ground surface movement is observed, the void is substantially filled, or grout is identified at the surface.

–        The upper 2 feet of cover over a 2 foot wide zone straddling the crack shall be reworked by compacting the existing cover to project specifications using compaction methods outlined above.

 

  • Cracks and voids in the cover adjacent to concrete channels or swales shall be repaired by grouting in the same manner described above.
  • Major cracks with vertical displacement across the crack, in particular on the slopes along the contours, may be indicative of slope deformation or sliding. The Operations Manager may consult with a specialist to evaluate such conditions and recommend appropriate repair measures. The repair may involve excavation of large areas of the cover material, possibly to the full depth of the multilayer cover including animal intrusion barrier replacement. The area affected shall be excavated making sure that the upper part of the slope showing cracks is excavated first to minimize potential for slope failure. The excavated area shall be backfilled with cover material in 6” thick horizontal lifts, moisture-conditioned, and compacted to project specifications using sheepsfoot compaction equipment. Animal intrusion barrier replacement should be performed according to specifications. The repair design shall be prepared by a registered civil engineer. The Operations Manager may consult with licensed/registered specialists to compile alternative repair plans or specifications.
  • Surface Depressions: Surface depressions that could cause ponding shall be repaired by backfilling with cover material. Prior to backfilling, the area of the depression shall be cleared of vegetation and scarified to a minimum depth of 6 inches. Backfill materials shall be placed in 6-inch thick lifts, moisture-conditioned, and compacted to project specifications.
    • Erosion Gullies:
    • 0” to 6” deep: May warrant cosmetic raking or track walking prior to reseeding
    • 6” to 12” deep: Remove loose soil, place cover soil in 6” thick lifts, moisture condition to project specifications, and compact parallel to slope face using sheepsfoot roller.
    • >12” deep: Remove loose soil. Place cover materials moisture conditioned and compacted to project specifications in lifts £ 6” thick. Backfill should be benched into competent in-place fill. Compact with hand held temper or other means in horizontal lifts, tilted slightly into slope
      • If the timely repair of the erosion gullies is not feasible due to continuing wet weather, temporary backfilling of erosion gullies may be performed to minimize potential for enlargement of channels. Such temporary backfilling may be performed using coarse rockfill or sandbags. The rockfill and sandbags shall, however, be removed prior to performing permanent backfilling with cover material.

 

  1. Sloughing/Slope Failures:
  • The Operations Manager may consult with a specialist to evaluate the cause of sloughing/slope failure and recommend remedial measures.
  • Should sloughing of the cover be shallow (less than 12 inches thick) and occur due to saturation from rains, irrigation line or surface water facility failure, the sloughed material shall be removed and the affected area shall be repaired in a similar manner as surface depressions.
  • Should sloughing occur on the slope along the contour, it may be indicative of slope failure. The remedial grading for slope failures shall be performed in a similar manner as for major surface cracks. Repair designs shall be prepared by a registered civil engineer.

 

 

FORM SOP 007-1 LANDFILL COVER REPAIR RECORD

Maintenance Technician:                                     Date:                            Time:                         

 

 

DEFICIENCY TYPE AND DETAILED DESCRIPTION:

Erosion                  Sloughing/Sliding                 Cracks/Fissures                    Subsidence/Depression               Other

 
   

 

 

 

 

LOCATION OF REPAIR ACTIVITY (Show on map):                                                                   

 
   

 

 

 

 

 

REPAIR ACTION TAKEN (refer to repair detail or design drawing as appropriate):                     

 
   

 

 

ATTACHMENTS (As-Built drawings, compaction reports, etc., as appropriate):                           

 
   

 

 

REMARKS:                                                                                                                                       

 
   

 

 

 

Signature

 


Operations Manager                                                                                                         Date

 

STANDARD OPERATING PROCEDURE

Last Revised: 10/18/00

 
   

 

 

 

 

Final Construction As-Built Report,

 

 

SOP 008

LANDFILL GAS PROBE MONITORING

 

1.0 GENERAL

 

Landfill gas probes are monitored for both the pressure and methane gas to provide for the protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone, and that levels are in compliance within ambient air at the landfill perimeter. This Standard Operating Procedure (SOP) addresses routine probe monitoring.

 

2.0 TASK DESCRIPTION

 

Landfill gas probes will be monitored quarterly. The condition of the probes is physically inspected prior to monitoring. Probes are monitored for both gas pressure and general composition (i.e., methane – CH4, carbon dioxide – CO2, oxygen – O2, and nitrogen – N2) using the GEM-500 gas analyzer or equivalent. Probe monitoring is conducted quarterly.

 

Records will be taken for barometric pressure, atmospheric temperatures, and general weather conditions at the time of gas collection. It is recommended to collect landfill gas during barometric low pressures. Depending on the weather, this may be late in the morning or early in the afternoon.

 

3.0 REQUIRED MATERIALS

 

The following materials and equipment are required for this procedure:

 

  • Landtech GEM-500 Gas Analyzer or equivalent
  • Dwyer Magnehelic pressure gauge set (Ranges: 0-2 inches of water and 0-100 inches of water and 0-30 psi)
  • Form SOP 008-1 (Probe Pressures)

 

4.0 TASK PERFORMANCE

 

Before conducting monitoring, inspect each probe for the following conditions:

 

  • Confirm identity of probe.
  • Laboratory stopcock or other flow restriction device is fitted and is effective.

 

 

  • The laboratory stopcock appears to be leak-tight.
  • Inventory of manufacturer quick connect fittings for ¼” PVC stopcock.
  • Condition of tubing (holes, kinks, water, etc.).
  • Condition of probe casing where present.

 

Adverse conditions are to be repaired if possible and reported to the Operations Manager. Maintenance actions may include the following:

  • Replace or repair stopcocks or tubing that are missing or leaking. Record actions taken.
  • Record probes that are filled with water. Measurements should not be collected from water-filled probes.
  • Repair damaged casing.

 

Select the Dwyer Magnehelic pressure gauge that is appropriate for the probe by selecting the gauge with the lowest applicable pressure range based on recent pressure readings at the probe. The gauge selected should have the smallest scale range possible without exceeding the scale limit. If the observed pressure reading is outside the pressure range of the selected gauge, use the next larger scale range gauge. Connect the Dwyer Magnehelic pressure gauge to the stopcock with the appropriate tubing. Open the stopcock or flow restriction device. Read and record the pressure in the column marked Static Pressure (in. of H2O) on the appropriate monitoring form when the gauge stabilizes. Record the time in the Time (hrs) column. Disconnect the Magnehelic gauge and close the stopcock after the reading is completed.

Calibrate the GEM-500 prior to the beginning of monitoring activities according to the manufacturers manual. Note: The GEM-500 should be recalibrated if the temperature changes 30°F from the initial calibration. Perform the following steps:

  1. Turn the GEM-500 on and select the Monitoring Probe ID
  2. Connect the clear tubing with the external filter/water trap assembly to the sampling port (top left corner) on the GEM-500. The shorter piece of tubing (from the water trap filter hosing) should be connected to the GEM-500. This allows visual of any liquid entering the hose, allowing time to shut the unit down.
  3. Ensure inventory of quick connect fittings in order to take field readings from perimeter probes.
  4. Connect the GEM-500 to the probe stopcock and turn the pump on to start analyzing for gas composition.
  5. Open the probe stopcock and start the reading. The readings will be in percent CH4, CO2, O2, and balance gas. The balance gas is assumed to be N2. Typically the analyzer pump should run until the gas composition readings stabilize.

 

 

  1. When the gas composition readings stabilize, record and store the data. Stabilization times should vary between 30 seconds and 2 minutes. Sampling period should not exceed 5 minutes.
  2. If water is observed in the sample line during the evacuation process, record it in the comment and terminate the measurement
  3. When the reading is completed, disconnect the sample line, allow the probe to purge for 30 seconds and close the stopcock valve.
  4. Purge the sample train and the gas analyzer in between probe readings.

Do not shut down monitoring equipment unless sample interval between probes is more than 30 minutes.

 

 

FORM SOP 008-1 PROBE PRESSURES

 

DATE:                                     TECH:                                      INSTRUMENT:

 

PROBE ID

TIME

PRESSURE (in H2O)

REMARKS

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SOP 009

LANDFILL PERIMETER GAS VENT INSPECTION AND MAINTENANCE

1.0  GENERAL

The inspection and maintenance of the passive gas control system and components, which include monitoring probes, riser vents, collection pipe and barrier trench described in this Standard Operating Procedure (SOP). The system provides for protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone, and that methane levels are in compliance at the landfill perimeter.

 

2.0   TASK DESCRIPTION

Inspection of passive gas control system components will take place during quarterly gas probe monitoring events.

 

3.0  TASK PERFORMANCE

As part of the annual survey, complete Form SOP 009-1. Any breakdown and subsequent repair of the gas control system shall be documented on Form SOP 009-2 and reported to the Operations Manager immediately. Below is a list of procedures associated with maintenance:

 

Gas Monitoring Probe/Vent Riser Inspection and Maintenance

 

Inspect and Maintain

  • Inspect and maintain monitoring probe components to ensure consistent and reliable operation.
    • Ensure the integrity of the PVC riser vent including paint coating and caps.

Document and Repair

  • Document damage and wear and tear. Repair components to function as intended. Document and include in quarterly report.

Inspection Frequency

  • Inspect monitoring probe as part of each quarterly monitoring event.

Sample Ports

  • Inspect sample port(s) and o-rings for cracks and damage. Replace if damaged.
    • Check for tightness and tighten as necessary.

 

 

  • Ensure sample ports are free of debris and clean as necessary.
  • Inspect sample port caps for damage or deterioration. Replace if damaged or deteriorated. It is important that caps are in place on sample ports to prevent deterioration of port and dirt accumulation.

 

Monitoring Probe Well Casing

 

  • Visually inspect above grade well casings and surrounding areas for signs of damage, deterioration, or potential problems.
  • Use below grade inspection techniques when monitoring data warrants (non-routine work).

 

Surface Completion

 

  • Inspect surface completion for above grade completion details (steel probe cover, well id tag, drain holes).

 

  • Verify that seal between well casing and cement-grout seal is intact.

 

Surrounding Area

 

  • Visually inspect the surrounding cover surface integrity.

 

  • Pay special attention to the cover located directly around each well casing or riser vent, noting signs that the soil is desiccated or pulling away from the well casing or riser vent.

 

  • Note surface water erosion, ponding, leachate breakouts or staining.

 

QUARTERLY INSPECTION CHECKLIST


 

Page 1 of 1

 

Inspection Performed by:                                                                           Date:                              

 

Component to Be Checked

Finding

Comment (Additional space end of form)

Gas Monitoring Probe

Surface completion intact?

Yes    No

 

Sample port(s) and o-rings cracked or damaged intact?

Yes    No

 

Cover erosion adjacent to casing?

Yes    No

 

Seal intact between well casing and cement-grout seal?

Yes    No

 

Surface water or erosion surrounding probe completion?

Yes    No

 

Passive Gas Vent Riser

Misalignment, loss of protective coating?

Yes    No

 

Leaks and/or deterioration at piping connections?

Yes    No

 

Seal between riser and cement-grout seal is intact

Yes    No

 

Surface water or erosion surrounding vent completion?

Yes    No

 

Liquid levels taken?

Yes    No

 

 

Comments                                                                                                                                         

 

 
   

 

 
   

 

 
   

 

BREAKDOWN AND REPAIR LOG

 

Date:                                                                           Inspector:                                                       

 

Observations                                                                           Personnel Notified:                            

  1. Missing Equipment
  2. Damaged Materials
  3. Erosion
  4. Settlement

 

 

Type of Breakdown/Failure                                                                                                              

 

 

 

 

 

Location (show on map)                                                                                                                    

 

 

 

 

 

Action Requested                                                                                                                               

 

 

 

 

 

Action Taken                                                                                                                                     

 

 

 

 

 

Comments                                                                                                                                          

 

 

 

 

 

 

 

 

 

 

 

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

 
   

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX C

PLAN ITEMIZED COST ESTIMATE

(on CD only)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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TABLE C.1-1

Detailed Annual Operation and Maintenance Costs

 

 

Item No.

 

Description

Estimated

Quantities

 

Units

 

Unit Price

 

Total Annual Cost

1

Project Management

 

 

 

$0

 

Professional Labor

176

hrs

$96

$16,955

 

ODC

1

ls

$3,033

$3,033

2

Field Work

 

 

 

$0

 

Professional Labor

152

hrs

$119

$18,155

 

Subcontractors

 

 

 

$0

 

- Groundwater Sampling Subcontractor

1

ls

$6,863

$6,863

 

- Surveying

1

ls

$6,863

$6,863

 

- Equipment

1

ls

$1,373

$1,373

 

- Biologist

1

ls

$8,693

$8,693

 

- Analytical

1

ls

$7,032

$7,032

 

- Data validation

1

ls

$2,905

$2,905

 

ODC

1

ls

$7,025

$7,025

3

Annual Report

 

 

 

$0

 

Professional Labor

224

hrs

$87

$19,423

 

Material

 

ls

 

$0

 

ODC

1

ls

$3,396

$3,396

Total

$101,715

Basis of Estimate

Task No.                      Assumption No.                     Description

1                                                                    1                                    One year of PM/adminstrative support.

2                                                                    1                                    Twenty-two groundwater monitoring wells to be sampled annually.

2                                             2                                    The 2 replacement wells will be sampled semiannually for the first year and if the results are consistent with previous results, the well will be sampled annually.

2                                             3                                    Groundwater sampling will be completed for 5 years and a trend analysis conducted during the 5-year review.

2                                             4                                    Site inspections will be conducted quarterly and will include a biologist.

2                                             5                                    Monuments will be surveyed annually and a full survey of the site will be conducted every 5 years.

2                                             6                                    The 2 replacement wells will be surveyed during the final construction.

2                                             7                                    A biologist will conduct quarterly inspections.

2                                                                    8                                    Includes costs for two minor repair events.

3                                                                    1                                    Reports will be three versions: Pre-Draft, Draft, and Final.

3                                             2                                    The LTM contractor will adopt or modify existing basewide documents (SAP/QAPP and HSP) and procedures.

3                                             3                                    Ten copies of each version will be prepared.

 

 

 

 

 

 

 

 

 

 

 

 

Final PCOMMP Final Remedial Action Work Plan, Revision 1 IR Site 2, Alameda Point, Alameda, California DCN: RMAC-0809-0009-0004.R1

CTO No. 0009

TPD1304155

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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APPENDIX D

EMERGENCY RESPONSE PLAN

(on CD only)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

 

CONTRACT No. N62473-10-D-0809 CTONo.0009

APPENDIX D

 

 

FINAL

EMERGENCY RESPONSE PLAN

April 2013

 

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT, ALAMEDA, CALIFORNIA

 

DCN: RMAC-0809-0009-0004

 

 

Prepared by:

 

 

 

 

 

TETRA TECH EC, INC.

1230 Columbia Street, Suite 750 San Diego, California 92101

       e_           

Pete Everds

Project Manager

4; ?;1.,g#

Program Health and Safety Manager

 

TABLE OF CONTENTS

 

PAGE ABBREVIATIONS AND ACRONYMS................................................................................ D.iii

1.0    EMERGENCY RESPONSE PLAN .............................................................................. D.1-1

1.1              PRE-EMERGENCY PLANNING.................................................................... D.1-1

1.2              PERSONNEL ROLES, LINES OF AUTHORITY, TRAINING AND COMMUNICATION......................................................................................... D.1-2

1.3       EMERGENCY RECOGNITION AND PREVENTION................................... D.1-3

1.4       FIRE PREVENTION AND PROTECTION ..................................................... D.1-3

1.5       SPILL CONTROL AND RESPONSE .............................................................. D.1-3

1.6 RELEASE PREVENTION AND MINIMIZATION MEASURES .................. D.1-4 1.7 SIGNIFICANT VAPOR RELEASE ................................................................. D.1-5 1.8 EARTHQUAKE RESPONSE ........................................................................... D.1-5 1.9 SAFE DISTANCES AND PLACES OF REFUGE........................................... D.1-5 1.10 SITE SECURITY AND CONTROL ................................................................. D.1-6 1.11 EVACUATION ROUTES AND PROCEDURES ............................................ D.1-6 1.12    DECONTAMINATION PROCEDURES ......................................................... D.1-6

1.13          EMERGENCY MEDICAL TREATMENT AND FIRST AID......................... D.1-7 1.13.1 First Aid................................................................................................ D.1-7 1.13.2 Minor Injury ......................................................................................... D.1-7 1.13.3 Medical Emergency.............................................................................. D.1-8 1.13.4 Fatal Injury ........................................................................................... D.1-8

1.14          EMERGENCY ALERTING AND RESPONSE PROCEDURES .................... D.1-9 1.15    PPE AND EMERGENCY EQUIPMENT ......................................................... D.1-9

1.16    PROCEDURES FOR HANDLING EMERGENCY INCIDENTS................... D.1-9

 

2.0        REFERENCES.............................................................................................................. D.2-1

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appx D Emergency Response                                                                                                           D.i                                                Emergency Response Plan Final Remedial Action Work Plan, Revision 1 IR Site 2, Alameda Point, Alameda, California DCN: RMAC-0809-0009-0004.R1

CTO No. 0009

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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ABBREVIATIONS AND ACRONYMS

 

Cal-OSHA                        California Occupational Safety and Health Administration CPR                                          cardiopulmonary resuscitation

DON                                 Department of the Navy

IR                                      Installation Restoration (Program)

NAS                                  Naval Air Station

OSHA                               Occupational Safety and Health Administration

PESM                                Project Environmental Safety Manager

PjM                                   Project Manager

ROICC                             Resident Officer in Charge of Construction

RPM                                  Remedial Project Manager

SSHO                                Site Safety and Health Officer

TtEC                                 Tetra Tech EC, Inc.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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1.0         EMERGENCY RESPONSE PLAN

 

 

Tetra Tech EC, Inc. (TtEC) has prepared this Emergency Response Plan to cover the Post- Closure Operations, Maintenance, and Monitoring Plan (Plan) for Installation Restoration (IR) Site 2, former Naval Air Station (NAS) Alameda, Alameda Point, Alameda, California. This Plan was prepared for the United States Department of the Navy (DON), Base Realignment and Closure Program Management Office West, under Contract No. N62473-10-D-0809, Contract Task Order No. 0009.

 

There are numerous emergency services nearby in the civilian community. This plan describes response activities as they apply to NAS Alameda and as required by the HAZWOPER regulations 29 Code of Federal Regulations 19101.120 (l) and 8 California Code of Regulations 5192 (l).

 

1.1         PRE-EMERGENCY PLANNING

Prior to performing any work, the Superintendent or Project Manager (PjM) and the Site Safety and Health Officer (SSHO) will verify emergency action plans by ensuring that planned support facilities are available and that emergency contact numbers are valid. The Alameda Fire Department will be notified of planned activities by the SSHO or the Superintendent. As work proceeds, the SSHO will continue to ensure that plans specified in this section can be implemented at all times. Furthermore, the SSHO will ensure that plans are modified as necessary to accommodate changes. The SSHO will coordinate changes with the Project Environmental Safety Manager (PESM). Upon arrival at the site, the Superintendent will ensure that personnel know the system for communication of emergency situations and how to use a radio or nearby phone to summon emergency assistance. A vehicle must be available  to transport personnel to a safe location or to a hospital. All personnel on this project will know how to use a portable fire extinguisher. All personnel will know the location of emergency equipment and supplies. The SSHO will ensure that emergency equipment is available in the work areas and that the equipment is inspected for compliance with the regulations:

  • Fire extinguishers – monthly, annual refill and servicing, 12-year hydrostatic test.
    • First aid kits – weekly as required by the Occupational Safety and Health Administration (OSHA).
    • Eyewashes, capable of delivering 0.4 gallon per minute for 15 minutes – weekly (If preservative is used, eyewash water may be changed every 4 months; otherwise, water must be changed weekly.) Only potable water may be used for eyewashes.

 

1.2         PERSONNEL ROLES, LINES OF AUTHORITY, TRAINING AND COMMUNICATION

The Superintendent or PjM is the primary emergency coordinator for the project. In the absence of either or both the Superintendent and the PjM, the SSHO is the emergency coordinator. The emergency coordinator will take charge and determine, direct, and delegate personnel and resources to manage the emergency. Key responsibilities of the emergency coordinator are to:

  • Initiate evacuation, if needed.
  • Initiate emergency response agency notification.
    • Evaluate and assess emergency situations to ensure that response activities are commensurate with the level of the emergency and, as discussed in this Plan, are implemented.
    • Interface and coordinate with outside agencies responding to on-site emergencies.

 

Project supervisors and forepersons will account for all their personnel and report their count to the emergency coordinator. They will follow the directions of the emergency coordinator. If directed by the emergency coordinator, the supervisors will direct workers to evacuate the area and report to the assembly area.

 

All workers will follow the instructions of the emergency coordinator.

 

All workers have had training for various emergency situations. For this project, workers will have had training in spill containment and control, fighting incipient stage fires, use of eyewashes, and basic rescue techniques for moving and carrying personnel in danger situations. There will always be personnel at the work site who can provide cardiopulmonary resuscitation (CPR) and first aid.

 

Personnel will maintain verbal communication. The following communication systems will be available during site activities:

  • Cellular telephone or access to a land phone for emergency purposes
  • Handheld radios, as needed
  • Compressed air horn (signals emergency evacuation only)
  • Hand signals (if used, will be diagrammed and posted)
  • Posted location of evacuation assembly area(s)
  • Posted route to the hospital located nearest the project site
  • Posted emergency phone numbers

 

1.3         EMERGENCY RECOGNITION AND PREVENTION

All personnel have received training on the potential hazards on this project. There are hazards that are commonly expected on any project site such as adverse weather, electrical hazards, traffic, and equipment hazards, chemical exposures, physical hazards, etc. These have been addressed in theSite Safety and Health Plan. If someone has been affected by a hazard, all personnel are trained on how to respond to an emergency. The first thing anyone is told to do is notify by radio or phone as noted above. There are other procedures to prevent emergencies by following the directions below.

 

1.4         FIRE PREVENTION AND PROTECTION

Fire prevention and protection measures require preplanning. At least one 20-pound dry  chemical ABC fire extinguisher will be located at each work area. A mounted fire extinguisher  is required in every vehicle including heavy equipment. Extinguishers mounted on heavy equipment will be a minimum 5-pound ABC dry chemical type. Fire extinguishers inside the  cab of pickup trucks will be 2 ½-pound dry chemical ABC. Fire extinguishers in the cabs of all vehicles must be mounted or secured. Fire extinguishers in the beds of all pickup trucks must be mounted or secured. Employees will follow safe work practices to include proper storage of flammable and combustible liquids. Smoking is permitted only in those areas designated specifically by the PjM, Superintendent, or SSHO and posted as smoking areas.

 

Personnel will follow hot work procedures to ensure that work is performed in a safe environment. In the event of a fire or explosion, the Fire Department will be summoned immediately, a head count will be taken, and evacuation procedures will be implemented. Smoking is not permitted inside buildings.

 

1.5         SPILL CONTROL AND RESPONSE

All spills, leaks, and fires involving oil or hazardous substances at former NAS Alameda must be reported to the DON Remedial Project Manager (RPM) and the PESM. The person reporting the leak or spill is required to provide the following information:

  • His/her name
  • Location of spill and facility number, if known
  • Number of injured personnel and nature of injuries, if known
  • Substance spilled
  • Estimated amount spilled
  • Extent of spill
  • Estimated rate at which the substance is currently being released
  • Estimated time the spill occurred
  • Any other pertinent information

 

 

The RPM, in coordination with  the  PjM,  will  manage  notifications  to  regulatory  agencies. In addition, all spills will be reported to the Environmental Compliance Manager or the PESM. Project personnel will not report spills directly to any agency unless specifically requested by the RPM or the Contracting Officer.

 

A minor spill would involve no immediate threat to human health or the environment. It would cause only minimal property damage and not exceed the reportable quantity for that material. In the event of a minor spill, the appropriate response action is for the responsible person to notify the RPM and the PjM and supply the responders with as much information as possible. In the case of a spill of contaminated or hazardous materials, the following procedures will be followed:

  • Notify the Superintendent, the PjM, and the PESM.
  • Identify protective clothing or equipment required to respond.
  • Contain the spill.
  • Neutralize and/or solidify any product.
  • Transfer material into 55-gallon drums.
  • Document the incident.

 

1.6         RELEASE PREVENTION AND MINIMIZATION MEASURES

In addition to training, the following procedures will be implemented to prevent and minimize releases of hazardous materials:

  • Do not conduct hazardous materials operations when the weather could cause significant risk to the surrounding area if a spill should occur.
  • Transfer all materials in or over a bermed or “protected” area. A protected area is one that is covered with an impermeable material, such as polyethylene.
  • Dike temporary storage tanks containing hazardous wastes or potentially hazardous wastes to contain potential releases.
  • Maintain a supply of basic spill response materials and protective equipment on-site to include:

-        Absorbent sheets, pillows, booms, or other absorbent material

-        Open top 55-gallon drums or other containers with lids

-        Brooms, shovels, and other tools, such as squeegees

 

1.7         SIGNIFICANT VAPOR RELEASE

Any project activity that releases significant amounts of vapor must be reported immediately, as described in the spill release procedure. Every attempt to mitigate the release must be taken if it can be safely performed. For example, during excavations, vapor releases may be controlled by simply replacing the cover on the excavation. Downwind evacuation procedures may be required. These will be initiated through coordination with former NAS Alameda emergency coordinators.

 

1.8         EARTHQUAKE RESPONSE

If an earthquake should occur during the course of site activities, take the following action:

 

  • Stop working. Remain calm and do not panic.
    • Do not use or do anything that might be a source of ignition (smoking, cutting, or welding).
    • Avoid power lines, power poles, and windows.
    • If in a vehicle, stay in the vehicle until the earthquake is over.
      • If in a building, take cover under a heavy piece of furniture or leave the building if possible.

 

After the earthquake is over:

 

  • Prepare for aftershocks. Stay out of severely damaged buildings.
  • Meet for a head count at a location designated by the Superintendent.
    • Check for injuries. Do not move seriously injured personnel, unless remaining where they are would create danger of further injury.
    • Check  vehicles,  equipment,  and  buildings  for any obvious damage.    Do not enter buildings until their structural integrity has been evaluated.
    • Check  utility  lines for damage.    Switch off power, water, and gas until a utility official has inspected the buildings and operational area and determined it is safe.
    • If driving, watch carefully for hazards created by the earthquake (undermined roads, weak bridges or overpasses, fallen power lines or poles, and so forth).

 

1.9         SAFE DISTANCES AND PLACES OF REFUGE

On this project, after an emergency inside the building is identified, the building will be evacuated. Only personnel authorized by the emergency coordinator will be allowed to return into the building depending on the nature of the emergency and whether the personnel have the training, the ability, and the need to return to the building. As noted below, personnel will assemble in the project trailer/offices. This area is several hundred feet from the buildings.

 

Immediately evacuate to an area located at least 50 feet from the building as an alternate area identified by the SSHO.

 

1.10     SITE SECURITY AND CONTROL

There are no buildings on-site. The site is secured by fencing on the north and east sides.

 

1.11     EVACUATION ROUTES AND PROCEDURES

In the event of an emergency situation such as fire or explosion, the SSHO or a supervisor will activate an air horn for approximately 15 seconds indicating the initiation of evacuation procedures. All personnel in both the restricted and non-restricted areas will evacuate and assemble near the support zone or other safe area identified by the SSHO. Prior to starting work, the SSHO will identify and mark the location of an evacuation assembly area. The location should be upwind of the site.

 

For efficient and safe site evacuation and assessment of the emergency situation, the Superintendent or SSHO will have authority to initiate proper action if outside services are required. Under no circumstances will incoming personnel or visitors be allowed to proceed into the area once the emergency signal has been given. The SSHO must ensure that access is provided for emergency equipment and that equipment that may cause combustion has been shut down once the alarm has been sounded. As soon as possible, and while the safety of all personnel is confirmed, emergency agency notification will commence. The SSHO will brief  site personnel each day as to the location of the evacuation assembly area. After gathering at the local site assembly point, and depending on the nature of the emergency, workers will be given further instructions.

 

Before starting work, the SSHO will establish safe egress routes from the site to the evacuation assembly area. The SSHO will prepare a drawing or map that diagrams these safe egress routes. The SSHO will use this same map to diagram egress from the evacuation assembly area to the facility gate to be used as an exit.

 

An evacuation exercise will be practiced within 1 week of the start of the project and randomly during the course of the project. After the practice drill or after any actual evacuation, all involved site personnel will attend a briefing to evaluate the evacuation. The employees will discuss the evacuation and anything that could be done to improve or change future evacuations. The results of this briefing will be documented on a safety meeting attendance form. A copy of the evaluation report will be sent to the PESM.

 

1.12     DECONTAMINATION PROCEDURES

Any personnel requiring emergency medical attention will be evacuated immediately from exclusion zones and contamination reduction zones. Personnel will not enter the area to attempt

 

a rescue if their own lives would be threatened. The decision whether or not to decontaminate a victim prior to evacuation is based on the type and severity of the illness or injury and the nature of the contaminant.

 

For some emergency victims, immediate decontamination may be an essential part of life-saving first aid.  For others,  decontamination  may aggravate the injury or delay life-saving treatment.  If decontamination does not interfere with essential treatment, it should be performed.

 

If decontamination can be performed:

 

  • Wash external clothing and cut it away.
  • Wrap the victim in a clean blanket or towel if necessary.

 

If decontamination cannot be performed:

 

  • Wrap the victim in blankets or plastic to reduce contamination of other personnel.
    • Alert emergency and off-site medical personnel to potential contamination; instruct them regarding specific decontamination procedures.

 

Send along site personnel familiar with the incident.

 

1.13     EMERGENCY MEDICAL TREATMENT AND FIRST AID

The following procedures should be observed if an accident with injury occurs.

 

1.13.1    First Aid

Only qualified personnel will provide first aid and stabilize an individual needing assistance.  Life support techniques such as CPR and treatment of life-threatening problems such as airway obstruction and shock will be given top priority. At least two persons certified in first aid techniques and CPR will be on each work site at all times; EHS 4-1, Bloodborne Pathogens, will be followed when first aid/CPR are administered. The SSHO will be current in first aid and CPR and bloodborne pathogen training. Professional medical assistance will be obtained at  the earliest possible opportunity. Ensure that WorkCare® has been contacted  at  (800) 455-6155. The hospital and clinic located nearest to former NAS Alameda are shown on a map that is part of every Site Safety and Health Plan. A general map to the nearest clinic and hospitals is  attached to this plan. Notify the PjM and the PESM.

1.13.2    Minor Injury

  • Contact a supervisor or “buddy.”
  • Have qualified first aid personnel treat the injury.
    • Record the injury and include the name of the injured person, nature of injury, and treatment given.
    • Notify the PjM and the PESM.

 

1.13.3    Medical Emergency

In the event of a medical emergency when actual or suspected serious injury occurs, the following procedures will be implemented:

  • Survey the scene and evaluate whether the area is safe for entry.
  • Remove the exposed or injured person(s) from immediate danger.
    • Render first aid if necessary. Decontaminate affected personnel after critical first aid is provided.
    • Obtain paramedic services or ambulance transport to local hospital. This procedure will be followed even if there is no visible injury.
    • Call 911 from phones at former NAS Alameda. Calling 911 from cell phones will notify California Highway Patrol who will notify county Emergency Medical Service. If using a cell phone, call Alameda (510) 337-2100. Preprogram cell phones with this emergency number.
    • Identify the location by the number of the nearest building, request medical assistance, and provide a name and telephone number.
    • Request assistance from emergency medical service and/or additional assistance.
      • Other personnel in the work area will be evacuated to a safe distance until the Superintendent determines that it is safe for work to resume. If there is any doubt about the condition of the area, work will not commence until all hazard control issues are resolved.
      • Notify the PjM and the PESM.
        • Notify the Resident Officer in Charge of Construction (ROICC) of the incident and fill out accident reporting forms and associated documents.

 

1.13.4    Fatal Injury

If a fatal injury occurs, the following additional steps will be followed:

 

  • Notify the Superintendent and PjM immediately.
    • Notify the PESM, who will initiate contact with the California Occupational Safety and Health Administration (Cal-OSHA).
    • Notify the ROICC.
    • Stop all work activities on the project for 24 hours.
    • Assist Cal-OSHA as directed.

 

1.14     EMERGENCY ALERTING AND RESPONSE PROCEDURES

This plan has identified the emergency alerting devices available to the project. While inside the buildings, the use of the air horn is most effective in alerting personnel. However, if personnel are located a distance from where the emergency occurred, the horn should be tested to ensure that personnel in all areas can hear the horn. When necessary, the on-site supervisor will give each work team an air horn. The supervisor will know the assigned area of each work team. The use of radios with each team can also provide information regarding the precise location of the emergency. Upon alarm, the first response is made by the emergency coordinators who will direct the activities required to respond to the emergency. This plan has described  many potential response procedures.

 

1.15     PPE AND EMERGENCY EQUIPMENT

The following emergency equipment will be stationed near each work area:

 

  • Fire extinguisher (minimum one 20-pound dry chemical ABC type in the contamination reduction corridor at the edge of the exclusion zone).
    • Industrial first aid kit (outside the building entrance). The kit must be filled as required by EM 385-1-1, Table 3-1 (USACE 2008) and 8 CCR 5812.
    • Portable eye wash (capable of supplying 15 minutes of water at 0.4 gallon per minute and protected from direct sunlight in the support area, at the edge of the support zone).
    • Air horn (at the support area, at the edge of the support zone).
      • Spill control material (absorbent pillows or absorbent material and shovels, plastic sheeting, and 55-gallon drum[s] in the support zone by the contamination reduction corridor entrance).

 

The following equipment will be available at the support trailer/offices for use in an emergency situation:

  • Industrial first aid kit
  • Blanket

 

The need for specialized personal protective equipment is not anticipated for this project.

 

1.16          PROCEDURES FOR HANDLING EMERGENCY INCIDENTS

This Plan has incorporated prevention procedures with procedures on how to handle the emergency event. After the emergency event is over, or during the course of the emergency  when possible, the SSHO will notify the PESM by telephone. Should an accident or incident occur, the Superintendent or PjM and the SSHO will immediately investigate the cause, notify the PESM, and promptly complete the following:

 

  • Incident Report Form – Details of the incident will be documented within 24 hours and copies of the report will be forwarded to the RPM and the PESM. Reports of serious incidents will also be faxed to the Program Manager by the Superintendent or PjM.
  • Incident Investigation Report – The Incident Investigation Report will have the same distribution as the Incident Report Form and must be completed within 3 days of the incident.
  • Contractor’s Significant Incident Report – If the accident/incident involves injuries requiring more than first aid or property damage greater than $2,000, a Contractor Significant Incident Report will be prepared and submitted to the ROICC as soon as possible after the incident but no later than 5 days after. The originals will be sent to the TtEC records coordinator for maintenance and distribution. Copies will be distributed to the PESM, Superintendent, subcontractor employees, if appropriate,  and the Contracting Officer. A copy of the completed forms will be kept in the  project file.

 

Any recommended additional hazard control measures must be discussed with the Superintendent, SSHO, and PESM and meet their approval prior to implementation. Corrective actions will be implemented as soon as reasonably practical. Any occupational injuries and illnesses will be recorded, if applicable, on an OSHA Form No. 300. The SSHO will report immediately to the PESM any serious injury or illness requiring hospitalization, or death of an employee occurring in a place of employment or in connection with any employment. The  PESM will immediately notify the closest CalOSHA office in Oakland at:

1515 Clay Street, Ste. 1301

Oakland, California 94612

Phone (510) 622-2916

Fax (510) 622-2908

 

Immediately means as soon as practically possible, but not longer than 8 hours after the incident. Records of all site accidents and first aid treatments will be maintained by the SSHO.

 

Emergency contact names and phone numbers will be posted. Maps showing egress routes, evacuation assembly areas, and the route to the clinic and hospitals will also be posted. The contact names, phone numbers, and maps will be placed on the dashboard of every project vehicle.

 

This plan also describes practice drills for emergencies. When there is an actual emergency event, similar to the practice drill, a project team debriefing will be held to review the event and discuss measures for improving or changing the response plan to correct deficiencies that may have been noted.

 

2.0   REFERENCES

 

USACE   (U.S.   Army    Corps    of   Engineers).     2008.     Safety   and   Health   Requirements Manual. Engineering Manual (EM) 385-1-1. September 15.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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ATTACHMENT 12

LAND-USE CONTROL REMEDIAL DESIGN

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

 

CONTRACT No. N62473-10-D-0809 CTONo.0009

 

ATTACHMENT 12

 

FINAL

LAND-USE CONTROL REMEDIAL DESIGN

April 2013

 

 

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA DCN: RMAC-0809-0009-0004

 

Prepared by:

 

 

 

 

 

TETRA TECH EC, INC.

 tW

 

1230 Columbia Street, Suite 750 San Diego, California 92101-8530

 

 

 

 

:rJ-el

Hedy Abed i, PhD, PE

Project Manager


 

 

Pete Everds Senior Project Manager

 

 

 

PAGE ABBREVIATIONS AND ACRONYMS.................................................................................... iii

1.0       PURPOSE...................................................................................................................... 1-1

2.0              SITE DESCRIPTION.................................................................................................... 2-1

2.1              SITE BACKGROUND...................................................................................... 2-1

2.2              CURRENT AND POTENTIAL FUTURE SITE USES.................................... 2-2

2.3              BASIS FOR REMEDIAL ACTION.................................................................. 2-2

2.4              DESCRIPTION OF SELECTED REMEDY..................................................... 2-3

3.0              INSTITUTIONAL CONTROLS................................................................................... 3-1

3.1              FEDERAL-TO-FEDERAL PROPERTY TRANSFER..................................... 3-1

3.2              PROPERTY TRANSFER TO A NONFEDERAL ENTITY............................. 3-1

4.0...... AREA REQUIRING INSTITUTIONAL CONTROLS................................................ 4-1

5.0              INSTITUTIONAL CONTROL PERFORMANCE OBJECTIVES, LAND USE RESTRICTIONS, AND ACTIVITY RESTRICTIONS.............................................................................. 5-1

5.1              LAND USE RESTRICTIONS........................................................................... 5-1

5.2              GENERAL ACTIVITY RESTRICTIONS........................................................ 5-1

5.3              ADDITIONAL ACTIVITY RESTRICTIONS RELATED TO RADIONUCLIDES        5-2

5.4              ACCESS............................................................................................................. 5-2

6.0              REMEDY IMPLEMENTATION ACTIONS................................................................ 6-1

6.1              RESPONSIBILITIES OF THE DON WITH RESPECT TO IC

INSPECTIONS, REPORTING, AND ENFORCEMENT................................. 6-1

6.2              DON RESPONSIBILITIES............................................................................... 6-1

6.3              RESPONSIBILITIES OF THE PROPERTY OWNER(S) AND SUCCESSORS WITH RESPECT TO IC INSPECTIONS AND

REPORTING..................................................................................................... 6-5

7.0       DOCUMENT REVIEWS.............................................................................................. 7-1

8.0              REFERENCES............................................................................................................... 8-1

FIGURES

Figure 2-1             Site Location Map

 

 

 

 

 

 

 

 

 

 

Attachment 12 Land Use Controls RD.doc                                                                                      i                                       Final Land-Use Control Remedial Design IR Site 2, Alameda Point Alameda, California

DCN: RMAC-0809-0009-0004

CTO No. 0009

 

(Continued)

 

 

APPENDICES

 

Appendix A    Land-Use Control Remedial Design Distribution List

 

Appendix B     Institutional Controls Compliance Monitoring Report and Compliance Certificate

 

ABBREVIATIONS AND ACRONYMS

 

ARIC                          area requiring institutional controls Cal. Code Regs.                  California Code of Regulations

CDPH                         California Department of Public Health

CERCLA                    Comprehensive Environmental Response, Compensation, and Liability Act

COC                            contaminant of concern

CRUP                         Covenant to Restrict Use of Property

DoD                            Department of Defense

DDD                           dichlorodiphenyldichloroethane

DDE                            dichlorodiphenyldichloroethene

DDT                            dichlorodiphenyltrichloroethane

DDx (total)                  sum of total dichlorodiphenyldichloroethane DON                                    Department of the Navy

DTSC                          California Department of Toxic Substances Control

EPA                            U.S. Environmental Protection Agency

FFA                             Federal Facility Agreement

GIS                             geographic information system

IC                                institutional control

IR                                Installation Restoration (Program)

LUC                            land-use control

MOA                           memorandum of agreement

MOU                           memorandum of understanding

NAS                            Naval Air Station

NCP                            National Contingency Plan

OEW                           ordnance and explosives waste

PCB                            polychlorinated biphenyl

RD                              remedial design

ROD                           Record of Decision

Water Board               San Francisco Bay Regional Water Quality Control Board yd3                                    cubic yard

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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1.0   PURPOSE

 

 

The Land-Use Control (LUC) Remedial Design (RD) for Installation Restoration (IR) Site 2, Alameda Point, Alameda, California, addresses the institutional controls (ICs) (including land use and activity restrictions) required by Section 2.9.2 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Record of Decision (ROD) for IR Site 2 issued in August 2010. The ROD requires the implementation of land use and activity restrictions to limit exposure of future landowner(s) and/or user(s) of the property to hazardous substances, and to maintain the integrity of the remedial action until remediation is complete and remedial goals have been met.

 

This LUC RD is a component of the RD for IR Site 2, a primary document under the Alameda Point Federal Facility Agreement (FFA). This LUC RD was prepared in accordance with the Navy Principles and Procedures for Specifying Monitoring and Enforcement of Land Use Controls and Other Post-ROD Actions attached to the January 16, 2004, Department of Defense (DoD) Memorandum titled CERCLA ROD and Post-ROD Policy.

 

The Alameda Point “FFA Signatories” consist of the Department of the Navy (DON), the U.S. Environmental Protection Agency (EPA), the State of California through the Department of Toxic Substances Control (DTSC), and the San Francisco Bay Regional Water Quality Control Board (Water Board). If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedy for IR Site 2 property from DON to another federal agency, the DON’s responsibilities under this LUC RD shall be assumed by the federal transferee, and DON will no longer be responsible for them. In the event of such an amendment the term “FFA Signatories” as used in this LUC RD report shall be construed to include EPA, DTSC, Water Board, and the federal transferee.

 

The California Department of Public Health (CDPH) regulates activities related to remediation of radionuclides on non-federally owned property. CDPH is involved in the IR Site 2 remediation as described in the ROD.

 

The inspections and reporting requirements described herein will be effective immediately upon approval of this LUC RD by EPA, DTSC, and the Water Board. The IR Site 2 property (“the property”) is currently owned by the DON and is not subject to a lease. The IC objectives will be met by access controls until the time of transfer of the property from DON ownership. The IC land use and activity restrictions described in this LUC RD report will be incorporated into a Memorandum of Understanding (MOU) or other agreement between the DON and the federal transferee if the property is transferred to another federal agency, or Quitclaim Deeds (deed[s]) and Covenant to Restrict Use of Property (CRUP) if the property is transferred to a nonfederal entity, and will take effect upon transfer of the property and issuance of those documents.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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2.0        SITE DESCRIPTION

 

 

IR Site 2 is located on the southwest corner of Alameda Point in Alameda, California (Figures 1 and 2). Alameda Point is approximately 2 miles long east-west and 1 mile wide, north-south, and occupies 1,734 acres of onshore land. IR Site 2 is approximately 110 acres in size (Figure 2-1).

 

The site consists of the former landfill, which occupies approximately 60 acres, and wetlands, which covers approximately 33 acres immediately south and west of the landfill. The remaining 17 acres within the IR Site 2 boundary is represented by areas known as the interior and coastal margins. The site is bounded to the south and west by the San Francisco Bay and to the east and north by runways and tarmacs. The former landfill was reportedly used for disposal of wastes generated by former Naval Air Station (NAS) Alameda activities from 1956 through early 1978. After landfill operations ceased in 1978, an earthen berm was constructed around the perimeter of the landfill site.

 

Previous site use has contaminated the soil with cadmium, chromium, lead, molybdenum, zinc, total DDx (sum of total dichlorodiphenyldichloroethane [DDD], dichlorodiphenyldichloroethene [DDE], and dichlorodiphenyltrichloroethane [DDT]), polychlorinated biphenyls (PCBs), benzo(a)pyrene, and radium-226 at concentrations that may pose a risk to human health and ecological receptors under a recreational use scenario, a proposed future reuse of IR Site 2. The selected remedy, a multilayer soil cover (cover) over the former landfill to isolate buried waste and soil contaminants, has been selected to protect human health and to address concentrations in soil and soil gas above the established remedial goals. The remediation strategy is described in the Proposed Plan (DON 2009) and in the Final ROD (DON 2010).

 

2.1         SITE BACKGROUND

Former NAS Alameda was an active military installation from the 1930s to the 1990s, which primarily provided facilities and support for fleet aviation activities. The area of present day IR Site 2 was originally open water until 1956 when a sea wall was constructed along the southern and western shorelines to confine and protect the area. Dredged fill was hydraulically placed within the seawall creating the area encompassed by IR Site 2.

 

The IR Site 2 landfill, also called the West Beach Landfill, was used as the main disposal area for the Alameda Point from approximately 1952 through 1978. An estimated 1.6 million tons of waste was deposited (E&E 1983). Historical waste disposal methods at the site generally consisted of trench-and-fill operations. Wastes included municipal solid waste, waste chemical drums (contents unknown), solvents, oily waste and sludge, paint waste, plating wastes, industrial strippers and cleaners, acids, mercury, polychlorinated biphenyl (PCB)-containing liquids, batteries, low-level radioactive waste (LLRW) including but not limited to radioluminescent dials and dial painting, scrap metal, inert ordnance, asbestos, several pesticides

 

(solid and liquid), tear gas agent, biological waste from the Oak Knoll Naval Hospital, creosote, dredge spoils, and waste medicines and reagents (E&E 1983). Ordnance and explosives waste (OEW) may have also been deposited in the 2.5-acre (approximate) Possible OEW Burial Site located in the southern part of the landfill. Previously identified areas of buried waste are shown on Figure 2-1.

 

In 1978, the DON developed plans to close the landfill in accordance with the requirements of the Water Board’s Minimum Criteria for Proper Closure of Class II Solid Waste Disposal Sites (Resolution No. 77-7). In 1983, the Water Board issued Order No. 83-35 to implement a final cover, leachate cutoff barrier, methane gas control, earthquake damage control, drainage control, and erosion control, and to generate compliance reports for the former landfill. Between 1983 and 1995, the DON responded by placing a partial clay-soil cover, installing an 820-foot-long, 2-foot-wide and 20- to 30-foot-deep slurry wall to restrict potential contaminant migration to San Francisco Bay. A gas venting system was installed for methane gas control, and repairs were made to the seawall also during this time period. In 1986, 20,000 cubic yards of imported fill soil was spread on the former landfill, which was insufficient in achieving a uniform cover layer of appropriate thickness over the landfill area. Also in 1986, the landfill was graded to prevent ponding, and an earthen perimeter berm was constructed around the landfill.

 

In August 1999, IR Site 2 was officially added to the EPA’s National Priority List of Superfund sites and assigned Comprehensive Environmental Response, Compensation, and Liability Information System identification number CA2170023236.

 

2.2         CURRENT AND POTENTIAL FUTURE SITE USES

IR Site 2 was used as a landfill between the mid-1950s and the latter part of the 1970s. No land use occurred at the site prior to 1956 when the perimeter sea wall was constructed and the site was first formed using dredged fill. Due to its sole historical use as a landfill, no persons have resided or currently reside at the site. Because it has never been used for full-time residence or occupancy, no above- or belowground utilities (e.g., potable water, electric, or telephone) exist at the site.

 

As stated in the ROD, the future use of the Site is to be restricted to open space and recreational uses. Please refer to the ROD, Table 2-13, Land Use Restrictions, for specific land use prohibitions.

 

2.3         BASIS FOR REMEDIAL ACTION

Potentially significant risk to human and ecological receptors due to exposure to contaminants of concern (COCs) (cadmium, chromium, lead, molybdenum, total DDx, total PCBs, benzo[a]pyrene, and radium-226) for the landfill area and lead, zinc, and radium-226 in the wetland area in soil, a recreational use scenario is the basis for the CERCLA remedial action

 

being undertaken by the DON. The FFA signatories considered the factors in accordance with the remedy selection criteria and concluded that a remedial action is necessary to minimize exposure of human receptors, sensitive habitats, and species to impacted soil at IR Site 2. The FFA signatories developed the following remedial action objectives to address the human health and ecological risk:

  • Protect sensitive human receptors, avian species, and mammal species from exposure to COCs in surface soil in the landfill and wetland portions of the site
  • Protect viable wetland area in the southwest portion of the site from impacts associated with the landfill
  • Protect sensitive human receptors from exposure through external radiation from surface soil in the landfill and wetland portions of the site
  • Protect beneficial uses of the surface water in the San Francisco Bay from the potential for discharge of site groundwater containing COCs

 

2.4         DESCRIPTION OF SELECTED REMEDY

The selected remedy identified in the ROD (DON 2010) consists of the placement of a cover to isolate buried waste and soil contaminants and to prevent animal burrowing. Prior to placing the cover, the surface will undergo scanning and removal of radiological hotspot material to prevent the spread of potential contamination during site grading. Engineering controls and ICs will be implemented to protect human health and the integrity of the cover; provide for any necessary wetlands mitigation, and monitor soil cleanup and wetlands mitigation; and conduct methane gas monitoring (as necessary).

 

The selected remedy for groundwater is monitored natural attenuation. Site groundwater will be monitored regularly using shoreline groundwater monitoring wells. Engineering controls will be in place to protect the monitoring wells from damage and/or to protect site users from harm. ICs will be implemented across the entire site, including the wetlands, to limit human exposure to contaminants in soil and to protect the integrity of the cover.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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3.0        INSTITUTIONAL CONTROLS

 

 

ICs are legal and administrative mechanisms used to implement land use and activity restrictions to limit the exposure to hazardous substances by current and future landowner(s) and user(s) of the property and to maintain the integrity of the remedial action. ICs are required on a property where the selected remedial cleanup levels result in contamination remaining at the property above levels that allow for unlimited use and unrestricted exposure. ICs will be maintained until the concentrations of hazardous substances in soil and groundwater are at such levels to allow for unrestricted use and exposure. Implementation of ICs includes requirements for monitoring, inspections, and reporting to ensure compliance with land use or activity restrictions.

 

3.1         FEDERAL-TO-FEDERAL PROPERTY TRANSFER

If the IR Site 2 property is transferred to another federal agency or department, the land use restrictions and activity restrictions set forth in Section 5.0 and the Remedy Implementation Actions set forth in Section 6.0 will be incorporated into an MOU or other agreement between the DON and the federal transferee. The MOU or other agreement will also require that 1) the transferee comply with all applicable federal and state environmental, public health, and cultural and natural resource protection laws following transfer; 2) any subsequent future transfer by the federal transferee to a federal agency shall incorporate the land use and activity restrictions set forth below into a subsequent MOU or other agreement and require the same for any further conveyances between federal agencies; and 3) if the federal transferee in turn transfers the property to a nonfederal entity, it shall comply with the requirements set forth in Sections 3.2, 5.0, and 6.0. If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedial action selected for IR Site 2 from DON to another federal agency, the DON’s responsibilities under this LUC RD shall be assumed by the federal transferee and DON shall no longer be responsible for them as provided in Section 1.0.

 

3.2         PROPERTY TRANSFER TO A NONFEDERAL ENTITY

If the IR Site 2 property is transferred from the DON or another federal transferee to a nonfederal entity, DON will rely upon proprietary controls in the form of environmental restrictive covenants as provided in the Memorandum of Agreement (MOA) Between the United States Department of the Navy and the California Department of Toxic Substances Control and attached covenant models (DON and DTSC 2000) (hereinafter referred to as the DON/DTSC MOA). More specifically, land use and activity restrictions will be incorporated into two separate legal instruments at the time of transfer as provided in the DON/DTSC MOA:

  1. Restrictive covenants included in one or more Quitclaim Deeds from the DON to the property recipient
  2. Restrictive covenants included in one or more “Covenant to Restrict Use of Property” entered into by the DON and DTSC as provided in the DON/DTSC MOA and consistent with the substantive provisions of California Code of Regulations Title 22, Section 67391.1.

 

 

The “Covenant to Restrict Use of Property” will incorporate the land use and activity restrictions into environmental restrictive covenants that run with the land and are enforceable by DTSC, EPA, and any other signatory state entity (such as CDPH) against future transferees. The Quitclaim Deed(s) will include the identical land use and activity restrictions in environmental restrictive covenants that run with the land and will be enforceable by the DON against future transferees.

 

ICs include land use and activity restrictions and will be applied to the property in the area requiring institutional controls (ARIC) (the entire area of IR Site 2 as described in Section 4.0). These IC’s will be included in the Environmental Summary Document (for transfer to a federal agency), or a Finding of Suitability to Transfer/Finding of Suitability for Early Transfer, Covenant to Restrict Use of Property, and Quitclaim Deed(s) (for transfer to a non-federal entity).

 

4.0   AREA REQUIRING INSTITUTIONAL CONTROLS

 

 

The ICs, including all land use and activity restrictions selected in the ROD and described in Section 5.0, will be applied to the IR Site 2 area requiring institutional controls (ARIC). The ARIC is shown on Figure 2-1.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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5.0       INSTITUTIONAL CONTROL PERFORMANCE OBJECTIVES, LAND USE RESTRICTIONS, AND ACTIVITY RESTRICTIONS

 

 

The following sections describe the objectives to be achieved through land use and activity restrictions within the ARIC at IR Site 2. If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedy for IR Site 2 from DON to another federal agency as provided in Section 1.0, the federal transferee shall also be responsible for compliance with the land use and activity restrictions set forth below after the IR Site 2 property is transferred to it.

 

5.1         LAND USE RESTRICTIONS

The IR Site 2 property shall be restricted to open space and recreational uses. In addition, the following land uses are specifically prohibited within the boundaries of the IR Site 2 ARIC:

  • A residence, including any mobile home or factory-built housing, constructed or installed for use as human habitation
  • A hospital for humans
  • A school for persons under 21 years of age
  • A daycare facility for children
    • Any permanently occupied human habitation including those used for commercial or industrial purposes

 

5.2         GENERAL ACTIVITY RESTRICTIONS

The following activities are restricted within the boundaries of the IR Site 2 ARIC unless prior written approval for these activities is granted by the FFA signatories, prior to conducting them:

  • Land disturbing activity is prohibited unless conducted pursuant to an approved soil management plan (SMP) (Note: Additional SMP requirements for addressing radiological activity restrictions are set forth below in Section 5.3). Land disturbing activity includes, but is not limited to, 1) excavation of soil and disturbance of the multilayer soil cover; 2) construction of roads, utilities, permanently occupied buildings, facilities, structures, and appurtenances of any kind; 3) demolition or removal of paved areas; 4) actions that may impair the multilayer soil cover or other exposure prevention barriers; 5) excavation and/or disturbance of soil or riprap areas; and 6) any other activity that involves movement of soil to the surface from below the surface of the IR Site 2 property.
  • Alteration, disturbance, or removal of any component of a response or cleanup action (including, but not limited to, soil cover/containment systems); groundwater extraction, injection, and monitoring wells and associated piping and equipment; or associated utilities.
  • Extraction of groundwater and installation of new groundwater wells.
    • Removal of or damage to security features (e.g., locks on monitoring wells, survey monuments, signs, or monitoring equipment and associated pipelines and appurtenances).

 

ICs will be maintained until the concentrations of hazardous substances in the soil and groundwater are at such levels to allow for unrestricted use and exposure.

 

5.3         ADDITIONAL ACTIVITY RESTRICTIONS RELATED TO RADIONUCLIDES

Excavation within the IR Site 2 ARIC below a depth 1.9 feet is strictly prohibited unless approved in writing by the FFA signatories and CDPH. Any proposed excavation below this depth shall be described in a Soil Management Plan that will include but not be limited to a radiological work plan, the identification of a radiological safety specialist, soil sampling and analysis requirements, and a plan for off-site disposal of any excavated radionuclides by the transferee in accordance with federal and state law. This work plan must be submitted to and approved in writing by the FFA signatories and CDPH in accordance with procedures set forth in Section 7.0 of this LUC RD report.

 

The integrity of the cover must be restored upon completion of any excavation as provided in the IR Site 2 Operation and Maintenance Plan, this report, or similar document. A completion report describing the details of the implementation of the Soil Management Plan, the sampling and analysis, the off-site disposal, and the restoration of the integrity of the cover must be submitted to and approved in writing by the FFA signatories and CDPH in accordance with procedures and time frames detailed in Section 6.0 of this document.

 

5.4         ACCESS

The MOU or other agreement, if the property is transferred to another federal agency, or the deed(s) and CRUP(s) if the property is transferred to a nonfederal entity, shall provide that the FFA signatories and CDPH, and authorized agents, employees, contractors, and subcontractors shall have the right to enter IR Site 2 at Alameda Point to conduct investigations, tests, or surveys; inspect field activities; or construct, operate, and maintain any response or remedial action as required or necessary under the cleanup program, including monitoring wells, pumping wells, treatment facilities, and landfill cap/containment systems.

 

6.0        REMEDY IMPLEMENTATION ACTIONS

 

 

This section describes the responsibilities of the DON and future transferees for implementing ICs. If the DON transfers responsibility for post-RACR Operation and Maintenance and monitoring of the remedial action for IR Site 2 to another federal agency, that federal agency shall assume the DON responsibilities described in Sections 6.1 and 6.2.

 

6.1         RESPONSIBILITIES OF THE DON WITH RESPECT TO IC INSPECTIONS, REPORTING, AND ENFORCEMENT

The DON is responsible for implementing, maintaining, inspecting, reporting, and enforcing the land use and activity restrictions identified in Section 5.0 of this LUC RD prior to conveyance of the IR Site 2 property. The DON may later transfer these procedural responsibilities to another party (transferee) by contract, property transfer agreement, MOU, or other means. Although the DON may contractually arrange for third parties to assume responsibility for and perform any and all actions associated with ICs, the DON shall retain ultimate responsibility under CERCLA for successful implementation of ICs, including maintaining, monitoring, reporting on, and enforcing the controls as necessary to assure remedy integrity unless the FFA is amended to transfer responsibility for IR Site 2 from the DON to another federal agency at the time of transfer as described in Sections 1.0 and 6.0 above. Should any IC objectives fail, the DON, or another federal agency as appropriate, shall ensure that appropriate actions are taken to re- establish protectiveness of the remedy and may initiate legal action to either compel action by a third party(ies) and/or recover the DON’s costs for mitigating any discovered IC violation(s).

 

6.2         DON RESPONSIBILITIES

The DON will undertake the following IC implementation actions to ensure that the aforementioned IC objectives and land use restrictions for IR Site 2 are met and maintained:

  • LUC RD Distribution:Within 30 days of receiving EPA’s, DTSC’s, Water Board’s, concurrence with this LUC RD, the DON will place the LUC RD in the Information Repository currently located at Alameda Point. A copy of the LUC RD will also be sent to EPA, DTSC, the Water Board, Alameda Reuse and Redevelopment Authority, and CDPH. Appendix A presents a list of agencies and mailing addresses.
    • Site Access: Each deed (or MOU or other agreement with another federal department or agency) will contain a reservation of access to the property for the DON, EPA, DTSC, and Water Board, and their respective officials, agents, employees, contractors, and subcontractors for the purposes consistent with the Navy IR Program or the FFA.
    • Site Inspections: Commencing upon concurrence upon this LUC RD by EPA, DTSC, and Water Board and continuing until the effective date of property transfer, the DON will undertake annual physical inspections of the site to confirm continued

 

compliance with all IC performance objectives and land use restrictions through the property transfer instruments described in Section 4.0. At the time of conveyance of the site, the DON and DTSC will require, via appropriate provisions to be placed in the MOU or other agreement if the property is transferred to another federal agency, or deed(s) of conveyance and CRUP if the property is transferred to a nonfederal entity, that the landowner(s) and subsequent transferees undertake continuing annual site inspections to ensure that all IC objectives and land use restrictions are complied with by all future user(s) as provided in Section 6.3 of this document.

  • Compliance Reporting: Beginning upon approval of this LUC RD and continuing until the effective date of property transfer by the DON, the DON will provide to the EPA, DTSC, and Water Board, an annual IC Compliance Monitoring Report and Certificate for IR Site 2 consistent with the form located in Appendix B. The annual IC Compliance Monitoring Report will address, among other things, whether the land use and activity restrictions were communicated in the MOU or other agreement or deed(s) and CRUP whether the owners and state and local agencies were notified of the use restrictions and controls affecting the property, whether use of the property has conformed with such restrictions and controls, and will evaluate the status of the ICs. In addition, should any deficiencies be found during the annual inspection, the DON will provide the EPA, DTSC, and Water Board with a separate written explanation with the IC Compliance Certificate indicating the specific deficiencies found and what efforts or measures have or will be taken to correct those deficiencies. Copies of a completed and signed IC Compliance Monitoring Report and Certificate shall be sent to the EPA, DTSC, and Water Board by Certified Mail, Return Receipt Requested annually. Upon conveyance of fee title for the site to a nonfederal entity, the DON will require, via appropriate provisions to be placed in deed(s) of conveyance and CRUP, that the landowner(s) and subsequent transferees respond to IC violations as required by compliance reporting and provide to the FFA signatories an IC Compliance Monitoring Report and Certificate for IR Site 2 consistent with the form located in Appendix B unless and until all ICs are terminated at the site.
  • If the transferee fails to provide an annual compliance monitoring report as described previously to the DON, the DON will notify EPA, DTSC and Water Board soon as practicable. If the EPA, DTSC, or Water Board do not receive the annual monitoring report from the transferee, it will notify the DON as soon as practicable. The DON shall ensure appropriate measures have been taken to verify the status of the ICs and that an annual compliance monitoring report is submitted to the EPA, DTSC, or Water Board within 90 days after the report’s due date.
  • CERCLA 5-Year Reviews: The DON shall conduct 5-Year Reviews of the IR Site 2 remedy as required by CERCLA Section 121(c) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The 5-Year Reviews will evaluate, among other things, implementation and compliance with the ICs to determine whether the remedy is or will be protective of human health and the environment in the future. The annual monitoring reports prepared by the DON and transferee will be used in preparation of the 5-Year Review reports to evaluate the effectiveness of the remedy.
  • Notice of Planned Property Conveyances: The DON will provide notice to the EPA, DTSC, and Water Board at least 6 months prior to any transfer or sale of IR  Site 2 by the DON so that all FFA signatories can be involved in discussions to ensure that appropriate provisions are included in the transfer terms or conveyance documents to maintain effective ICs. If it is not possible for the DON to provide notification at least 6 months prior to any transfer or sale, then the DON will notify as soon as possible but no later than 60 days prior to the transfer or the sale of any property by the DON. In addition to the land transfer notice and discussion  provisions in this LUC RD report, the DON further agrees to provide the FFA signatories with similar notice, within the same time frames, as to federal-to-federal transfer of property. The DON shall provide a copy of executed deed(s) of conveyance or CRUP or MOU or similar agreement to the EPA, DTSC, and Water Board.
  • Opportunity to Review Text of Intended Deed Restrictions: Prior to conveyance of the site, the EPA, DTSC, and Water Board will be given reasonable opportunity to review and comment upon the applicable deed(s) and CRUP language related to all ICs and associated rights of entry for the FFA signatories for purposes of IC oversight and enforcement. The provisions in the deed(s) or other enforceable document(s) will be consistent with the IC objectives in Section 5.0.
  • Notification should Action(s) that Interfere with IC Effectiveness be Discovered: The DON or transferee will notify the FFA signatories as soon as practicable, but no longer than 10 working days after the DON’s or transferee’s discovery of any activity that is inconsistent with the IC objectives or use restrictions or any other action that may interfere with the effectiveness of the ICs. The DON or transferee will notify the FFA signatories regarding how a breach will be addressed or has been addressed as soon as practicable, but no later than 10 working days after notification of the breach. This reporting requirement does not preclude the DON from taking immediate action pursuant to its CERCLA authorities to prevent any actual or perceived risk(s) to human health of the environment.
  • IC Enforcement: The process of addressing any activity that is inconsistent with the IC objectives or use restrictions, or any other action that may interfere with the effectiveness of the ICs will be initiated by the landowner as soon as practicable, but no longer than 60 days after the landowner becomes aware of the breach. If a violation of a land use restriction is identified and/or documented by the FFA signatories, or in an owner’s annual IC Compliance Monitoring Report, the entity identifying the violation will notify the others within 10 working days of identifying the violation. The FFA signatories and CDPH will then consult to evaluate what, if any, action(s) should be taken, who shall take the action(s), and when they shall be undertaken. These actions may range from informal resolution with the owner or violator of an IC provision(s) as described in this LUC RD, to the pursuit of legal remedies or enforcement action to enforce deed or CRUP restrictions under the auspices of state property law or CERCLA if the property is transferred to a nonfederal entity. Alternatively, the DON may choose to exercise its response authorities under CERCLA and seek cost recovery from the person(s) or entity(ies) who violate a given IC objective/land use restriction set forth in the deed(s)

 

 

transferring the property. Should the DON become aware that any future owner or user of the property has violated any IC requirement over which a local agency may have independent jurisdiction, the DON will notify these agencies of such violation(s) and work cooperatively with them to reachieve owner/user compliance with the ICs.

DTSC and the DON as signatories to a CRUP (and EPA as a third-party beneficiary) will have independent authority to enforce violations of restrictions, requirements, and obligations under a CRUP. While DTSC may agree to consult with other parties before taking any enforcement action under a CRUP, it will not waive its authority to take action as necessary in the event of violations.

  • Modification of Restrictions in Quitclaim Deed(s) and DTSC CRUPs:Modifications to the ICs may be required based on changes in site conditions (e.g., reduction in ARIC) during the expected duration for the ICs. When the DON or  future property owner(s) determines, with EPA, DTSC, and Water Board concurrence, that modifications to the ICs are appropriate, the IC modifications shall be documented in accordance with procedures consistent with applicable laws and regulations. The DON or future property owner(s) shall be responsible for providing pertinent information on the IC modifications to the Alameda Reuse and Redevelopment Authority and will also advise the additional interested parties listed in Appendix A. The FFA signatories, in consultation with CDPH, shall determine whether a ROD Amendment, Explanation of Significant Differences (ESD), or some other procedure consistent with the NCP is required to support the modification of the IC. The DON shall not modify or terminate LUCs, implementation actions, or modify land use without EPA, DTSC, and Water Board concurrence. The DON or transferee shall seek prior concurrence before any action anticipated by the DON or transferee that may disrupt the effectiveness of the LUCs or any action that may alter or negate the need for LUCs.
    • Termination of ICs: When the DON determines, with EPA, DTSC, and Water  Board concurrence, in consultation with CDPH, that one or more of the ICs at IR Site 2 are no longer needed for protection of human health and the environment because the property is remediated to levels of contamination that allows for unrestricted use, the DON and DTSC shall provide to the current landowner(s) of the property an appropriate release of the restriction (DON for the deed[s] and DTSC for the CRUP) in accordance with state law for recordation with the deed(s) pertaining to the site and will also timely advise the additional interested parties listed in Appendix A. Termination of restrictions contained in the ICs may be possible; however, most ICs (such as those that require protection of the soil cover) will continue in perpetuity to provide protection of human health and the environment. ICs will be maintained until the concentrations of hazardous substances in soil and groundwater are at such levels as to allow for unrestricted use and exposure.
    • Survey Plat: Prior to transfer, the DON will survey the ARICs at IR Site 2 to define the legal metes and bounds for inclusion in the property transfer documents. The DON will forward copies of the survey to the EPA, DTSC, and Water Board and will place a copy in the Administrative Record.

 

6.3         RESPONSIBILITIES OF THE PROPERTY OWNER(S) AND SUCCESSORS WITH RESPECT TO IC INSPECTIONS AND REPORTING

By including appropriate provisions in the MOU or other agreement if the property is transferred to another federal agency, or in deed(s) and CRUPs if the property is transferred to a nonfederal entity, the DON will cause the future property owner(s) to assume the following IC implementation responsibilities upon the DON’s conveyance of the property to ensure that the aforementioned IC objectives and land use restrictions for IR Site 2 are complied with after property transfer:

  • Site Inspections: The property owner(s) will conduct annual physical inspections of the site to confirm continued compliance with all IC objectives and land use restrictions in the MOU, or deed(s) and CRUPs unless and until all ICs at the site are terminated with FFA signatories’ and CDPH approval.
  • Compliance Reporting: The property owner(s) will notify the FFA signatories and CDPH within 5 working days of the property owner(s)’ discovery of any violation of an IC and include in the notification a written explanation indicating the specific IC violations found and what efforts or measures have or will be taken to correct those violations. The property owner(s) will also provide to the FFA signatories and CDPH an annual Compliance Monitoring Report and IC Compliance Certificate for IR Site 2 consistent with the form attached hereto as Appendix B unless and until all ICs are terminated at the site. In addition, should any IC violations be discovered during the annual site inspection, the property owner(s) will provide to the FFA signatories and CDPH, along with the required IC Compliance Monitoring Report Certificate, a separate written explanation indicating the specific IC violations found and what efforts or measures have or will be taken to correct those violations. The annual Compliance Monitoring Report and Certificate shall be sent to the DON, EPA, DTSC, Water Board, and CDPH by Certified Mail, Return Receipt Requested annually. The need to continue to provide such inspections and certifications on an annual basis will be re-evaluated by the FFA signatories and CDPH using the CERCLA five-year review process.
  • Monitoring Well Protection: Prior to conveyance, to preclude damage to the monitoring well network at IR Site 2, the DON will provide appropriate information regarding monitoring well locations and necessary ICs to the future property owner, including, if available, any well coordinates maintained in a geographic information system (GIS) database and/or applicable maps and drawings. This will enable the future property owner and other entities responsible for planning and development of future projects within the ARIC to add the well coordinates to their GIS database and/or applicable maps and drawings.

Whenever the DON proposes to transfer real property where monitoring wells are located, the DON shall include appropriate information regarding monitoring well locations and necessary ICs in transfer documents to assure nondisturbance of the monitoring well network and prevent interference with IC effectiveness.

 

The future property owner(s), or other entity responsible for review and approval of any development plans prepared for projects within the ARIC, shall identify any potential for the project to impact the IC effectiveness and coordinate with the FFA signatories to prevent interference with the IC effectiveness. The DON and other FFA signatories reserve the right to deny approval of projects within the area requiring ICs ARIC deemed to interfere with IC effectiveness. This process will be evaluated during the CERCLA 5-Year Review to determine whether any changes need to be implemented.

  • Notification of Proposed Changes in Land Use: Prior to seeking approval from the FFA signatories and CDPH for restricted activities within the ARIC, the recipient of the property must notify and obtain approval from the DON of any proposals for a land use change at a site inconsistent with the use restrictions and assumptions described in the final ROD.

 

7.0   DOCUMENT REVIEWS

 

 

Various documents may be prepared by the DON or the transferee during the implementation of ICs (e.g., Soil Management Plans). These documents are subject to review and approval by the FFA signatories (and CDPH for documents required by Section 5.3, Additional Activity Restrictions Related to Radionuclides).

 

Draft documents will be subject to a review period of 45 days. Reviewing parties may request extension of the review period for up to an additional 45 days from the party submitting the document. The party submitting the document will have 45 days to revise the document to address the comments received.

 

Draft final documents will be subject to a review period of 30 days. Reviewing parties may request extension of the review period for up to an additional 30 days from the party submitting the document. The party submitting the document will have 45 days to revise the document to address the comments received. Draft final documents will be considered to be final if no comments are received within the 30-day comment period.

 

All parties preparing or reviewing documents will adhere to the scheduled document preparation and review times to the maximum extent practicable.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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8.0   REFERENCES

 

 

Battelle and BBL (Blasland, Bouck, and Lee,  Inc.). 2008. Final Feasibility Study Report  IR  Site 2, West Beach Landfill and Wetlands Alameda Point, California. October.

 

DON (Department of the Navy). 2009. Final Proposed Plan for IR Site 2, Former NAS Alameda.

August.

 

—————. 2010. Final Record of Decision (ROD) for IR Site 2, Former Naval Air Station Alameda, California. August.

 

DON and DTSC (California Department of Toxic Substances Control). 2000. Memorandum of Agreement Between the United States Department of the Navy and the California Department of Toxic Substances Control. March 10.

 

E&E (Ecology and Environment, Inc.). 1983. Initial Assessment Study, Naval Air Station, Alameda, California. Prepared for the Department of the Navy, Navy Assessment and Control of Installation Pollutants Department, Naval Energy and Environmental Support Activity, Port Hueneme, CA.

 

Weston Solutions, Inc. 2007. Historical Radiological Assessment, Alameda Naval Air Station, Use of General Radioactive Materials 1941–2005.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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FIGURES

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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SAN PABLO                                 780

BAY

1                            101                                              4

80

SAN RAFAEL

 

580                                                     680

 

1                                        BERKELEY                 24

SAUSALITO

13      FORMER NAS

80      OAKLAND                                           ALAMEDA

1

SAN FRANCISCO

 

 

 

580

PLEASANTON

SAN FRANCISCO              880

35                          BAY

92                                          84

HAYWARD                 238

82

SAN

MATEO                                                                                                84         FREMONT

1

NEWARK

 

92                REDWOOD          101

CITY

 

PALO

PACIFIC OCEAN                                                                                     ALTO

280                              237

MOUNTAIN                                                                                    680

VIEW                  SUNNYVALE

 

85           82

0              6             12                                                                                                      SAN JOSE

84                35

Miles                                                                           880

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

IR SITE 2

 

 

 

 

 

980

OAKLAND            880

 

 

 

 

INNER                HARBOR

OAKLAND

 

 

 

 

 

 

 

 

 

 

IR SITE 2

SEAPLANE

LAGOON                                 ALAMEDA

 

 

 

 

SAN FRANCISCO BAY

 

 

 

 

0          2,000       4,000

Feet

 

 

LEGEND

IR SITE 2 BOUNDARY

ROAD/RUNWAY                                       (AREA REQUIRING INSTITUTIONAL CONTROLS)

       1       STATE HIGHWAY

      101     US HIGHWAY

280         INTERSTATE HIGHWAY                                                                                             225            0            225          450

NOTES:

FORMER NAS ALAMEDA         IR - INSTALLATION RESTORATION                                                   Feet

BASE REALIGNMENT AND CLOSURE PROGRAM MANAGEMENT OFFICE WEST

SAN DIEGO, CALIFORNIA

 

LAND USE CONTROL REMEDIAL DESIGN INSTALLATION RESTORATION SITE 2

FIGURE 2-1

SITE LOCATION MAP

ALAMEDA POINT, ALAMEDA, CALIFORNIA

 

 

REVIEW: 0 AUTHOR: MS

FILE NUMBER: 120025S7357.mxd

   

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX A

LAND-USE CONTROL REMEDIAL DESIGN DISTRIBUTION LIST

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Land-Use Control Remedial Design Distribution List IR Site 2, Alameda Point, Alameda, California

 

  1. United States Environmental Protection Agency Region IX 75 Hawthorne Street

San Francisco, CA 94105

  1. Department of Toxic Substances Control 700 Heinz Avenue

Berkeley, CA 94710

  1. Regional Water Quality Control Board San Francisco Bay Region

1515 Clay Street, Suite 1400

Oakland, CA 94612

  1. Department of Veterans Affairs (VA) VA Sierra Pacific Network

Capital Asset Managers Office 201 Walnut Ave

Mare Island, CA 94592

  1. California Department of Public Health Environmental Management Branch 1616 Capitol Avenue, MS 7405 Sacramento, CA 95899-7377

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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APPENDIX B

INSTITUTIONAL CONTROLS COMPLIANCE MONITORING REPORT AND COMPLIANCE CERTIFICATE

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Attachment 12 Land Use Controls RD.doc                                                                                                                                                                     Final Land-Use Control Remedial Design

 

Institutional Controls Compliance Monitoring Report IR Site 2, Alameda Point, Alameda, California

EPA ID No. CA2170023236

Property Owner:                                                                                                                                                                                                                                                                                This evaluation is the final Navy certification immediately prior to site conveyance (Yes or No)

If for an annual inspection, this evaluation covers the period from                  through                 _

Certification Checklist

 

 

 

Compliance Item

In

Compliance

Non-

Compliance

 

See Comment

1

No use of IR Site 2 for residence, including any mobile home or factory-built housing, constructed  or installed for use as residential human habitation, a hospital for humans, a school for persons under 21 years of age, a daycare facility for children, a playground or any permanently occupied human habitation including those used for commercial or industrial purposes.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2

No extraction of groundwater or installation of new groundwater wells of any type within the area requiring institutional controls.

 

 

 

 

 

 

3

No use of groundwater for any purpose (no evidence of tampering with existing wells, no evidence of new subsurface penetrations) within the area requiring institutional controls.

 

 

 

 

 

 

 

 

 

4

No alteration, disturbance, or removal of any component of groundwater response or cleanup action, including monitoring wells, groundwater extraction wells, treatment facilities, and associated equipment within the area requiring institutional controls.

 

 

 

 

 

 

 

 

 

 

 

 

5

No removal or damage to security features (such as monitoring well locks, or signs) or to survey monuments, monitoring equipment, piping or other appurtenances.

 

 

 

 

 

 

 

 

 

6

Notification provided for any unauthorized change in land use.

 

 

 

 

 

 

7

Any violations of these LUCs were reported within 10 business days of discovery and an explanation provided of those actions taken or to be taken was provided within 10 days of notification of discovery.

 

 

 

 

 

 

 

 

 

8

No surface or subsurface activity that causes or could cause the preferential movement of contaminated groundwater.

 

 

 

 

 

 

9

No excavation unless approved by FFA signatories and CDPH.

 

 

 

 

 

 

 

I, the undersigned, hereby certify that the above-described land use restrictions have been complied with for the period noted. Alternately, any known deficiencies and completed or planned actions to address such deficiencies are described in the attached Explanation of Deficiencies.

 

       
       

Signature                                                                                             Date

 

Comments:

 

 

 

 

 

 

 

 

Future property owners may provide plans to the DON, EPA, DTSC, and Water Board for review and approval if the plans do not impact land use restrictions provided in the LUC RD.

 

Mail completed form(s) to the DON, EPA, DTSC, Water Board, and CDPH in January of each calendar year.

 

IR SITE 2 SOIL ANNUAL INSTITUTIONAL CONTROLS COMPLIANCE CERTIFICATE

 

Installation Restoration Site 2 Alameda Point, Alameda, California EPA ID No. CA2170023236

 

I,                                                                                          , hereby certify that the attached IR Site 2 Soil Land Use Control Compliance Monitoring Report is complete and accurate. The requirements of LUC RD Section 5.0 have been met. I further certify that a copy of this compliance certificate and the attached IR Site 2 Soil Land Use and Groundwater Use Control Compliance Monitoring Report have been sent by Registered Mail to the following addressees:

 

 

 
   

(Name and title)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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ATTACHMENT 13

RESPONSE TO COMMENTS ON THE DRAFT REMEDIAL ACTION WORK PLAN, DATED MAY 4, 2012

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from James R. Fyfe, PE

Department of Toxic Substances Control (DTSC) Project Manager California Environmental Protection Agency

Comments Dated: July 13, 2012

GENERAL COMMENT

RESPONSE

Comment 1. Studies indicate that due to sea-level rise, mean sea level in the San Francisco Bay is projected to be at least three feet higher in 2100 than it is today. Please provide information on how the remedial action for IR Site 2 will remain protective of human health and environment in the face of rising sea level.

Response 1. The Post-Closure Monitoring Plan has been revised to address the comment.

The current Bay Plan promulgated by BCDC states sea level rise needs to be addressed with adaptive management and innovation. From the 2011 Bay Plan, “Approaches for ensuring public safety in developed vulnerable shoreline areas through adaptive management strategies (that) include but are not limited to: (1) protecting existing and planned appropriate infill development; (2) accommodating flooding by building or renovating structures or infrastructure systems that are resilient or adaptable over time.” (Bay Plan, 3/2012, page 33, Section o)

As gradual sea level rise occurs, quarterly inspections and the mandated CERCLA 5-Year Review are existing tools to monitor and report sea level. Using adaptive management, a decision can be made as to the optimum course to take for maintaining the integrity of the soil cover.

Gradual inundation of the landfill itself should not increase groundwater contamination as the waste is already inundated (i.e., below the current water table).

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James R. Fyfe, PE, DTSC Project Manager California Environmental Protection Agency

Comment 2. DTSC shares the concerns of the public and of other agencies that the planned fence at IR Site 2 should not prevent public access to the entire site, especially to the anticipated San Francisco Bay Trail.

Response 2. The Navy has revised the RD/RAWP to remove the permanent cyclone fencing and barbed wire from the project design. Consistent with active construction projects, the site will be temporarily fenced during construction to protect equipment and ensure public safety. Once construction is complete and the soil cover has been hydroseeded, the fencing will be replaced with simple signage and symbolic fencing, examples provided below. The purpose is to protect the cover and allow the vegetation to establish.

 

                                                                

The Navy's design and CERCLA requirements for this project do not preclude future use of the site for limited public access or passive recreational purposes. It is understood a future Bay Trail may be constructed by property recipients and/or land managers that would traverse the western and southern boundaries of the site. The Navy will not be involved in the construction or management of the proposed future Bay Trail and interposes no objection to the use of simple exclusionary or symbolic fencing as shown in the examples above to require pedestrians to remain on the established pathway or trail.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James R. Fyfe, PE, DTSC Project Manager California Environmental Protection Agency

SPECIFIC COMMENT

RESPONSE

Comment 1. Section 1.3 Points of Contact: Under the heading of “entity” on the list of key personnel, for Cal/EPA, please correct the entry as follows:

Cal/EPA DTSC

700 Heinz Avenue

Berkeley, CA 94710

The remainder of the entry is correct. Also, please delete the entry for Cal/EPA CDPH altogether. As a side note, CDPH is not a part of Cal/EPA.

Response 1. The address for Cal/EPA DTSC has been corrected and the entry for CDPH has been corrected.

Comment 2. Attachment 1 90% Remedial Design, Design Drawings, Sheet C-3: The legend shows -----XX-------------------------------------------------- as “temporary construction

fence”. On the drawing there is also -----X---- around the perimeter of

the site that is not included on the legend. Construction notes indicate that this is the new permanent fence. Please indicate in the drawing legend what -----X--------------------------- represents.

Response 2. See response to DTSC General Comment 2. The symbol

----X---- has been removed from the design drawings and from the legend.

Comment 3. Attachment 1, 90% Remedial Design, Design

Specifications, Section 31 11 00, Clearing, Subsection 3.1.4, Species and Habitat: Toward the end of the paragraph it is stated (based on California Fish and Game Code 3511 and 2080) “If nests are found, the birds will be allowed to fledge before excavation. If this is not possible, the eggs/chicks will be taken to a licensed wildlife rehabilitator for captive rearing. The Navy will consult with the US Fish and Wildlife. Approval of the US Fish and Wildlife is not required before proceeding with CERCLA remedy.” Please also consult with California Department Fish and Game before removing any eggs or checks from their nest.

Response 3. The Navy will coordinate through the DFG-OSPR prior to implementation of reasonable measures that ensure adequate protection of ecological receptors during response action construction at IR Site 2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James R. Fyfe, PE, DTSC Project Manager California Environmental Protection Agency

Comment 4. Attachment 4, Sampling and Analysis Plan, SAP Worksheet #3 – Distribution List, page 18 of 204: Please delete the entry for Mr. Robert Wilson, Cal/EPA DPH. Also please add the following entry:

Ms. Michelle Dalrymple Engineering Geologist Cal/EPA DTSC

(510) 540-3926

700 Heinz Avenue

Berkeley, CA 94710

Response 4. The entry for Cal/EPA CDPH has been corrected to list Robert Wilson, CDPH. The CDPH is one of the regulatory agencies designated in the ROD and will remain in the contact list. Ms. Dalrymple has been added to the distribution list on SAP Worksheet #3.

Comment 5.  Attachment 5, Project Contractor Quality Control Plan, Section 2.18 Points of Contact, page 2-11: Please make the same changes as in Specific comment 1, correcting the address and deleting the CDPH entry.

Response 5. The Points of Contact list in the PCQCP (Attachment 5), Section 2.18 has been updated to correct the CDPH entry. See Response 4 regarding the deletion request.

Comment 6. Attachment 11, Post-Closure Operations, Maintenance, and Monitoring Plan, Section 1.3 Future Use, page 1-2:  It is stated: “A permanent 6-foot-high chain-linked fence with three strands of barbed wire will be placed on the eastern and northern boundary of IR Site 2 at the completion of all work activities, restricting access to the landfill.

Access to the shoreline trail south and west of the landfill will remain open.” This statement does not make sense. A fence on only two sides of Site 2, the northern and eastern boundary that also allows access to a shoreline trail south and west of the landfill cannot possibly restrict access to the landfill. Design drawings indicate that the permanent fence will be on the northern and eastern boundary of IR Site 2 all the way to the shoreline. This will not allow access to a shoreline trail. Please correct this inconsistency and indicate whether or not there will be access

to the shoreline trail. Also, Construction Note 4 on Design Drawing D-6

Response 6. Please see response to General Comment #2. Attachment 11 has been revised to reflect changes.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James R. Fyfe, PE, DTSC Project Manager California Environmental Protection Agency

states that “Barbed Wire shall be used only when specified.” Is the statement above in the Post-Closure Operations, Maintenance, and Monitoring Plan specifying barbed wire on the entire fence? If so, then why not just show the barbed wire on Design Drawing Site Details?

 

Comment 7. Attachment 11, Post-Closure Operations, Maintenance, and Monitoring Plan, Section 6.1, Scheduled Inspection: Please add a requirement to notify and invite regulatory agencies for scheduled site inspections.

Response 7. The Navy interprets this request to require a Navy invitation as a pre-condition for allowing access to the site. The Navy suggests that a better approach would be to rely upon the existing access requirements of CERCLA and Section 18 of the FFA.

Comment 8. Attachment 12, Land-Use Control Remedial Design, Appendix A, Land-Use Control Remedial Design Distribution List: Please correct the address in the second entry as follows:

Department of Toxic Substances Control 700 Heinz Avenue

Berkeley, CA 94710

Also, please correct the address in the fifth entry as follows: California Department of Public Health

Environmental Management Branch 1616 Capitol Avenue, MS 7405

Sacramento, CA 95899-7377

Response 8. The entries for DTSC and CDPH in Attachment 12 have been corrected.

 

 

 

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from James M. Polisini, Ph.D. Senior Toxicologist

Office of Human and Ecological Risk (HERO) Ecological Risk Assessment Section (ERAS)

Comments Dated: June 15, 2012

GENERAL COMMENT

RESPONSE

Comment 1. DTSC comments dated October, 21, 2011 and California Department of Fish and Game comments dated November 9, 2011 on the Intermediate Draft Remedial Design Report, Installation Restoration Site 2, Alameda Point Alameda, California transmitted through James Fyfe, DTSC Project Manager, received no response as the ‘two sets of comments were received after the comment period’ (Attachment 13, Response to comments on the Intermediate Draft, page 32 of 32). The response indicated that each comment will be evaluated and, as appropriate, the Draft RAWP will address these comments. Please indicate which specific comments were addressed and which were not addressed.

Response 1. Navy reviewed the DTSC comments dated October 21, 2011. Many of those comments overlap comments received for this 90% document. Resolution of October 21, 2011 comments is now superseded by the current IR Site 2 RAWP comment and response document. DFG-OSPR’s requests for Navy to reconsider ARARs and comply with more than CERCLA requirements are declined. However, DFG-OSPR will be a part of the process, as required.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

SPECIFIC COMMENT

RESPONSE

Comment 1. Future use of IR Site 2 is outlined as ‘includes low-impact recreational uses such as a recreational trail around the site’ (Section 2.3, page 2-9). IR Site 2 has been designated for federal agency (DON) transfer to federal agency (Office of Veterans Affairs). One potential future use, discussed in the past, was as an Office of Veterans Affairs long-term care facility. Because the human health risk assessment for IR Site 2 did not include a residential use scenario, Institutional Controls should be included to preclude development of a long-term care facility and require IR Site 2 ‘is limited to recreational uses such as a recreational trail around the site’ and specifically reference the Land Use Restrictions outlined in the Land-Use Control Remedial Design (Attachment 12, Section 5.1, page 5-1) which prohibit hospitals, day care and residences.

In addition, the Environmental Protection Plan (Attachment 6; Section 3.0, page 3-1) indicates that portions of IR Site 2 have been proposed for transfer to the US Fish and Wildlife Service (USFWS) as a National Wildlife Refuge. Therefore, ‘low impact recreational use’ does not completely describe the potential future use. Please revise Section 2.3 of the main text to completely describe potential future uses and restrictions.

Response 1. The reference to USFWS has been deleted from Section 3.0 of Attachment 6. The ROD and the LUCRD (Attachment 12) both state that future use for IR Site 2 is recreational, and residential or other occupied structure development is prohibited. Refer to DTSC Response 2.

Comment 2. The Draft Work Plan indicates that mobilization is ‘expected to begin in the Spring of 2012’ with earthwork anticipated to begin shortly thereafter (Section 5.1, page 5-1). As this is a 90 percent completion document, and earthwork has not yet begun, HERO suggests the projected initiation date be revised.

Response 2. Section 5.1 has been revised to state that mobilization is expected to begin in early 2013.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

Comment 3. The barge unloading area is described as to the north of IR Site 2 and references Figure 5-1 (Section 5.1.2, page 5-1). The referenced figure shows an additional unloading area to the south. The text and/or the figure should be amended so that they are correct and agree.

Response 3. The location of the barge offloading area has since been revised to the southern location only due to access limitations at the northern location. Section 5.1.2 has been revised to reference the southern offloading areas and is in agreement with the location as shown on Figure 5-1 which has been revised.

Comment 4. A biological survey conducted one week prior to earth moving activities (Section 5.2, page 5-1), will identify only terrestrial natural resources with fixed locations (i.e., plants) or small home ranges and will not be sufficient to identify all the protected, listed and/or threatened biological resources requiring protection during the entire length of the project. Later description of the biological survey (Attachment 6, Environmental Protection Plan, Section 6.3.2, page 6-6) indicates that the pre-construction biological survey will consist of four separate visits in the 30 days prior to construction. The latter description is sufficiently detailed. Please amend the main text and Attachment 6 so that they are correct and agree.

Response 4. Section 5.2 of the main text has been changed to be consistent with similar text in Attachment 6.

Comment 5. Demolition of the ammunition bunkers and the associated guard towers are not planned (Section 5.5, page 5-2). Ammunition bunkers on at least one other closed Department of Defense (DoD) base in the San Francisco Bay area have been locations of trespass and disturbance. Please provide the rationale for not removing all attractive nuisances in an area planned for recreational use in this section of the document.

Response 5. The bunkers (Bldgs 353 and 354) may be used for storage in the future by the property recipient. Section 5.5 of the RAWP has been revised to include tack-welding the bunker doors shut to ensure public safety and security until the future property recipient decides to use the buildings.

Comment 6. The Department of Fish and Game should be consulted to determine whether the 220-mil un-seamed layer of HDPE geonet with half-inch openings proposed as animal penetration control, rather than a rock cover (Section 5.6.6.2, page 5-7), is sufficient.

Response 6. Please see Response to Polisini Specific Comment #1 dated 12/17/12 (Attachment 14).

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

Comment 7. Ground elevations from the final topographic survey (Section 5.11.1, page 5-12) should be entered into a Geographic Information System (GIS) to facilitate monitoring of post-remedial settling. NAS Alameda had a functional GIS in the mid-1990s.

Response 7. Topographic survey reports regarding monitoring for subsidence are part of the post-closure monitoring plan reporting requirements.

Comment 8. Please amend the text to reference to ‘recent wetland delineation recently conducted at IR Site 2’ by CH2M Hill Kleinfelder (Attachment 6, Environmental Protection Plan, Section 6.1.2, page 6-2) as included in Attachment 7, Appendix A of this Draft RAWP. This wetland delineation is described as following the Army Corps of Engineers (ACE) methodology. The California DFG and the USFWS interpret the results of the wetland survey differently from the ACE. Specifically, wetlands are identified by DFG and USFWS by the presence of any of the three (water, vegetation and soil) criteria: a) presence of water; b) presence of hydrophytic vegetation; and, soils typical of permanent or intermittent inundation, not the ACE requirement for all three for wetland designation. Use of the DFG and USFWS wetland identification process could significantly increase the area of wetlands in IR Site 2.

Response 8. A reference has been made to the KCH Delineation report (2011) in the RAWP, Section 5.10. The Navy will continue to rely on the ACE methodology as it has done at other CERCLA IR sites in California.

Comment 9. The DFG and the USFWS should be contacted prior to the surveys conducted by the ‘specified’ biological monitor to assess the presence of special status plan and animal species and the focused survey of nesting birds and nests to determine if they wish to send representatives to participate in the biological surveys (Attachment 6, Environmental Protection Plan, Section 6.3.1, page 6-5, first bulleted item; Attachment 6, Environmental Protection Plan, Section 6.3.2, page 6-6).

Response 9. Concur. The DFG and USFWS will be contacted prior to conducting the surveys. Sections 6.3.1 and 6.3.2 in Attachment 6 have been revised.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

Comment 10. Any written notification of the accidental death or injury of any state-listed or Federal-listed species received by the Department of the Navy (DON) (Attachment 6, Environmental Protection Plan, Section 6.3.1, page 6-5, sixth bulleted item; Attachment 6, Environmental Protection Plan, Section 6.3.4, page 6-7) should be forwarded to the DFG or USFWS as applicable.

Response 10. Concur. Attachment 6, Section 6.3.1, page 6-5, sixth bullet has been revised.

Comment 11. The proposed replacement ratio for ‘lost’ tidal wetlands and non-tidal wetlands is 1:1 (Attachment 6, Environmental Protection Plan, Section 6.3.3, page 6-7). Wetland replacement at the former Mare Island Naval Shipyard (MINSY) was initially proposed at a replacement ratio of 1:5 to 1, but finalized at 1.15 to 1 (http://www.denix.osd.mil

/awards/upload/Environmental-Restoration-Individual-or-Team- MANSY.pdf). The DFG and USFWS should be contacted to confirm agreement with the proposed 1:1 replacement ratio for IR Site 2 wetlands.

Response 11. Section 2.9.2.1 of the CERCLA ROD for IR Site 2 provides: “If impacts to wetlands occur, an equivalent acreage of similar wetland habitat will be constructed onsite at Alameda Point, the details of which will be presented in a Wetlands Mitigation Plan to be developed during the remedial design phase.” Section 3.0 of the draft Wetland Mitigation Plan included as Attachment 7 of the draft Remedial Action Work Plan is consistent with the ROD. The Navy will respond to any comments provided by DFG and USFWS addressing this issue.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

Comment 12. Several radiological issues have been forwarded to Valerie Chenoweth-Brown, Senior Health Physicist, HERO-CalCenter for review and potential comment:

  1. a.       All radiological components of the IR Site 2 RA will be performed under a valid NRC or California Agreement State license maintained by TtEC. Appropriate and timely notification will be given to the NRC or CDPH, as applicable, that the corresponding TtEC NRC or California Agreement State license will be invoked in support of the IR Site 2 RA (Section 3.2, page 3-2).
  2. b.      Trees, shrubs, and grasses will be cut flush with the land surface. Vegetation that has been radiologically-screened and cleared (Section 5.6.1, page 5-4) will be disposed of off-base at a local composting facility. Trucks hauling cleared vegetation will be passed through the radiological portal monitor prior to leaving the site. The radiological portal monitor will be operated in accordance with the Radiological Work Plan (RadWP; Attachment 2) and the appropriate SOPs. Vegetation that fails radiological screening will be handled and disposed of per procedures described in the RadWP and the WMP (Attachments 2 and 10, respectively).
  3. c.       Radiological survey activities (Section 5.7, page 5-9) will be conducted in accordance with the guidelines in the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), NRC NUREG-1575.

Response 12a–c. Noted.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

James M. Polisini, Ph.D., Senior Toxicologist HERO, ERAS

This comment is meant for the DTSC Project Manager and no response is required from the Navy or Navy contractors. Any further HERO comment on these radiological issues will be transmitted under separate cover.

 

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Xuan-Mai Tran Remedial Project Manager

Federal Facilities and Site Cleanup Branch

U.S. Environmental Protection Agency, Region IX

Comments Dated: July 5, 2012

GENERAL COMMENT

RESPONSE

Comment 1. While a tidal influence study was conducted in 2004 at Installation Restoration (IR) Sites 1 and 2 to quantify the influence of tides on water levels in Alameda Point wells, Section 2.1.3 (Hydrogeology) states that, “Wells distal from the shoreline and in the vicinity of the landfill were not included in the tidal study.”  As a result, it is unclear if the tidal influence study is representative of IR Site 2 conditions. Please revise the Draft Remedial Design Remedial Action Work Plan, Installation Restoration Site 2, Alameda Point, Alameda, California, dated May 4, 2012 (Draft RD/RA WP) to clarify how the tidal influence study provided is representative of IR Site 2 conditions when interior wells at IR Site 2 were not evaluated.

Response 1. Interior wells and wells along the eastern boundary of IR Site 2 were included as a part of the 2004 tidal study (Shaw, 2005). See Figure 7 of the referenced report. Section 2.1.3 of the RAWP has been revised to reflect this correction and the sentence in question has been removed.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 2. Maintaining the interconnection with the SF Bay is critical to the preservation of the saltwater wetlands habitat. As described in the ROD, the connection is provided by the existing pipe culvert connecting the North Pond to the San Francisco Bay. The Navy has asserted in

its Response 18 in Attachment 13 (Response to Comments on the Intermediate Draft Remedial Design Report, dated August 2011), that the existing pipe culvert will be retained, however there is no evaluation of the culvert to demonstrate that the culvert is appropriately sized or constructed to minimize the potential for future blockages, nor is there any provision for the periodic inspection and maintenance. Either the connection to the Bay needs to be reconstructed to reduce the potential for blockage or an obligation to periodically inspect the culvert and clear blockages needs to be included in the O & M plan. The details for the inspection and maintenance should be reviewed with BCDC as part of the Navy’s compliance with the substantive provisions of Bay Plan.

Response 2. The Navy agrees with the comment that the culvert is critical to the health of the tidal wetlands at IR Site 2. Text has been added to Wetlands Mitigation Plan (Attachment 7) as follows:

The Navy recognizes that the existing culvert (Figure 2) is critical to the life of these IR Site 2 tidal wetlands, as without the culvert, there would be no tidal circulation. As a part of defining successful hydrology for the tidal wetlands, the Navy will have a qualified structural engineering evaluation of the culvert (as it is known to be significantly rusted and damaged) as soon as is practical during cover construction activities. Further, the Navy will make necessary repairs, modifications or replacement to maintain tidal circulation as recommended by the structural assessment of the culvert, and do so during remedy construction if warranted. In the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days of the failure).

The Post-Closure Operations, Maintenance, and Monitoring Plan (Attachment 11) has been modified to include Culvert Inspection as part of regular visual inspections defined in Attachment 11, Appendix C, SOP 001 Multilayer Soil Cover Inspections.

Comment 3. The Draft RD/RA WP does not include a plan to address munitions and explosives of concern (MEC). Since MEC was disposed in the Site 2 landfill and only the top foot has been cleared, a plan to address MEC if it is exposed during site grading or while making “cuts” into the subsurface should be included. Note that although the text refers to the MEC as “inert ordnance” (e.g., Section 2.5), this cannot be determined without physically inspecting each item. Items buried below 1 foot below ground surface have not been inspected, so it cannot be concluded that all of the items are inert. Please revise the text to delete the phrase “inert ordnance” and provide a plan to address MEC.

Response 3. The text has been revised to delete reference to inert ordnance. Cuts into the soil cover have been eliminated in the 90% design and the only excavation will be removal of radiological anomalies. A UXO tech will be on call in the unlikely event that MEC is encountered during excavation of radiological anomalies.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 4. The text (e.g., Sections 2.0 and 2.2.2) and Figure 2-1 use the obsolete term ordnance and explosive waste (OEW). This term should be replaced with MEC. Please revise the text and figures to replace “OEW” with “MEC.”

Response 4. The term OEW is used to be consistent with historical references. The text of Section 2 has been revised to replace OEW with MEC.

Comment 5. Site grades are stated to be established at 1.5 percent (%) slope; however, several areas exist where steeper slopes are proposed. While the results of Table 7, Summary of Slope Stability and Permanent Seismic Deformation Analyses, of Attachment 1, Draft Geotechnical Report (DGR), to Attachment 1 (90% Remedial Design) indicate that the interior slope between the landfill and wetlands is relatively stable, the overall impact of the steeper slopes identified below on the overall slope stability analysis is not discussed. The following represent areas where steeper slopes are proposed:

-          A 2.5% slope is proposed on Drawing C-4 (Subgrade Plan - Northwest) of Attachment 1 (90% Remedial Design)

-          A 5:1 and a 2:1 slope are proposed on Drawing C-6 near the North Pond (Subgrade Plan - Southwest) of Attachment 1

-          A 2:1 slope is proposed on Drawing C-7 near the North Pond (Subgrade Plan - Southeast) of Attachment 1

-          A 3:1 slope and a 10% slope are proposed on Drawing C-10 (Final Grading and Cover Plan - Northeast)

-          A 2:1 slope, 2.5% slope, and 6% slope, and 5:1 slope are proposed on Drawing C-11 (Final Grading and Cover Plan - Southwest)

-          A 2:1 slope is proposed on Drawing C-12 (Final Grading and Cover Plan - Southeast)

Please revise the Draft RD/RA WP to discuss the implications of steeper slopes on the slope stability analysis provided in Attachment 1 (Draft DGR) of Attachment 1 (90% RD).

Response 5. The 1.5% slope is a minimum slope and steeper slopes are acceptable to facilitate drainage. The critical Section C-C’ considered for the interior slope between the landfill and wetlands has a slope height of approximately 12 feet and an average slope of 1.4(H):1(H), taken from the bottom of the submerged pond to where the slope breaks to being relatively flat, i.e., sloped only for drainage at 1.5% minimum. Section C-C’ analyzed is considered to be critical in relation to the 5(H):1(H) to 2(H):1(V) slopes shown on the Drawings. The slope provided for drainage above the steeper slope directly adjacent to the wetlands margin is not considered to be critical with respect to stability and permanent seismic deformation predictions.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 6. The Draft RD/RA WP does not state whether the remedial design addresses the possibility of a rise in sea level, and there is no analysis of the consequences of future expected sea level changes.

Please revise the Draft RD/RA WP to address these issues.

Response 6. Please see response to DTSC General Comment #1.

Comment 7. The Draft RD/RA WP does not discuss how penetrations of the geonet (e.g., for monitoring wells or gas monitoring probes) will be done to maintain the integrity of the geonet. If monitoring wells are installed with a hollow stem auger or rotary drill rig through the geonet, significant damage to the geonet could occur. Please provide detailed procedures to ensure geonet integrity when it must be penetrated.

Response 7. Detail 4 on sheet D-3 of the RD (Attachment 1) includes a detail for a typical geonet penetration if necessary. As shown in the detail, a geonet boot would be installed around a pipe penetrating the geonet layer.

Comment 8. Section 5.8.1 (Installation of Access Roads) indicates that travel on unpaved portions of the cover will be restricted to eliminate the formation of preferential drainage channels that would erode the cover in a manner that would impact the cover performance; however, Section

5.8.2 (Installation of Groundwater Monitoring Wells and Landfill Gas Monitoring Probes) indicates that replacement groundwater monitoring wells will be drilled in the interior of the cover once the cover has been completed. As such, it is unclear how travel on unpaved portions of the cover will be prevented. Please revise the Draft RD/RA WP to eliminate any travel on unpaved portions of the cover, or expand the current network of paved portions of the landfill cover to allow for full access to all monitoring locations without exiting a paved roadway and submit an updated access road and monitoring location figure.

Response 8.  Section 5.8.1 of the main text has been revised to include  gravel access roads leading to groundwater monitoring wells within the footprint of the cover. Associated sheets in the RD (Attachment 1) have been revised to add the monitoring well access roads.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 9. An outline of the contents of the Remedial Action Completion Report (RACR) has not been provided. In addition to the items typically provided in a Navy RACR, the estimated and actual costs for this remedy should be provided. Further, the RACR should state how many tons or yards of materials were disposed off-site and where the material was disposed.

Response 9. The RACR will follow streamlined EPA guidance and will include estimated costs and discussion of materials disposed off-site, if any.

Comment 10. Table 2-1, Summary of Previous Investigations and Reports for IR Site 2, indicates that soil cement gravity wall and stone columns were determined to be the most feasible remedial option to address geotechnical hazards at IR Site 2; however, the text does not discuss why these remedial options were not incorporated into the remedial design. Please revise the Draft RD/RA WP to specifically discuss why previous geotechnical recommendations were not incorporated into the remedial design.

Response 10. The Geotechnical Report included in Attachment 1 of the 90% Remedial Design (May 4, 2012) indicated that a wide range of permanent seismic deformations and liquefaction-induced flow failures were predicted for a potential MCE event at IR Site 2. This report recommended ground improvement including a soil cement gravity wall and stone columns to mitigate the predicted seismic deformation and flow failure. In order to confirm that these ground improvements provided best value for this project, the Navy performed additional analyses and focused modeling of permanent seismic deformations and flow run-outs to better and more accurately quantify the impact of an MCE event. The additional analyses indicated that ground improvements were not required because:

Solid refuse is not anticipated to be released into the SF Bay by the predicted permanent seismic deformations and /or flow run-outs; and

The site will remain isolated from and will not be flooded by waters of the SF Bay.

The predicted nature and magnitude of the seismic displacements and deformations are quantified in the revised version of the Geotechnical Report and summarized in Section 12 of that report.

Since the waste will still be isolated from the SF Bay following an MCE event and therefore the cover integrity to act as a pathway interruption

between the landfill waste and human and environmental receptors is

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

 

expected to remain effective; the MCE would not compromise the CERCLA remedy and ground improvements such as cement gravity walls or stone columns are not warranted. However, some level of damage to the cover and seawall should be anticipated after an MCE event, and will be repaired. It is common for landfills in southern California to have stockpiled cover soil in the event that repairs are required due to earthquake, storm water runoff, and/or subsidence. Section 5.9 Geotechnical Recommendation of the Draft RD/RAWP has been revised to include this discussion.

Comment 11. Figure 1-3, Revised Schedule, includes an “Onsite Preparation/Procurement of Concrete for Animal Intrusion Barrier (if necessary)” remedial action; however, the Draft RD/RA WP text does not discuss this remedial action.  As such, it is unclear what criteria would trigger the onsite preparation/procurement of concrete for the animal intrusion barrier. Further, it is unclear how this action will impact the overall remedial design. Please revise the Draft RD/RA WP to include details related to the onsite preparation/procurement of concrete for the animal intrusion barrier and clearly show its footprint on a scale drawing to allow for full assessment of its overall impact on the design.

Response 11. Concrete barrier was replaced with HDPE geonet and the schedule has been revised accordingly. Plans do not currently include the use of crushed concrete for an animal intrusion barrier. The animal intrusion barrier extends to the soil cover boundary.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 12. Sections 6.2.7 [Soil-Mixing Improvement Zone (Western Coastal Margin)] and 6.2.8 [Jet-Grouting Improvement Zone (Southern Coastal Margin)] of Attachment 1 (Draft Geotechnical Report) of Attachment 1 (90% Remedial Design) discuss cement deep soil mixing and jet-grouting in the western and southern coastal margins of IR Site 2; however, further discussion of these remedial actions is not provided elsewhere in the Draft RD/RA WP. Table 7 (Summary of Slope Stability and Permanent Seismic Deformation Analyses) of Attachment 1 (Draft Geotechnical Report) of Attachment 1 (90% Remedial Design) indicates that the southern coastal margin and the western coastal margin would liquefy under seismic conditions without ground improvement. As such, it is unclear from the Draft RD/RA WP if the Navy has determined that the risk of failure of the perimeter slopes at the western and southern coastal margins which could result in permanent seismic deformation or flow failure is an acceptable long term risk resulting in electing not to perform the ground improvement. Please revise the Draft RD/RA WP to discuss the use of cement deep soil mixing and jet-grouting as part of the remedial action, if applicable, or revise the cement deep soil mixing and jet-grouting discussion to clearly indicate that they were not selected for use and the associated risk of failure as a result of this decision.

Response 12. The Geotechnical Report has been revised and reviewed subsequent to these comments. Please see Attachment 14 for Response to Comments on the latest version of the Geotechnical Report.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 13. Section 8.2 (Liquefaction Induced Lateral Spreading) of Attachment 1 (Draft Geotechnical Report) of Attachment 1 (90% Remedial Design) states that, “It should be noted that based on the presented analyses the seawall along the southern coastal margin which is founded on liquefiable hydraulic fill and coarse-grained Young Bay Mud is prone to edge failure and lateral spreading;” however, no remedial actions are proposed in the Draft RD/RA WP to address these issues. As such, it is unclear how edge failure and lateral spreading will be addressed. Further, the integrity of the seawall is used in the second paragraph of Section 8.2 of Attachment 1 of Attachment 1 to indicate that lateral spreads will be localized; however, if the seawall is prone to failure and lateral spreading, it is unclear how further lateral spreading will be localized and will not distort the cover and result in depressions, drainage reversals or similar effects. Please revise the Draft RD/RA WP to address the potential edge failure and lateral spreading of the seawall along the southern coastal margin or clarify where it will be addressed.

In addition, clarify how the integrity of the seawall will impact its ability to prevent further lateral spreading at IR Site 2.

Response 13. The Geotechnical Report has been revised and reviewed subsequent to these comments. Please see Attachment 14 for Response to Comments on the latest version of the Geotechnical Report..

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 14. Section 10.1, Summary of Results, of the DGR indicates that the likelihood of landfill solid waste reaching the San Francisco Bay is considered to be remote given the width of the coastal margin; however, it is unclear whether the coastal margin is a thin strip of land or a stretch of land sufficiently wide to prevent landfill solid waste from reaching the San Francisco Bay should failure occur. Section 2.1 of the Draft RD/RA WP and Section 6.1.1, Upland, of Attachment 6 (Environmental Protection Plan) describe the coastal margin as a “thin strip of land.” For example, Section 6.1.1 states, “A coastal margin composed of the perimeter dike and riprap seawall is present between the landfill and/or wetland, and the bay, and is characterized as a thin strip of land that acts as a buffer for the landfill and the wetland.” Please clarify whether the coastal margin is a thin strip of land or a stretch of land wide enough that landfill solid wastes are unlikely to reach the San Francisco Bay.

Response 14. The width of the coastal margin is taken from the back of berm to the top of the seawall and is on the order of 100 feet wide at its narrowest. The likelihood of solid waste reaching the current limits of the Bay as a result of permanent seismic deformations in excess of 100 feet is considered to be remote. Section 2.1 of the main text and Section 6.1.1 of Attachment 6 have been revised to clarify that the Coastal Margin embankment is 100 feet wide at its narrowest.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 15. Additional subsurface evaluation and laboratory testing were not proposed to address uncertainties related to subsurface conditions (e.g., geotechnical samples). The recommendations and opinions expressed in the DGR are based on background documents and historical field explorations and the laboratory testing. As such, it is unclear if the geotechnical recommendations presented in the DGR are representative of current site conditions as site conditions can change with time as a result of natural processes or anthropogenic activities at Site 1 or at nearby sites, as stated in Section 11 (Limitations) of the DGR. No examples of such conditions are provided. While it is understood that any site development or structural modifications would apply, the statement implies that the mere passage of time could alter conditions so as to make the recommendations provided no longer valid. Presumably, this includes subsidence that may occur as waste degrades. Please revise the Draft RD/RA WP to clarify why an updated subsurface evaluation and more recent laboratory tests results were not performed to address uncertainties related to subsurface conditions, and include examples of the range and type of natural and anthropogenic processes that would render the recommendations invalid.

Response 15. The subsurface site conditions have not changed enough since data collection to affect the closure design. Geotechnical recommendations have been replaced by a new analysis in a revised Geotechnical Report dated October 29, 2012 (Attachment 1). See Response 10.

The previous geotechnical field and laboratory results are sufficient to support the conclusions presented in the report. Natural processes would typically be limited to changing groundwater conditions and settlement resulting from waste decomposition, but in this case, given the predictable groundwater conditions due to the proximity to the Bay and the age of the waste, natural processes are unlikely to invalidate the conclusions presented in the report.

Only human activities such as site modifications would be anticipated to appreciably impact the conclusions presented in the report.

The conclusions provided in Section 12 of the revised Geotechnical Report predict a more specific range of deformation for the berm and soil cover.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 16. The soil classification properties for the coastal margin are not distinctly defined in Section 6.2.1 (Landfill Cover and Perimeter Berm Fill) of the DGR; instead the landfill cover and perimeter berm fill parameters are defined based on an assumed typical value for compacted fill characterized as sand with some fines. Based on Section 6.1.1 (Upland) of Attachment, “A coastal margin composed of the perimeter dike and riprap seawall is present between the landfill and/or wetland, and the bay, and is characterized as a thin strip of land that acts as a buffer for the landfill and the wetland. Materials identified in the coastal margin differ from those in the landfill and wetlands.” Since the materials are different, it is unclear if the soils within the coastal margin have been appropriately characterized and whether the resulting slope stability analysis is representative of site conditions. Please revise the Draft RD/RA WP to specify collection of site-specific values representative of the landfill cover and perimeter berm area to be utilized in the slope stability analysis for the landfill cover and perimeter berm in place of the assumed typical values.

Response 16. The Geotechnical Report has been revised and reviewed subsequent to these comments. Please see Attachment 14 for Response to Comments on the latest version of the Geotechnical Report.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 17. The Draft Radiological Work Plan, IR Site 2 (RWP) in Attachment 2 states that the time-critical removal action (TCRA) previously performed at the IR Site 2 did not completely remove Radium-226 (Ra-226) contamination. The highest concentration of Ra- 226 detected from collection of random soil samples at the bottom of the excavation was 7.59 picoCuries per gram (pCi/g), but the full nature and extent of contamination had not been identified. While the RWP states that a previous time critical removal action did not completely identify the horizontal and vertical extent of contamination, no reference is

provided for the levels of contamination (particularly for Ra-226) that are anticipated to remain at the IR Site 2. For completeness and clarity, it is recommended that the RWP provide some information about previous sampling events that gives a reference to the potential levels of radiological contaminants remaining at the site. Please revise the RWP accordingly.

Response 17. Although historical documents and prior remediations performed at IR Site 2 qualitatively indicate that Ra-226 contamination concentrations are potentially greater, the RWP (Attachment 2) presents 7.59 pCi/g as the largest concentration detected during the TCRA (i.e., soils outside of the embankment and landfill cover) because that is the most elevated soil sample on record. All other sample data from that TCRA indicated contamination concentrations less than 7.59 pCi/g. The full nature and extent of contamination within the bermed and fenced bunker areas of IR Site 2 are unknown and will remain unknown as no records indicating quantity of radioactive material deposited in the area have been discovered. Sampling beneath the top 12 inches of material will not occur as the RWP states that a surface scan will be conducted to remove surface radioactive anomalies, followed by surface soil sample collection for dose and risk modeling, and the subsequent capping of the area with radiologically clean fill material. Note that the decision to provide a soil cap of the area was largely based on the fact that the nature and extent of contamination within IR Site 2 are undefined.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 18. Section 1.0, Introduction, of the RWP does not clearly state the remedial goals or release limits are required to be achieved for the remedial action at the Site 2. Section 2.2.1 (Radiological Investigations) in the main body of the document, and Section 2.1 (Radiological History) in the RWP states that the 2009 TCRA had a primary objective “to mitigate the potential risk posed by material potentially presenting an explosive hazard and radiological contamination and threatened release of hazardous substances to the environment.” Radiological removal action objectives for the TCRA were established as follows: “1) prevent ingestion, dermal contact, or inhalation of radiological anomalies with concentrations that significantly exceed background concentrations of 6.000 counts per minute; and 2) to ensure the total effective dose equivalent received through all potential pathways from the radium-impacted waste to any member of the public does not exceed 15 millirem per year.” Neither the main sections of the Draft RD/RA WP nor the RWP in Attachment 2 clearly presents this information or states whether these objectives meet the requirements of the RD/RA WP.  Please revise the RWP to clearly present the objective of the remedial action and associated remedial goals.

Response 18. A bullet in the third paragraph of Section 1.0, Introduction, of the RWP (and the Objectives section of the Executive Summary of the SAP) has been added stating the following:

Providing modeling, based on analysis of soil samples collected from the subgrade surface, to demonstrate that with the 2-foot cover installed, the maximum annual dose to an individual of 15 mrem, and the excess lifetime cancer risk (ELCR) at 3 × 10-4 for the critical group, are not exceeded.

This is consistent with Section 2.7 of the ROD (DON, 2010).

Comment 19. Sections 7 through 11 of the RWP describe the formulas and general procedural requirements of the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) surveys planned as part of the remedial action at IR 2, but do not provide the project-specific information which demonstrates how the surveys will be implemented.

For instance, the text in Sections 7 through 11 do not state which radiation survey instruments will be selected from those listed in Table 10-1 (Portable Survey Instruments) or what the achievable minimum counts per minute (cpm) or Minimum Detectable Concentration (MDCs)

will be achieved for this project based on site-specific background levels

Response 19. Sections 7.0 through 11.0 of the RWP describe the formulas and general procedural requirements of the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) surveys planned as part of the remedial action at IR Site 2. Site specific MDCs and other equipment parameters have not been calculated as site-specific reference background areas have not been sampled and analyzed. Sampling and analysis associated with IR Site 2 will not be conducted until the RWP has been approved. As stated in Section 8.3.3, Final Status Surveys: “Although the FSS of IR Site 2 is not intended to provide for radiological release of IR Site 2, the sample

density is designed to ensure data commensurate with a Class 1 survey is

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

and the selected radiation survey instrumentation. Further, text in Section 8.3.3, Final Status Surveys (FSS), does not provide specific calculations for determining the required number of definitive/confirmation samples that will be collected in the FSS. The RWP should include this project- specific information for all planned radiological surveys. Please revise the RWP to include this information.

collected. Derived concentration guideline levels (DCGLs) for each ROC are based on the exposure pathways and parameters presented in the Final Remedial Investigation Report IR Site 2, West Beach Landfill and Wetlands (Battelle and BBL 2006), and limit the maximum annual dose to an individual to 15 mrem and the ELCR to 3 × 10-4 for the critical group.” These DCGLs used in conjunction with conservative assumptions of approximate background concentrations of the radionuclides of concern result in a minimum of 9 samples from the reference area and 9 from the survey unit area. The number of calculated samples (9) was based on an assumed mean concentration for the specific radionuclides of concern based on gamma spectroscopy results from previous work at Alameda and Hunters Point Naval Shipyard. This calculation included a 20% increase in samples, as recommended in MARSSIM section 5.5.2.2, to obtain sufficient sample points to attain the desired power level with the statistical tests and allow for possible lost or unusable data. Note that losing or having unusable gamma spectroscopy data is highly unlikely, as the DON has used gamma spectroscopy data extensively in final status survey reports at Alameda Point and Hunters Point Naval Shipyard in the past 4 years, and has not had a single instance of unusable gamma spectroscopy data. Additionally, as the Rad Work Plan requires that all areas be remediated such that all samples are beneath the DCGLs for each respective radionuclide of concern, and each sample point must have a maximum annual dose to an individual less than 15 mrem and an ELCR of less than 3 x 10-4 for the critical group. As such, the power level for any statistical test will easily be met. In summary, the additional sample collected from each survey unit is a further level of conservatism above and beyond an extremely conservative calculation of required samples. In the interest of conservatism, these sample number values are increased to 10 in each respective area.

The remedial action completion report will include the specific calculations

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

 

used to derive the number of required samples at the IR Site 2 for purposes of demonstrating defensibility in the conclusions regarding the levels of contamination remaining within the area sampled. Note that as stated in NUREG-1505, “A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys”, Section 10.4, the retrospective power calculation is only necessary when the null hypothesis is not rejected. As stated above, each sample point result will demonstrate that each sample point has a maximum annual dose to an individual less than 15 mrem and an ELCR of less than 3 x 10-4 for the critical group, so that the null hypothesis must statistically be rejected as shown in MARSSIM Section 8.2.5, Table 8.2.

Comment 20. Attachments 2 and 3 do not provide sufficiently detailed information about project-required dosimetry. Section 5.3 (Personnel Dosimetry) on Page 5-2 in the RWP states that any personnel working in the Radiological Control Areas (RCA) will be required to wear personal dosimetry. Section 3.10 (Monitoring and Measuring External Exposure) on page 3-5 of the Radiation Protection Plan (RPP) in Attachment 3 states that a vendor accredited by the National Voluntary Laboratory Accreditation Program will be used to provide dosimetry services.

However, neither section discusses which vendor has been selected or specifies the kind of dosimetry/detector(s) that will be used. This information is important for demonstrating that the types of dosimetry that will be used are appropriate for the site-specific radiological hazards. Additionally, the RWP and/or RPP should clarify whether the same vendor or project personnel will oversee the air monitoring program to demonstrate compliance with the 10% Derived Air Concentration (DAC) limits and/or in the unlikely event of an internal exposure, the bioassay program. Please revise the RWP and RPP to provide this information.

Response 20. The RPP commits to providing external dosimetry from a vendor accredited by the National Voluntary Laboratory Accreditation Program. A specific vendor has not been named as the contractor reserves the right to change external dosimetry contractors based on performance of the vendor. The dosimetry selected will be appropriate for quantifying dose from the beta and gamma energy spectrum for radium-226 and its progeny, as the most prominent radionuclides of concern.  Additionally, project personnel will oversee compliance with the 10% DAC limits in accordance with SOP 9, “Air Sampling and Sample Analysis.”

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 21. The Draft RD/RA WP includes an Environmental Protection Plan in Attachment 6 and Wetland Mitigation Plan in Attachment 7; however, sections of each of these documents present information that could be corroborated by cross-referencing the other to support these plans. For example, Section 6.0 of the Wetland Mitigation Plan identifies special status species but does not mention that ecological surveys will be performed before starting work in the project areas, nor does it discuss results of historical surveys, which are presented in Section 6.2 of the Environmental Protection Plan. Please ensure that these documents cross-reference each other to support implementation of the remedial action at IR Site 2 and environmental compliance requirements.

Response 21. The EPP and the Wetlands Mitigation Plan (Attachments 6 and 7, respectively) have been revised to better cross-reference each other.

Comment 22. Attachment 8 (Stormwater Pollution Prevention Plan) uses inconsistent terminology to define a rain event. For example, Section 4.3, Site Inspections, defines a qualifying rain event as 0.5 inch of rain or more per 24 hours while Section 4.5, Water Quality Sampling and Analysis, defines a qualifying rain event as at least 0.5 inch of rain. Further, Attachment 8 frequently refers to “extended storm events” but does not define or quantify the term. Please revise the Draft RD/RA WP to clearly define a qualifying rain event and an extended storm event, ensuring that the definitions are based on documented, appropriate, site- specific conditions.

Response 22. A qualifying rain event is defined in Appendix 5 (Glossary) of the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities as “Any event that produces 0.5 inches or more of precipitation with a 48 hour or greater period between rain events.” This definition will be added to Sections 4.3 and 4.5 of the SWPPP (Attachment 8).

An extended storm event is a storm that lasts longer than 24 hours. This definition will be added to the two places in the text of the SWPPP that refer to “extended storm events.”

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 23. Inconsistent terminology is used in Attachments 8 and 9. For example, Section 3.3 (Dust Control Measures) of Attachment 9 states that chemical soil stabilizer will be applied to on-site storage piles of soil or sediments while Attachment 8 (Stormwater Pollution Prevention Plan) states that soil tackifier will be used to provide dust control and prevent runoff of stockpiled soils. In addition, Section 5.0 (Mitigation Contingencies) of Attachment 9 indicates that a nontoxic lockdown material will be used to suppress dust. It is unclear if these references are to the same product. In addition, a material safety data sheet (MSDS) should be included for this (these) product(s). Please revise the Draft RD/RA WP to use consistent terminology throughout the document and include a MSDS for the intended dust mitigation media.

Response 23. The terminology in Attachments 8 and 9 has been revised to consistently reference a “soil tackifier (Soiltac® or equivalent)” when discussing stabilization of stockpiled soil/sediments or dust control measures. A MSDS has been included in Attachment 9.

Comment 24. The integrity of the cover system is dependent upon the cover system profile and the ability of the cover components to work together; however, Section 3.6 (Access Roads) of Attachment 11 (Post- Closure Operations, Maintenance, and Monitoring Plan) states that inspection and repair of the access roads is not critical to the integrity of the cover system. However, the potential exists for standing water to accumulate in access road ruts resulting in an increased potential for surface water to infiltrate the cap. Alternatively, the access road could allow surface water runoff to transverse the cap surface at greater flow rates potentially inducing a higher scour threat along roadways. Please revise the Draft RD/RA WP to clarify how the condition of the access roads is not critical to the integrity of the cover system, especially since it appears that the roadway will be treated as a part of the cap.

Response 24. Access roads will be easier to maintain than the remainder of the cover as they will be the easiest to inspect and the easiest to repair. That being said it is an important part of the cover system and Section 3.6 of Attachment 11 has been revised to indicate that access roads will be maintained.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 25. Appendix A of the Sampling and Analysis Plan (SAP) in Attachment 4 of the Draft RD/RA WP indicates that laboratory specific standard operating procedures (SOPs) will be provided in the Final SAP, but laboratory SOPs should be submitted for regulatory review and approval prior to finalizing the SAP so that the adequacy of the information contained in the SOPs can be assessed. For example review of the laboratory SOPs is necessary to evaluate the information presented in the SAP Worksheet 19. During the June 2012 BCT meeting, in order to address the same concern that has been raised for every SAP, the Navy has agreed to add clarification language to current and future SAPs that the laboratory will meet the EPA’s analytical methods or the Navy’s SAP, whichever is more stringent. Please add this clarification language to the SAP. Laboratory SOPs should be submitted once every two years for each analytical method for each laboratory being used at Alameda for regulatory review and approval. This submittal would be sufficient so that the Navy does not have to submit the SOPs for each SAP.

Response 25. The following has been added to Worksheet #19 under the notes section:

The laboratory will meet the analytical requirements in the EPA methods listed above or the requirements in this SAP, whichever is more stringent.

The laboratory SOPs for this SAP will be submitted to the agencies along with the Draft Final RD/RA WP.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 26. The objectives listed in the Executive Summary of the SAP are not consistent with the scope of work presented in Section 1.2 of the Draft RD/RA WP. Section 1.2 of the Draft RD/RA WP indicates that soil samples will be collected from the subgrade surface for radiological dose and risk modeling and a radiological surface scan will be performed on the finished cover to document effectiveness of the remedy. The objectives in the SAP indicate that the radiological survey of the cover will be used to establish final risk and dose estimates and does not mention the collection of samples for radiological testing. Please revise the Draft RD/RA WP to resolve this discrepancy.

Response 26. Two bullets in the Objectives section of the Executive Summary of the SAP have been added stating the following:

  • Collecting of soil samples from the subgrade surface for radiological dose and risk modeling
  • Providing modeling, based on analysis of soil samples collected from the subgrade surface, to demonstrate that, with the 2-foot cover installed, the maximum annual dose to an individual of 15 mrem, and the excess lifetime cancer risk (ELCR) at 3 × 10-4 for the critical group, are not exceeded

Additionally, the final bullet has been changed to:

Performing a final radiological survey of the cover to document effectiveness of the remedy

Comment 27. The items and questions listed on pages 14 and 15 of the Workbook for Unified Federal Programs for Quality Assurance Project Plans (UFP-QAPP Workbook) are not addressed in these worksheets.

Please revise Worksheets 10 and #11 to address each of the items and questions listed on pages 14 and 15 of the UFP-QAPP Workbook.

Response 27. The information provided in Worksheets #10 and 11 are meant to be used in conjunction with each other according to the NAVFAC SW SAP template. The “If…, then…” statements are provided in Worksheet #11. However, Worksheet #11 has been revised to include answers to questions in the UFP-QAPP workbook that were not addressed.

Comment 28. The SAP does not discuss manual integrations for chromatographic analyses. If manual integration is required, please ensure that supporting information for manual integrations (i.e., chromatograms before and after manual integration as well as a brief explanation for the manual integration) will be included in the data package deliverables and evaluated during data validation.

Response 28. SAP Worksheet #29 has been revised to clarify that if manual integration is required, supporting information for all manual integrations (i.e., chromatograms before and after manual integration as well as a brief explanation for the manual integration) will be included in the data package deliverables and evaluated during data validation.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 29. There are several analytes for which a project action limit (PAL) has not been established. It is unclear how results for analytes without defined PALs will be assessed. For example, the table for alpha spectroscopy in soil in Worksheet #15.1 does not provide a PAL for any of the analytes listed except for Uranium-238. Please revise the SAP to define PALs for all analytes, or alternatively, discuss how these analytes will be assessed.

Response 29. Chemical analytes in SAP Worksheet #15.1 that have “Not Established” for the Project Action Limits (PALs) will be reported along with the analytes that have non-hazardous criteria or ROD criteria and this will be sufficient for evaluating analytical results to determine 1) if material is suitable for use as subgrade or cover material or 2) waste classification prior to disposal. The laboratory results will be provided to the regulatory agencies as soon as they are available.

The chemical analytes in Worksheet #15.2 that have “Not Established” for the PAL have been deleted and the analytes that remain have STLC or TCLP CCR Title 22 criteria listed which will be sufficient for determining waste classification of material prior to disposal. If a compound with no PAL is reported, the data will be evaluated to determine if additional screening is warranted. The Table in Worksheet 15.1 will have a footnote to that effect.

As Uranium-238 is the only radionuclide of concern listed for alpha spectroscopy, all other analytes have been deleted from the alpha spectroscopy table in SAP Worksheets #15.1 and 15.2. In addition, the following has been added to SAP Worksheet #17: Uranium-238 is the only analyte of interest to be analyzed by alpha spectroscopy, because all other radionuclides of concern are easily quantified through gamma spectroscopy.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 30. The SAP does not provide copies of the data validation checklists. Since the SAP references multiple sources for data validation procedures in Worksheet #36, a checklist describing the criteria that will be used to evaluate the quality control (QC) measures, how samples will be qualified (e.g., the qualifiers that will be used, when samples will be qualified as estimated/rejected, and if individual or all samples in a batch will be qualified) should be provided. Please revise the SAP to provide data validation checklists.

Response 30. SAP Worksheet #36 has been revised to include a reference to the data validation checklists for each method that will be provided as Appendix C and that all samples in a batch will be qualified based on the checklists. In addition the following text has been added after the reference to Appendix C in Worksheet #36:

In addition to the checklists in Appendix C, the following criteria will be evaluated by the validator and flagged as indicated:

  • Manual integration will be evaluated during data validation for the organic methods (i.e., volatiles, semivolatiles, pesticides, PCBs and herbicides). If the manual integration is not  calculated appropriately, the validator will flag the associated results  with a “J” for estimated.
  • Second column confirmations for pesticides and herbicides analyses and DDT/Endrin breakdown for pesticides will be evaluated during data validation. If results between primary and second column confirmations have an RPD ≥ 40%, the associated results will be flagged with a “J” for estimated. If the DDT/Endrin breakdown is ≥ 15%, the associated results will be flagged with a “J” for estimated.
  • For radiological methods, if the calibration criteria listed in SAP Worksheet #24 is not met, the associated results will be flagged with a “J” for estimated.

Comment 31. The SAP does not indicate that EPA will be notified of any significant corrective action or changes to the SAP, or provide the timing for notification. Please revise the SAP to provide this information as well as the method of communication that will be used to notify EPA.

Response 31. SAP Worksheets #6 and 32 have been revised to include that the Navy will communicate with the EPA regarding corrective actions or significant changes and a timeframe has been provided for this notification in SAP Worksheet #32.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 32. The SAP discusses document control procedures but does not provide sufficient detail regarding the management of all project files. It is unclear where field documents, such as logbooks, surveillance reports, and change requests will be stored (i.e., address), who will manage them, how long they will be stored, and that the records will be offered to the Navy prior to disposal. Please revise the SAP to provide this information.

Response 32. Worksheet #29 has been revised to include the following:

Project files are maintained at the project site under the oversight of the PQCM until completion of the project. Files are then sent to the TtEC San Diego for storage. Once the CTO is complete and closed out, the files are sent to an off-site archive for 10 years.

Comment 33. The SAP discusses background levels of radiological analyses but does not provide sufficient detail indicating how background levels will be determined. For example, step five in Worksheet #11 indicates that if the initial gamma survey identifies areas greater than twice background, then each of these areas will be excavated. No further information is provided for how background will be determined.

Additionally, the notes for the tables located in Worksheet #15.2 indicate that background levels are used to determine project quantitation limits and minimum detectable activities for radiological analyses. Please revise the SAP to discuss background levels and their sources for radiological analyses.

Response 33. Background levels will be determined by conducting gamma scan surveys of a reference area approximately 1,000 square meters, as agreed upon by the project team. The mean of all readings for the respective survey instrument (Vehicle Towed Array or Ludlum 2350-1 survey meter with 44-10 2” by 2” NaI detector) will be used to calculate the mean reference area gamma background rate. Verbiage describing this process has been added to the first paragraph in Step 7 of Worksheet #11 of the SAP.

Background levels from footnote a) in both Worksheet #15.1 and 15.2 refer to instrument background radiation in the area of the detectors.  This background value is distinct from the reference area background and is unique to the radioanalytical laboratory radiological background resulting from naturally occurring radioactive materials that are inherent in the laboratory. Footnote a) in Worksheets #15.1 and 15.2 has been changed to refer to “instrument” background.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 34. The SAP does not provide all of the QC samples and criteria as detailed in Section 3.4.2 of the Uniform Federal Policy for QAPPs Manual, dated March 2005 (UFP QAPP Manual). Examples include:

-          Internal standards should be included for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and polycyclic aromatic hydrocarbons (PAHs).

-          Dichlorodiphenyltrichloroethane (DDT)/Endrin breakdown check and second column confirmation for pesticides.

Please revise the SAP to include all of the required QC samples.

Response 34. Worksheets 28.1 and 28.2 have been revised to include applicable laboratory QC samples and criteria.

Comment 35. During the review of this Draft RD/RA WP, the public has identified issues about the installation of permanent fencing. The Draft RD/RA WP states, “At the completion of all work activities, a permanent 6-ft high chain-linked fence with three strands of barbed wire will be placed on the eastern and northern boundary of the IR Site 2.” Although fencing is an important element for the protection of the landfill soil cover and associated components (e.g., monitoring wells, settlement monuments, landfill gas probes), other alternatives could also serve similar purpose in lieu of proposed chain-link fence (topped with three strands of barbed wire) around the property boundary which would be consistent with its indented use as open space/refuge. Protection of human health and the environment is the primary goal of CERCLA actions; however, we request that other alternatives should be evaluated to address public concerns regarding the appearance of the landfill.

Response 35. See Response to DTSC General Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 36. Similar public concerns have also been raised regarding the visual impact of the proposed height and number of vertical gas venting pipes. The number of vertical gas venting pipes could be reduced through the use of horizontal wells, which are capable of redirecting/conveying landfill gas to larger vertical venting pipes. An evaluation of the current landfill gas conditions should be completed prior to finalizing the passive landfill gas system. Again, we request the Navy look into other alternatives so public concerns can be addressed.

Response 36. The existing methane venting system was constructed to comply with California Air Quality Management District requirements for protection of human health and the environment. Design and construction of a different replacement system is cost prohibitive. The existing system will be left in place to the maximum extent possible. If vent risers or other venting system components are required to be removed during cover construction, the components will be replaced. Then after cover construction, as a part of Operations and Maintenance, methane monitoring will be performed to determine the minimum venting system required, which may reduce the number and height of vents. Visual impacts will also be reduced to the extent possible by using materials and colors that blend with vegetation and landscape.

SPECIFIC COMMENT

RESPONSE

Comment 1. Section 2.2.2 Ordnance Explosives Waste Investigation, Page 2-7: This section notes that a “20 millimeter (mm) target practice projectile” was found during the surface characterization. It then notes that, “the 20mm round was subsequently demilitarized…”  As a projectile is a component of a round, and a round is all of the components necessary to fire the associated weapon once (i.e., projectile, cartridge case, propellant, primer, and fuze), the two items noted appear to be different munitions.  Please review the cited verbiage and determine if the term “round” is being used incorrectly to refer to a projectile. If that is the case, please correct the term “round” to read “projectile.”

Response 1. The word “round” was cited in error and has been replaced with the word “projectile” in Section 2.2.2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 2. Section 5.1.1, Field Support Facilities, Page 5-1: The location where potable water will be acquired is not specified. The text states that, “Potable water will be acquired from a nearby water hydrant,” but the location is not described or shown on a figure. Please revise Section 5.1.1 to specify the location and distance from IR Site 2 where potable water will be acquired and provide a figure with the location of the hydrant.

Response 2. Water for site construction activities will be provided by running a temporary pipeline from a water hydrant located to the southeast of IR Site 2. Drinking water will be supplied by a water service. Section 5.1.1 has been revised to discuss the location of the hydrant.

Comment 3. Section 5.3, Utility Location, Page 5-2: The criteria that will be utilized to determine a geophysical utility survey is necessary to confirm the depths and location of utilities is not provided. It is unlikely that Underground Service Alert of Northern California has much information about the Site 2 subsurface utilities. Further, since subsurface utilities have been identified in the vicinity of the former ammunition bunkers, it appears a geophysical utility survey will be necessary. Please revise the Draft RD/RA WP to require a geophysical utility survey or to clarify the criteria that will be utilized to determine that a survey is necessary to confirm the depths and location of utilities.

Response 3. Geophysical utility surveys have been conducted in association with the numerous historic site investigations at the site and that data, along with generator’s knowledge, confirm the area free of energized utilities.

Underground Service Alert of Northern California have been notified regarding fieldwork by TtEC in 2002, 2004, and 2007 and for each notification they have confirmed that there are no municipal services in the area. Additionally, the Caretaker Site Office for Alameda has also confirmed that there are no energized Navy utilities in the area. Aboveground vaults and exposed conduits in the area have been investigated in the past and confirm the lack of energized systems. Although historic geophysical investigations by others may have identified lineaments suspected to be utility lines, these likely represent abandoned utility conduits. TtEC will not perform additional geophysical surveys prior to excavations based on historic findings and the fact that the site is a former landfill area and abundant documentation exists indicating the site contains metal debris that interferes with geophysical surveys.

There are known aboveground and subsurface stormwater conveyance channels in the area that have been identified by past surveys. These systems will be protected and maintained during the construction period.

Section 5.3 has been revised to reflect this response.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 4. Section 5.5.1, Soil Gas and Groundwater Monitoring Well Destruction, Page 5-3: To maintain data continuity, monitoring wells M-024A and M-024E should be retained. Replacement wells rarely provide the same data as the original wells. Also, the text and project schedule do not state when the existing wells will be destroyed or how long it will be before groundwater samples can be collected in replacement wells (i.e., when stabilization occurs after well development). Please revise the Draft RD/RA WP to require preservation of monitoring wells M-024A and M-024E. In addition, please specify the timeframe between destruction of the other wells and the time samples could be collected.

Response 4. The RAWP has been revised to include preservation of all existing monitoring wells pending potential changes based on the results of the Groundwater Monitoring Evaluation (GME). Any changes to the existing groundwater monitoring network will be identified in the Remedial Design Addendum which will include the GME and associated recommendations. The first sampling event post-cover construction is anticipated to be in January 2014.

Comment 5. Section 5.6.4, Barge Delivery and Stockpile of Soils, Page 5-5: The text does not indicate that soil and rock material imported from off-base will be tested for geotechnical properties and compared with the design specifications to confirm suitability as fill. As such, it is unclear if the materials are appropriate for use. Please revise Section

5.6.4 to provide and/or reference the design specifications that the fill material will meet to show that the materials are appropriate for this use.

Response 5. Section 5.6.4 will be revised to indicate moisture density (ASTM D 1557), sieve analyses (ASTM D 1140), Atterberg limits (ASTM D 4318), and soil classification (ASTM D2487) will be performed daily or for every 8,000 cubic yards for the first week, and weekly or every 40,000 cubic yards after the first 5 consecutive passing tests (except for continuous Visual Inspection per ASTM D 2488) thereafter per Article 3.11 of Specification Section 31 00 00. Visual inspection will be conducted continuously.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 6.  Section 5.6.5, Reuse of Material from Previous Alameda Projects, Page 5-6: The text states that fill material from previous Alameda projects will be available for use and will be tested for geotechnical properties and compared with the design specifications to confirm suitability as fill; however, design specifications for fill materials are not provided or referenced. Without a comparison of geotechnical properties, it is unclear if the reuse of material from previous Alameda projects is appropriate, especially given the magnitude of the slope stability concerns.  Please revise Section 5.6.5 to provide and/or reference the design specifications for the fill material and provide a comparison of the fill materials to show that the materials are appropriate for use and consistent with the material properties of the layers evaluated during the slope stability analysis.

Response 6. Section 5.6.5 will be revised to reference Article 3.11 of Specification Section 31 00 00 in the RD. All fill material will undergo testing to determine the suitability for use at the site. Material from previous Alameda or other projects will be compared to this specification.

Comment 7. Section 5.6.6, General Site Grading and Multilayer Soil Cover Construction, Page 5-6: The second paragraph indicates that grading in the ammunition bunker area will occur around the structures without any modifications being made to the structures themselves; however, it is unclear if the grading and compacting in the vicinity of the structures will have any structural impact. As such, it is unclear if any reinforcement measures should be made prior to grading and compacting in the vicinity of the structures. Please revise Section 5.6.6 to clarify that an assessment will be made to determine whether any structural reinforcement measures will be necessary prior to grading and compacting in the vicinity of the structures.

Response 7. Section 5.6.6 has been revised to state that the structural integrity of the structures in the ammunition bunker area will be assessed prior to commencing site grading in that area.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 8. Section 5.6.6.4, Vegetative Layer, Page 5-8: The text states that the vegetative layer will be protected from erosion by hydroseeding the surface with native vegetation and indicates that the hydroseed mixture will be applied during the rainy season; however, the rainy season is not formally defined. As such, it is unclear when the hydroseed mixture will be applied. Further, it is unclear what temporary erosion measures will be implemented should the vegetative layer be completed prior to the rainy season. Please revise Section 5.6.6.4 to clearly define the rainy season and clarify how the vegetative cover will be protected from erosion should the cap construction be completed during the dry season (i.e. before the vegetation has been established).

Response 8. Rainy season is generally November through April. Based on the schedule, hydroseeding will occur during rainy season. Erosion mats or other appropriate controls will be used as necessary. In addition erosion damage, if it occurs, will be monitored and repaired as part of O&M. Section

5.6.6.4 will be revised to add text as such.

Comment 9. Section 5.8.2 Installation of Groundwater Monitoring Wells and Landfill Gas Monitoring Probes, Page 5-11 and Figure 5- 2, Groundwater and Soil Gas Monitoring Wells Proposed for Destruction: The locations of replacement wells for M-037A, M-37E, and M-039A have not been provided. The locations of these replacement wells should be optimized to monitor for potential discharges to the wetlands. Please provide a figure that depicts proposed optimized locations for these wells.

Response 9. The RAWP has been revised to include preservation of all existing monitoring wells pending potential changes based on the results of the Groundwater Monitoring Evaluation (GME). Any changes to the existing groundwater monitoring network will be identified in the Remedial Design Addendum which will include the GME and associated recommendations.

Figure 5-2 has been updated to show the existing monitoring well network.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 10. Section 5.11.2, Site Inspection, Page 5-12: The Regulatory Agencies should be invited to attend the site inspection. Please revise the text to include the Regulatory Agencies in the Site Inspection.

Response 10. The text has been revised to include regulatory agency participation.

Comment 11. Section 6.4, Water Conservation, Page 6-2: Although the source moisture conditioning (i.e., at the quarry that will provide backfill materials), moisture will be lost if soil is stockpiled on site prior to use. “Just-in-time delivery” to minimize the number of stockpiles and the time they are on site should be attempted. Please revise the text to explain how stockpiling can be minimized.

Response 11. Section 6.4 has been revised to add that stockpiling will be minimized by matching delivery rates with production rates to the extent practicable.

Comment 12. Attachment 1, Drawing C-4, Subgrade Plan - Northwest: Drawing C-4 indicates that the ammunition bunker door will be welded shut; however, details regarding this action are not included elsewhere in the Draft RD/RA WP. As such, it is unclear when and how the door will be welded. Please revise the Draft RD/RA WP to include details and specifications to accomplish the welding of the ammunition bunker door.

Response 12. Section 5.5 of the RAWP has been revised to include tack welding of the bunker doors. Tack welding will be one or two spot welds to provide security without fencing until the VA chooses to use the bunkers.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 13. Attachment 1, Draft Geotechnical Report, Section 8.1, Liquefaction Induced Settlements, Page 25: The text appears to be inconsistent with the Tetra Tech Foster Wheeler (TT FW) Report and may not accurately predict the settlement potential. Section 8.1 states that, “The KCH report predicts liquefaction induced settlements of generally less than 4 inches, with the exception of the southern coastal margin and the center of the landfill where 10 to 12 inches of liquefaction induced settlements are predicted, respectively.” However, the TT FW report indicates that transverse cracks up to 4 inches wide and 3 to 4.5 feet deep were reported as a result of liquefaction during the 1989 Loma Prieta earthquake. Therefore, it is unclear if the predicted liquefaction induced settlements accurately predict the settlement potential given the wide variation between calculated and actually documented liquefaction induced settlements. Please revise the Draft RD/RA WP to clarify how the predicted liquefaction induced settlements are appropriate given their wide variation from actual recorded liquefaction induced settlements, ensuring that the Draft RD/RA WP documents and supports any site- specific conditions which changed as a result of the 1989 Loma Prieta earthquake so as to limit the anticipated settlement.

Response 13. The Geotechnical Report has been revised and reviewed subsequent to these comments. Please see Attachment 14 for Response to Comments on the latest version of the Geotechnical Report.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 14.  Attachment 1, Draft Geotechnical Report, Section 10.1, Summary of Results, Page 27: The text states that, “The proposed final cover includes a geonet as a biotic barrier, which effectively acts as soil reinforcement. The surficial manifestation of liquefaction will be therefore somewhat reduced;” however, information to support this statement is not provided and/or referenced. Thus, it is unclear how effective the geonet will be for reducing surficial manifestation of liquefaction. Further, specifications for the geonet to show the material’s property capabilities are not provided. Also, it is unclear how the geonet will be tied into soil at the base of slopes surrounding the landfill and whether liquefaction could extrude materials beneath the edge of the geonet. Please revise the Draft RD/RA WP to provide and/or reference information to substantiate that geonet will be effective at reducing surficial manifestation of liquefaction.  In addition, please revise the Draft RD/RA WP to include specifications for the geonet and calculations to show the material will be effective as soil reinforcement. Also, please clarify how the geonet will be tied into soil at the base of slopes surrounding the landfill and whether liquefaction could result in extrusion of soil beneath the edge/bottom of the geonet.

Response 14. The geonet is intended to function as a biotic layer. Any other benefits incidental to use of a geonet as a biotic layer described in the report were not considered in the design analysis. The geonet biotic layer is not intended to provide soil reinforcement, as such, they have not been evaluated for performance in a liquefaction scenario.

Specifications for the geonet have been prepared, but do not include any parameters for soil reinforcement, as this was not part of the selection criteria for the geonet layer.

The geonet is a component of the multilayer soil cover and its sole function is an anti-burrowing barrier. As such the geonets lateral limits coincide with the lateral limits of the soil cover which typically do not extend to the toe of the perimeter berm slopes. The geonet has no function to mitigate or control the effects of liquefaction.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 15. Attachment 2, Section 5.4, Air Monitoring, Page 5-3: The text states that 10% of the DAC values for Thorium 232 (Th-232) and Strontium 90 (Sr-90) will be used to determine whether the area is no longer safe to work in, but does not specify the air volume that must be collected. While Table 5-1, Derived Air Concentration, has been provided, neither the text nor the table state how much air volume will need to be collected to correspond to achievable detection limits for identifying the 10% DAC limit for these radionuclides.  The amount of air volume required will affect how long the air sampler must run before a sample can be counted. This information is important in identifying the length of time a worker may be exposed to unacceptable air concentrations before the radiological hazard is identified. Please revise Section 5.4 to provide this information.

Response 15. Section 5.4 has been revised to reflect that a minimum volume of 1.4 × 108 milliliters must be collected to ensure the 10% DAC value for Th-232 is met.

Comment 16. Attachment 2, Section 5.5, Bioassays, Pages 5-3, 5-4: The text states that in the unlikely event that the results of air monitoring suggest an intake of radiological contamination has occurred, bioassay measurements will be collected as necessary to determine the potential dose to the affected personnel, but procedures should be in place to address this situation should it arise. Text in this section does not state what contingency plan or procedures are in place in such an event. This would include information pertaining to what lab the samples will be sent to, who will be responsible to ensure the proper bioassay samples are collected, how the data will be reported, and others. Please revise this section to reference the SOP or contingency plan that will guide actions in the event of an internal exposure or to state how the program will be administered through an outside vendor.

Response 16. NRC regulation 10CFR20.1502 does not require internal monitoring unless (at a minimum for minors or declared pregnant workers) an individual is likely to receive an annual committed effective dose equivalent of 0.1 rem (which is equivalent to 40 DAC-hrs). For other radiation workers, this limit is 10% of the ALI (which is equivalent to 200 DAC-hrs). As continuous air monitoring will be provided, internal monitoring is not required, and since previous TCRA work did not indicate elevated airborne concentrations of radionuclides, the need for bioassay is highly unlikely. As such, committing to a bioassay provider and detailed bioassay procedure is unnecessary.  However, the RSO will ensure the proper dosimetry samples are collected, and the data reported for required individual personal dosimetry reports.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 17.  Attachment 2, Section 6.3, Initial MARSSIM Survey of Subgrade Prior to Installation of Cover, Page 6-2: The criteria for final cover installation are not specified in this section. The text states that subgrade areas will be surveyed with a sodium iodide scintillation detector and areas that exceed twice the background during the survey will be remediated to a depth of 1 foot. The text subsequently states that once the gamma surveys and any remediation are performed, a number of samples will be collected so as to perform a baseline dose and risk assessment using the RESRAD model prior to installation of the cover.

However, it is unclear what dose or risk level will be considered acceptable for proceeding with the installation of the cover. This should be based on a risk of 1x10-6. Please revise this section to state what acceptance criteria for ceasing soil removal and installing the final cover have been established.

Response 17. The remedial goal is to remove radioactive anomalies greater than twice background within the first 12 inches of the surface and to demonstrate that, with the 2-foot cover installed, the maximum annual dose to an individual of 15 mrem, and the excess lifetime cancer risk (ELCR) at

3 × 10-4 for the critical group, are not exceeded. No subgrade surface release criteria or remedial goals are specified. Note that the intent of the 2-foot cover design was to adequately shield and contain radionuclides of concern such that the cover surface remediation goals are met regardless of the concentrations of the radionuclides of concern beneath the cover.

Comment 18. Attachment 2, Section 6.5, Final MARSSIM Survey of the Cover, Page 6-3, and Table 2-1 (Release Criteria): The text states that the cover material will meet the release criteria in Table 2-1. Table 2-1 lists the release criteria for Ra-226 as 1.0 pCi/g, with a footnote indicating that the remediation goal is 1 pCi/g above background.

However, neither the text in Section 6.5 nor Table 2-1 provides the background concentration of Ra-226 in pCi/g. This information will be required in the final reporting of the data so that quantitative value from the laboratory (as total Ra-226) can be evaluated to determine if the 1 pCi/g above background criteria has been met.

Response 18. A reference area and background concentration for Ra-226 based on gamma spectroscopy analysis (EPA Method 901.1M) of soil samples collected from the reference area will be established when the work plan has been approved. This information will be provided in the final reporting of the data to demonstrate that the quantitative value for the cover material from the laboratory (as total Ra-226) is less than 1 pCi/g above background concentrations.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 19. Attachment 4, Worksheet #3, Distribution List, Pages 17 to 19: This worksheet is missing key personnel including the TtEC field crew and Ms. Sabina Sudoko, TtEC Project Chemist. Since these roles involve responsibilities related to adherence with the SAP, they should be included in the distribution list. Please revise Worksheet #3 to include these key personnel.

Response 19. SAP Worksheet #3 has been revised to include the Project Chemist. A footnote has been added to SAP Worksheet #3 that states:

The PQCM, Vincent Richards, who is listed above, will have multiple copies of the final SAP on-site for field crews to reference while sampling.

Comment 20. Attachment 4, Worksheet #11, Step 5, Develop the Analytic Approach, Pages 44 and 45: Under step 5c, the calculated total excess lifetime cancer risk (i.e., from all constituents, not just radionuclides) should not exceed 1x10-4 as EPA is moving away from a dose-based approach to a risk-based approach. Please revise the text to specify that the calculated total risk should not exceed 1x10-4.

Response 20. The calculated total risk of 3 × 10-4 as listed in the SAP is based on recommendations from OSWER 9200.4-18, “Establishment of Clean Up Levels for CERCLA Sites with Radioactive Contamination” from August 22, 1997. This calculated total risk value limit has been accepted for recent radiological remediations of Navy properties. As such, no change to the SAP will be made.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 21. Attachment 4, Worksheet #11, Step 7, Develop the Plan for Obtaining Data, Pages 45 and 46 and Worksheet #17, Sampling Design and Rationale, Page 96: The SAP does not explain why 10 samples are sufficient for a survey unit or define the survey unit size (in square feet); this information should be provided under Worksheet #11, Step 7 and in Worksheet #17. Further, it is unclear whether 10 samples is sufficient under MARSSIM. Also, Step 7 and Worksheet #17 do not explain why 2 samples per 40 cubic yards is sufficient after excavation has been done or if this was based on MARSSIM calculations. Finally, the basis for 10 backfill samples per source has not been provided. Please revise Worksheet #11, Step 7 and Worksheet #17 to explain why 10 samples per survey unit, 2 samples per 40 cubic yards of excavated soil and 10 backfill samples per source are sufficient, including whether these sample numbers were based on MARSSIM calculations. Also, please provide the survey unit size in square feet.

Response 21. Information regarding the survey unit size of a maximum of 2000 square meters or 21,780 square feet and number of samples collected per survey unit is described in the RWP (Attachment 2), specifically in Section 8. As such, this information need not be included in the SAP. The basis for the collection of 10 samples in the survey unit and the reference area is from using MARSSIM calculations for a statistically significant number of samples for free releasing a Class 1 survey unit, despite the fact that these are not free release surveys and is therefore conservative. Also, conservative assumptions about the radionuclide of concern median values and standard deviations were used in the calculation of sample numbers. Note that the number of samples to be collected will be re-calculated based upon actual radionuclide of concern medial values and standard deviations from soil samples collected in the selected reference area. As 10 samples per survey unit were calculated for each survey unit and the reference area, 10 backfill soil samples were deemed appropriate. Although not based on a MARSSIM calculation, the 2 samples per 40 cubic yard sampling of soil excavated as the result of exceeding twice the background level, and subsequent to an additional survey in 6-inch lifts has been standard practice for previous Navy radiological survey and removal actions. (Note that this is approximately 1 sample per 100 square meters.) No changes were made to the SAP based on this response.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 22. Attachment 4, Worksheet #11, Step 7, Develop the Plan for Obtaining Data, Page 46: There is an apparent contradiction between the requirements described in the first and second paragraphs on page 46. The first paragraph states that 1 of 10 samples will be analyzed for total strontium and/or Sr-90, but the second paragraph states that samples that exceed the release criterion for Cesium-137 (Cs-137) will be analyzed for total strontium and/or Sr-90. The first paragraph does not appear to require analysis for Cs-137 and it is unclear if the analysis for total strontium and/or Sr-90 will be done for 1 of every 10 samples, if it will be done for additional samples if the release criterion for Cs-137 is exceeded, or if it will only be done for samples when the release criterion for Cs-137 is exceeded.  Please revise the text to clarify when analyses for total strontium and/or Sr-90 will be done. In addition, please include Cs-137 in the discussion about the 10 samples that will be collected per survey unit.

Response 22. Paragraphs 3, 4, and 5 in Step 7 on SAP Worksheet #11 were deleted and replaced with the following: Details on collection and analysis of samples are in SAP Worksheet #14.

Comment 23. Attachment 4, Worksheet #13, Secondary Data Criteria and Limitations Table, Page 49: Worksheet #13 states that no secondary data for this project will be used; however, the Work Plan references other documents for previous site work that appear to be relevant to the current investigation. Additionally, Worksheet #11 indicates that previous chemical and radiological analytical results for soil stockpiles that may be used for fill material will be reviewed against criteria in this SAP. Please revise Worksheet #13 to include all secondary data that will be used for decision making for this project.

Response 23. Worksheet #13 has been revised to included references to previous documents that are relevant to the current investigation.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 24. Attachment 4, Worksheet #14, Summary of Project Tasks, Page 51: The second paragraph states that “Radiological control technicians (RCTs) will periodically scan the cut areas,” but it is unclear what criteria will be used to determine when these scans are necessary. For example, scans could be done once a day, once a week, once a month, when a 6-inch lift is excavated, when a 12-inch lift is excavated, randomly, etc. Specific criteria to determine when these scans will be done are necessary. Please revise Worksheet #14 and any other text discussing the periodic scans of cut areas to provide specific criteria that will be used to determine when the scans are necessary.

Response 24. The third sentence in the second paragraph under the Building Up to Subgrade section of Worksheet #14 in the SAP has been revised as follows:

Radiological Control Technicians (RCTs) will periodically scan the cut areas on a frequency based on the professional judgment of the RSOR taking into consideration the previous survey results, accessibility of the affected areas, and soil movement in the area. At a minimum, the affected area will be surveyed each time a lift is excavated, a new surface area is exposed, or when personnel entry is required into the affected area.

These radiological scans will be performed for health and safety reasons during soil moving operations to ensure that radiological contaminants are not disturbed. The radiological scans will be documented in the field and in the remedial action completion report if a radiological scan identifies an area greater than twice background using a Ludlum 2350 meter with a Ludlum 44- 10 NaI detector or equivalent.

Establishing a firm periodicity for all radiological surveys is not recommended, as each “cut area” may present varying degrees of radiation safety hazards.

Comment 25. Attachment 4, Worksheet #14, Summary of Project Tasks, Pages 52 and 53: The numbered soil sampling procedures do not specify the sampling equipment that will be used to collect the samples so it is unclear if disposable equipment (e.g., scoops or trowels) or equipment that requires decontamination between samples will be used. The sampling equipment is specified in the procedures for fill material sampling. Please revise the soil sampling procedures to specify the sampling equipment that will be used to collect the samples, including whether decontamination will be necessary.

Response 25. The numbered soil sampling procedures have been revised in Worksheet #14 to include the following:

A disposal scoop or equivalent may be used to fill the containers.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 26. Attachment 4, Worksheet #14, Summary of Project Tasks, Page 55: The SAP does not discuss how qualifiers uploaded to the database will be verified. Please revise the SAP to discuss how data qualifiers will be verified in the database.

Response 26. Worksheet #14 under Data Management Tasks has been revised as follows:

After receipt of the validated data, the validation qualifiers will be uploaded into the TtEC database and will be checked against the hardcopy validation report for accuracy.

Comment 27. Attachment 4, Worksheet #15.1, Reference Limits and Evaluation Table for Soil Samples, Page 71: Footnotes “e” and “f” provide conflicting information and need further clarification. Footnote “e” states that if a result exceeds the PAL, the toxicity characteristic leaching procedure (TCLP) must be performed. Footnote “f” states that if a result exceeds the PAL, the waste will be considered “non-RCRA hazardous” and sent off-site for disposal; if the results do not exceed the PAL, the results will be evaluated to determine if soluble threshold limit concentration (STLC)/TCLP testing is required. It is unclear why samples with results exceeding PALs are considered “non-RCRA hazardous” according to footnote “f”, or if these samples will be shipped to a hazardous waste disposal facility. If the results do not exceed the PAL, it is unclear why STLC/TCLP analyses need to be considered.

Further, it is unclear if both tests will be performed. Finally, for both footnotes, it is unclear how the PALs were established. Please revise Worksheet #15.1 to clarify how the PALs were established and provide the decision criteria for sending the material to a hazardous waste facility for disposal or performing STLC and/or TCLP testing.

Response 27. TCLP criteria is used to classify waste as RCRA hazardous. STLC criteria is used to classify waste as non-RCRA (or state of California) hazardous. According to the regulations, some analytes only have TCLP criteria and no STLC criteria and some analytes have both TCLP and STLC criteria. Footnote e) lists a PAL for analytes that only have TCLP criteria.

Hence, if that PAL is exceeded, then TCLP analysis will be performed to determine if the waste is RCRA hazardous. If the PAL is not exceeded, the rest of the analytical data must be evaluated against the information listed in footnote f) before proceeding to use material as backfill. Footnote d) has been revised as follows to clarify this:

Limit listed is the value at which if exceeded then TCLP analysis must be performed. TCLP results will then be evaluated against CCR Title 22 criteria. If the TCLP results are below the CCR Title 22 criteria, then the material may be suitable for backfill pending evaluation of the rest of the analytical data against criteria in footnote f below. Otherwise, the material will be disposed of off-site.

The PAL values listed in conjunction with footnote f) are the Total Threshold Limit Concentrations (TTLC) that if exceeded the material is automatically considered non-RCRA hazardous but will need to be further evaluated for TCLP analysis. If the TTLC values are not exceeded, then the data will be evaluated for further STLC or TCLP analysis as required. Footnote g) has been revised as follows to clarify this:

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

 

Limit listed is the Total Threshold Limit Concentration value at which if exceeded the material is automatically considered non-RCRA hazardous and will be evaluated for TCLP analysis. If the value is not exceeded, results will then be evaluated to determine if STLC/TCLP analysis is required in accordance with CCR Title 22. If STLC/TCLP analysis is required, those results will be evaluated against criteria in CCR Title 22. If the STLC/TCLP results are below the CCR Title 22 criteria, then the material may be suitable for backfill pending evaluation of the rest of the analytical data against criteria in footnote e above. Otherwise, the material will be disposed of off- site.

Comment 28. Attachment 4, Worksheet #15.2, Reference Limits and Evaluation Table for Water Samples, Page 92: It is unclear what regulatory limits for hazardous waste criteria will be used to assess results from wastewater samples (i.e., federal, state, etc.). Further, these limits should be listed in the SAP to ensure that the laboratory limits are less than, or equal to, the regulatory limits. Please revise Worksheet #15.2 to provide numerical PALs and indicate the specific source of these values.

Response 28. Project action limits and their reference have been added to SAP Worksheet #15.2 for analytes that have STLC or TCLP CCR Title 22 criteria. Chemical analytes that do not have criteria have been deleted from Worksheet #15.2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 29. Worksheet #17, Sampling Design and Rationale, Pages 95 and 96: Worksheet #17 should provide the sampling design and rationale for the number of samples and analyses (e.g., why the specified number of samples of each type is sufficient, how sample locations will be chosen, etc.), but this information is not provided. In addition, the text under the subsections titled “Building Up to Subgrade” and “Initial MARSSIM Survey of Subgrade Prior to Installation of Cover,” is unnecessary and repeats the text provided in Worksheet #14. Further, Worksheet #17 is missing a table that lists each type of sample, the number of samples that will be collected, and the required analyses.

Required QC samples should be included in this table. Please delete the text under the subsections titled “Building Up to Subgrade” and “Initial MARSSIM Survey of Subgrade Prior to Installation of Cover” and revise the Worksheet to provide the sampling design and rationale for the number of samples and analyses. Also, please include a table that lists each type of sample, the number of samples that will be collected, required QC samples, and the required analyses.

Response 29. Worksheet #17 of the SAP has been revised to include sampling design and rationale for the number of samples and analyses. Furthermore, text that was repetitive from Worksheet #14 has been removed from Worksheet #17.

In regards to a table with the number of samples and required analyses, that information is provided in Worksheet #18. QC samples are discussed in Worksheet #12. No changes were made to the SAP based on this part of the response.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 30. Worksheet #17, Final MARSSIM Survey of the Cover, Page 96: This section discusses the potential need for remediation (excavation) of portions of the cover in the unlikely event that radiological contamination is found after the cover is constructed, but does not specify surveys or sampling to determine that sufficient soil has been removed. Please revise the text to specify whether a gamma survey of the excavation will be done and the number of samples that must be collected.  In addition, please include this information in other worksheets of the SAP as necessary.

Further, the text states, “Soil samples will be collected for waste characterization purposes at a frequency defined by the disposal facility,” but the disposal facility should be contacted so that the number of required samples and analyses can be specifically included in the SAP. Please revise the SAP to include the number of and analyses for required waste characterization samples.

Response 30. Worksheet #17 was completely revised as indicated in Response 29 above. As already indicated in Worksheet #14 regarding the Final MARSSIM Survey of the Cover, “If remediation is warranted, then the area will be excavated as directed by the project team, then filled in to bring the surface back up to grade, and another gamma survey will be conducted.” Sampling the area after excavation will not be conducted; however, the material that is excavated will sampled as described in Worksheet #14.

Regarding the second statement about the text and frequency of sampling by the disposal facility, that section has been revised as follows:

Any soil that is excavated during this time will be placed in six inch lifts. The soil will be surveyed again and soil samples will be collected at a rate of two samples per 40 cubic yards. All samples will be analyzed for gamma isotopes. Ten percent of the samples will be analyzed for total strontium and/or 90Sr, and alpha isotopes (238U). Additionally, any sample result exceeding the release criterion for 137Cs will also be analyzed for total strontium and/or 90Sr. These results will be used to determine if the material is LLRW or non-LLRW. LLRW material will be transported to the waste broker for subsequent disposal. Non-LLRW will be sampled at a minimum of one sample per 500 cubic yards for chemical analyses as listed in Worksheet #18. These chemical results will determine if the any of the material can be reused as fill material for IR Site 2 or if off-site disposal of the material is required.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 31.  Attachment 4, Worksheet #18, Sampling Locations and Methods/SOP Requirements Table, Page 99: Footnote “c” and “d” indicate that the number of waste soil and wastewater samples is unknown since the amount of waste is unknown; however, the SAP should indicate the frequency for collecting waste samples (e.g., 1 sample per 40 cubic yards). Please revise Worksheet #18 to indicate the frequency for collecting waste samples.

Response 31. Footnote “c” and “d” have been deleted from Worksheet #18 and instead the following has been added to Worksheet #18:

Minimum of 1 per 500 cubic yards for the excavated soil waste samples and a minimum of one sample per container for the wastewater samples

Comment 32. Attachment 4, Worksheet #28.1/28.2, Laboratory QC Samples Table - Soil/Water, Pages 144 and 159: The acceptance limits for the post digestion spike (PDS) (75 - 125%) do not meet the acceptance limits in method 6020A (80 - 120%). Please revise SAP to utilize the PDS acceptance limit requirements in Method 6020A.

Response 32. Worksheets #28.1 and 28.2 have been revised to list the 80- 120% criteria for the post-digestion spike for method 6020A.

Comment 33. Attachment 4, Worksheet #29, Project Documents and Records Table, Page 173:  Worksheet #29 states that the Quality Control Program Manager (PQCM) will use an Initial Inspection Checklist during inspections; however, a copy of this inspection checklist has not been provided. Please revise the SAP to provide a copy of this inspection checklist.

Response 33. This quality form can be found in Attachment 5 of this Work Plan and is called the Initial Phase Inspection Form. No changes were made to the SAP based on this response.

Comment 34. Attachment 5, Section 7.5, Additional Inspections, Page 7-3: The third bullet states that if activity on a definable feature of work (DFW) is resumed after a substantial period of inactivity, an additional inspection may be conducted; however, a “substantial period of inactivity” is not defined. As such, it is unclear what amount of time this constitutes (e.g., week, month). Please revise Attachment 5 to clearly define the period of inactivity that would result in an additional inspection being conducted.

Response 34. The third bullet of Attachment 5, Section 7.5, Page 7-3 has been revised to replace “substantial period” with “2-month period of inactivity.”

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 35. Attachment 5, Table 3-1, Definable Features of Work, Page 9 of 15: The Follow-Up column for the Biotic Barrier (Geonet Layer) Placement row states that, “Inspect operation and ensure that material cures properly.” However, no concrete is utilized for the installation of the geonet based on Drawing D-5 (Site Details) of Attachment 1 (90% Remedial Design). As such, it is unclear what component of the geonet layer “cures”. Further, it is unclear what criteria are utilized to determine curing has occurred properly. Please revise Table 3-1 to clarify the component of the geonet layer which cures. In addition, please clarify what criteria will utilized used to determine curing has occurred properly.

Response 35. Comment noted. Table 3-1 of Attachment 5 has been revised to remove this bullet.

Comment 36. Attachment 6, Section 2.1, Agency/Client/Contractor Interface and Contractual Responsibilities, Page 2-1: The EPA is not listed as a regulatory agency overseeing this project. Please revise Section 2.1 to include all key parties overseeing this project.

Response 36. Attachment 6, Section 2.1 has been revised to list the regulatory agencies providing oversight through the Base Closure Team (BCT).

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 37. Attachment 6, Sections 6.3.2 and 6.3.6, Pages 6-6 and 6- 8: It is unclear why only plants and birds will be monitored. Based on information presented in Attachment 6, ecological surveys and construction monitoring proposed at IR Site 2 appear to be limited to protecting special status plant and avian species.  However, Attachment 7, Wetland Mitigation Plan indicates the presence of pickleweed (Salicornia virginica), which provides a food source and habitat for the endangered salt-marsh harvest mouse (Reithrodontomys raviventris).

Further, a remedial action objective specified in Section 2.4, page 2-9, is to protect mammal species, as well as human receptors and avian species. Table 6-1 shows that mammals have been observed at IR Site 2. Please justify why only plants and birds, but not mammals will be monitored in the future.

In addition, these sections state that a “qualified biologist” will conduct ecological surveys of the plants and animals at Site 2 to collect information on species present in or near the intended project areas and to monitor construction activities in areas of suitable habitat to avoid the take of individual animals and to minimize habitat disturbance. The current text does not describe the qualifications of the biologist. Please discuss the qualifications of the biologist that will be required for these activities.

Response 37. Special status plants and avian species are indicated because they are more likely to be present.

Two Salt Marsh Harvest Mouse surveys have been conducted at Alameda Point, including IR Site 2, one in 1995 and one in 2009. Both concluded the Salt Marsh Harvest Mouse was not present. (PRC Environmental Management Inc. 1995), (H.T. Harvey & Associates, Inc. 2009). 2,397 and 1,600 trap nights of effort were performed as a part of the 1995 and 2009 studies, respectively.

A “qualified biologist” will have experience monitoring and identifying the special status species mentioned in the report, as well as experience monitoring in tidal wetlands, and be able to set up and execute a monitoring program for these species.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 38. Attachment 7, Section 5.0, Page 5-2: This section states that habitat for the salt-marsh harvest mouse, consisting of dense pickleweed, is present in seasonal wetlands and tidal wetland. Yet, the text does not discuss any mitigation measures to address this species.

The salt-marsh harvest mouse is a Federal endangered species and has fully protected status in California and needs to be addressed in the Wetland Mitigation Plan. Please discuss mitigation measures for the salt- marsh harvest mouse and other small mammals, as appropriate, in the Wetland Mitigation Plan. Additionally, please include mitigation goals, success criteria, implementation activities, and long-term monitoring and maintenance requirements for small mammals as part of the creation of compensatory wetlands.

The second paragraph states, “Due to their patchy and isolated nature, the seasonal wetlands at the north end of the site, which are the seasonal wetlands that would be filled, offer minimal habitat value.” This concept is reiterated in Section 9.0 on Page 9-1; however, the text does not discuss whether filling these seasonal wetlands may eliminate potential amphibian breeding habitat by replacing freshwater wetlands with tidal wetlands. Please discuss whether the ecological surveys, proposed in Attachment 6, Section 6.3.2, will include the identification of amphibian populations.

Response 38. This section indicates that “marginal” habitat for the SMHM is present, and lists reasons why it is not likely to occur there, as stated in the previous response (Response #37). Requiring mitigation measures for the SMHM at this point is unwarranted because it assumes that they are present and would be affected by construction.

In response to the second paragraph, we concur that amphibian surveys should be performed to identify whether a listed species is present, in substantive compliance with the California Endangered Species Act, Section 2080, and 2081(b). The surveys would be conducted during the amphibian breeding season, typically December to March. The EPP and Wetlands Mitigation Plan (Attachments 6 and 7) have been revised to reflect this change.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 39. Attachment 7, Section 10.0, Implementation, Section 10.1, Page 10-2: The Navy has not proposed revegetating the Tidal Wetland Mitigation Area with pickleweed (the desired plant species) and instead, proposes to let the excavated areas revegetate themselves naturally. However, the text does not discuss contingencies in the event that invasive plant species, which seem to be present in the surrounding area, revegetate the newly-created wetlands. It would appear that planting pickleweed as part of the restoration phase will increase the chances that the mitigated wetlands will support the desired plant and animal species. Please propose planting pickleweed or explain the reason(s) for not replanting the area with pickleweed following development of the new marsh.

Response 39. Planting pickleweed is not recommended since it will revegetate quickly without replanting. The rationale for this, as explained in Section 10.1, is that at other tidal marsh restoration sites, notably at Piers 94 and 98 in San Francisco, pickleweed revegetated quickly without any plantings.

Section 10.1 also indicates that the two main invasive plant species that threaten tidal wetland plant communities (Spartina alterniflora and Lepidium latifolium) were not observed at the site. The only observed invasive plants that would compete with pickleweed were NZ spinach and Salsola soda, neither of which are particularly aggressive. In addition, the text does discuss contingencies in the event of colonization by invasives, and sets a very low threshold (essentially 0% Spartina or Lepidium) before control measures are implemented (Section 11.1). Section 11.1 also proposes planting pickleweed plugs if the performance goals for Years 2 and beyond are not met.

Comment 40. Attachment 7, Section 11.0, Monitoring and Maintenance, Section 11.2 Success Criteria for Wildlife, Page 11-2: The last sentence of this section defines success criteria for wildlife as increased bird use over a 5-year period as the invertebrate community in the substrate increases yet no plan is discussed in case the success goals are not met. Please provide more details to address actions that the Navy will implement if the 5-year wildlife goals are not met.

Response 40. Additional details regarding actions that would be implemented if the 5-year wildlife success goals are not met would be speculative and are beyond the scope of the remedial design.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 41. Attachment 8, Section 3.2.3, Management of Contaminated Soil, Page 3-2 and Attachment 9, Section 3.3, Dust Control Measures, Page 3-2: The text indicates that stockpiled soil will be treated with a soil tackifier to provide dust control and prevent runoff; however, the specific soil tackifier is not named and the application rate is not specified. Similarly, Section 3.3 (Dust Control Measures) of Attachment 9 (Dust Control and Air Monitoring Plan) indicates that chemical soil stabilizer will be applied in sufficient quantities to disturbed areas; however, the specific chemical soil stabilizer is not named and the application rate is not specified. Further, it is not clear if the soil tackifier and chemical soil stabilizer are the same product, and if not, it is unclear if the chemical soil stabilizer and the application rate are appropriate to provide dust control and prevent runoff. Please revise Attachments 8 and 9 to clarify if the soil tackifier and chemical soil stabilizer are the same product. Further, please include a product specification sheet for all applicable media as well as the associated application rate which will provide dust control and prevent runoff.

Response 41. Please see response to EPA Comment #23.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 42. Attachment 8, Section 3.2.5.1, Diesel Fuel, Page 3-2: The text states that fueling will occur in designated areas; however, the designated areas are not specified. In addition, the text states that, if a spill occurs as equipment is being fueled, the spill will be immediately contained with an earthen berm and an excavation retention trap will be provided; however, the materials to construct an earthen berm are not listed in Section 1.6 (Release Prevention and Minimization Measures) of Appendix A (Emergency Response Plan) of Attachment 11 (Post-Closure Operations, Maintenance and Monitoring Plan) as basic spill response materials on-site. As such, the source of the materials to construct an earthen berm is unspecified. Please revise Attachment 8 to clarify where materials to construct an earthen berm will be obtained and where the berms will be placed relative to the designated areas for fueling.

Response 42. Attachment 8, Section 3.2.5.1 has been revised to specify that fueling will occur on the pavement inside the radiological control area (see Figure 5-1 in the work plan) and that import cover material will be used to construct the earthen berm.

Comment 43.  Attachment 8, Section 3.3.4, Soil Stockpile Areas, Page 3-4: The text states that large stockpiles will be sloped to reduce the infiltration of rainwater; however, the slope is not specified. As such, it is unclear what approximate angle the large stockpiles will be sloped at to prevent infiltration of rainwater, but not support erosion. Please revise Attachment 8 to specify the angle or a range of appropriate angles at which the large stockpiles will be sloped at to prevent infiltration of rainwater while not inducing erosion.

Response 43. Stockpile angles will be at the angle of repose for the material. This is to say, as the material is stockpiled higher, it naturally settles to a slope angle related to the moisture content, grain size, and coefficient of friction between the grains. Stockpiles are covered with a tackifier and bermed so that erosion concerns are mitigated. Specifying a slope angle for the stockpiles is not required.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 44. Attachment 8, Section 3.5, Non-Stormwater Management, Page 3-6: The text states that inspections to identify any non-stormwater discharges will be performed quarterly; however, it is unclear why inspections will not be performed more frequently than quarterly, especially during active construction when the potential for non-stormwater discharge is greatest. Please revise Attachment 8 to specify more frequent inspections or to clarify why inspections to identify any non-stormwater discharges will not be performed on a more frequency basis than quarterly.

Response 44. The frequency for the Non-Stormwater Discharge Inspections is specified in Section I. 10. a. ii. of Attachment D (Risk Level 2 Requirements) of the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities.

Comment 45. Attachment 8, Section 4.5, Water Quality Sampling and Analysis, Page 4-4: Section 4.5 states that a minimum of three effluent samples will be collected per day during each qualifying rain event; however, it is unclear how a minimum of three samples is appropriate to assess water quality. Further, these samples are not included in the Attachment 4 SAP. The objectives for these samples, sampling procedures, required analytes, etc. must be included in the SAP. Please revise Attachment 8 to clarify how a minimum of three samples is appropriate to assess water quality, and the lines of evidence which support this frequency. Also, please ensure that these samples are included in the Attachment 4 SAP.

Response 45. The frequency for water quality sampling is specified in Section I. 4. b. of Attachment D (Risk Level 2 Requirements) of the General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities which is provided in Appendix B. The effluent samples are collected for field measurements only and are not submitted to a laboratory for analysis. Attachment 8 Section 4.5 has been revised to clarify that effluent samples will be measured in the field using hand-held instruments.

Field measurement information would be included in a SAP if the measurements pertained directly to decision criteria associated with the CERCLA remedial action for the site. However, for this project, the field measurements pertain to storm water discharge requirements associated with a permit. Furthermore, field measurement information is not applicable to SAP Worksheets #15, 20, and 28 as those worksheets only pertain to samples sent to a laboratory for analysis. In addition, Attachment 8 Section 4.5 already states a) the criteria for the field measurements (which would be applicable to information required for SAP Worksheets #10 and 11); and b) the sampling

frequency requirements and which parameters to measure (which would be applicable to information required for SAP Worksheets #14, 17, and 18).  In

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

 

order to address information that would be provided in SAP Worksheets #21 (Sampling SOPs) and 22 (Field Calibration), Attachment 8 Section 4.5 has been revised as follows:

Effluent sampling will be performed during each qualifying rain event (i.e., at least 0.5 inch of rain or more within a 48-hour or greater period). Prior to collecting samples for measurement, the hand-held field meter will be calibrated in accordance with manufacturer’s instructions, and the calibration information will be recorded on the effluent sampling field form provided in Appendix D. A sample will then be collected at each location where storm water is discharged off-site. A minimum of three samples will be collected per day during each qualifying rain event. An 8-ounce glass jar or equivalent will be used to collect a sample at each location. The jar will be filled with water at least ¾ full. The samples will then be measured for pH and turbidity using the calibrated hand-held field meter by inserting the meter probe into the water container. The readings will be recorded on the same effluent sampling field form that the calibration information was recorded on. The numeric action level (NAL) for pH is lower than 6.5 pH units or greater than 8.5 pH units, and the NAL for turbidity is greater than 250 nephelometric turbidity units. Section I.15 of Attachment D in Appendix B describes actions to take in the event a measurement exceeds these NALs. Completed effluent sampling field forms will be inserted at the end of Appendix D of the IR Site 2 SWPPP Master Copy to be located in the Field Engineer’s office.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 46. Attachment 9, Section 2.1, Climate, Page 2-1: The sources for the average daily temperature, mean annual precipitation, and windrose diagram are not provided and/or referenced. As a result, it is unclear if the information is representative of conditions at IR Site 2.

Please revise Attachment 9 to provide and/or reference the sources for the average daily temperature, mean annual precipitation, and windrose diagram.

Response 46. A reference to the IR Site 2 TCRA (FWENC 2002) has been added to Attachment 9, Section 2.1.

Comment 47. Attachment 9, Section 3.3, Dust Control Measures, Page 3-2: The second bullet indicates that active construction areas outside the dewatering and radiological screening pads will be watered at a minimum of twice daily and more often during windy periods; however, what constitutes a windy period is not defined. Similarly, the third bullet indicates that active excavation areas will be wetted every two hours during periods of dry weather or in windy conditions; however, windy conditions are not defined. As a result, the quantifiable conditions that are associated with windy periods and windy conditions are unclear. Please revise Attachment 9 to quantitatively define windy periods and windy conditions.

Response 47. Attachment 9, Section 3.3, second bullet and third bullets have been revised to replace “windy period” with “windy conditions that generate visible dust.”

Comment 48. Attachment 9, Section 8.0, Data Evaluation, Page 8-1: The criterion for elimination of data is not specified. The text states that, “Field records and logbook entries of calibration results will also be reviewed and verified, as appropriate, and final calculated data values will be entered into the data file. Any data known to be erroneous will be edited out of the data file.” It is unclear if this elimination of data is appropriate. Please revise Attachment 9 to specify the criterion that will be used to eliminate data.

Response 48. The reference to elimination of data has been removed from Attachment 9, Section 8.0.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 49. Attachment 11, Section 2.2.2, Proposed Monitoring Network and Sampling Frequency, Page 2-3:

a) The text indicates that replacement wells M024R-A, M024R-E, M037R-A, M037R-E, and M039R-A will be sampled semiannually for the first year then annually thereafter; however, it is unclear why the results from the semiannual sampling will not be evaluated after the first year to determine the ongoing frequency of sampling. Further, Section

6.1.1 of Attachment 11 states that only replacement wells M024R-E and M024R-E will be sampled semiannually for the first year. Please revise the Draft RD/RA WP to provide flexibility to adjust the sampling frequency based on the results of the initial sampling. In addition, please ensure that the monitoring wells which will be sampled semiannually for the first year are clearly defined and that the sampling plan reflects all newly installed replacements wells.

b) Further, it is unclear why semiannual baseline sampling is warranted given that the wells to be sampled are replacement wells to assess the viability of the landfill remedy. EPA’s Unified Guidance states in Section 5.1, that, “High quality background data is the single most important key to a successful statistical groundwater monitoring program.” Please revise Attachment 11 to include the lines of evidence which support the proposed frequency or revise the frequency to reflect the available lines of evidence.

Response 49a. The RAWP has been revised to include the preservation of the existing groundwater monitoring well network. The Navy has continuous quarterly to annual GW data from the wells in this network from 2002.

The DTSC, in a written communication dated March 1, 2013, requested that the Navy submit a separate Groundwater Monitoring Evaluation (GME) as a Remedial Design Addendum document. Groundwater monitoring requirements, including sampling frequency, will be detailed in the evaluation. Section 2.0 of Attachment 11 has been revised to reflect this change.

 

 

 

 

 

Response 49b. Please see Response 49a above.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 50. Attachment 11, Section 2.2.3, Data Analysis, Page 2-4: Internal wells are not proposed for use in the trend analysis. The first sentence states that, “Wells at the site perimeter and along the bay will be used for the trend analysis, as required by the ROD [Record of Decision].” It is unclear if this trend analysis will be representative of IR Site 2 conditions. Please revise the text to clarify why interior wells are not proposed for trend analysis to provide a more representative evaluation of IR Site 2 conditions and changes in plume composition and make boundary assessments more meaningful since interior wells could be used to predict boundary changes.

Response 50. Specifics regarding groundwater trend analyses will be discussed in the Remedial Design Addendum which will be prepared pursuant to the GME.

Comment 51. Attachment 11, Section 6.1, Scheduled Inspection, Page 6-1: The text states that, “IR Site 2 will be inspected quarterly and after major weather or seismic events for damage, and maintenance will be performed as necessary;” but the text does not define a major weather or seismic event making it unclear when inspections will occur.

Similarly, Section 6.1.2 (Cover Settlement) of Attachment 11 states that the landfill cover condition and the slopes of the landfill inspections will occur on a quarterly basis and after significant events; however, significant events are not defined. Please revise Attachment 11 to clearly define a major weather, seismic event and significant event so that inspection triggers are clearly understood and the appropriate inspections can be completed.

Response 51. Attachment 11, Section 6.1 has been revised to include specific descriptions of significant weather and seismic events.

Significant weather events would include any rain event with 0.5 inch of rain occurring in a 24-hour period.

A Modified Mercalli Intensity (MMI) of VII as reported in the USGS intensity maps for recent earthquakes in California is an appropriate threshold to trigger an engineering site inspection, corresponding to the reported intensity of the Loma Prieta earthquake in Alameda when lateral spreads but no slope failures were reported for the site. MMIs are available almost immediately after an earthquake at the following website: http://earthquake.usgs.gov/earthquakes/dyfi/. The benefit of this scale for the purposes of triggering an inspection is that the value is readily available and understandable by site personnel.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 52. Attachment 11, Section 6.1.4, Site Structures,

Page 6-1: The section indicates that settlement monuments will be surveyed annually; however, it is unclear why settlement monuments will not be surveyed on a more frequent basis initially after construction to establish an appropriate baseline data set or following seismic events.

Without a more structured monitoring frequency, it is unclear how robust the data set will be upon which landfill settlement assessment will be based if the settlement monuments are only surveyed on an annual basis. Please revise Attachment 11 to clarify how annual surveying of the settlement monuments is appropriate to assess settlement and why a seismic event should not trigger a settlement monument monitoring event.

Response 52. It is important to keep the purpose of this landfill cover in context, which does not include limiting infiltration of ponded groundwater that can be increased in areas of the cover that have settled. The ROD is clear that this is a multilayer cover, and not a landfill cap. Therefore, the type of landfill settlement assessment and the associated robust data set appropriate for landfills with infiltration requirements are not applicable for IR Site 2, and the prescribed annual surveys are sufficient. After a seismic event, the entire site would be inspected to ensure integrity of the final cover and that the environmental control systems are functioning. Any damage to the cover, including areas of localized settlement, would be repaired by importing soil and grading.  After a seismic event, settlement monuments would be inspected for damage and localized differential settlement.

Comment 53. Attachment 11, Appendix B, Plan Itemized Cost Estimate, Table B.1-1, Detailed Annual Operation and Maintenance Costs: The level of detail provided in Table B.1-1 is not sufficient to support the annual costs. For example, all the costs for work not to be performed by Tetra Tech are provided as lump sums. Detailed cost estimates for the proposed activities have not been presented and, as such, the individual costs and associated assumptions for individual components of the proposed activities are unclear and the costs cannot be evaluated. Please revise Table B.1-1 to include detailed “roll-up” costs used to develop the lump sum costs so that an evaluation of the components of the lump sums may be conducted.

Response 53. Level of detail to be provided is the same as in the ROD when presenting remedy costs. The estimate in Appendix B is based on similar O&M costs at Navy CERCLA Sites in the Bay Area. A separate contract will awarded for the O&M at Site 2, and the government will develop a more detailed estimate at that time for bid evaluation purposes.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 54. Attachment 12, Section 4.0, Area Requiring Institutional Controls, Page 4-1: The text states that the institutional controls (ICs) which will be applied to IR Site 2 are shown on Figure 2-1 (Site Location Map) of Attachment 12; however, no ICs are shown on Figure 2-1 of Attachment 12. As such, it is unclear where the limits of the ICs are, and how the corresponding land use limitations and activity restrictions specified in the ROD will be applied. Please revise Figure 2- 1 of Attachment 12 to include all ICs.

Response 54. The text of Attachment 12, Section 4.0 has been revised to reference Section 5.0 and the boundary of the area of required institutional controls for IR Site 2 is shown on Figure 2-1.

MINOR COMMENT

RESPONSE

Comment 1. Section 5.6.8, Settlement Monuments, Page 5-9: Section

5.6.8 includes details related to the settlement monuments that will be installed on the final grade of the multilayer soil cover system; however, details related to the monitoring of the settlement monuments is not provided and/or referenced. Please revise Section 5.6.8 to reference Section 3.5 (Settlement Monuments) of Attachment 11 (Post-Closure Operations, Maintenance, and Monitoring Plan).

Response 1. Section 5.6.8 of the main text has been revised to add reference to Section 3.5 of Attachment 11 for settlement monitoring.

Comment 2. Section 8, References, Page 8-2: Please reference the Final TCRA Post-Construction Report, IR Sites 1, 2, and 32, dated August 2009 instead of the Draft TCRA.

Response 2. Section 8 of the main text has been revised to correct the reference from Draft to Final.

Comment 3. Attachment 1 (90% Remedial Design): Attachment 1 does not include any text to introduce or summarize the contents of the attachment. Please revise Attachment 1 to include text to introduce or summarize the content of the attachment.

Response 3. A flysheet with a brief description of each component of the RD has been added to Attachment 1.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 4. Attachment 4, Worksheet #2, SAP Identifying Information, Page 13: Item 4 in Worksheet #2 states that scoping sessions are not applicable. However, Worksheet #9 provides details of a scoping session that was held on September 8, 2011. The date and general description of this scoping session should be provided on Worksheet #2. Please revise Worksheet #2 to provide this information.

Response 4. Item 4 in Worksheet #2 has been revised to include the scoping session listed in Worksheet #9.

Comment 5. Attachment 4, Worksheet #15.1, Reference Limits and Evaluation Table for Soil Samples, Page 70:  Footnote “a” is referenced in the table for metals; however, this notation applies to radiological analyses, not metals analyses. Please revise the worksheet to apply footnote “a” to the appropriate table(s).

Response 5. The footnote a) listed in the metals table in Worksheet #15.1 has been removed.

Comment 6. Attachment 4, Worksheet #18, Sampling Locations and Methods/SOP Requirements Table, Page 99: Footnote “a” states that the sequential numbering system used to determine sample identification in the field is explained in Worksheet #29. However, this process is not explained in Worksheet #29. Instead, Worksheet #27 provides a brief explanation of this process. Please revise Worksheet #18 to resolve this discrepancy.

Response 6. Footnote a) in Worksheet #18 has been revised to reference Worksheet #27 instead of #29.

Comment 7. Attachment 4, Worksheet #37, Usability Assessment, Page 201: Worksheet #37 states that the data quality assessment report (DQA) will include review of “field QC samples to verify that these were collected in accordance with Worksheet #12.” However, Worksheet #12 was not included in the SAP because they are not required for the project. Please remove the reference to field QC samples in Worksheet #12 for consistency.

Response 7. Worksheet #37 bullet #1 has been revised to remove the reference to review of field QC samples.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 8. Attachment 10, Waste Management Plan, Section 1.2.3 (Soil and Waste Stockpiles and Staging Piles), Page 1-6: The last sentence of Section 1.2.3 states that, “A site-specific Stormwater Pollution Prevention Plan (SWPPP) will also be prepared for the project in accordance with [Applicable or Relevant and Appropriate Requirements] ARARs;” however, it is unclear why Attachment 8 (Stormwater Pollution Prevention Plan) is not directly referenced. Please revise Section 1.2.3 of Attachment 10 to directly reference Attachment 8.

Response 8. Attachment 10, Section 1.2.3 has been revised to reference Attachment 8.

Comment 9. Please correct the mail code for Xuan-Mai Tran as SFD-8- 3 for all Points of Contact pages where mail code is listed.

Response 9. The mail code has been corrected where present.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from John R. West Remedial Project Manager Groundwater Protection Division

California Regional Water Quality Control Board, San Francisco Bay Region

Comments Dated: June 13, 2012

COMMENT

RESPONSE

Comment 1. Wetlands. Wetland delineations of the seasonal, intermittent, and tidal wetland areas at the site are currently pending verification by the Army Corps of Engineers. Because the verification of the delineation of jurisdictional wetlands is a critical component in decision making related to wetland destruction and creation design, we cannot approve or support the design and mitigation proposals until the Army Corps has verified the wetland delineation.

In Attachment 7, page 5-2 the report states: “although extensive pickleweed habitat was found at the site and was not identified as wetland, the areas identified as tidal wetlands in the wetland delineation report appear to be those areas that receive frequent tidal inundation. All other pickleweed habitat does not meet hydrology criteria needed for a wetland designation to be applied. The tidal wetland portion of the proposed project area, which comprises part of the area that would be filled, is of relatively low value to the waterfowl and shorebird species that use the general area, but it may offer good foraging habitat for raptors.”

Response 1. Navy has prepared wetlands delineation reports for IR Site 2 in accordance with the ROD agreement. CERCLA response actions are exempt from federal and state permits (Section 121[e] of CERCLA). However, substantive provisions of the ACOE’s Section 404 regulations have been accepted and identified as federal ARARs in the ROD. Refer to Attachment 7, Appendix A, Section 2.0 of the IR Site 2 RD/RAWP for compliance.

The comment does not cite to any law or regulation that requires ACOE verification of wetlands delineations. However, if there were such statute provision in a law or regulation, it would not qualify as an ARAR because administrative /procedural provisions do not qualify as CERCLA ARARs.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

John R. West, Remedial Project Manager

Groundwater Protection Division, California Regional Water Quality Control Board, San Francisco Bay Region

We disagree with two components in these statements and have discussed our concerns below:

a-1) We find inadequate information supporting the premise that wetland indicators have not been met at portions of the site. What evidence has been collected indicating that other wetland indicators, (e.g., having adequate hydrology, vegetation, etc.) have not been met?

a-2) What is the basis for calling the tidal wetland portion of the project to be of relatively low value? Ecologically speaking as a whole, we consider tidal wetlands to be quite valuable and pickleweed as a species is generally considered to be a valued habitat throughout the Bay.

b) We are very concerned about the age and integrity of the culvert that is the sole source of Bay water to the tidal wetlands. It is our understanding that the aged culvert is in very poor shape and may collapse any time. The value of this culvert became painfully apparent a year ago when some driftwood or other material clogged it up and impeded all tidal flow of brackish water to the wetland. In a matter of days the tidal wetland started drying up. Should that culvert collapse, the delays in rebuilding, from getting contracts to actual physical work, could be devastating and even fatal to the wetland flora and fauna.

Response to comment a-1: Pickleweed is the key issue here and its presence is usually considered evidence of wetland conditions, given that it's an obligate wetland species (occurs in wetlands >99% of the time). However, the delineators did explain why they called some areas with pickleweed “upland,” and had a discussion of problematic vegetation in Section 3.5.3 of the delineation report (See Appendix A, Attachment 7). In this section, they indicated that pickleweed can spread rhizomatously from wetland areas into upland areas, where it was found comingling with upland species such as coyote brush, ice plant, and ripgut brome. The pickleweed was present at densities less than 5% in locations that the delineators referred to as upland, and was generally a small component of an otherwise upland plant community. This is particularly likely to occur in areas filled with dredge spoils that may still have a high salt content, which would favor pickleweed and salt grass over the upland species.

Response to comment a-2: The passage says the tidal wetland portion of the project area (meaning the pickleweed area that was identified as jurisdictional wetland, not the open water/mudflat area) is of relatively low value to the waterfowl and shorebirds that use the general area. The pickleweed marsh at the site is not sufficient to support waterfowl and shorebirds breeding requirements, nor is pickleweed their primary choice for foraging habitat.

However, we do recognize that pickleweed marsh contributes detritus to the mudflat area and helps to sustain the benthic community that in turn sustains the shorebirds. Attachment 7 will be revised to clarify this distinction.

Response to comment b: See Response to EPA Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

John R. West, Remedial Project Manager

Groundwater Protection Division, California Regional Water Quality Control Board, San Francisco Bay Region

Comment 2. Proposed Groundwater Monitoring Program and Well Network. It is unclear from Attachment 11, Section 2.2.2 of the report if the proposed monitoring well network will be adequate to demonstrate protection of surface waters in the two onsite wetlands and areas adjacent

S.F. Bay. Will there be an adequate number of wells effectively placed to monitor landfill leachate concentrations that might adversely affect the adjacent wetland species? Groundwater monitoring information will be especially important after the proposed site activities are completed (e.g., re-grading, capping) to assess hydrological changes and any associated increases in contaminant concentrations that may have occurred due to the site work. Therefore, please provide a comprehensive Groundwater Monitoring Program including a monitoring well network evaluation for the entire site so that we can better assess if the proposed monitoring well network will be sufficient.

Response 2. The DTSC, in a written communication dated March 1, 2013, requested that the Navy submit a separate Groundwater Monitoring Evaluation (GME) as a Remedial Design Addendum document. Groundwater monitoring requirements will be detailed in the evaluation.

Comment 3. Exclusionary Fencing and Gas Vent Pipes. There has been considerable public concern regarding the proposed 6’ high chain link barbed wire fence to circumscribe the landfill and the thirty, 10-feet high, methane gas vents at the Site. The main public concern is that this location is extremely unique and arguably offers one of the best Bay views in Alameda. The Public has also expressed the desire to avoid the stigma of leaving the landfill as a toxic waste dump. Also, it is unclear why the methane vents need to be so high.

Although protection of human health and the environment is our primary goal, we request that alternatives be evaluated for the fence line and methane gas venting so that public concerns and environmental health might more naturally coexist with the other beneficial uses that are planned for the area.

Response 3. Please see Response to DTSC General Comment #2 regarding the site fence and Response to EPA General Comment #36 regarding the vents.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

John R. West, Remedial Project Manager

Groundwater Protection Division, California Regional Water Quality Control Board, San Francisco Bay Region

MINOR COMMENT

Comment 1. Section 1.3 Points of Contacts. Please list as a contacts:

a)  John West, Water Board PM, (510) 622-2438, jwest@waterboards.ca.gov.

b)  Peter Russell, City of Alameda, (415) 902-3123, peter@russellresources.com.

Response 1. Section 1.3 has been revised to add the contact information for John West and Peter Russell.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Peter Russell, PhD, PE Russell Resources, Inc.

Comments Dated: May 31, 2012

COMMENT

RESPONSE

Comment 1. Perimeter Fence: The August 2010 ROD for IR Site 2 specifies Institutional Controls (ICs, Table 2-13), which include Land Use Restrictions and Activity Restrictions. Briefly, the Land Use Restrictions restrict IR Site 2 to open space and recreational uses, and prohibit residential and other specified sensitive land uses. The Activity Restrictions restrict land disturbing activities, extraction of groundwater, disturbing infrastructure, etc. Note that the ROD’s ICs explicitly do not prohibit recreational uses.

The RD/RA Work Plan contemplates recreational use once remedial action is complete:

“The proposed future use at IR Site 2 includes low-impact recreational uses such as a recreational trail around the site.” (Section 2.3)

“The proposed future use at IR Site 2 is ‘undeveloped’ with potential for recreational uses such as a perimeter hiking trail. ...

Access to the shoreline trail south and west of the landfill will remain open.” (Attachment 11, Section 1.3)

However, Design Drawing C-9 of Attachment 1 of the RD/RA Work Plan indicates that the new 6’ high chain link fence is to join the existing fence and that a chain link gate is to be constructed near the northwest corner of IR Site 2. The other end of the chain link fence (at the southeast corner of IR Site 2) is not shown on any drawings: it is outside the limits all of the RD’s drawings.

Response 1. Please see response to DTSC General Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Peter Russell, PhD, PE Russell Resources, Inc.

To ensure that access to the shoreline trail south of the landfill will remain open, please add a note to Design Drawing C-12 that specifies a gate in the perimeter fence at the southeast corner of IR Site 2. Further, please add “Access to the shoreline trail south and west of the landfill will remain open” to Section 2.3 of the RD/RA Work Plan. This is the same sentence appearing in Attachment 11, Section 1.3, a less prominent location.

 

Comment 2. Design Drawing C-17 of Attachment 1 of the RD/RA Work Plan specifies that the newly installed 4-inch PVC vertical landfill- gas vent pipes are to extend a minimum of 10 feet above the ground surface. The vent pipes are a replacement and expansion of the landfill gas control system installed following the 1983 Water Board Order No. 83-35. However, tall vertical vent pipes may not be needed for landfill gas control at the IR Site 2 landfill. Typically, vent pipes are engineered with two objectives: (1) to prevent the buildup or migration of landfill gas and (2) to protect the health of recreational users. The vertical vent height may be important for the second objective, because it promotes atmospheric mixing of the emitted gases before they might reach the breathing zone of recreational users.

The tall vent pipes would be visually conspicuous and may detract from the esthetic experience of future recreational users of the shoreline perimeter trail and other recreational users. Thus, alternatives to the tall vent pipes may be preferable. For example, the vent pipes could be shortened to a few feet above ground surface, where they would be concealed in vegetation and less conspicuous. With this option, a posted and fenced exclusion area could be installed around each vent to prevent users from approaching the vents.

Please modify the design of the vent pipes. If modifications to the

Response 2. Please see response to EPA General Comment #36.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Peter Russell, PhD, PE Russell Resources, Inc.

vertical vent pipes’ design is not adopted in the RD/RA Work Plan, please explicitly recognize in the RD/RA Work Plan that, in the future, the vents’ design may be altered, with Water Board approval.

 

Comment 3. The August 2010 ROD for IR Site 2 specifies non- radiological Soil Remediation Goals (RGs) in Tables 2-4 and 2-5. However, the RD/RA Work Plan’s Reference Limits and Evaluation Table for Soil Samples (Attachment 4, SAP Worksheet #15.1) contains multiple instances where the Project Action Limit (PAL) exceeds the RG by at least one order of magnitude. For example, the ROD’s RG for cadmium is 6.5 mg/kg, but the PAL is 100 mg/kg. For chromium, the values are 48.5 mg/kg and 2500 mg/kg, respectively; for molybdenum,

1.9 mg/kg and 3500 mg/kg; and for zinc, 263 mg/kg and 5000 mg/kg. For benzo(a)pyrene, the ROD’s RG is 0.24 mg/kg, but the PAL is “Not established”. Finally, for total DDx and total PCBs, the ROD specifies numerical RGs, but SAP Worksheet #15.1 provides no PAL. The PALs specified for the individual chemicals that comprise total DDx and total PCBs exceed the RGs for the respective sums of their concentrations. This appears to allow use of cover soil at IR Site 2 that exceeds RGs selected to be protective of recreational users and ecological receptors. Please clarify this apparent discrepancy.

Response 3. For those compounds with RGs, the PALs should be the same as the RG, and SAP Worksheet #15.1 will be revised accordingly.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

RAB COMMENTS

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Carol Gottstein, MD, George Humphreys, James D. Leach, Kurt Peterson, Dale Smith, Michael John Torrey Naval Air Station Alameda Restoration Advisory Board

Comments Dated: July 2, 2012

COMMENT

RESPONSE

Comment 1. It seems cynical to claim that a thinner cap supports a sustainability goal, when the document states that in the event of a maximum credible earthquake (MCE), the site is projected to turn into “soup” and that permanent displacement has been calculated to range from 0.2 to 11 inches and transverse cracks up to 4.5 feet deep are expected. The document also states that a full seismic stability analysis has never been completed, either by TetraTech or CH2M Hill, whose contract was cancelled. The Navy representative, Mr. Jacques Lords, announced at a planning meeting that “there is already enough information about seismic hazards and it’s time to design something rather than study it further”. He also stated that with this cap design, the site doesn’t have to withstand a MCE and repairs can be performed when cracks appear and the cap slides towards the bay. These all lead to a lack of confidence that this remedy will endure. This is the first time limits of liability have been included by a consultant, indicating a lack of certainty as to the efficacy of the solution and an attempt to limit liability.

Response 1. A thinner soil cover means less mass, and that reduced soil mass is placed at lower slope angles, all of which reduces the potential energy for mass displacement during an earthquake.

Three rounds of Seismic Stability analysis were performed over the course of Site 2 assessment, and the Navy has reviewed and reassessed the response to comments regarding seismic stability presented in the RD/RAWP RTCs.

Prior recommendations for ground improvements were based on default assumptions in the modeling. The Navy has performed a new analysis of existing data using site-specific model parameters to predict a tighter range of deformation of the soil cover and the berm. See Response to EPA General Comment #10.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Carol Gottstein, MD, George Humphreys, James D. Leach, Kurt Peterson, Dale Smith, Michael John Torrey Naval Air Station Alameda Restoration Advisory Board

Comment 2. Because hazardous materials, including munitions and explosives of concern and radioactive material, are interred on site and are not very deeply buried, it can be assumed they will move towards the surface during a seismic event, even one less than an MCE, such as the Lorna Prieta earthquake. The Bay Area is constantly subjected to small “shudders”, causing buried hazards to migrate to the surface. This will be an ongoing problem and will require constant monitoring and remediation. We would prefer a more permanent solution that did not present the possibility of unnecessary exposure.

Response 2. The assumption that waste will migrate to the surface during an event that is marginally less than the MCE was not observed during the Loma Prieta event. The soil cover has been selected as the remedy precisely because it will function as a barrier between waste and receptors, and it is required by the ROD to accommodate a maximum credible earthquake while maintaining cover integrity. The vegetative cover and HDPE biobarrier also provide stability through the establishment of a root system and uniform horizontal geonet in the cover, providing barriers to waste possibly migrating to the surface.

The reviewer is correct that the site represents an obligation on the part of the property owner of monitoring. The RAWP Attachment 11, Post-Construction Maintenance and Monitoring Plan, details the Navy’s obligations once the cover is installed.

Comment 3. The document states that the vertical pipes along the inside eastern and northern perimeter fencing are for the purpose of venting gas generated in the landfill. Based on the site tour they appear to be offsite migration monitoring devices, rather than part of a gas collection system. This infrastructure was installed to meet a 1982 Bay Area Water Quality Control Board requirement to detect offsite migration of soil gas. Why are new pipes being installed when there is a functioning set of pipes already in existence?

Response 3. Please see Response to EPA General Comment #36.

Comment 4. As is the case with almost every project on Alameda NAS, the number of monitoring wells is less than adequate and does not cover the entire site sufficiently to ensure contaminant migration is not occurring, especially since the design anticipates soil movement.

Response 4. The DTSC, in a written communication dated March 1, 2013, requested that the Navy submit a separate Groundwater Monitoring Evaluation (GME) as a Remedial Design Addendum document. Groundwater monitoring requirements will be detailed in the evaluation.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Carol Gottstein, MD, George Humphreys, James D. Leach, Kurt Peterson, Dale Smith, Michael John Torrey Naval Air Station Alameda Restoration Advisory Board

Comment 5. If Site 2 is to be fenced, how will mosquito abatement and other safety personnel gain access to the site in a timely manner? The document describes razor or barbed wire in association with the fence, but this not shown as part of the design drawings.

Response 5. Please see Response to DTSC General Comment #2.

Comment 6. The choice of Decker Island sand is a fine choice for habitat remediation. However, we would prefer to see the replacement ratio for lost habitat be greater than one to one. Site 34 and 32 also lost wetlands habitat and that does not appear to have been replaced. Thus, overall the Navy is not leaving as much wetland area as existed before, in spite of its poor quality. There is an endemic lupinus in the northeast side of the site that should be protected during construction, either by removal and tending or shielding from damage. There is also distichlis present that should be protected and used for propagation purposes. The restoration with native grasses is much appreciated.

Response 6. Wetlands mitigation strategy was agreed to in the ROD. The endemic lupines will be protected during construction to the extent practicable. Navy is working with the construction Contractor to hydroseed the soil cover with a native grassland plant community that is as closely associated with Alameda and the East Bay habitat as practicable. This specific seed mix was proposed by the RAB, at the request of the Navy.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Richard Bangert Restoration Advisory Board member

Comments Dated: June 11, 2012

COMMENT

RESPONSE

Comment 1. The security fence should not be used as an institutional control. By incorporating design changes for the soil gas vents, the security fence will not be necessary. The risks to soil gas probes, groundwater monitoring wells, and the soil cap itself are close to nonexistent. The only institutional control should be a digging restriction. An example of a park on top a landfill that illustrates the lack of need for a fence is Byxbee Park in Palo Alto, California. The park is open from 8 am until sunset. There is no fence to keep anyone off of the landfill. And on a recent visit, I saw no evidence of any supervision or any damage to equipment located in the ground. Soil gas monitoring equipment is located inside of concrete casements with cast-iron covers with no padlock. They are easily visible and accessible and show no signs of damage. I did not see any visible groundwater monitoring wells, but I did see a different type of equipment that the public had unsupervised access to: high voltage underground transmission lines. The park trails had active use on a Sunday, and there were no signs of damage to the grasslands caused by humans. The only ground disturbances were from ground squirrels. The only fence is around the soil gas flare equipment.

Response 1. Please see Response to DTSC General Comment #2.

Comment 2. New 10-foot-tall soil gas vent pipes on top of the soil cap will be a blight on views of the Bay and San Francisco.

Response 2. See Response EPA Comment #36.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Richard Bangert Restoration Advisory Board member

Comment 3. Landfill methane gas is typically captured and burned off in compliance with Bay Area Air Quality Management District regulations. Explain why methane gas is being vented into the atmosphere. If this were not a CERCLA site, would a permit for flaring off methane gas be required?

Response 3. Per the ROD (DON 2010), “The operator shall ensure that landfill gases generated at a disposal site are controlled. Methane must not exceed 1.25 percent by volume in air within on-site structures, concentrations of methane gas migrating from the landfill must not exceed 5 percent by volume in air at the property boundary, and trace gases shall be controlled to prevent adverse acute and chronic exposure to toxic and/or carcinogenic compounds.” Annual monitoring has demonstrated compliance with the ROD requirement, as documented in the Basewide Groundwater Monitoring Reports.

Comment 4. Groundwater monitoring wells should remain permanently in place and operable. Regardless of how clean the groundwater ever becomes, or whether monitoring is discontinued, the inevitable earthquake on the Hayward Fault will require investigation to determine if the geotechnical assumptions about the site remain valid. Exercising the work plan’s option of destroying the groundwater monitoring wells in five years would be shortsighted. This option should be removed from post-closure options in the plan.

Response 4. Geotechnical data does not come from groundwater sampling. Groundwater monitoring wells are an asset so long as the information collected is useful. But they are also a liability as a potential pathway for an accidental spill to get to the aquifer. Potential spills include liquids associated with the vehicles that perform the monitoring. Text will remain but wells are not removed without a review and concurrence from the BCT

Comment 5. The North Pond culvert connecting to San Francisco Bay is the lifeline for this high value tidal wetland. The steel culvert is old and will someday need replacement. If it rusts out and succumbs to the weight of overlying soil and collapses, the cutoff of water interchange would have a devastating effect on the North Pond. The culvert is also subject to clogging by driftwood. The Remedial Action Work Plan should include a pre-approved design and authorization for replacement/upgrade to this culvert so that work by the new owner can  be executed in a timely fashion without cumbersome CERCLA post-

closure administrative procedures. Optionally, the Navy should consider replacing the culvert during the current remedial work project through a

Response 5. Please see Response to EPA General Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Richard Bangert Restoration Advisory Board member

collaborative funding effort with other agencies. Preservation, as well as expansion, of wetlands around San Francisco Bay is a key part of Bay ecosystem health.

 

Comment 6. Soil cap testing – The following statement in the Remedial Action Work Plan does not provide adequate assurance that the soil for the soil cap will be free of mercury or other harmful chemicals: “This import material (Decker Island Aggregates) has been chemically and radiologically tested for use on other Navy projects including Hunters Point Naval Shipyard, and testing results will be provided prior to use.”

5.6.4 Barge Delivery and Stockpile of Soils.

Since the soil for Site 2 (at least 400,000 cubic yards) has not yet been excavated, describe the tests that were conducted on the area from which this soil will be excavated. The soil cap will shed water onto the wetlands, including the North Pond that is connected to San Francisco Bay, and must not pose a risk to the marine environment or waterfowl. Are screening requirements higher for soil that drains to a wetland, as opposed to use at Hunters Point Naval Shipyard as cited in 5.6.4 Barge Delivery and Stockpile of Soils?

Response 6. The excavated soil from Decker Island is in situ delta sediment and is known to be free of mercury or other harmful chemicals at concentrations above screening levels. The Soil from Site 17 currently stockpiled at IR Site 2 is also profiled and acceptable for use as subgrade material, but not for the 2-foot-thick cover layer.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OTHER COMMENTS

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Jaime Michaels, Coastal Analyst and Andrew Winetroub, Legal Intern

San Francisco Bay Conservation and Development Commission

Comments Dated: July 9, 2012

COMMENT

RESPONSE

Comment 1. Commission’s Authority Under the Coastal Zone Management Act and ARARs.

Section 3.2 of the RAWP correctly states that the IR-2 remediation activity is not subject to the Commission’s permitting authority, yet also asserts: “wherever relevant, substantive provisions of permits that would be required for a non-CERCLA action will be adhered to.” Additionally, the RAWP cites the permit exemption in CERCLA Section 121(e) as being applicable, while failing to address the consistency review process authorized under the federal Coastal Zone Management Act (CZMA) (RAWP Attachment 6, § 5.3.3) (stating that the Navy will submit project information to the Commission to support “an informal federal consistency determination”).1

[Footnote 1: The CZMA imposes on federal agencies both the substantive requirement to be consistent to the maximum extent practicable with the enforceable policies of the Commission’s federally- approved Coastal Management Program as well as the procedural requirement to undergo a consistency review process (CZMA § 307(c)(l)(C)). The Commission previously outlined in a letter to the Environmental Protection Agency dated May 3, 2010, the legal basis for its view that in conducting onsite remediation activities under the CERCLA the DON is subject to both the substantive and the procedural requirements of the CZMA. Furthermore, while the Commission agrees that its permit requirements do not generally apply to the activities of federal agencies (see 15 CFR § 930.39(e)), it is not correct to state,

Response 1.

 

Comment acknowledged.

In order to clarify the language of the RAWP, the last sentence of the third paragraph of Section 3.2 shall be revised to say “However, substantive provisions of federal and state applicable or relevant and appropriate requirements (ARARs) will be adhered to as required by CERCLA and the NCP. Section 121(e) of CERCLA provides that no Federal, State or local permit shall be required for on-site remedial actions.” In addition, the fourth paragraph of Section 3.2 will be deleted.

As explained in the June 10, 2010, letter from Mr. Keith Forman of the Navy to Mr. Jaime Michaels of BCDC regarding the Hunter’s Point Naval Shipyard, the Navy’s CERCLA remedial actions are not subject to permit requirements based on the CERCLA permit exemption at Section 121(e) of CERCLA and are not subject to federal and state administrative/procedural requirements (see National Oil and Hazardous Substances Pollution Contingency Plan [NCP] preamble at 55 Federal Register 8756, March 8, 1990).

The Navy has prepared a “CERCLA Substantive BCDC Bay Plan Consistency Evaluation for IR Site 2, Former Landfill, Alameda Point California,” which is included in the RAWP in Attachment 6, Table 5-2. This document is the substantive CERCLA equivalent to a CZMA “consistency determination” for IR Site 2 on-site activities and evaluates and demonstrates

 

 

 

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Jaime Michaels, Coastal Analyst, and Andrew Winetroub, Legal Intern San Francisco Bay Conservation and Development Commission

as section 5.3.3 does, that projects “that require federal approval,” or “that are supported by federal funds” are for these reasons alone also exempt from the Commission’s permit requirements.]

Further, the ROD states that the Navy intends to carry out the remediation activities in a manner that meets the Commission’s applicable or relevant and appropriate regulations (ARARs) (ROD Appendix A, pp. A-18 & A-32). Importantly, for the Commission’s jurisdiction, the North Pond is connected to the bay by-a culvert installed in the seawall, which connects the Bay to waters within IR-2 (RA WP § 2.1). Specifically, the Comments section regarding the CZMA in the ROD states, “To the extent that during the remedial design phase it is determined that some minor filling of the North Pond is required to place the multilayer soil cover, the Navy will ensure [ARARs] are followed to protect the beneficial uses of San Francisco Bay in compliance with the CZMA” (ROD Appendix A, p. A-18). Lastly, Attachment 12 of the RA WP indicates that future transfer of property would involve the preparation of a Memorandum of Understanding or other agreement between the Navy and transferee to ensure that it would comply with all federal and state environmental, public health, and cultural and natural resource protection laws (RAWP Attachment 12, § 3.1).

While the RA WP’ s inclusion of “Chemical-Specific” ARARs (RAWP Attachment 6, Table 5-1) and exclusion of “Location-Specific” ARARs (see ROD Appendix A, p. A-18 & A-32) is not adequately explained, we interpret the applicable or relevant regulations to include the federal Coastal Zone Management Act (16 U.S.C. § 1451 et seq.), the McAteer- Petris Act (Cal. Gov. Code§ 66600 et seq.),the San Francisco Bay Plan (Bay Plan), and the Commission’s federally-approved Coastal Management Program for San Francisco Bay.

the Navy’s compliance with the substantive provisions of the San Francisco Bay Plan.

 

Comment noted.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The IR Site 2 ROD identifies specified substantive provisions of the CZMA and McAteer–Petris Act as relevant and appropriate ARARs. See Attachment 6, Table 5-2 for an evaluation of the DON’s compliance with the substantive provisions of the Bay Plan. Table 5-1 of Attachment 6 will be revised to include all ARARs identified in the ROD.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Jaime Michaels, Coastal Analyst, and Andrew Winetroub, Legal Intern San Francisco Bay Conservation and Development Commission

Therefore, we recommend that future revisions to the RAWP, including Attachment 6, Table 5-1, refer to the above-referenced Commission requirements and any specific policies identified in sections below.

While the Commission’s laws and regulations are recognized in the ROD, their identification is incomplete due to the lack of details regarding relevant policies.  The Commission’s ARARs, as they appear in the ROD, should be supplemented with references to how specific provisions relate to the proposed project and, further, should appear in the next document drafted for remedial design/remedial action at IR-2. The revised RAWP should also note that the Commission’s substantive requirements likely relate to other remediation activities described in the RAWP, including (1) the implementation of a mitigation plan at the northern pond’s southern boundary; (2) the temporary establishment of any off-loading facilities for barges either in the water or at the shoreline;

(3) the removal of weir structures, venting systems, and fencing, and the abandonment of monitoring facilities; and (4) the installation of monitoring and security facilities, including a six-foot-high permanent fence at the eastern and northern site boundaries, monitoring wells, and venting systems (RAWP §§ 5.1-5.12).

Please see responses to the specific comments that follow and Table 5-2 of Attachment 6. The evaluation addresses how the remedial design and remedial action will comply with the substantive provisions of the coastal zone ARARs identified by the Navy in the CERCLA IR Site 2 Record of Decision (ROD) and BCDC in these comments.

The DON has reviewed the Bay Plan policies to determine how they relate to

(1) implementation of a mitigation plan at the northern pond’s southern boundary; (2) temporary establishment of any off-loading facilities for barges either in the water or at the shoreline; (3) removal of weir structures, venting systems, and fencing, and abandonment of monitoring facilities; and

(4) installation of monitoring and security facilities, including a 6-foot-high permanent fence at the eastern and northern site boundaries, monitoring wells, and venting systems. The relevant Bay Plan policies relate only to implementation of the mitigation plan. The DON does not plan to establish off-loading facilities for barges in the water or at the shoreline. Removal of weir structures, venting systems, and fencing and abandonment of monitoring facilities are not expected to affect the bay and, therefore, these policies do not apply.  The remedial design has been revised and currently there is no plan for the 6 foot fence referred to in the comment; therefore, the Bay Plan policies similarly do not apply.

Comment 2. San Francisco Bay Plan and McAteer Petris Act – Tidal Wetlands, Bay Fill, and Mitigation.

According to the RAWP, the proposed placement of cover material at the IR-2 site would result in a loss of 0.89 acres of tidal wetlands at the North Pond (RAWP Attachment 7, § 3.0). Attachments 6 (Draft Environmental Protection Plan) and 7 (Wetland Mitigation Plan) of the RAWP provide information about existing habitat, potential impacts of remediation, and a mitigation plan, which states that on-site tidal

Response 2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Jaime Michaels, Coastal Analyst, and Andrew Winetroub, Legal Intern San Francisco Bay Conservation and Development Commission

wetlands provide resting and foraging areas for migrating waterfowl and habitat for other resident bird species. The plans further state that special- listed species, including California least tern, California clapper rail, and western snowy plover, could potentially locate at the site, but that the remediation project is not anticipated to adversely affect such species (RAWP Attachment 7, §§ 6.1-6.1.3). Proposed mitigation measures include staff training and education programs, wildlife surveys and appropriate construction schedules, the creation of a pickleweed marsh— using a replacement ratio of 1:1— at the North Pond’s southern boundary, and the implementation of a monitoring and corrective action plan for the mitigation site (RAWP Attachment 7).

In general, the mitigation and monitoring plan outline an approach that is typical of successful restoration programs. However, we have a number of questions about the details of the program. To fully evaluate the program, it is essential to know the following:

1)  the range of elevations that support pickleweed in the immediate vicinity (i.e. within the north pond). Page 11-1 states that above -0.2 feet NGVD 29, the restored areas will support primarily pickleweed. However, this elevation is much lower than normally supports picklweed elsewhere in San Francisco Bay. Please explain this discrepancy;

2)  the range of tides experienced at the site and the elevation of Mean Sea Level (MSL), Mean High Water (MHW), Mean Higher High Water (MHHW), and the highest expected tide within the north pond;

 

 

3)  the target habitat types and their respective square foot coverage within the restored wetlands;

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Response to comment 1): Elevations were reported in NGVD29, rather than NAVD88. Converting the elevations to NAVD88 indicates that pickleweed first appears at elevation 2.34 feet, which is just below the MHHW. The main pickleweed community appears starting at MHHW. The RAWP will be revised to show elevations in NAVD88.

Response to comment 2): Navy can estimate MSL, MHW and MHHW based on the closest USCG tidal gauge. The Navy will also use published data including the 2004 tidal study at Site 2 to estimate the highest expected tide, although none of the goals or design elements are tied to that elevation, so it is not clear why that data are needed.

Response to comment 3): The Navy will insert this data into the revised report.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Jaime Michaels, Coastal Analyst, and Andrew Winetroub, Legal Intern San Francisco Bay Conservation and Development Commission

4)  the composition of the uncovered substrate after excavation (e.g. is it bay mud?);

 

 

 

5)  rates of sedimentation within the pond, if any;

 

 

 

 

6)  a grading plan showing the range of elevations proposed at the restored area, slopes and any channels. If the uncovered substrate is not bay mud, and little sedimentation is expected, overexcavating the restored area and backfilling with a thin (six inch) layer of Bay mud has been proven the improve plant colonization of the restored site.

The approach outlined in the event that success criteria are not met is also typical of successful restoration programs. While we appreciate that no invasive cordgrass or pepperweed are currently found at the mitigation site, the Commission generally requires that all nonnative, invasive species be controlled to five percent or less of the vegetative cover to assure that the target species have the best chance of establishment.

Also, restoration in areas that experience muted tidal action (which may be the case for the north pond) have sometimes irrigated restored areas until the plants become established. It is not clear if monitoring would continue until the success criteria are met, for the specified give year period only, or extended for an additional five years if the restoration goals for Year 2 are not met.

Response to comment 4): A test pit that was excavated in the marsh as part of a previous investigation is still usable and reveals a homogeneous composition of mud from the surface to at least 4 feet in depth (well below the level of excavation proposed for this project). No additional soil sampling is proposed.

Response to comment 5): It is not anticipated that sedimentation would occur as a result of tidal processes, but erosion of the upland areas may contribute sediment to the ponded areas. Preparation of a sediment budget is beyond the scope of this study and is not required to implement a CERCLA remedy.

Response to comment 6): The final grading plans are included as Sheets C9-C13 of the Design Drawings included in Attachment 1.

 

 

 

Response to comments regarding success criteria:

The Navy concurs that invasive species should comprise no more than 5 percent of vegetation; Section 11.1 already incorporates a threshold lower than this percentage for the main species. Plan documents will be revised to reflect this comment.

Tidal action may be somewhat muted compared with areas with no levee, but full tidal exchange appears to occur on a diurnal basis in the north pond. The newly excavated marsh area will be inundated under most tidal conditions; therefore, no irrigation is needed. The Navy is obligated to monitor annually and report observations and recommendations at a minimum of every 5 years as long as necessary to provide adequate protection of human health and the environment.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Jaime Michaels, Coastal Analyst, and Andrew Winetroub, Legal Intern San Francisco Bay Conservation and Development Commission

As stated above, the ROD recognized that placing cover material at the North Pond may be necessary, in which case “the Navy will ensure applicable substantive requirements are followed to protect the beneficial uses of San Francisco Bay in compliance with the CZMA” (ROD Appendix A, p. A-18). The Commission’s applicable or relevant requirements include the Bay Plan policies on: (1) Fish, Other Aquatic Organisms and Wildlife, particularly Policy No.1, which states, in part: “... the Bay’s tidal marshes, tidal flats, and subtidal habitat should be conserved, restored, and increased;” (2) Tidal Marshes and Tidal Flats, particularly Policy No.1, which states: “Tidal marshes and tidal flats should be conserved to the fullest possible extent. Filling, diking, and dredging projects that would substantially harm tidal marshes or tidal flats should be allowed only for purposes that provide substantial public benefits and only if there is no feasible alternative;” and (3) Mitigation, particularly Policy No.1, which states, in part: “Projects should be designed to avoid adverse environmental impacts to Bay natural resources such as ... tidal marshes or tidal flats. Whenever adverse impacts cannot be avoided, they should be minimized to the greatest extent practicable.............. Mitigation is not a substitute for meeting the other

requirements of the McAteer-Petris Act,” as well as Mitigation Policies 2 through 8.

Additionally, Section 66605 of the McAteer-Petris Act sets forth criteria for Commission authorization of fill in the Bay (including wetland areas). Specifically, to satisfy statutory requirements, the water area to be filled must be the “minimum necessary” (McAteer-Petris Act § 66605(c)). As such, the Navy should explain why the 0.89 acres of fill are necessary to achieve the purpose of the fill. Other standards that must be satisfied include, but are not limited to, the fill being for a water-oriented use,

Response to specific comments regarding Bay Plan policies.

The discussion below summarizes how the Navy has complied with each of the Bay Plan policies specified in this comment. Refer to Table 5-2 of Attachment 6 for a complete evaluation of how the existing RAWP documents demonstrate compliance with the substantive requirements of the CZMA and San Francisco Bay Plan ARARs as identified in the ROD.

(1) Fish, Other Aquatic Organisms and Wildlife Policy

Policy No. 1 states:

To assure the benefits of fish, other aquatic organisms, and wildlife for future generations, to the greatest extent feasible, the Bay’s tidal marshes, tidal flats, and subtidal habitat should be conserved, restored, and increased.

Implementation of the remedy will comply with the substantive provisions of this policy. The remedy is designed to minimize damage to the tidal marshes, tidal flats, and subtidal habitat and to protect fish, other aquatic organisms, and wildlife. The wetland areas at Site 2 do not support a high diversity or density of invertebrates or mammals, and although the wetland ponds may be used by a variety of avian species, they do not support aquatic vegetation or significant invertebrate and fish populations. However, the DON will implement reasonable measures to ensure adequate protection of ecological receptors during excavation and cover placement, and the remedy will ultimately result in improved habitat.

The DON will also comply with the additional Fish, Other Aquatic Organisms and Wildlife policies. Policy No. 2 states that specific habitats that are needed to conserve, increase, or prevent the extinction of any native species, species threatened or endangered, species that the California

 

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the fill benefits exceeding the public detriment from the loss of water, and the fill being such that is minimizes harmful effects to the Bay (McAteer-Petris Act § 66605(a), (d)). In making this request, we also recognize that “public health, safety or welfare” is a statutorily established justification for fill placement (McActeer-Petris Act § 66632(f)(1)).

In light of impacts to 0.89 acres of tidal wetlands, the Commission staff recommends that the Navy consider how the above-cited Commission ARARs would be followed in capping the former landfill as described in the RAWP. We also recommend that, if feasible, consideration be given to an alternative cover approach that minimizes impacts to existing tidal wetlands.

Department of Fish and Game has determined are candidates for listing as endangered or threatened under the California Endangered Species Act, or any species that provides substantial public benefits, should be protected.

The DON has identified the California Endangered Species Act as an ARARs and will comply with the substantive provisions of the requirements identified. The habitats of listed species will be protected during remediation and after it is completed through the mitigation measures identified in Attachment 7. The DON will coordinate with the USFWS and California Department of Fish and Game during remedial design and construction to ensure compliance with the substantive provisions of these ARARs. As described in Attachment 6, the DON will implement measures to avoid, minimize, and mitigate for potential impacts from remedial activities.

(2) Tidal Marshes and Tidal Flats Policy

Policy No. 1 states:

Tidal marshes and tidal flats should be conserved to the fullest possible extent. Filling, diking, and dredging projects that would substantially harm tidal marshes or tidal flats should be allowed only for purposes that provide substantial public benefits and only if there is no feasible alternative. As described immediately above, tidal marshes and tidal flats will be conserved to the fullest extent possible and the remedy complies with the Tidal Marshes and Tidal Flats policies.

Tidal marshes and tidal flats will be conserved to the fullest possible extent and the filling of 0.89 acres of tidal wetland will provide substantial public benefits as explained below. The evaluation presented in Section 5.6.6.1, and Attachment 1, and Section 3, Attachment 7, of the Remedial Design/Remedial Action Work Plan (RD/RAWP) establishes that there is

 

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no feasible alternative to installing a soil cover that will anchor into the margin of the intertidal zones and wetlands at IR Site 2. Bulldozing the landfill back from the wetland margin in an effort to consolidate the footprint eliminates destruction of the wetland margin, in theory, but the re-grading and placement of contaminated material creates unnecessary risk for releases.

The larger mass being moved during consolidation has a similar potential to disturb the surrounding wetlands, there is unnecessary potential for worker exposures, and the consolidation approach had significant cost and schedule increases. The approved remedy incorporates appropriate actions to minimize adverse impacts to San Francisco Bay such as erosion controls (Attachment 8), and on-site mitigation of lost wetlands with equal or better value.  The total affected wetland area is 0.89 acre of tidal wetland. The success criteria are outlined in Section 11 of Attachment 7.

The remedy also complies with the other Tidal Marshes and Tidal Flats policies, which include:

  • Thoroughly evaluating any proposed filling, diking, or dredging project to determine the effect of the project on tidal marshes and tidal flats, and designing projects to minimize, and if feasible, avoid any harmful effects
  • Designing projects to avoid or minimize adverse impacts on any transition zone present between tidal and upland habitats
    • Including clear long- and short-term biological and physical goals, success criteria and monitoring of ecosystem restoration projects

 

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Through the CERCLA process, and particularly through the feasibility study, the DON thoroughly evaluated the remedy and considered the impact on tidal areas. The DON, with the approval of the regulatory agencies, selected this remedy, which has been designed to minimize any harmful effects. In addition, the DON will monitor the success of the mitigation as outlined in Attachment 7, Section 11.

(1) Mitigation Policy

Policy No.1 states:

Projects should be designed to avoid adverse environmental impacts to bay natural resources such as to water surface area, volume, or circulation, and to plants, fish other aquatic organisms and wildlife habitat, subtidal areas, or tidal marshes or tidal flats. Whenever adverse impacts cannot be avoided, they should be minimized to the greatest extent practicable. Finally, measures to compensate for unavoidable adverse impacts to the natural resources of the bay should be required. Mitigation is not a substitute for meeting the other requirements of the McAteer-Petris Act.

The evaluation presented in ROD verifies that there is no feasible alternative to addressing site contaminants within the intertidal zones and wetlands at IR Site 2 in a manner that completely avoids disturbance. The Navy proposed on-site mitigation for the tidal marshes in the IR Site 2 ROD. Damage to other natural resources of the bay, including on-site tidal flats, would be avoided because excavation would not extend into shoreline areas located below mean sea level. The Navy will perform mitigation in accordance with the substantive provisions of Part IV of the San Francisco Bay Plan.

 

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Included in the RAWP as Attachment 7 is a detailed wetlands mitigation program intended to address any adverse impacts. Approximately 2.27 acres of seasonal wetland and 0.89 acre of tidal wetland will be filled during construction and will be replaced with an equivalent area of similar or higher quality wetlands outside of the landfill cover but within the Site 2 boundary. The wetlands have been avoided to the extent possible, but given the capacity and design requirements of the landfill, the remaining wetland impacts are considered unavoidable.

In addition, Attachment 6, Section 6.3 sets forth additional project mitigation measures, which include:

  • Training all personnel who will work at the site during construction
  • Ecological surveys that will be conducted by a qualified biologists
  • Documentation and reporting including a preconstruction survey report

Policy No. 2:

Individual compensatory mitigation projects should be sited and designed within a bay-wide ecological context, as close to the impact site as practicable to: (1) compensate for the adverse impacts; (2) ensure a high likelihood of long-term ecological success; and (3) support the improved health of the bay ecological system.

Determination of the suitability of proposed mitigation locations should be guided in part by the information provided in the Baylands Ecosystem Habitat Goals report.

 

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The compensatory mitigation is sited within Site 2 in an area as close as practicable to the impact area. The mitigation will compensate for adverse impacts, and monitoring will be implemented to ensure a high likelihood of long-term ecological success (See Attachment 7, Section 11).

Policy No. 3:

When determining the appropriate location and design of compensatory mitigation, the Commission should also consider potential effects on benefits provided to humans from bay natural resources, including economic (e.g., flood protection, erosion control) and social e.g. aesthetic benefits, recreational opportunities.

The remedy has been designed to address erosion control (see Attachment 8) and to accommodate potential recreational uses of the site as a trail.

Policy No. 4:

The amount and type of compensatory mitigation should be determined for each mitigation project based on a clearly identified rationale that includes an analysis of the probability of success of the mitigation project; the expected time delay between the impact and the functioning of the mitigation site; and the type and quality of the ecological functions of the proposed mitigation site as compared to the impacted site.

Section 11 of Attachment 7 addresses this policy.

 

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Policy No. 5:

To increase the potential for the ecological success and long-term sustainability of compensatory mitigation projects, resource restoration should be selected over creation where practicable, and transition zones and buffers should be included in mitigation projects where feasible and appropriate. In addition, mitigation site selection should consider site-specific factors that will increase the likelihood of long-term ecological success, such as existing hydrological conditions, soil type, adjacent land uses, and connections to other habitats.

Section 11 of Attachment 7 addresses this policy. Policy No. 6:

Mitigation should, to the extent practicable, be provided prior to, or concurrently with those parts of the project causing adverse impacts.

Mitigation will be conducted as part of the remediation process and is expected to be conducted concurrently.

Policy No. 7:

When compensatory mitigation is necessary, a mitigation program should be reviewed and approved by or on behalf of the Commission as part of the project. Where appropriate, the mitigation program should describe the proposed design, construction and management of mitigation areas and include:

(a)    Clear mitigation project goals

(b)    Clear and measurable performance standards for evaluating the success of the mitigation project, based on measures of both composition and function, and including the use of reference sites

 

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(c)    A monitoring plan designed to identify potential problems early and determine appropriate remedial actions. Monitoring and reporting should be of adequate frequency and duration to measure specific performance standards and to assure long-term success of the stated goals of the mitigation project

(d)    A contingency plan to ensure the success of the mitigation project, or provide measure to ensure alternative appropriate measures are implemented if the identified mitigation cannot be modified to achieve success. The Commission may require financial assurances, such as performance bonds or letters of credit, to cover the cost of mitigation actions based on the nature, extent and duration of the impact and/or the risk of the mitigation plan not achieving the mitigation goals

(e)    Provisions for the long-term maintenance, management and protection of the mitigation site, such as a conservation easement, cash endowment, and transfer of title.

Attachment 7 complies with the substantive provisions of this policy. Because the DON is not required to comply with the procedural requirements under CERCLA, the DON is not required to obtain formal approval of the mitigation plan.

Policy No. 8:

Mitigation programs should be coordinated with all affected local, state and federal agencies having jurisdiction or mitigation expertise to ensure, to the maximum practicable extent, a single mitigation program that satisfies the policies of all the affected agencies.

The mitigation program has been coordinated with all appropriate local, state, and federal agencies through the CERLCA process.

 

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California Government Code Section 66605 (McAteer-Petris Act):

The Legislature further finds and declares:

(a) That further filling of San Francisco Bay and certain waterways specified in subdivision (e) of Section 66610 should be authorized only when public benefits from fill clearly exceed public detriment from the loss of the water areas and should be limited to water-oriented uses (such as ports, water- related industry, airports, bridges, wildlife refuges, water-oriented recreation, and public assembly, water intake and discharge lines for desalinization plants and power generating plants requiring large amounts of water for cooling purposes) or minor fill for improving shoreline appearance or public access to the bay;

(c)  That the water area authorized to be filled should be the minimum necessary to achieve the purpose of the fill;

(d)  That the nature, location, and extent of any fill should be such that it will minimize harmful effects to the bay area, such as, the reduction or impairment of the volume surface area or circulation of water, water quality, fertility of marshes or fish or wildlife resources, or other conditions impacting the environment, as defined in Section 21060.5 of the Public Resources Code;

Attachment 7 explains in detail the wetlands mitigation program. It explains that the wetlands that will be filled during the project total 0.89 acre and will be replaced with an equivalent area of similar or higher-quality wetlands.

The justification for filling the wetlands has been documented throughout the CERCLA process and has been approved by the regulatory agencies.

The filling of the 0.89 acre satisfies the substantive requirements of Section 66605(a) and (d) and is necessary to implement the remedy. Ultimately, the fill will result in increased protection of human health and the environment

because the site will be remediated and the wetlands will be of higher quality.

 

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The fill is necessary to implement the remedy. Remediating the contamination at the site is a public benefit that exceeds the public detriment from the loss of water. The DON has considered the McAteer-Petris Act as an ARAR throughout the CERCLA process, and the remedy was designed to comply with the substantive requirements. The selected remedy was developed and selected with the approval of the regulatory agencies and, at this time, the DON does not plan to develop an alternative cover approach.

California Government Code Section 66632(f)(1):

(f) The commission shall take action upon an application for a permit, either denying or granting the permit, within 90 days after it files the application. The permit shall be automatically granted if the commission shall fail to take specific action either denying or granting the permit within the time period specified in this section. A permit shall be granted for a project if the commission finds and declares that the project is either (1) necessary to the health, safety or welfare of the public in the entire bay area, or (2) of such a nature that it will be consistent with the provisions of this title and with the provisions of the San Francisco Bay Plan then in effect.

Because permits are not required for CERCLA actions, the DON is not required to comply with the permit requirement of this section. The DON recognizes that the public health, safety, or welfare is one of the statutory justifications for fill placement. The DON believes that it has established through the CERCLA process the justification for the remedy.

 

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Comment 3. San Francisco Bay Plan and McAteer Petris Act – Aquatic Resources, Dredging, and Water Quality.

According to the RAWP, landfill cover material would be transported to IR-2 site via barges (RAWP § 5.6.4). The RAWP illustrates the general locations for temporary barge and material off-loading, but does not provide details about the establishment of any related facilities (RAWP Figure 5-1). If dredging, pile-driving, or in-water excavation of material are needed to facilitate such operations, we recommend that the Navy consider how the Commission’s requirements would be followed with particular focus on the following Bay Plan policies: (1) Fish, Other Aquatic Organisms and Wildlife Policy No. 1 (cited above) and No. 4, which states, in part, that the Commissions should consider project- related recommendations of the state and federal agencies for protecting resources; (2) Water Quality Policies Nos. 1 and 2, which, respectively, provide, in part: “Bay water pollution should be prevented to the greatest extent possible” and “The policies, recommendations, decisions, advice and authority of the State Water Resources Control Board and the Regional Board should be the basis for carrying out the Commission’s water quality responsibilities;” and (3) Dredging Policy No. 1, which states, in part: “Dredging and dredged material disposal should be conducted in an environmentally and economically sound manner,” and, if applicable, Dredging Policy Nos. 2 through 4.

Response 3. Barges and soil transportation and off-loading operations associated with IR Site 2 will not involve dredging, pile driving, or excavating. The barges will drop two anchors (e.g., concrete blocks on ropes) to temporarily stabilize the craft during off-loading, a safety necessity.

Therefore, the Fish, Other Aquatic Organisms and Wildlife Policy No. 1 and No. 4, Water Quality Policies Nos. 1 and 2; and Dredging Polices 1- 4 are not relevant and appropriate.

 

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Comment 4. San Francisco Bay Plan and McAteer Petris Act – Public Access and Views.

The RAWP states that the proposed remediation plan would involve the removal and/ or abandonment of existing facilities, including a weir, fencing, venting and monitoring structures, and the installation of new monitoring wells, probes and venting facilities, and a six-foot-high fence at the former landfill (RAWP §§ 5.5-5.8.4). The document also states that, in planning for site remediation, a future shoreline public path for low-impact recreation activities is envisioned (see RAWP §§ 2.3, 5.8.1). When planning for this recreational path, please be aware that Section 66602 of the McAteer-Petris Act establishes “maximum feasible public access” as the applicable standard for projects along the shoreline.

Ensuring public access to the Bay is a cornerstone of the Commission’s law, so we look forward to the development of further plans that satisfy this standard.  Additionally, the Bay Plan Appearance, Design, and Scenic Views Policy No. 2 states, in part: “All bayfront development should be designed to enhance the pleasure of the user or viewer of the Bay.” Also relevant is the Bay Plan Public Access Policy No. 4, which requires, in part: “Public access should be sited, designed and managed to prevent significant adverse effects on wildlife.” Lastly, the Bay Plan Public Access Policy No. 5 states, in part: “Public access should be sited, designed, managed and maintained to avoid significant adverse impacts from sea level rise and shoreline flooding.”

We understand that the future shoreline trail at the IR-2 site is in the early stages of development and that the RAWP is not intended to provide detailed information about trail design. However, The Commission staff recommends that, if feasible, the Navy consider locating the remediation

facilities proposed for abandonment or installation outside of the area

Response 4. Please see response to DTSC General Comment #2 in reference to the fencing design, the response to EPA General Comment #36 in reference to the vent design, and the response to DTSC General Comment #1 in reference to sea level rise. Please also see response to BCDC Comment #1 referencing the weir and monitoring structures and wells. Also see Table 5-2 of Attachment 6.

The Navy, in this remedial design, has removed fencing, other than symbolic, and has been responsive to community concerns regarding access. The Navy has complied with the cited substantive provisions of the Bay Plan in addressing the fence issue.

 

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envisioned for the shoreline path. In addition, if feasible, we recommend that any planned adjacent remediation facilities, including fencing or monitoring structures, be located so as to minimize their impact— visually and physically—on the experience of those using the trail.

Additionally, we recommend that, as illustrated in Figures C-9 to C-13 of the RAWP, proposed fencing at the former landfill area be installed with openings at the northwest and southeast corners of the IR-2 site for appropriate connections with future neighboring open space areas and with areas managed to sustain habitat or sensitive wildlife, including the special-listed California least tern. Lastly, we recommend that the area and dimensions envisioned for a shoreline trail be adequate to adapt to anticipated sea level rise. Therefore, we recommend that future revisions to the RAWP (or related documents) provide greater specificity about the future shoreline trail boundaries, remediation structures (including height, dimensions, and construction materials) proposed for placement within or adjacent to those boundaries, and strategies for minimizing physical or visual impacts of permanent remediation facilities on those using the future shoreline trail.

 

 

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INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comments Dated: July 9, 2012

COMMENT

RESPONSE

Draft Remedial Action Work Plan – May 2012

Comment 1. 5.8.3 Installation of Landfill Gas Passive Vent System

/referenced Sheets C-16 and C-17.

It is strongly hoped that there are other ways to vent methane at Site 2 rather than using 30 PVC pipes “a minimum of ten feet above the ground surface” along the north and east sides of the property. The pipes will serve as roosts for raptors which already use similar structures at the site. Are there other solutions that would not provide high perches? In addition, the pipes provide a significant blemish on a natural setting, impairing unique and beautiful views with a reminder of its Superfund status.

Response 1. Please see Response to EPA General Comment #36. Anti- perching devices have been added to the vent specification, as required.

Comment 2. 5.8.4 Installation of Permanent Fencing and Institutional Controls/referenced Sheet D-6

It is not clear how the refuge properties where Least Terns nest and adjacent lands and ponds, including Site 2, will be finally defined. Fencing will be needed to provide a barrier to public access along the northern border of Least Tern habitat running east and west, in addition to the fence currently on the east side running north and south. These barriers should provide the “institutional controls” needed for Site 2. A fence within a fence shouldn’t be necessary. Once again, Site 2 design is hoped to reduce raptor perches and minimize visual interruption to Alameda’s most spectacular views.

Response 2. Please see Response to DTSC General Comment #2.

 

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Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

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Attachment 6, Environmental Protection Plan

Comment 3. 6.1.1 Upland.

Plants mentioned in this habitat description are minimal. A table of plants would have enhanced the ability to identify habitat values for the site.

The multi-species acacia stand (northwest corner) and willows (east of tidal pond) adds another dimension to the uplands habitats of Site 2 that are not described here. Delineations are not described.

Response 3. The RAB has worked with the Navy to re-define the hydroseed mix to be applied to the soil cover. Rather than a generic California native plant list, the RAB has participated in selecting native grassland species endemic to the East Bay and Alameda for the cover. In addition, a lupinus species currently living outside the fence on the east side of the site (2 specimens) will be identified, flagged, and protected to encourage its propagation, to the extent practicable.

The area of the Site that will be covered with the soil cover will be cleared (vegetation will be removed by cutting them at the ground surface, and mulching the detritus) so all plants currently on site that will be under the soil cover will be removed.

Comment 4. 6.1.2 Wetlands and Ponds.

A description of wetlands, as in the prior section regarding uplands, does not occur which left this reader confused. It is important to identify at least the types of wetlands found in each of the ponded areas, salinities, and associated vegetation. Delineations are important, but should not be the entire focus.

Response 4. The wetlands delineation report was in Attachment 7 in CD form. It describes the wetlands. Navy complied with the substantive requirements of the ACE wetlands identification procedures.

Comment 5. 6.1.3 Vegetation.

Limited discussion mentions no wetland species. An organized pattern of reporting would be helpful in a document of this dimension and importance.

Response 5. See the Wetlands Delineation Report, Attachment 7 of the RAWP, CD.

 

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Comment 6. 6.2 Fish and Wildlife/Threatened, Endangered, and Sensitive Species.

The statement that “[n]o avian foraging at ponds was observed during the DON’s RI sampling activities of 2004/2005 (Battelle and BBL 2006),” is very misleading. The document does not provide date(s) or methods for observation, length of time or specific purpose of visit. Foraging is almost always observed on waters or along waters of both ponds, which serve as a valued wildlife resource. Site 2 currently hosts a complex food chain, which includes foraging and nesting of significant number of species along the wetland and in upland areas.

A short list in the text of four very common avian species is not helpful and misleading. Site 2 is important habitat for numerous species and breeding habitat for Red-winged Blackbirds, Black-necked Stilts, ducks, Savannah Sparrows, American Goldfinch (using trees), and more. Both Sora and Virginia Rail have been detected from the high berm along wetlands without using tapes. We suspect many birds are undetected even by twice monthly surveys since April 2004 made from inside a vehicle on the berm. DON receives annual data. FAWR surveys offer a much more comprehensive view of Site 2 avian activity and the data are available upon request.

The document states that “[t]he habitat also is suitable for the red fox, but this species has not been specifically observed at this site,” a year or two ago, a refuge biologist did observe a red fox run under the fence from the eastern perimeter road into Site 2.

Without extensive trapping it should not be assumed that Salt Marsh Harvest Mouse (SMHM) is absent from Site 2. Small mammals can survive being water-borne for some time; rafting (riding floating debris)

is possible; and it is likely that marshes in West Alameda historically

Response 6.

 

The reference to the RI report, Battelle and BBL, 2006, directs the reader to the backup details requested by the commenter. Foraging almost certainly takes place at the Site, but it was not observed at the time of the study.

 

 

 

 

 

The full list of birds observed on site is given in Table 6-2 of the EPP, Attachment 6. Text has been revised to include a reference to Table 6-2.

 

 

 

 

 

 

 

During the referenced studies, no foxes were observed. Navy is aware of the anecdotal observations (including Least Tern Colony predation) and will be sensitive to the potential presence of Red Fox.

Surveys for the Harvest Mouse including trapping have been conducted at IR Site 2 in 1995 (PRC Environmental Management, Inc.) and 2009 (H. T. Harvey and Associates). In both cases none were identified. See EPA response 37.

 

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hosted SMHM, being pushed ever westward as fill was added.

We understand that small mammal trapping was done at Site 2. If this is the case, please confirm whether trapping is occurring and the methods used. If trapping is occurring, why weren’t results included in the document?

The document states that “[s]cheduled remedial activities planned for the site are not anticipated to have an adverse effect on the listed species.” Species mentioned here are California Least Tern, California Clapper Rail, Western Snowy Plover. The Salt Marsh Harvest Mouse is not mentioned. We strongly challenge the statement regarding all but the Western Snowy Plover.

  1. California Least Tern: Avian and mammalian Least Tern predators that rely on Site 2 will be displaced by the important and necessary work. The consequences to Least Terns will require additional management. Site 2 currently offers foraging to Northern Harrier, Red-tailed Hawk, White-tailed kite, American Kestrel, Peregrine Falcon, Sharp-shinned and Cooper’s Hawks. With the removal of vegetation and expected prey, these predators will be forced to put heavier foraging on outlying areas, including the Least Tern colony. Red fox has been seen at Site 2 once. Gray fox has been observed nearby at least twice. Mitigation could be additional Wildlife Service funding. The impact should be a topic of discussion. Fox presence is documented in Least Tern annual reports.
  2. Salt Marsh Harvest Mouse: The document does not show that the Salt Marsh Harvest Mouse does not exist at Site 2 which

offers excellent and adequate habitat. If it does occur on the site,

 

 

 

 

 

 

 

 

 

 

 

Please refer to page 6-4 of Attachment 6 to understand the Navy’s current agreement with USFWS to provide Least Tern Colony Management and protection, including from predation.

 

 

 

 

 

 

 

 

 

See previous response regarding Harvest Mouse.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

impacts will occur and mitigation could be required.

3. California Clapper Rail This rail has not been heard or seen during twice monthly surveys, and may not be impacted because of its absence and that habitat is not perfect. That most of local invasive cordgrass has been removed and that most local Clapper Rail habitat lost, this species should be given some consideration. A small effort to detect it specifically would be appropriate. Dawn listening or tapes played are methods available.

It is an omission to exclude any discussion of aquatic vertebrates and invertebrates. Fish are mentioned only in the headline, but not in the text. Invertebrates and reptiles of the uplands are an omission also.

 

Prior surveys have yet to report a Clapper Rail on site, though they have been reported within 3 to 4 miles away. The Navy is aware of the shy nature of Rails and that they are rarely seen, so the pre-construction survey activities will be sensitive to this protected bird

 

 

 

An amphibian survey has been included as part of the pre-construction activities. Attachment 6 text is revised to refer to prior aquatic studies done at Site 2.

Comment 7. 6.3.2 Ecological Surveys

Reference to a “qualified biologist” does not say what the qualifications are. We hope that it means that the biologist(s) will have training in multiple areas of Bay Area biology and ecology, and years of local field investigation experience for all habitats found at Site 2. The biologist(s) should also have training on appropriate methods for collecting and reporting data to bring the best possible results and understanding of habitat use and ecological function of the valuable site. It is sometimes the case that the DON brings scientists from other areas and even out of state. In the case of ecological surveys, this does not offer the best results. We suspect it is more costly, as well.

Response 7. Comment noted. A “qualified biologist” will have experience monitoring and identifying the special status species mentioned in the report, as well as experience monitoring in tidal wetlands, and be able to set up a monitoring program for these species.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comment 8. 6.3.6 Construction Monitoring.

It is hoped that the biologist(s) will have qualification stated in 6.3.2. Having a “clearance survey” done 1 day “prior to the onset of each phase of construction activities” is short sighted. One to 7 days is stated. As a courtesy to workers and hiring equipment, 3 or 4 to 7 days prior to activities seems more reasonable in case cancellation is needed. It would also likely take more than one day to conduct and report all suggested surveys.

Response 8. The requirement is one week prior to the start of the first phase, and one day before each subsequent phase. Because the first phase involves vegetation clearing most if not all of the upland habitat, the schedule is not unreasonable.

Comment 9. Table 6-1 Mammalian Species Observed at IR Site 2.

That the list of mammals does not include California vole, house mouse, opossum, Salt Marsh Harvest Mouse given perfect habitat for this endangered species, gray fox, red fox, mule deer, and dog is a considerable omission. Site 2 could potentially host all of these mammals. A deer has lived on Alameda Point for over a year, but not seen recently.

The table should be accompanied with methods for detection and dates of field work.

Response 9. Assessment for the Harvest Mouse has been conducted and reports published that conclude the SMHM is not present. Please see Response to EPA Comment #37.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comment 10. Table 6-2 Avian Species Observed at IR Site 2.

Neither the table nor text (6.2) has information about “sampling” methods. Text (6.2) refers to avian sampling during “the DON ‘s IR sampling activities of 2004/2005 (Battelle and BBL 2006)”, but numbers of Caspian Terns (1086 birds in 6 visits) on the Table is not in line with FAWR twice monthly surveys. These high numbers averaging 181 Caspian Terns per visit (with none in 4 visits?) would not likely happen unless there is a breeding colony. If surveys were done when Caspian Terns nested at Site 2 these numbers would make more sense. Succession caused habitat changes that forced them elsewhere. It appears that there are 10 “sampling” dates, but that isn’t stated clearly. Numbers and species in the table raise a few questions. For example seeing 20 Brandt’s Cormorants in 2 visits is unlikely. They are not often seen. We are happy to see one in a year or two. California Gulls are showing very high numbers on this table. Even when this gull had a sizeable colony at the south end of the north/south runway near the pier, Site 2 would not attract 2741 birds in 8 visits. It did not provide appropriate habitat or foraging resources. Unfortunately, these numbers without an explanation raise questions about the data that causes concern for the whole body of work.

The table should be accompanied with methods and dates of field work.

Response 10. The information regarding sampling methods and dates of field work that the reviewer requests to be included in Table 6-2 are cited by referral to the Battelle and BBL, 2006 IR document.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Attachment 7, Draft Wetland Mitigation Plan

Comment 11. 5.0 Habitat Types and Values, Open Water/Mudflat.

It is appreciated that the non-tidal South Pond is seen as a “high tide refugia for wading shorebirds and low tide refugia for ducks and geese.” And that the pond “is available as foraging habitat year-round.” And “…in late October (2011?), an estimated 500 birds representing eight species were observed foraging in this pond and mudflat.” This corrects the impression of no foraging created in Attachment 6.

Response 11. Comment noted.

Comment 12. 5.0 Habitat Types and Values, Seasonal Wetlands.

There are assumptions made about the patchy and isolated seasonal wetlands on the north and northeast corner of the site, suggesting “access to them by small mammals is very restricted; therefore their value as habitat is similarly restricted. It is important to consider them as accessible and valuable seasonal wetlands for avian fauna. No matter how access is limited by development and fencing, ducks and shorebirds do use these waters in winter. Patches of inland water appear without rainfall, during some high tides along the Perimeter Road adjacent to Site 2, just west of the curve heading north and then west. The small ponds are used by breeding Killdeer and American Avocets which nest on the shores. The hydrology of this water raises curiosity. Is there an explanation?

Response 12. Comment noted. Wetlands have been delineated using U.S. Army Corps of Engineers protocols.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comment 13. 5.0 Habitat Types and Values, Tidal Wetland.

We do not understand the sentence, “All other pickleweed habitat does not meet hydrology criteria needed for a wetland designation to be applied.” Isn’t Salicornia spp. a “wetland indicator”.

The Long-billed Dowitcher mentioned is unusual to rare at Site 2. Identification of dowitchers is very difficult and is traditionally made by vocalization in the field. Table 6.2 Avian Species Observed at IR Site 2 lists Short-billed Dowitcher, which is expected in Central SF Bay, but it is safest to call it dowitcher spp. unless clearly heard.

Response 13. Please see response to Water Board comment a-1, page 66, for clarification regarding the pickleweed. Comment noted regarding Dowitcher spp.

Comment 14. 6.1.1 California Clapper Rail.

Again, the presence or absence of Clapper Rails at Site 2 should not be assumed. Loss of habitat locally due to invasive cordgrass removal has forced rails to seek other sites for survival. The Elsie Roemer Bird Sanctuary in recent years hosted breeding Clapper Rails and no longer serves them well. The size of the sanctuary is not any bigger than Site 2, and Site 2 would be nearest habitat. Young Clapper Rails seeking new territories can be found in lesser habitats, including rip-rap.

6.1.2 Western Snowy Plover

Not expected at Site 2.

6.1.3. California Least Tern

Not expected to use Site 2 under current conditions except in transit.

Response 14. Comment noted.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comment 15. 6.1.4 Salt Marsh Harvest Mouse.

For reasons stated above (Attachment 6, section 6.2), there should be an effort to confirm the absence of the Salt Marsh Harvest Mouse before making assumptions. Once again, habitat is suitable; these mice can raft and swim, and could have existed historically and moved just ahead of westward filling activity.

Response 15. Please see Response to EPA Specific Comment #37.

Comment 16. 10.1 Seasonal Wetland Mitigation and Figure 2.

It is suggested that the South Pond or Seasonal Wetland is comprised of fresh water both in text and Figure 2. It is more to be salt water or at least brackish water as the primary associated vegetation is pickleweed, a salt water indicator. No fresh water wetland flora indicators have been named. Have salinity tests been made? If not, the salinity of this pond is essential before habitat type can be identified. There may be a hydrological explanation for brackish conditions in this pond that appears to have no tidal influence.

Response 16. Comment noted. No further testing is required.

Comment 17. The Project Schedule in the first part of the document appears to be aimed at finishing in April 2013 before the Least Tern season begins, but healing of Site 2 and maturation of habitat to serve predators will take longer, if not years. We want to express concern for migrating raptors as well as other species, White-tailed Kites, Say’s Phoebe, Western Meadowlark, and more which rely on Site 2 for the winter. We have no suggestion for mitigation, but wish that biologists would have offered some discussion of the loss to these species and resident animals during the work. Without reintroduction, it isn’t clear how small mammals, for instance, will reestablish themselves. It would be helpful for science and future projects of this kind to conduct pre project small mammal-sampling testing and annual post small mammal sampling until it matches the pre-sampling rates.

Response 17. The Salt Marsh Harvest Mouse Survey in 2009 (H. T. Harvey and Associates, 2009) trapped over 130 house mice in a 10-day period in wetland areas outside of the IR Site 2 construction area. This is a good indication the areas around IR Site 2 have mammal populations to supplant what is lost during construction and to migrate to IR Site 2 once construction is complete.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Leora Feeney, Co-chair of Friends of the Alameda Wildlife Refuge

and Mike Lynes, Conservation Director, Golden Gate Audubon Society

Comment 18. There is a rare opportunity to see how long it takes for a mature and complex habitat to return to this disturbed area. Can biological recovery be a component, measured and reported in the final documents by the DON? Can this be done with DON funding, grant funds? Or volunteers?

Response 18. The definition of success is discussed in the Wetlands Mitigation Plan, Attachment 7, Section 11.

Comment 19. The spring of 2013 may find ground nesting colonial species of birds such as Caspian Tern, California Gull, Snowy Plover or even Least Tern attracted to breed at Site 2. Has any thought been given to this possibility; how this might impact the project; and what steps would be made?

Response 19. EPP and WP require a biologist to monitor conditions. The appropriate response will be taken once the situation is observed. State and regulators will be notified when appropriate.

Comment 20. The culvert that now serves the tidal pond (North Pond) at Site 2 has suffered a log/debris jam, which took considerable effort to correct using heavy equipment forcibly pulling large and rigid items through the culvert. WE wonder about its current condition and strength. Does this culvert have a functioning tide gate? Is one needed? Will the culvert’s condition maintain long term tidal action to the North Pond sustaining tidal wetlands? Will the culvert, over time, support the berm that runs over it. If necessary wouldn’t it be best to repair or replace the culvert during the extensive efforts of the Remedial Action Work?

Response 20. Please see Response to EPA General Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Paul Stanton Kibel

Center on Urban Environmental Law (CUEL) Co-Director Golden Gate University School of Law

Comments Dated: July 7, 2012

COMMENT

RESPONSE

Comment 1. Chain Link/Barbed Wire Fencing for Site 2 and Above- Ground Gas Vents Network.

In CUEL’s previous submissions to the City of Alameda, including our September 2011 booklet referenced above, CUEL emphasized that the planning for the federal portions of Alameda Point and the City portions of Alameda Point are necessarily inter-related. That is, if the federal portions of Alameda Point are planned as beautiful and scenic landscapes, with grant vistas, waterfowl habitat and recreational opportunities, this will contribute greatly to the prospects for a successful redevelopment of the City Portions of Alameda Point. People will want to live and work in and visit Alameda Point to take advantage of these magnificent open space amenities. Conversely, however, if the federal portions of Alameda Point are perceived as polluted, as dangerous, as ugly, as an eyesore -- the federal portions will remain a stigma for Alameda Point. The federal portions will embody and perpetuate perceptions that Alameda Point is a toxic wasteland and a blight.

At the late May 2012 Alameda Point RAB meeting, the Navy unveiled a series of proposed permanent cleanup remedies that would unfortunately create the eyesores and stigma that threaten the City’s redevelopment plans. More specifically, in the most scenic area of the federal portions, along the edge of San Francisco Bay and immediately adjacent to wetlands in the area known as Site 2, the Navy proposed to install a 6- foot high chain link exclusionary fence with barbed wire on top around 110 acres. In addition, the Navy has proposed installing a network of 30

Response 1. See Response to DTSC Comment #2 regarding the fencing. Please see Response to EPA General Comment #36 regarding the venting.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Paul Stanton Kibel, CUEL Co-Director Golden Gate University School of Law

10-foot high methane gas vents. This fence and these gas vents would obstruct and degrade the viewsheds and landscapes on the federal portions of Alameda Point.

To provide the Navy, BCT staff and the public with a sense of the adverse scenic/viewshed impacts that would result from these proposed structures, CUEL’s colleagues at the UCLA Landscape Architecture Department have prepared full color landscape depictions of views across Site 2 with and without the proposed fencing and vents. These landscape depictions are attached as Exhibit C to this letter.

CUEL’s analysis suggests an absence of technical support for the Navy’s claim that the current proposed fencing and gas vents network are needed because these 110 acres were previously a landfill. Throughout the San Francisco Bay Area there are many examples of former landfills that have been re-purposed for open space and habitat that do not include exclusionary fencing and that do not include 10-foot high gas vents (such as Shoreline Park in Mountain View, Oyster Point Park in San Leandro and Cesar Chavez Park in Berkeley). Further, and specifically in regard to the proposed network of gas vents, there is the alternative of installing a below grade/subsurface piping network to collect and transport methane gas to a single (or limited number) of venting locations (instead of littering the landscape with 30 towering above-ground gas vents).

To explore these alternatives, CUEL retained its own environmental consultants, Pangea Environmental Services Inc. (Pangea), to evaluate the Navy’s proposed fencing and vents and compare this approach with other landfill-to-open space sites in the region Pangea’s report, a copy of which is attached as Exhibit D to this letter, identifies several alternatives to what the Navy has proposed that are protective of public health and the environmental..

 

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Paul Stanton Kibel, CUEL Co-Director Golden Gate University School of Law

In regard to Shoreline Park in Mountain View, Oyster Point Park in San Leandro and Cesar Chavez Park in Berkeley, Pangea noted: “The interviewees all reported that they could not recall encountering any vandalism or other damage associated with public use to either monitoring wells/vapor probes, landfill cover materials or landfill gas venting systems during the periods (generally exceeding a decade) for which they had roles in managing the landfills.”

In regard to the configuration of the gas vents, Pangea found: “Although [the Navy’s initial proposal] is likely the cheapest solution to venting Site 2, it would have a significant negative visual impacts that conflicts with the proposed future land use of open space and recreational uses at a location where scenic vistas are a substantial aspect of that land use ...

The current passive vent configuration design should be reviewed and revised based on proposed landfill geometry and current gas generation estimates to ensure that the venting is optimized to employ the minimum number of vents necessary ... For example, could the system be re- engineered to run slanted subsurface vent pipes upslope to common outlets, using the topography of the landfill berm slope to disguise part of the vents and adjusting spacing and vent diameters to compensate for such design and still allow for adequate venting. Passive venting could be enhanced with a wind-activated roof turbine fan or similar (or a solar- powered fan) to place a small vacuum on the piping network. Such a vacuum may allow further consolidation or modification of the venting network.”

In regard to the height of the vents, Pangea observed: “If methane and other constituents have concentrations that are sufficiently low to not constitute fire or breathing hazards, then pipe heights should be reduced as much as permitted by applicable regulations.”

 

 

 

 

 

 

 

Please see Response to EPA General Comment #36.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Paul Stanton Kibel, CUEL Co-Director Golden Gate University School of Law

Pangea’s analysis evidences that there is not substantial evidence from a public health/safety perspective to support the need for the proposed exclusionary fencing, and that feasible alternatives approaches are available to significantly reduce both the number of gas vents and as well as the height of such gas vents.

 

Comment 2. Federal Consistency under the CZMA and California State Coastal Policy of Maximum Shoreline Public Access to San Francisco Bay.

As reflected in state legislation establishing the San Francisco Bay Conservation and Development Commission (BCDC), it is a longstanding California state policy to provide maximum public access to areas along our shorelines (including those along San Francisco Bay) and avoid the siting of structures in shoreline areas that would degraded the views and experience of persons using such shoreline areas. Moreover, pursuant to such laws as the federal Coastal Zone Management Act (CZMA), it is the general policy of federal agencies such as the Navy to avoid federal actions that are inconsistent with State coastal policies and to consult closely with state coastal agencies (such as BCDC) regarding such federal consistency. In the case of the Navy’s proposed fencing and gas vents network in the shoreline area of Site 2 at Alameda Point, BCDC staff have provided comments to the Navy outlining concerns about the consistency between California state coastal policies (regarding public shoreline access) and the exclusionary fencing and gas vents network currently proposed. These federal consistency considerations again suggest that alternatives to what the Navy has proposed should be more fully explored.

Response 2. See response to DTSC General Comment #2.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Paul Stanton Kibel, CUEL Co-Director Golden Gate University School of Law

Comment 3. Maintaining Site 2 Culvert to Preserve Tidal Flow Between Wetlands and San Francisco Bay.

In the vicinity of Site 2 there are extensive wetland resources (and waterfowl dependent on such wetland resources). These wetlands maintain their tidal connection to San Francisco Bay via a culvert that runs beneath Site 2. The maintenance and functioning of this culvert is essential to the wetlands as without this tidal influence such wetlands will be destroyed. According to members of the Friends of the Alameda Wildlife Refuge, there have been previous incidents in which this culvert has collapsed and/or become clogged, with serious resulting adverse impacts on the wetlands. These wetlands are subject to protection pursuant to Section 404 of the Clean Water Act (Section 404).

These culvert-related concerns were highlighted in the San Francisco Bay Regional Water Quality Control Board’s June 13, 2012 letter to the Navy commenting on the Draft Site 2 RAW. The Regional Water Board stated: “We are very concerned about the age and integrity of the culvert that is the sole sources of Bay water to the tidal wetlands. It is our understanding that the aged culvert is in very poor shape and may collapse at any time. The value of this culvert became painfully apparent a year ago when some driftwood or other materials clogged it up and impeded all tidal flow of brackish water to the wetland.. In a matter of days, the tidal wetlands started drying up. Should that culvert collapse, the delays in rebuilding, from getting contracts to actual physical work, could be devastating and even fatal to the wetland flora and fauna.”

For the reasons noted above in the letter from the Regional Water Board, it is critical that the Navy properly delineate the Section 404 wetlands (both at Site 2 and elsewhere at Alameda Point) and that the Navy

thoroughly evaluate the condition of the Site culvert to determine

Response 3.

The Navy agrees with the comment that the culvert is critical to the health of the tidal wetlands at IR Site 2. The culvert is currently functioning adequately, and based on work done to unclog debris from the culvert in 2008, it is not in need of repair. The Post-Closure Operations, Maintenance, and Monitoring Plan has been modified to include Culvert Inspection as part of regular visual inspections defined in Attachment 11, Appendix C, SOP 001 Multilayer Soil Cover Inspections.

 

RESPONSE TO COMMENTS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Paul Stanton Kibel, CUEL Co-Director Golden Gate University School of Law

whether replacement and/or reinforcement is needed to maintain this critical tidal flow between the wetlands and the Bay. If such replacement and/or reinforcement work is deemed necessary, the provision for such work should be included in the RAW so that the federal government’s obligations (of the Navy or of the Veterans Administration if ownership of Site 2 is transferred) going forward are clear to the regulators and the public.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ATTACHMENT 14

ADDITIONAL RESPONSE TO COMMENTS DATED DECEMBER 2012

  • James M. Polisini, PhD, Senior Toxicologist Office of Human and Ecological Risk December 17, 2012
  • Xuan-Mai Tran, Remedial Project Manager

U.S. Environmental Protection Agency, Region IX January 17, 2013

  • Peter Gathungu, GE, Hazardous Substances Engineer California Department of Toxic Substances Control January 25, 2013

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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RESPONSE TO COMMENTS TO

RESPONSE TO COMMENTS, DRAFT REMEDIAL ACTION WORK PLAN INSTALLATION RESTORATION SITE 2, ALAMEDA POINT

ALAMEDA, CALIFORNIA

Comments from James M. Polisini, PhD Senior Toxicologist

Office of Human and Ecological Risk (HERO) Ecological Risk Assessment Section (ERAS)

Comments Dated: December 17, 2012

SPECIFIC COMMENT

RESPONSE

Comment 1. Response to Specific Comment number 6: HERO commented that the Department of Fish and Game (DFG) should be consulted to determine whether the 220-mil un-seamed layer of HDPE geonet with half-inch openings proposed as animal penetration control (Section 5.6.6.2, page 5-7 of Draft RI Work Plan) would be sufficient rather than a rock cover. The response indicates that DFG received the Draft RI Work Plan, had no comments, and included a statement on the uniformity of HDPE geonet over crushed concrete rubble as the basis for selection of geonet. Second, HERO never mentioned ‘crushed concrete rubble’ and is more familiar with compacted crushed rock of varying size as cover to prevent animal penetration. For a detailed explanation of the DFG objection to use of geotextile alone as a biological barrier to prevent penetration by burrowing animals please see the attached pages of the October 31, 2012 DFG memorandum to Ryan Miya, DTSC Remedial Project Manager, regarding the Draft Final Record of Decision for Parcel E-2, Hunters Point Shipyard, San Francisco, California. Specifically the section titled DFG-OSPR’s Response to the Navy’s Second Response to DFG-OSPR’s General Comments on the PP (page 4 of 24 through page 18 of 24), outlines the DFG position on use of geomembranes alone as a control on burrowing animals. This DFG memorandum is referenced as it contains DFG responses to the Navy’s original responses to a November, 18, 2011 DFG memorandum outlining their objections to geomembrane alone as a biological barrier at Parcel E-2. While this DFG memorandum is lengthy, a summary of DFG concerns regarding the susceptibility of

Response 1.   The comment referenced a 2011 DFG response memo to the Hunter’s Point Parcel E-2 landfill which states that “designing a landfill cap to only meet the minimum regulatory requirements for a landfill cover does not guarantee it will be effective against damage from burrowing animals in perpetuity…The Navy had not presented sufficient technical information to support its assertions that a geomembrane would deter or control animals from burrowing under the cover…”

Section 5.6.6.2 of the RAWP has been revised to list the reasons that HDPE geonet was selected as follows:

The HDPE geonet was selected as an alternative to a rock layer for the following reasons:

  • High strength and durability
  • An approximately half-inch opening size, which is too small for burrowing animals
  • Consistent barrier quality—no variety in rock or crushed concrete size or thickness as with a rock layer, uniformity in installation and at seams and penetrations
  • Reduced mass for increased seismic stability of cover
  • Lower profile
  • Sustainability (lower fuel use, less to transport, no compaction necessary)
  • USEPA’s Technical Guidance Document: Final Covers on

 

RESPONSE TO COMMENTS TO

RESPONSE TO COMMENTS, DRAFT REMEDIAL ACTION WORK PLAN INSTALLATION RESTORATION SITE 2, ALAMEDA POINT

ALAMEDA, CALIFORNIA

geomembranes alone, based on installed landfill covers is on page 14 of 24 (underlining is presented as in the original text):

“Designing a landfill cap to only meet the minimum regulatory requirements for a landfill cover does not guarantee it will be effective against damage from burrowing animals in perpetuity. The Navy has installed landfill covers without biotic barriers at other locations in California (i.e., Port Hueneme Site 14 and Moffett Field Site 1). As a result of inadequate cover design at these locations, the Navy has resorted to poisoning gophers in perpetuity to prevent these animals from damaging the landfill cap. DFG-OSPR does not believe that a remedy that proposes to clean up one type of chemical of ecological concern (COEC) (i.e., lead and mercury) only to substitute them with another type of COEC (i.e., pesticides), complies with CERCLA and the requirement that the remedy be protective of the environment.”

Just from the description, geonet, with half-inch openings, would appear more susceptible to penetration by burrowing mammals than unbroken geomembrane. Agreement should be reached on the type of biological barrier to be implemented prior to finalization of the IR Site 2 Work Plan.

Hazardous Waste Landfills and Surface Impoundments, July 1989 indicated "There also is little evidence that insects or burrowing animals destroy polymer liners or cover materials. In tests done with rats placed in lined boxes, none of the animals were able to chew their way through the FMLs [flexible membrane liners]. Thus, degradation from a wide spectrum of biological sources seems highly unlikely."

  • Specification sheets from a geonet manufacturer (Tenax) circulated in January 2009 indicated that the example geonet materials had a hardness of about 68 on "Shore D" scale. This hardness is in the same class as some soft, non-ferrous metals, or the covering on a golf ball, or a typical hard hat (approximately 75).
  • Precedents and technical basis exist for the use of geonets and other polymeric materials to impede animals in cover systems for solid waste containment:
    • HDPE geonet was the USEPA-recommended design for Casmalia Resources Disposal Site , and was agency- approved for use at the Concord Stie 1 landfill
    • HDPE geonet was approved for a burrowing animal barrier in 2010 by DTSC in a landfill cover at Naval Air Weapons Station China Lake (TtEC 2010)
    • HDPE geonet used for a CERCLA action at the Site 300 landfill located at the U.S. Department of Energy facility, Lawrence Livermore National Laboratory (U.S. Department of Energy 1997)

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Xuan-Mai Tran Remedial Project Manager

Federal Facilities and Site Cleanup Branch

U.S. Environmental Protection Agency, Region IX

Comments Dated: January 17, 2013

GENERAL COMMENT

RESPONSE

Comment 1. Section 2, Basis of Design, of Attachment 1, Final Report, Geotechnical Recommendations, Installation Restoration Site 2, Alameda Point, Alameda, California, October 29, 2012 (the Geotechnical Report) indicates that the integrity of the Site 2 cover is considered to be maintained if there is no release of solid refuse to the San Francisco Bay beyond the perimeter seawall, the site will remain isolated from and will not be flooded by the San Francisco Bay water, and the function of the cover to act as a pathway interruption between landfill content and human and environmental receptors will not be rendered ineffective; however, Section 9.1, Slope Stability and Newmark-Type Displacement Interpretation and Conclusions, indicates that some incidental refuse beneath the perimeter berm may be exposed at the western coastal margin and Section 12, Summary of Analyses, indicates that substantial remedial grading will be required to repair damage following a maximum credible earthquake (MCE). As such, the integrity of the Site 2 cover appears to be rendered ineffective following a MCE because the potential exposure pathway between landfill content and human and environmental receptors will be complete. Please revise the Geotechnical Report to clarify how the function of the cover to act as a pathway interruption between landfill content and human and environmental receptors is expected to remain effective when the potential exposure pathway between landfill content and human and environmental receptors following a MCE will be complete.

Response 1. The proposed design concept assumes that relatively large displacements may take place during an MCE event. Although refuse is not predicted to be released into the Bay (lateral direction), substantial disturbance (cracking, separations, offsets) of the cover is anticipated that might expose the refuse to the human and environmental receptors (vertical direction). This exposure is expected to be localized due to 1) localized distribution of the refuse beneath the berm 2) localized nature of cover disturbance. The overall cover disturbance will require substantial remedial grading (Section 12, p.33). This remedial grading will re-establish the barrier between the human and environmental receptors.

It is understood that this comment is concerned with the exposure of refuse under the berm along the western coastal margin. The cover along the western coastal margin will be subject to deformations from perimeter slope movements and/or possibly also from lateral spreading. It is expected that the larger of the two effects will govern, i.e., the effects are not additive. The Final report includes rationale/basis for determination that the refuse along the western coastal margin is localized and therefore its exposure to the open environment following an MCE event is also expected to be localized. The performance concept for the site anticipates that significant repair will need to be implemented following a design seismic event.

 

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ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 2. Given the size of the coastal margin along the western portion of Section D-D’ compared to Section A-A’ and Section B-B’, it is unclear why a slope stability and Newmark-type seismic deformation evaluation was not conducted on Section D-D’. Please revise the Geotechnical Report to clarify why an evaluation of slope stability and Newmark-type seismic deformation was not conducted at Section D-D’.

Response 2. Section D-D’ is presented in the Report to illustrate the interpreted subsurface conditions. . Section D-D' is neither suitable nor intended for engineering analyses due to its oblique angle to the governing engineering mechanisms. It is presented mainly to illustrate the variability of the thickness of the fine-grained Young Bay Mud under the project site. The vertical dimensions of the cross-section are exaggerated to capture this variability. Instead, Sections A-A’, B-B’, and C-C’ were developed as representative of the critical subsurface conditions along the southern coastal margin, western coastal margin, and interior wetland margin, respectively, and perpendicular to the margin to be suitable for engineering analyses.

Sections A-A', B-B', C-C' were developed for the specific purposes of engineering analyses as they are all deemed representative and critical. Another cross-section not directly inferred from cross-section D-D' would need to be prepared for any additional analyses. However, it is our professional opinion that the provided cross-sections A-A', B-B', C-C' adequately and sufficiently characterize the site and provide basis for engineering analyses.

Comment 3. The Geotechnical Report does not discuss the impact of the existing slurry wall, shown on Plate 4, Geologic Section B-B’, on the geotechnical analysis for cross section B-B’. For example, it is unclear if it was assumed that no slurry wall existed or if it was factored into the slope stability and Newmark-type seismic deformation evaluation. Please revise the Geotechnical Report to discuss the existing slurry wall. If the existing slurry wall was factored into the slope stability and Newmark- type seismic deformation evaluation, please clarify how the integrity of the existing slurry wall was incorporated into the evaluation.

Response 3. The existing slurry wall is considered to be a typical bentonite- soil cut-off wall to impede groundwater connection between the landfill and the Bay. Due to its size (2 feet wide) the slurry wall does not have any engineering impact on the deformation and stability analyses of Section B-B’ and was not rigorously considered in the analyses. Given the predicted seismic deformations along the western coastal margin of 10 feet, the integrity of the slurry wall is expected to be commensurately disturbed.

 

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ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 4. The Geotechnical Report does not discuss how Sections A- A’, B-B’, C-C’, and D-D’ are representative of site conditions along the coastal margin areas and areas between the landfill and wetlands. As such, the validity of the geotechnical evaluation is uncertain. Please revise the Geotechnical Report to discuss how Sections A-A’, B-B’,

C-C’, and D-D’ are representative of site conditions along the coastal margin areas and areas between the landfill and wetlands.

Response 4. The cross-sections were developed based on geologic interpretation of the data collected during subsurface investigations described and presented in the report. All four sections were developed to illustrate the subsurface conditions interpreted from the previous field investigations discussed in Sections 4 and 5 of the Report and logs and lab testing results included in Appendices A and B. Sections A-A’, B-B’, and C-C’ were considered critical and utilized for the engineering analyses. Section D-D’ was deemed necessary to present the thinning of the fine Young Bay Mud prone to seismic softening and appearance of the liquefiable coarse Young Bay Mud between the western and southern coastal margins.

Comment 5. Section 7.1, Slope Stability and Newmark-Type Deformation Evaluation Methodology, indicates that a simplified method, based on a database of similar simulations, rather than the SHAKE2000 software, was used to predict permanent seismic deformations at Section C-C’ because the interior slope between the landfill and wetlands is not critical due to the width of the buffer zone between the landfill boundary and the seawall. While the width of the buffer zone between the landfill boundary and the seawall is larger than along the coastal margin areas, seismic deformations at Section C-C’ are still critical as waste could enter the ponds or wetlands. It should be noted that the North Pond is connected to San Francisco Bay through the existing culvert pipe so the potential for refuse to reach San Francisco Bay exists. Please revise the Geotechnical Report to utilize SHAKE2000 software to assess Section C-C’.

Response 5. Simplified seismic deformation method by Bray & Travasarou (2007) was utilized for Section C-C’ in accordance with the Standard of Practice and as recommended by Special Publication 117A (California Geological Survey, 2008, Guidelines for evaluating and mitigating seismic hazards in California). This method is considered to yield adequate results compared to more rigorous methods, i.e., SHAKE2000. On this basis, the seismic deformation predictions presented in the Report for Section C-C’ are considered appropriate and adequate.

The simplified method also allows to quantify the probability of exceedance of a given resulting seismic deformation, whereas SHAKE2000 yields a deterministic value calculated based on a given time history or average for a design time history set. The simplified method result presented in the Report for Section C-C’ was a mean value, i.e., probability of exceedance of 50%.

Results for other risk levels (probability of exceedance of 84% and 16%) were provided in Appendix E.

 

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ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 6. Section 8.2, Approximate Energy Method, indicates that a flow model for simplified geometries was utilized for the southern coastal margin; however, the text does not discuss the simplified geometries at the southern coastal margin or discuss why the geometries at the western coastal margin and interior slope between the landfill and wetlands were not appropriate for use in a flow model for simplified geometries. Please revise the text to discuss the geometries for the coastal margins and interior slope between the landfill and wetlands to substantiate the use of a flow model for simplified geometries for the southern coastal margin.

Response 6. The Approximate Energy Method is applicable to all geometries subject to plastic flow. As such this model is applicable to both the western and southern coastal margins. The text of the Report is not clear by implying that the method is applicable only to the southern coastal margin, whereas the intent was to state that the method was used only for the southern coastal margin. This is because the southern coastal margin was still unstable at the end of the design MCE event and therefore subject to further deformations evaluated using the Approximate Energy Method. For the western coastal margin the configuration was determined to be stable at the end the design MCE event and therefore the Approximate Energy Method did not need to be utilized.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 7. The conclusions presented in Sections 9.2, Flow Model Interpretation and Conclusions, and 12, Summary of Analyses, require additional discussion. For example, the conclusions imply that the perimeter berm remains intact following a MCE and only appears to settle four feet; however, the text does not explain why the perimeter berm does not flow. Similarly, the perimeter berm is not predicted to be overtopped by rising water yet there is no discussion of tides/rising water in the Geotechnical Report. Please revise the Geotechnical Report to provide additional discussion of each conclusion, including associated assumptions.

Response 7. The perimeter berm is not subject to liquefaction because it is above groundwater, nor is the compacted fill of the berm considered sensitive and prone to significant seismic weakening. As a result, the berm  is considered to translate as a rigid body as the underlying liquefied hydraulic fill flows plastically. Based on borings KCHSB-1, -2, and -3 advanced on top of the perimeter berm, the berm is primarily composed of LEAN CLAY (CL) with plasticity index and liquid limit of 28 and 46, respectively. As such this material is not liquefiable  because  the prerequisite condition for liquefaction is 1) saturated and 2) contractive (loose, metastable) granular soils or silts. Although under some extreme conditions and certain tides the toe of the berm could get saturated, the material that comprises the berm is primarily cohesive clay, which is not usually considered liquefiable. Recent advances in soils  mechanics indicated that under certain conditions fine-grained soils may be subject to either to liquefaction-like behavior (built-up of pore pressures and reduction of effective stress) or a significant loss of strength due to thixotropic response of the soils grains during earthquake shaking, i.e., sensitivity. This propensity was evaluated based on the following criteria:

 

  1. Fine-grained soils with Plasticity Index < 12 and moisture content greater than 85 percent of the liquid limit are classified as fine-grained soils susceptible to liquefaction (typically silts);

 

  1. Fine-grained soils with Plasticity Index > 18 are classified as soils potentially susceptible to significant loss of strength during seismic shaking and require additional evaluation. The sensitivity of the on-site fine-grained

soils is then evaluated based on the water content, Atterberg limits, and

 

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ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

 

effective vertical stresses using the procedures suggested by Holtz and Kovacs (1981) and Mitchell and Soga (2005).

 

3. Fine-grained soils falling outside the two categories above are  considered to behave like clays and are not considered susceptible to liquefaction.

 

As indicated above, the materials that compose the berm are typically lean clays with plasticity index and liquid limit of 28 and 46, respectively, and fall into the 2nd category defined above. Considering the assumed saturated moisture content of about 35 percent, the Liquidity Index is about 0.6 and the associated sensitivity is about 3 (Mitchell and Soga, 2005). Soils with sensitivity less than 4 are considered low sensitive (Holtz and Kovacs, 1981) and therefore the potential for significant loss of strength of fine-grained materials and ensuing failure during seismic shaking is not considered likely. However, the seawall and perimeter berm will be inspected immediately after the MCE event, and repaired or raised as necessary to maintain acceptable freeboard above the King tide as part of post-MCE remedial grading already deemed necessary to repair cover damage from lateral spreading. Rising sea level on the order of 0.1 feet over a period of time measured in decades is considered relevant to long term maintenance. If sea level rise is appreciable in the coming decades, the seawall and berm should be raised to keep pace with rising mean sea level as part of long term maintenance.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

SPECIFIC COMMENT

RESPONSE

Comment 1. Section 2, Basis of Design, Page 2: The second paragraph references the Applicable or Relevant and Appropriate Requirements (ARARs) presented in the Final Record of Decision (ROD) for IR Site 2; however, a specific reference to the ROD is not included in Section 2 or Section 15, Selected References. Please ensure that the ROD is referenced.

Response 1. Agreed. The ROD reference will be included as follows: Final Record Of Decision IR Site 2; Former Naval Air Station Alameda, California, BATL-6009-0007-0010, August 2010.

Comment 2. Section 7.1, Slope Stability and Newmark-Type Deformation Evaluation Methodology, Page 18: The text indicates that the mean predicted seismic deformation was taken as representative of anticipated permanent deformation during the MCE for Section C-C’; however, information to substantiate the use of the mean predicted seismic deformation is not provided. It is unclear if the mean predicted seismic deformation represents a conservative assessment of seismic deformation. Please revise the Geotechnical Report to clarify how the use of the mean predicted seismic deformation is a conservative assessment of seismic deformation.

Response 2. The mean predicted seismic deformation of 1.0 foot is intended to be the likely deformation, with a 50% probability of being less and a 50% probability of being greater. That is, it is not intended to be a conservative assessment. A conservative estimate may be taken from the result presented in Appendix E as 1.9 feet, with only a 16% probability of being exceeded.

For the purpose of evaluating the permanent seismic deformation of the interior slope adjacent to the wetland, either 1.0 foot or 1.9 feet are effectively comparable indexes of permanent deformation with respect to impact to the cover and in relation to other deformation magnitudes including liquefaction induced lateral spreading. Nonetheless, the Report will be revised to use a conservative value of 1.9 feet.

Comment 3. Section 7.1, Slope Stability and Newmark-Type Deformation Evaluation Methodology, Pages 18-19: The text indicates post-earthquake movement was anticipated for Section A-A’ and no post- earthquake displacement was anticipated for Section B-B’; however, the text does not discuss Section C-C’. Please revise Section 7.1 to discuss the post-earthquake movement at all cross sections.

Response 3. Post-earthquake displacement is not predicted for Section C-C’ because the post-earthquake Factor of Safety is 1.36. Section C-C’ has been included in the discussion presented in Section 7.1 of the Report.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 4. Section 8, Flow Run-Out Analyses, Page 23: The text states that, “Although most slides behave largely like rigid bodies as the involved materials soften, the deformation character transitions more towards the flow-type movement. This flow-type movement is considered applicable to the type of slide movements anticipated along the southern coastal margin, where potential for liquefaction of the coarse-grained Young Bay Mud sands is determined;” however, information to substantiate this statement is not provided. Please revise the Geotechnical Report to provide information to substantiate why this flow-type movement is only applicable for the southern coastal margin.

Response 4. This flow-type movement is applicable to all geometries subject to plastic flow. As such this model is applicable to both the western and southern coastal margins for seismic wakening and liquefaction type failures, respectively. The text of the Report is not clear by implying that the method is applicable only to the southern coastal margin, whereas the intent was to state that the method was used only for the southern coastal margin. This is because the southern coastal margin was still unstable at the end of the design MCE event and therefore subject to further deformations evaluated using the Approximate Energy Method. For the western coastal margin the configuration was determined to be stable at the end the design MCE event and therefore the Approximate Energy Method did not need to be utilized.

Comment 5. Section 8.1, Flow Constitutive Model, Page 23: Based on Section 8.1, flow resistance is utilized rather than viscous resistance for plastic flow; however, no information is provided to substantiate that viscous resistance is not occurring. Please revise the Geotechnical Report to clarify why viscous resistance is not utilized in the plastic flow constitutive model.

Response 5. Viscous flow where resistance is a function of flow velocity will likely occur. However, plastic flow model where resistance to flow is provided by a constant residual shear strength was selected for the analyses

to utilize a closed-form solution based on the conservation of energy to determine the resultant run-out distance. The choice of a plastic flow rheological constitutive model was a matter of convenience, but deemed appropriate for an order of magnitude estimate of the run-out distance. The selection of the plastic flow model is also consistent with conventional modeling of liquefied materials using a single shear strength parameter (undrained shear strength). Given the positive confining contribution of the rock seawall is ignored, the plastic flow model to estimate of the run-out distance is deemed to be conservative.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Xuan-Mai Tran, Remedial Project Manager

Federal Facilities and Site Cleanup Branch, U.S. Environmental Protection Agency, Region IX

Comment 6. Section 9, Results of the Slope Stability and Permanent Seismic Deformation Analyses, Pages 26 to 30: The text does not discuss the results of the slope stability and permanent seismic deformation analysis conducted on Section C-C’. Please ensure that the results of the slope stability and permanent seismic deformation analysis conducted on Section C-C’ are discussed in the Geotechnical Report.

Response 6. Agreed. The results of the slope stability and permanent seismic deformation analysis conducted on Section C-C’ are described in Reponses 3 and 2 above, respectively.

Comment 7. Table 7, Summary of Slope Stability and Permanent Seismic Deformation Analysis, Page 28: The vertical translation of the crest, as shown in Figure D-8, Post-Seismic Stability Analysis (Section B-B’), is not discussed. Please ensure that the vertical translation of the crest is discussed in Table 7 and the text of the Geotechnical Report.

Response 7. Agreed. The vertical translations shown on the figures in Appendix D were considered supplementary to the lateral deformations, which were the focus of the analyses. For completeness, the vertical translations has been added on Table 7 and discussed in the text.

Comment 8. Section 12, Summary of Analyses, Page 33: The text indicates that lateral spreads of the cover throughout the interior of the landfill are on the order of a few feet; however, information to support this statement is not provided. Please revise the Geotechnical Report to provide information to substantiate that lateral spreads of the cover throughout the interior of the landfill are on the order of a few feet.

Response 8. The basis for this conclusion is provided in Section 10.2 while Section 12 is intended to provide only a summary of the conclusions. The rationale includes discussion that liquefaction induced lateral spreads are intrinsically difficult to predict, and in particular for a case of edge constraint provided by a large seawall. As a result, the historic lateral spreads observed at the site during the 1989 Loma Prieta Earthquake are considered to provide the best estimate and are believed to be on the order of a few feet (California Geological Survey, 2003, Seismic Hazard Report for the Oakland West 7.5- Minute Quadrangle, Alameda County, California).The requested reference and discussion is included in the Draft Final report

 

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INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Comments from Peter Gathungu, GE Hazardous Substances Engineer Engineering and Special Projects Office

California Department of Toxic Substances Control

Comments Dated: January 25, 2013

COMMENT

RESPONSE

Comment 1. Section 1.0, Introduction. The text in the first paragraph indicates that a multilayer cover system consisting of a biotic geonet barrier and a minimum two-foot thick layer of soil, including a minimum six-inch vegetative layer, will be installed over the landfill. The report does not indicate the properties/type of soil, such as low permeability clay, to be used in the landfill cover. The described system does not include a mechanism to keep water out of the waste other than the two foot soil layer. Although the Report appears to be focused on preventing release of solid waste into or flooding of the site by waters of San Francisco Bay during a seismic event, preventing infiltration of water into the waste which is in contact with groundwater that is subject to tidal influences should be considered.

Response 1. The proposed cover is intended to provide a physical barrier between the refuse and the surrounding environment. The parameters of the geotechnical design do not include qualification, quantification, or control of precipitation water infiltration into the refuse or groundwater movement and interaction. The selected remedy for groundwater is monitoring and natural attenuation as described in the ROD. . The landfill content is already sitting in the groundwater, so the cover does not need to be designed to prevent infiltration. According to the ROD, engineering controls for groundwater remedy are not an issue because active remediation of groundwater will not be conducted.

Comment 2. Section 6.1 Causative Faults. The text in the first sentence states that Caltrans’ ARS Online v.1.0.4, a web based tool was used to select the causative faults for the deterministic Maximum Credible Earthquake (MCE). We note that a newer version of the web based tool is currently available. Please determine if using the latest version of the web-based tool changes the current results and make adjustments as necessary.

Response 2. ARS Online (version 2.0.4) was implemented on November 14, 2012 and has since been updated to the current version 2.1.05. The ARS tool was utilized to develop the deterministic response spectra for the governing faults (Hayward Fault and San Andreas Fault). The comparison of the deterministic response spectra generated by the ARS Online Tool v.1.0.4 and

v.2.1.05 for the governing faults indicates no difference. As such the results of the ARS Online Tool v.1.0.4 presented in the Report remain fully applicable.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Peter Gathungu, GE, Hazardous Substances Engineer

Engineering and Special Projects Office, California Department of Toxic Substance Control

Comment 3. Section 6.5 Design Peak Ground Acceleration. The text in the second paragraph states that the design peak ground acceleration (PGA) is taken as the average result for the seven input acceleration time histories, but no rationale is provided for using the average values. Please expand the text in this paragraph and include a rationale for using the average PGA values.

Response 3. The reference to the PGA in the Report is provided only for reference purposes and for comparison with the PGA values presented in the previous reports (if desired). This value is not used for any subsequent deformation analyses, except to verify that liquefaction is triggered and the liquefaction induced settlements presented in previous reports remain applicable. Furthermore, the use of average values is conventionally utilized when several input time histories are utilized, e.g., PEER Center target spectrum matching procedure or AASHTO Guide Specification for Seismic Isolation Design, 3rd Edition, prescribes using the maximum response when 3 time-histories are used and the average when 7 or more time-histories are used. 7 time-histories are used in our analysis.

Comment 4. Section 7.1 Slope Stability and Newmark-Type Deformation Evaluation Methodology. The text in the third sentence states that two typical sections representing the western and southern coastal margins were selected for analyses. The text in the second paragraph indicates that a third section was also considered. However, it would appear that because the North Pond communicates with San Francisco Bay via a 36-inch diameter pipe, a section through the pond including the landfill and seawall likely would present greater vulnerability than Section C-C'. Please include analyses for an additional section through the north pond.

Response 4. The third section, Section C-C’, was developed to evaluate the stability of the landfill perimeter in the wetland area. Because of the large setback of the landfill from the Bay (well in excess of 400 feet) by inspection this section is not expected to be critical and did not need to be extended to the Bay and analyzed. The presence of the pond at the toe does not affect the stability and deformation calculations and the calculated deformations indicate only minor potential seismically induced deformations, which are not expected to impact the refuse confinement. From that perspective analyses on an additional section are not considered necessary.

Comment 5. Section 7.1 Slope Stability and Newmark-Type Deformation Evaluation Methodology. The text in the last sentence of the third paragraph states that post-earthquake flow failure is considered imminent for factors of safety less than 1. However, it would appear that in common usage a factor of safety less than 1 indicates failure/instability and not imminent failure. Please clarify and revise the text accordingly.

Response 5. The text of the report refers to the imminent post-earthquake flow failure. This is an important distinction since even with the Factor of Safety of less than 1, further analysis is needed to evaluate if a flow failure associated with large displacement or “conventional” failure with much more limited displacements would take place.

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Peter Gathungu, GE, Hazardous Substances Engineer

Engineering and Special Projects Office, California Department of Toxic Substance Control

Comment 6. Section 8.2 Approximate Energy Method. The text in the third sentence states that the final geometry is taken as a parabolic profile, and the initial and final geometries are shown in Figure 9.

However, it is not clear whether the berm and sea wall will remain intact, and their location and configuration, after movement. In addition, the sea wall along the southern coastal margin appears to be based on liquefiable hydraulic fill. Please clarify the final post-earthquake configuration of the sea wall, berm, and landfill cover, and indicate whether the waste would still be isolated from bay waters taking into account the presence of the North pond (see Comment 4), and anticipated future sea level rise.

Response 6. The berm is expected to remain as a block because it is composed of compacted fill not susceptible to liquefaction or seismic weakening. Consequently the berm is expected to deform as a rigid block on a foundation susceptible to plastic flow, illustrated below:

 

 

In the model, the seawall is conservatively assumed to be non-existent, instantaneously whisked away and replaced with a 25-foot vertical face of liquefiable sand subject to plastic flow without being constrained by a rigid shell (sea wall). Actual seawall will limit deformation to less than shown above.

The final post run-out configuration shown below predicts the berm will not be overtopped by the waters of San Francisco Bay and freeboard of about

5 feet above mean sea level will remain and so the refuse will remain isolated:

 

 

 

 

 

RESPONSE TO COMMENTS

ATTACHMENT 1, FINAL REPORT, GEOTECHNICAL RECOMMENDATIONS DRAFT REMEDIAL ACTION WORK PLAN

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT ALAMEDA, CALIFORNIA

Peter Gathungu, GE, Hazardous Substances Engineer

Engineering and Special Projects Office, California Department of Toxic Substance Control

Comment 7. Section 9.1 Slope Stability and Newmark-Type Displacement Interpretation and Conclusions. The text in the first bullet states that the perimeter slope at the southern margin is prone to liquefaction and may flow as evidenced by the calculated post- earthquake factor of safety. The conclusions in this section should be expanded to discuss liquefaction and flow effects on the berm, perimeter wall and whether post-earthquake overtopping of the deformed berm and/or sea wall is likely to occur.

Response 7. Liquefaction and flow effects on the berm and perimeter seawall are described in Response 6 above.

Comment 8. Section 9.2 Flow Model Interpretation and Conclusions. The text in the last bullet states that the cover is predicted to settle a maximum of four feet adjacent to the perimeter berm. This bullet appears to be incomplete as it does not draw any conclusions on the effect of the predicted settlement on the adjacent berm and whether if similar settlement of the berm occurs it could lead to flooding of the landfill from the bay. Please expand the text to include any conclusions regarding berm performance in light of the predicted settlement of the adjacent cover.

Response 8. Agreed. Translation and settlement of the berm and the potential flooding of the landfill as shown in Response 6 have been discussed in Section 9.2 of the Report.

Comment 9. Section 10.2 Liquefaction Lateral Spreading. The text in the first paragraph states that previous studies have predicted liquefaction induced lateral spreads ranging from a few inches to flows of many tens of feet and goes on to state that lateral spreads are poorly constrained and uncertain. However, the text in the second paragraph states that lateral spreads in some areas may be on the order of several feet. The statements appear to be overly vague and we would suggest refining the predicted lateral spreading values to provide a better sense of the anticipated lateral spread and related effects.

Response 9. The anticipated and most likely estimate of lateral spreading deformations is the reference to the experience from the 1989 Loma Prieta earthquake, i.e., “order of several feet”. Given the nature of the empirical relationship by Youd (2002), in particular the impediment to lateral spreading provided by the seawall, refinement of the analytical predictions is not considered practical or reliable.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ATTACHMENT 15

RESPONSE TO COMMENTS ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 (INTERNAL DRAFT) DATED AUGUST 2013 (SPECIFIC TO GROUNDWATER MONITORING)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Response to EPA Comments Dated September 9, 2013

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Xuan-Mai Tran

U.S. Environmental Protection Agency, Remedial Project Manager Comments Dated: September 9, 2013

GENERAL COMMENT

RESPONSE

Comment 1. The April 2013 Final Remedial Action Work Plan, Revision 1, Installation Restoration (IR) Site 2 (the Final RAWP) and Attachment 4, Sampling and Analysis Plan (SAP), do not include details and criteria for abandoning and installing monitoring wells.                                                                                      The August 2013 revision to the Final RAWP (August 2013 Final RAWP) includes a list of wells to be abandoned and text describing the wells to be abandoned, but this is not sufficient to implement this work in the field. For example, the proposed borehole diameter, screen depth and length, screen and casing diameter, and sand pack type have not been provided. Similarly, there are no procedures for well development.                                                                                      Further, the rationale for the location of each monitoring well should be provided in the SAP (i.e., in Worksheet #17 or #18). Please revise the RAWP and Attachment 4, SAP, to provide detailed procedures for abandoning wells, installing monitoring wells, and developing monitoring wells. In addition, please revise the SAP to include monitoring well destruction, installation, and development tasks in all affected worksheets. Finally, please include the rationale for the location of each new monitoring well in the SAP.

Response 1. Groundwater monitoring well destruction specifications were included in the 100% Remedial Design, Attachment 1, Specification 02 41

10. A specific reference to the specification has been added to Section 5.5.1.

Groundwater monitoring well installation methods and materials have been added to Section 5.8.3 of the RAWP. A groundwater monitoring well schematic has been added as Figure 5-3 to the RAWP.

A discussion of well development has been added to Section 5.8.3 of the RAWP.

An addendum to the Basewide Groundwater Monitoring Program SAP will be prepared by the BGMP contractor to reflect the changes to the IR Site 2 groundwater monitoring network and sampling program. The BGMP plans are approved including procedural descriptions of well development, well abandonment, sampling requirements and will be referenced to minimize duplication.

Comment 2. A Work Plan or SAP for groundwater monitoring activities has not been provided.

Worksheet #10 in the SAP, states, “Monitoring activities for groundwater, which include groundwater sampling, are not discussed in this SAP since these activities are not part of the TtEC [TetraTech EC] scope for this project. A separate SAP will be prepared by the contractor who receives that scope of work.” Please provide a schedule for submission of this SAP.

Response 2. The Basewide Groundwater Monitoring Program SAP Addendum covering IR Site 2 is being prepared and will be finalized prior to the first post-cover groundwater sampling event, estimated to be February 2014.

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Xuan-Mai Tran

U.S. Environmental Protection Agency, Remedial Project Manager Comments Dated: September 9, 2013

Comment 3. The August 2013 Final RAWP does not include conducting a well inventory.     Appendix A, Long-Term Groundwater Monitoring Evaluation, states “A well inventory should be performed to evaluate current condition of monitoring wells that will remain in the program.

The construction details should be provided and the current conditions of the wells should be evaluated.                                                Corrective measures (such as redevelopment) should be proposed if deemed necessary;” however, no revisions have been made to the Final RAWP to incorporate the compilation of a well inventory.  Data quality objectives, procedures, and a checklist should be provided in the Final RAWP.                                                Please revise the Final RAWP to incorporate the compilation of a well inventory as specified in the Sampling and Analysis Plan section of Appendix A.

Response 3. A Groundwater Monitoring Well Inventory has been added to the RAWP as Section 5.8.2.1. The existing wells at the site will be inventoried once the cover has been completed. If wells are found to be in need of repair or redevelopment, then they will be addressed at the same time the new wells are being installed and developed which is scheduled to be completed by early February 2014 (based on construction progress through September 2013).

 

Routine groundwater monitoring well maintenance and repair will be performed during sampling events. An inspection checklist and procedure for redevelopment will be included (by reference) in the IR Site 2 addendum to the Basewide Groundwater Monitoring Program SAP.

SPECIFIC COMMENT

RESPONSE

Comment 1. Section 5.8.3, Installation of Groundwater Monitoring Wells, Page 5-10: The second paragraph of Section 5.8.3 of the August 2013 Final RAWP states “two groundwater monitoring wells will be installed within the cover between existing clusters M036 and M037;” however, the text does not discuss whether installing wells through the soil cap will impact or compromise the cover in any way and does not state whether specific measures will be taken to prevent damage to the soil cap.               Please revise Section 5.8.3 to discuss any potential impacts to the soil cap from well installation and to describe any measures that will be taken to prevent damage to the soil cap during well installation.

Response 1. Section 5.8.3.1 has been added to the RAWP to provide details on well installation.  Two of the well clusters (Locations M042 and M043) are within the footprint of the soil cover. At these locations, the soil cover will be removed prior to drilling and a section of the geonet will be cut to provide for auger access through the biobarrier. Once well installation is complete, the biobarrier will be repaired per Detail 4, Sheet D-3 of the 100% Remedial Design (Attachment 1, Design Drawings) and the soil cover reinstalled and compacted to project requirements.

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Xuan-Mai Tran

U.S. Environmental Protection Agency, Remedial Project Manager Comments Dated: September 9, 2013

Comment 2. Figure 5-2, Soil Gas and Groundwater Monitoring Wells and Attachment 11, Final Post-Closure Operations, Maintenance, and Monitoring Plan, Table 2-1, Proposed Groundwater Monitoring Well Network, Analyses, and Sampling Frequency: Figure 5-2 includes upper first water-bearing zone (FWBZ) well 442-MW1 in the northern portion of IR Site 2; however, Table 2-1 of Attachment 11 does not include this well.                                              It is not clear whether well 442-MW1 will be sampled in the future, and if so for what analytes and at what frequency. At a minimum, this well should be used for water level measurements.   Please revise Table 2-1 of Attachment 11 to specify water level measurements in well 442-MW1 and clarify whether this well will be sampled.

Response 2. Table 2-1 has been revised to include well 442-MW1 which will be used for water level measurements. This well will not be sampled.

Comment 3. Attachment 11, Section 2.1.1, Groundwater Monitoring Well Network and Sampling Frequency, Pages 2-1 and 2-2:                                                                                                Section

2.1.1 states, “After 1 year of monitoring, the [quarterly monitoring] frequency may be reduced to semiannual based on the criteria described below,” but specific criteria for this decision have not been provided. Also, the only descriptions of conditions for changes in monitoring frequency involve increasing concentrations or increasing variability, which would require more frequent monitoring. It appears that a decision tree that presents the range of potential changes to the monitoring frequency may be useful.                                         Please revise Section 2.1.1 to provide the referenced criteria for reducing the monitoring frequency from quarterly to semiannual monitoring and consider providing a decision tree that presents the range of potential changes to the monitoring frequency.

Response 3. Criteria for the reduction of sampling frequency have been added to Section 2.1.1 of the PCOMMP. The decision tree included as Figure 2-2 has been revised to be consistent with Section 2.1.1.

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Xuan-Mai Tran

U.S. Environmental Protection Agency, Remedial Project Manager Comments Dated: September 9, 2013

Comment 4. Attachment 11, Final Post-Closure Operations, Maintenance, and Monitoring Plan, Sections 2.1.3, Data Analysis, Page 2-2: According to the first paragraph of Section 2.1.3, “data from future analyses will be evaluated with the post-2002 historical data;” however, the text does not discuss why only post-2002 historical data will be used. Please revise Section 2.1.3 to discuss why only post-2002 historical data will be used to evaluate groundwater.

Response 4. Section 2.1.3 of the PCOMMP has been revised to include historical data in trend analysis provided that the historical detection limits were below project action levels.

Comment 5. Attachment 11, Final Post-Closure Operations, Maintenance, and Monitoring Plan, Sections 2.1.3, Data Analysis, Pages 2-2 and 2-3: Section 2.1.3 discusses various trend analyses that will be performed using the groundwater monitoring data; however, the text does not indicate how often the trend analyses will be performed (e.g., annually and documented in the annual report, after five years of monitoring are completed, etc.). In addition, the text does not indicate where the trend analyses will be presented (e.g., annual report, some other report, etc.). Please revise Section 2.1.3 to specify how often trend analyses will be completed using the groundwater monitoring data and indicate where the trend information will be presented.

Response 5. Section 2.1.1 of the PCOMMP has been revised to clarify that trend analyses will be performed annually and the results reported in the Annual Groundwater Monitoring Reports.

Comment 6. Attachment 11, Final Post-Closure Operations, Maintenance, and Monitoring Plan, Sections 2.1.3, Data Analysis, Pages 2-2 and 2-3: There are a minimum number of data points required for various trend analyses, but the text of Section 2.1.3 does not summarize the minimum number of data points needed for each type of trend analysis that will be performed or discuss what will be done if there are an insufficient number of data points to conduct a trend analyses for a given monitoring location.                                                                Please revise Section 2.1.3 to summarize the minimum number of data points required to conduct

Response 6. The minimum number of analyses for each of the statistical tests has been added where missing. Minimum requirements are as follows:

Graphical representation – 2 or more data points Outlier analysis – 3 or more data points

Linear regression – 3 or more data points

Visual qualitative assessment – 2 or more data points Mann-Kendall – 4 or more data points.

New wells will be monitored quarterly for one year prior to performing trend

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Xuan-Mai Tran

U.S. Environmental Protection Agency, Remedial Project Manager Comments Dated: September 9, 2013

each type of trend analysis and discuss what will be done if there are an

insufficient number of data points to conduct a specific trend analyses for a monitoring location.

analysis, and since the minimum number of data points for trend analyses is

four or less as indicated above, all new wells will have sufficient number of data points after 1 year.

Comment 7. Attachment 11, Final Post-Closure Operations, Maintenance, and Monitoring Plan, Section 2.2, Compliance Period, Page 2-3: The second paragraph of Section 2.2 states “following 5 years of post-closure monitoring, the monitoring data will be reviewed and if concentration trend data are consistent with

pre-closure data or exhibit declining concentrations, groundwater monitoring may be terminated after the review in January 2017;” however, the first groundwater monitoring event “is planned to occur in January 2014,” which is only three years before the January 2017 review. In addition, Section 2.1.1, Groundwater Monitoring Well Network and Sampling Frequency, does not discuss the potential to terminate monitoring or provide criteria for a reduction in monitoring frequency and Appendix A, Long-Term Groundwater Monitoring Evaluation states that changes to the monitoring frequency must be approved by the Regulatory Agencies. Since one of the purposes of the monitoring program is detection monitoring (i.e., see introductory paragraph of Appendix A, Long-Term Groundwater Monitoring Evaluation) long-term monitoring is required to meet this objective.

However, it may be possible to reduce monitoring frequency to the semiannual frequency mentioned in Section 2.1.1 and in the future to annual monitoring, but criteria for these potential reductions in monitoring frequency have not been provided. Please revise Attachment 11, Section 2.2 to delete text that discusses terminating groundwater monitoring and provide criteria for reducing the monitoring frequency to semiannual and annual.

Response 7. This language has been removed.  Criteria for reducing sampling frequency have been added to Section 2.1 and are included in the decision tree provided as Figure 2.2. Section 2.2 has been revised to clarify that sampling frequency may be reduced to annual if concentration data show declining concentrations and that trends will be reviewed and reported on an annual basis. Results of trend analyses and increases or decreases in the sampling frequency will be discussed primarily in the annual Basewide Groundwater Monitoring Program Reports and secondarily in the 5-Year Review documents.

 

 

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Michelle Dalrymple

Department of Toxic Substances Control, Geologist Services Unit Comments Dated: September 17, 2013

SPECIFIC COMMENT

RESPONSE

Comment 1. The term Groundwater Monitoring Evaluation (GME) applies to RCRA regulated landfills and is not directly applicable to IR Site 2. It is more appropriate to use the term “Long-Term Groundwater Monitoring Program” for the purposes of remedy performance monitoring of IR Site 2.

Response 1. Comment noted. Reference to the GME has been modified to read “Long-term Groundwater Monitoring Program”.

Comment 2. A section (or sections) should be added that describes the following:

  • Well construction methods
  • Well construction details
  • Well development procedures
  • Well abandonment procedures
  • Existing well inventory methods
  • Corrective measures (i.e. well rehabilitation), if necessary

Response 2. See responses to EPA General Comments #1 and #3.

Comment 3. A new Sampling and Analysis Plan (SAP) should be prepared for the long-term monitoring program for IR Site 2 in compliance with California Code of Regulations Title 27, Subchapter 3. Water Monitoring, and Title 22 Chapter 14, Article 6. The SAP should include a field sampling plan and quality assurance project plan.

Response 3. See response to EPA General Comment #2.

Comment 4. Section 2.1.1 and Section 2.1.2: Table 2-1 lists analytical methods but not analytes. The analytes should be specified in this document and/or in the SAP along with the method detection limits.

Response 4. Text has been added to list the analytes listed in the ROD. A complete list of analytes that will be reported are found in the Basewide Groundwater Monitoring Plan SAP, Worksheet 15A.

 

 

RESPONSE TO COMMENTS

ON FINAL REMEDIAL ACTION WORK PLAN, REVISION 1 DATED AUGUST 2013

INSTALLATION RESTORATION SITE 2, ALAMEDA POINT, ALAMEDA, CALIFORNIA

Comments from: Michelle Dalrymple

Department of Toxic Substances Control, Geologist Services Unit Comments Dated: September 17, 2013

Comment 5. In Section 2.1.1, it is stated: “To reduce any effects due to tidal influence on groundwater sampling of wells immediately adjacent to the shoreline, the sampling will be conducted during the outgoing tide or during low tide. This will reduce the tidal influence (i.e., dilution of the groundwater samples) and improve the sampling event's representation of conditions site-wide.” The meaning is not clear and should be revised. Alternatively, this discussion can be deferred to the SAP.

Response 5. The language has been removed from Section 2.1.1. Information on sampling in respect to tidal events is already included in Section 3.2 of the Basewide Groundwater Monitoring Work Plan (Ses-Tech, 2011).

Comment 6. Section 2.1.3: In addition to concentration trend analysis, water level trends should be evaluated. Please discuss measurement of water levels and evaluation of trends.

Response 6. Water level trends will be reported in the Annual Basewide Groundwater Monitoring Report.

Comment 7. In Section 2.1.3, it is stated: “Data from future analyses will be evaluated with the post-2002 historical data.” Why are only post- 2002 data to be used? Older data are available that may provide useful information

Response 7. See response to EPA Specific Comment #4.

Comment 8. Section 2.2: Groundwater monitoring is planned to commence in January 2014. Please note that new wells must be installed and new SAP must be completed before sampling can begin.

Response 8. Based on construction progress through September 2013, installation and development of new wells is scheduled to be completed by early February 2014. Also see response to EPA General Comment #2.

Comment 9. In Section 2-2, it is stated: “Following 5 years of post- closure monitoring, the monitoring data will be reviewed and if concentration trend data are consistent with pre-closure data or exhibit declining concentrations, groundwater monitoring may be terminated after the review in January 2017 or after subsequent review.” As long as waste is left in place, termination of monitoring is not an option, only reduction in frequency. Also, water level monitoring is necessary to evaluate whether the network remains appropriate, such as in the case of sea level rise. Please revise this section accordingly.

Response 9. See response to EPA Specific Comment #7. Water level monitoring is included in the groundwater sampling events and trends will be reported annually.

 

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Responses to Comments Provided by DTSC Directly in Document

 

 

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

 

CONTRACT NO. N62473-10-D-0809 CTO NO. 0009

 

ATTACHMENT 11

 

FINAL

POST-CLOSURE OPERATIONS, MAINTENANCE, AND MONITORING PLAN

 

R evision 1

 

 April October 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA

 

DCN: RMAC-0809-0009-000X4

 

Prepared by:

 
   

1230 Columbia Street, Suite 750 San Diego, California 92101-8536

 

 

 

Pete Everds Technical Lead

 

 

 

Hedy Abedi, PhD, PE

Project Manager

 

 

 

 

 

 

 

 


TABLE OF CONTENTS

PAGE                                                                                      ABBREVIATIONS AND ACRONYMS............................................................................................... v

1.0         INTRODUCTION...................................................................................................................... 1-1

1.1              SITE DESCRIPTION................................................................................................. 1-1

1.2              SITE HISTORY.......................................................................................................... 1-1

1.3              FUTURE USE.............................................................................................................. 1-2

1.4              PREVIOUS ACTIVITIES......................................................................................... 1-2

1.4.1           Remedial Investigation/Feasibility Study................................................. 1-2

1.4.2           Record of Decision...................................................................................... 1-2

1.4.3           Remedy for Soil........................................................................................... 1-2

1.4.4           Remedy for Groundwater........................................................................... 1-3

1.5              SELECTED REMEDY COMPONENTS................................................................ 1-3

1.5.1           Gas Venting.................................................................................................. 1-3

1.5.2           Subgrade and Foundation Fill..................................................................... 1-4

1.5.3           Multilayer Soil Cover.................................................................................. 1-4

1.5.4           Settlement Monuments............................................................................... 1-5

1.6              DOCUMENT  ORGANIZATION............................................................................. 1-5

2.0         OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND

METHANE MONITORING.................................................................................................... 2-1

2.1              LONG-TERM  GROUNDWATER  MONITORING WELL EVALUATION.... 2-1

2.1.1           Groundwater  Monitoring Well  Network and Sampling Frequency...... 2-1

2.1.2           Proposed Analysis and Field Parameters...................................... 2-32-32-2

2.1.3           Data Analysis.................................................................................... 2-32-32-2

2.2              COMPLIANCE PERIOD............................................................................... 2-42-42-3

2.3              METHANE  MONITORING............................................................................... 2-52-4

3.0         OPERATIONS  AND MAINTENANCE FOR SITE STRUCTURES................................ 3-1

3.1              LANDFILL COVER  SURFACE WATER MANAGEMENT SYSTEM............ 3-1

3.2              WETLANDS CULVERT........................................................................................... 3-2

3.3              GAS COLLECTION.................................................................................................. 3-2

3.4              GAS PROBES............................................................................................................. 3-2

3.5              MONITORING WELLS............................................................................................ 3-2

3.6              SETTLEMENT  MONUMENTS.............................................................................. 3-2

3.7              ACCESS ROADS........................................................................................................ 3-3

3.8              SIGNAGE..................................................................................................................... 3-3

4.0         OPERATIONS AND MAINTENANCE FOR LANDFILL COVER

SETTLEMENT, EROSION, AND VEGETATION.............................................................. 4-1

4.1              DIFFERENTIAL  SETTLEMENT AND EROSION.............................................. 4-1

4.1.1           Detection....................................................................................................... 4-1

4.1.2           Repairs.......................................................................................................... 4-1

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                          i                                                                   Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 


PAGE

4.2              VEGETATION............................................................................................................ 4-2

4.3              DOCUMENTATION.................................................................................................. 4-2

4.4              EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND

SEAWALL................................................................................................................... 4-2

5.0         MONITORING AND MAINTENANCE OF WETLANDS MITIGATION

AREAS........................................................................................................................................ 5-1

5.1              SUCCESS  CRITERIA FOR VEGETATION......................................................... 5-1

5.2              SUCCESS  CRITERIA FOR WILDLIFE................................................................ 5-2

5.3              SUCCESS  CRITERIA FOR HYDROLOGY.......................................................... 5-2

6.0         SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE

ACTIVITIES.............................................................................................................................. 6-1

6.1              SCHEDULED INSPECTION................................................................................... 6-1

6.1.1           Cover Settlement......................................................................................... 6-1

6.1.2           Geonet Animal Intrusion Barrier............................................................... 6-1

6.1.3           Methane Monitoring.................................................................................... 6-1

6.1.4           Wetlands Culvert......................................................................................... 6-1

6.1.5           Site Structures.............................................................................................. 6-2

6.2              FIELD DOCUMENTATION.................................................................................... 6-2

6.2.1           Document Corrections................................................................................ 6-2

7.0      REPORT REQUIREMENTS AND  DATA MANAGEMENT............................................ 7-1

8.0      POST-CLOSURE FINANCIAL ASSURANCE.................................................................... 8-1

9.0      REFERENCES........................................................................................................................... 9-1

TABLES

Table 2-1            Proposed Groundwater Monitoring Well Network, Analyses, and Sampling Frequency

Table 2-21          Standard Operating Procedures for Post-Closure Monitoring and Maintenance

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                          ii                                                                  Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 


FIGURES

 

Figure 1-1           Site Location Map

Figure 2-1           IR Site 2 Groundwater Monitoring Well Locations Figure 2-2          Analytical Trends Comparison Flow Chart

 

Figure 6-1           Proposed Schedule

 

APPENDICES

(on CD only)

 

Appendix A           Long-term Groundwater Monitoring Evaluation Appendix BA  Standard Operating Procedures

Appendix CB        Plan Itemized Cost Estimate Appendix DC      Emergency Response Plan

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                         iii                                                                  Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                         iv                                                                  Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


ABBREVIATIONS AND ACRONYMS

 

 

BGMP                    Basewide Groundwater Monitoring Program CCR       California Code of Regulations

CFR                        Code of Federal Regulations

COC                       contaminant of concern

CTR                        California Toxics Rule

DON                       Department of the Navy

DTSC                     Department of Toxic Substances Control

EC                           engineering control

EPA                        U.S. Environmental Protection Agency

FS                            Feasibility Study

FWBZ                    first water-bearing zone

GME                       Groundwater Monitoring Evaluation

HCH                       hexachlorocyclohexane

IC                            institutional control

IR                            Installation Restoration (Program)

MNA                      monitored natural attenuation

NAS                        Naval Air Station

PCGMP                  post-closure groundwater monitoring program RAO       remedial action objective

RAWP                    Remedial Action Work Plan

RD                          Remedial Design

RI                            remedial investigation

ROD                       Record of Decision

SOP                         standard operating procedure

SWBZ                    second water-bearing zone

 

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                          v                                                                  Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                         vi                                                                  Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


1.0        INTRODUCTION

 

 

Tetra Tech EC, Inc., has prepared this Post-Closure Operations, Maintenance, and  Monitoring  Plan (Plan) for Installation Restoration (IR) Site 2, former Naval Air Station (NAS) Alameda, Alameda Point, Alameda, California. This Plan was prepared for the Department of the Navy (DON), Base Realignment and Closure Program Management Office West under Contract No. N62473-10-D-0809, Contract Task Order 0009. The purpose of this Plan is to describe the operations, maintenance, and monitoring to be implemented after construction of the multilayer  soil cover (cover) on the IR Site 2 landfill. The approach set forth in  this Plan was developed  based on the description of the selected soil remedy in Record of Decision (ROD) (DON 2010), site conditions described in the Remedial Investigation (RI) Report (Battelle and BBL 2006), and the Feasibility Study (FS) Report (Battelle and BBL  2008),  and  procedures  and recommendations presented in the Long-term Groundwater Monitoring Evaluation (Alameda Agencies, 2013).

1.1            SITE DESCRIPTION

The site covers approximately 110 acres in the southwest corner of the former Alameda  NAS,  now referred to as Alameda Point (Figure 1-1). The site consists  of  the  former  landfill  area (West Beach Landfill), which occupies approximately 60 acres, and a wetland, which covers approximately 33 acres immediately south and west of the landfill.  The wetland  area includes  two surface water features, the north pond and the south pond. The north pond is connected by a culvert to San Francisco Bay. The remaining 17 acres within the site boundary is known as the interior margin and the coastal margin. The site is bound on the south and west by San Francisco Bay and on the east and north by runways and tarmacs.

Additional site background information is presented in Section 2.0 of the Remedial Action Work Plan (RAWP).

 

1.2            SITE HISTORY

The site was formerly part of the San Francisco Bay and was created by construction of a seawall around the perimeter, filling with dredge materials, and subsequent disposal of wastes generated  by former NAS Alameda activities  from 1956 through  early 1978.  Historical disposal methods   at the site generally consisted of trench-and-fill operations and placement of cover soil on an intermittent basis. These operations resulted in waste that is in  contact  with  shallow  groundwater. Alameda Point was included on the National Priorities List of Superfund sites in August 1999, U.S. Environmental Protection Agency (EPA) (Identification: CA2170023236).

After landfill operations  ceased in 1978, an  earthen berm was constructed around  the perimeter  of the landfill. The extent of the landfill, as defined in the ROD (DON 2010) and as modified  based on the Intermediate Draft Remedial Design Report (KCH 2011), is shown on Figure 1-1.

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


1.3            FUTURE USE

IR Site 2 has been designated for federal agency (DON) to federal agency (Office of Veterans Affairs) transfer. The proposed future use at IR Site 2 is “undeveloped” with potential for recreational uses such as a perimeter hiking trail.

1.4            PREVIOUS ACTIVITIES

IR Site 2 was used as a landfill. There was no land use at the site prior to 1956, when  the  perimeter sea wall was constructed and the site was first formed by using dredged fill. Due to its historical use solely as a landfill, no persons have resided or currently reside at the site.

1.4.1       Remedial Investigation/Feasibility Study

The Final RI Report (Battelle and BBL 2006), the FS, and Basewide Groundwater Monitoring Program (BGMP) reports describe in detail the nature and extent of groundwater contamination. The most commonly detected organic contaminants in site groundwater are volatile organic compounds, total petroleum hydrocarbons, and other fuel-related compounds (ITSI 2008). Groundwater contamination is characterized by a relatively widespread pattern of low-level contamination. The source of contamination is attributed to the operation of the site as  the principal waste disposal facility for Alameda Point between 1956 and 1978.

1.4.2       Record of Decision

The DON conducted  an FS  (Battelle and BBL 2008) to evaluate potential remedial alternatives  for IR Site 2 and prepared a  ROD  (DON 2010) to document the selected  remedy for  the site.  The DON and the Federal Facility Agreement signatories (the EPA, California Environmental Protection Agency, Department of Toxic Substances Control [DTSC], and the San Francisco Bay Regional Water Quality Control Board) concurred on the selected remedy for the site. The  decision agreed to in the ROD is based on information contained in the administrative record file  as well as on extensive field investigations, laboratory analyses, interpretation of the data, review of current and future conditions, assessment of the potential human health and ecological risks,  and an evaluation of potential remedial alternatives.

1.4.3       Remedy for Soil

The selected remedy for soil, as outlined in the ROD, is Alternative 2, a multilayer soil cover, engineering controls (ECs) and institutional controls (ICs), and monitoring. This alternative consists of installation of an engineered soil cover over the former landfill to isolate buried waste and soil contaminants and prevent animal burrowing;  implementation  of  engineering and  land use controls to protect human health and soil cover integrity; provision for  any  necessary  wetlands mitigation if impacts to wetlands occurs; monitoring of the soil cleanup action and wetlands mitigation to ensure their proper construction and long-term effectiveness; and  conduct of methane gas monitoring as necessary. The RAWP addresses the design of the soil remedy and includes more details on the ECs and ICs.

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


1.4.4       Remedy for Groundwater

The selected remedy for groundwater, as outlined in the ROD, is Alternative 2 –  Monitored Natural Attenuation (MNA). This alternative consists of  regularly  monitoring  groundwater quality using shoreline groundwater monitoring wells to ensure that there are continued stable to decreasing trends in contaminant concentrations, and protection of the beneficial uses of surface water in San Francisco Bay; and implementation of engineering controls and  ICs  to  protect human health and the groundwater remedy.

The objective of MNA is to verify the occurrence of natural attenuation of groundwater contaminants through monitoring. In accordance with the ROD, contaminants  will  not  be  actively remediated, but will be allowed to degrade, adsorb, dilute, or transform according to natural, unaided environmental processes (DON 2010). The groundwater remedy meets the Remedial Action Objective (RAO) described in the ROD to protect beneficial uses of surface  water in San Francisco Bay from the potential for discharge of site groundwater (DON 2010).

Because groundwater at the site is not used for drinking water and is not considered a potential drinking water source, numerical standards associated with groundwater (such as maximum contaminant levels for drinking water) do not apply. Instead, chemicals identified during the remedial investigation in excess of California Toxics Rule (CTR) surface water quality criteria were summarized in ROD Table 2.7.

While the CTR criteria are not directly applicable to groundwater, the criteria are appropriate to provide suitable context for evaluating IR Site 2 groundwater relative to groundwater RAOs. Currently, risk to San Francisco Bay surface water from site  groundwater  is  considered negligible. A groundwater monitoring evaluation and groundwater monitoring activities will be detailed in an Addendum to the RAWP.

1.5            SELECTED REMEDY COMPONENTS

1.5.1       Gas Venting

The landfill area was designed with a passive gas venting system to prevent landfill gas buildup which could disrupt the cover. The gas venting trenches are filled with high  permeability aggregate and geotextile surrounding a 4-inch perforated pipe. The pipes connect to gas  vents  open to the atmosphere.

Ten existing landfill gas probes will be destroyed during soil cover construction. Nine new perimeter gas probes will be installed at IR Site 2, as shown in the design drawings presented in RAWP Attachment 1. These probes will be designed and located as described in the RAWP and attached 100% Remedial Design (RD).

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-3                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 


1.5.2       Subgrade and Foundation Fill

The subgrade and foundation fill will consist of common fill materials or natural ground. The primary requirement for this fill material is that it be compatible and provide stable support for    the cover. The primary purpose of the subgrade and foundation fill is to build up the original landfill surface to moderate, uniform slopes. Grades established for the cover system will be approximately 1.5 percent to account for potential settlement and maintain positive drainage over the cover system.

1.5.3       Multilayer Soil Cover

The proposed cover will be 2 feet thick to provide required isolation from the waste, and will consist of three distinct layers:

  • Animal intrusion barrier consisting of minimum 220-mil high-density polyethylene geonet
  • Cover layer of 18 inches of common fill
  • Vegetative layer of 6-inch-thick topsoil amended to help establish vegetation

 

1.5.3.1              Animal Intrusion Barrier

The animal intrusion barrier will be installed utilizing minimum 220-mil layer of high-density polyethylene geonet.  The material will require no specialized seaming and  will  transverse the  fill.

1.5.3.2              Cover Layer

After the animal intrusion barrier is placed over a portion of the site, a cover  layer  will  be installed consisting of an 18-inch layer of import  material  meeting  geotechnical specifications and conditioned for moisture.

 

1.5.3.3              Vegetative Layer

The vegetative layer is a 6-inch layer that requires only 85 percent compaction and is amended to help establish vegetation. This fill material is similar to the cover material.

 

1.5.3.4              Vegetation

The landfill cover will be hydroseeded with a mixture identified in  the Specifications  in  the  100% RD (Attachment 1 to the RAWP).

 

1.5.3.5              Surface Water Management System (Drainage and Swale Layer)

Two new earthen swales with turf reinforcement mats are integrated into the cover design. The channels slope from 0.5 to 1 percent and have been placed to maximize the efficiency  of  collection and transfer of sheet flow from the completed cover.   An existing concrete channel

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-4                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

located on the eastern boundary of the site will be maintained throughout construction and incorporated into the final drainage system.

1.5.4       Settlement Monuments

Four settlement monuments will be installed on the final cover system as specified in the 100%  RD (Attachment 1 of the RAWP). Markers will be located where the depth of fill is the greatest and therefore settlement potential the highest. The monuments will be located so that settlement rate and trends can be monitored and assessed.

1.6            DOCUMENT ORGANIZATION

This Plan is organized as follows:

 

  • Section 1.0 provides the site description, history, previous activities, site remedy components, and document organization.
  • Section 2.0 describes the requirements for post-closure groundwater and methane monitoring.
  • Section 3.0 describes the operation and maintenance requirements for site structures.
  • Section 4.0 describes the operation and maintenance requirements for  the  landfill cover settlement.
  • Section 5.0 describes the monitoring and maintenance requirements for the wetlands mitigation areas.
  • Section 6.0 provides the proposed schedule.
  • Section 7.0 describes reporting requirements.
  • Section 8.0 provides post-closure financial assurance.
  • Section 9.0 provides post-closure certification.
  • Section 10.0 lists the references cited in the text.
  • Tables and figures follow the text.
  • Appendix A presents the Long-term Groundwater Monitoring Evaluation (GME)
  • Appendix BAincludes the Standard Operating Procedures (SOPs).
  • Appendix CBpresents the estimated annual cost for operations, maintenance, and monitoring.
  • Appendix DCpresents the required Emergency Response Plan.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-5                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       1-6                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


2.0        OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND METHANE MONITORING

 

 

2.1            LONG-TERM GROUNDWATER MONITORING WELL NETWORK EVALUATION

The DTSC, in a written communication dated March 1, 2013, requested that the DON submit a separate Groundwater Monitoring Evaluation (GME) as a Remedial  Design  Addendum  document. Groundwater monitoring requirements will be detailed in the GME and will be incorporated in the post-closure United Federal Programs Quality Assurance Project Plan. The construction of the soil remedy is not dependent on concurrence with a GME.

In accordance with groundwater requirements in the ROD, this section presents the groundwater monitoring methods and criteria for assessing groundwater data trends to  confirm  that contaminant levels remain within an acceptable range. The monitoring well network, monitoring schedule, analytes, and methods are defined. As part of their technical review and oversight, the regulatory agencies provided recommendations for the long-term groundwater monitoring programperformed a Groundwater Monitoring Evaluation (GME) of for Alameda IR Site 2 (Alameda Agencies, 2013), which areis included as Appendix A. These recommendations were based on an evaluation of available historical geologic, hydrogeologic, and analytical data for IR Site 2. Post-closure groundwater monitoring requirements are presented below incorporating details from the GME (Appendix A).

2.1.1       Groundwater Monitoring Well Network and Sampling Frequency

The long-term monitoring plan has been designed to demonstrate protection of San Francisco    Bay (bay) and the North and South Ponds (wetlands) from contamination in groundwater that   may migrate beneath IR Site 2 and discharge to these surface water bodies. The long-term groundwater monitoring well network focuses on groundwater potentially influenced by the landfill that is hydraulically connected to the wetlands and the bay. The groundwater monitoring well network includes interior FWBZ wells that are downgradient of the landfill and upgradient   of the wetlands, and shoreline downgradient FWBZ wells that are downgradient of the landfill   and adjacent to the bay (Figure 2-1).  Historical groundwater flow directions support the  placement of these monitoring wells and flow directions will continue to be evaluated to ensure that the monitoring network remains appropriate for its intended purpose.Existing upgradient FWBZ wells will be used for water level information and to monitor quality of groundwater migrating on to the site. Figure 2-1 shows the locations of wells that constitute the groundwater monitoring well network.

 

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

Comment [DM1]: Add section describing new well construction methods and details, including well development.

Comment [MB2]: This information was added to the main text of the work plan.

 

 

in the mid-1990s and have been sampled since that time yielding a robust historical data set.  As

shown on Figure 2-1 and

discussed further in Section 5.8.3 of the RAWPXX

, 4 new well

Comment [DM3]: Add well abandonment procedures.

Comment [MB4]: This information was added to the main text of the work plan

 

 

clusters, completed in the upper and lower FWBZ wells will be constructed and added to the program to enhance coverage of the  monitoring network.   Existing upgradient FWBZ wells on the upgradient perimeter of the site will be used for water level information and to monitor   quality of groundwater migrating on to the site.    SWBZ wells (i.e., within and/or below the  BSU) are not included in the monitoring program because data from these wells are not representative of the shallow groundwater water discharging to the wetlands and/or bay, and because they are below the depth of the influence if the landfill.  SWBZ wells will be abandoned

as shown on Figure 2-1. and

discussed in Section XX

Well

destruction methods are described in

Section 5.5.1 of the RAWP..

 

 

Comment [DM5]: Analytes are not listed on table 2-1. They should be specified somewhere.

Comment [MB6]: A complete list of analytes for each EPA method along with reference limits is included in the SAP, Worksheet #15A

 

 

Table 2-1 identifies the monitoring well, water-bearing zone, proposed analytical methods, and                                                                                                                                                                     well sampling frequency. A new Sampling and Analysis Plan will be prepared for the long-term monitoring program for IR Site 2, in compliance with California Code of Regulations Title 27,

Comment [DM7]: Discuss how well inventory will be performed and possible corrective measures.

Comment [MB8]: A discussion of well inventory has been added to the main text of the RAWP and will take place prior to new well installation.

Additionally, a well inventory will be completed prior to each post-completion groundwater sampling event as detailed in Section 3.5 of this Plan.

 

 

Subchapter 3. Water Monitoring, and Title 22  Chapter 14, Article 6.   The new SAP  will include  a field sampling plan and quality assurance project plan along with a complete listing of analytes. As discussed further in Section XX3.5, a well inventory will be performed to evaluate the  condition of existing monitoring wells  that will remain in the program.. Corrective measures   (such as redevelopment) will be performed as necessary.

The groundwater monitoring well network is considered sufficient to demonstrate the protection of San Francisco Bay surface water from the potential for discharge of site groundwater and that the concentrations of groundwater contaminants that may pose a threat to San Francisco Bay surface water are stable or decreasing.

Comment [DM9]: Not sure what this means. Please revise.

Comment [MB10]: Text has been removed.

Comment [DM11]: This can be discussed in the SAP.

Comment [MB12]: Comment noted. This text has been removed as information on sampling in respect to tidal events is already included in Section

3.2 of the Basewide Groundwater Monitoring Work Plan (Ses-Tech, 2011).

 

 

To reduce any effects due to tidal influence on groundwater sampling of wells immediately adjacent to the shoreline, the sampling will be conducted during the outgoing tide or during low tide. This will reduce the tidal influence (i.e., dilution of the groundwater samples) and improve the sampling event’s representation of conditions site-wide.

Well sampling frequency will be quarterly for the first year for all newly installed wells. After one1 year of monitoring, the frequency may be reduced to semiannual based on criteria described below. Existing wells at the site will continue to be sampled semi-annually. In the event that unusual variability is seen in the groundwater results, the frequency of sampling events will be evaluated and potentially increased.

 

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

and on the Analytical Comparison Flow Chart  (Figure 2-2). Decreases  to  sampling frequency  will be considered if:

  • Current concentrations continue to show stable or decreasing trends  compared  to  historical results

 

Increases to sampling frequency will be considered if:

 

  • Concentration trends are found to be increasing (assumption is  currently there are  none trending upward)
  • Concentration of a constituent is greater than the historical maximum in three successive samples
  • Concentrations become significantly more variable than seen in the historic data set

 

Maximum sample frequency will be quarterly. Trends will be evaluated in  the annual  report  based on the methodology described in Section 2.1.3. If an increasing trend is confirmed, the operations and maintenance contractor will notify the DON who will notify DTSC and the Regional Water Quality Control Board. A corrective action plan may be developed as necessary.

2.1.2       Proposed Analysis and Field Parameters

Comment [DM13]: The table only lists the analytical methods, not specific analytes.

Comment [MB14]: The analyte list from the ROD has been added back into the text and reference to the worksheet for the SAP with a complete listing of analytes has been added.

 

 

Proposed analytes include metals, pesticides, and semi-volatile organic compounds (SVOCs) and volatile organic compounds (VOCs). Proposed analytes include those listed in ROD Table 2-7.  The list includes metals (arsenic, copper, and nickel), pesticides (aldrin, alpha chlordane, a- hexachlorocyclohexane [HCH], b-HCH, 4,4-dichlorodiphenyldichloroethene, 4,4- dichlorodiphenyltrichloroethane, dieldrin, endrin, gamma chlordane, heptachlor, and heptachlor epoxide), and the semivolatile organic compound/polynuclear aromatic hydrocarbon diethylexyl phthalate. The list was developed to meet the RAOs described in the ROD to protect beneficial uses of surface water in San Francisco Bay from the potential for discharge of site groundwater (DON 2010). Table 2-1 lists the proposed analytes analyses for each well. A complete list of analytes is included in Worksheet 15A of the Basewide Groundwater Monitoring Program SAP (SES-TECH, 2011).

Comment [DM15]: In addition to concentration trend analysis, water level trends should be evaluated. Please discuss measurement of water levels and evaluation of trends.

Comment [MB16]: Measurement of water levels and discussion of trends can be found in the Work Plan and the Annual Reports of the Basewide Groundwater Monitoring Program.

 

 

Field parameters including depth to groundwater, pH, conductivity, turbidity, temperature, dissolved oxygen, and oxidation reduction potential will be  recorded  during  post-closure sampling events.

2.1.3 

Data Analysis

 

 


Downgradient wells at the site perimeter and along the bay and interior coverData from all shoreline and interior wells will be used for the trend analysis, as required by the ROD. Data

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-3                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 

Comment [DM17]: Why? Older data are available and may be meaningful.

Comment [MB18]: Older data is fine as long as the detection limits are below the action levels.

 

 

from future analyses will be evaluated post-2002 using historical data. New wells will be

monitored for at least 4 quarters before evaluating trends.

 

Analytical results for each well will be evaluated using a graphical representation of the concentrations trends. A time-series plot will be generated for all wells for the analytes listed above. in Table 2-1. The plots will be examined to identify obvious trends and outlier data. A minimum of two samples are required for the plots.

Next, a statistical outlier analysis will be conducted for each data set using either the Dixon Test (less than 25 samples with a minimum of 3 samples), the Rosner Test (greater than  25 samples  and normally/lognormally distributed), or the Discordance Test (3 or more samples and normally/lognormally distributed after outlier removal).

After the outliers are removed, new trend plots will be created. Each trend plot will include a first-order linear trend line statistically derived using Microsoft Excel or other comparable software. Non-detect observations will be treated as nil values (i.e., zeros) in  the trend  plots, which is consistent with the procedure used in the FS Report (Battelle and BBL 2008).

A visual, qualitative assessment will be performed on each time-series  plot.  Professional  judgment will be used on the evaluation with an understanding of site conditions and considering inconsistent results and the possible effects  of changes  in detection  limits.  A minimum number of two data points are required for the plots.

Finally, a Mann-Kendall trend analysis will be performed for each well/analyte. The Mann- Kendall test will determine whether there is an upward, downward, or no trend. The Mann-  Kendall test is not affected by large variations in analyte concentration, which can  cause  erroneous results from methods such as  linear regression analysis. A minimum of four samples  are required.

Groundwater data and trends need to be evaluated with the ROD criteria “to confirm that the contaminants remain within an acceptable range” (DON  2010).  This  operations  and  maintenance plan proposes that so long as monitoring results do not trigger a response as defined  in Section 2.1.1, the results are within an acceptable range.

2.2            COMPLIANCE PERIOD

The PCGMP is configured as a remedial action monitoring program where the purpose of the monitoring is to assess the performance of the remedial action (Title 22 California Code of Regulations [CCR] Section 66264.100). Because the landfill will  be  in  post-closure,  the provision of Section 66264.100 for returning a facility to detection  monitoring  (Section  66264.98) is not applicable.  The performance of the PCGMP will be evaluated during the 5 year

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-4                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 

review process. The protectiveness of the groundwater monitoring remedy along with the cover system and ICs will also be evaluated as part of 5-Year reviews required by EPA.

 

Comment [DM19]: New wells must be installed and new SAP must be completed

Comment [MB20]: Comment noted.

Comment [DM21]: This is confusing. The five- year review is in 2017 which is after only three years

of monitoring. Please revise.

Comment [MB22]: IR Site 2 will be evaluated during the basewide 5-yr reviews, the next one is

scheduled for 2017

Comment [DM23]: As long as waste is left in place, termination is not an option, only reduction in frequency. Also, water level monitoring is necessary to evaluate whether the network remains appropriate,

such as in the case of sea level rise. Please revise.

Comment [MB24]: Revised to state that monitoring requirements may be reduced, rather than terminated based on reviews either conducted during the scheduled basewide 5-yr reviews or annual groundwater monitoring reports.

 

 

The first groundwater monitoring event is planned  to occur  in JanuaryFebruary 2014 based on    the current landfill construction schedule. Groundwater monitoring data will be reviewed and  results of the trend analyses will be reported coincident with the Basewide Groundwater Program Monitoring Reports and the scheduled 5-Year reviews. If concentration trend data are consistent with pre-closure data or exhibit declining  concentrations,  groundwater  monitoring  frequency  may be terminated reduced.

 

 

2.22.3METHANE MONITORING

Methane monitoring will be conducted in accordance with Title 27 CCR, Section 20921 (a), to provide for the protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone and that methane levels in  ambient air at  the landfill perimeter is in compliance. Nine new monitoring probes will be installed around the landfill perimeter. Methane monitoring probe construction details are included in the 100% RD (Attachment 1 to the RAWP, sheet D-2). Probe locations are shown on sheets C-9 through C-11.

Methane monitoring will be conducted quarterly. Methane will be measured at each probe to evaluate subsurface concentrations. An exceedance of the criterion will be considered verified if concentrations are above 5 percent by volume for any two of three consecutive quarters. If  methane concentrations are confirmed, the EPA and the San Francisco Bay Regional  Water Quality Control Board will be promptly notified and the gas control system design re-evaluated.

In addition, barometric pressure, atmospheric temperatures, and general weather conditions will   be reported at the time of gas collection. It is recommended by  the  Integrated  Waste  Management Board to collect landfill gas during barometric low pressures. Depending on the weather, this may be late in the morning or early in the afternoon.

In addition to monitoring  the  probes,  perimeter  monitoring  locations  spaced  approximately  250 feet apart along the boundary of the landfill cover will be used to monitor ambient air at the point of compliance.   Establishing the perimeter monitoring locations  will be the responsibility   of the post-closure operations and maintenance contractor. Relevant  standard  operating procedures for landfill probe and surface perimeter monitoring are listed in Table 2-21 and included in Appendix BA.

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-5                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       2-6                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


3.0        OPERATIONS AND MAINTENANCE FOR SITE STRUCTURES

 

 

The maintenance and monitoring will begin once the landfill soil cover construction is complete, anticipated to be in January 2014.

 

3.1            LANDFILL COVER SURFACE WATER MANAGEMENT SYSTEM

Existing drainage features include concrete channel, drainage piping and inlets, concrete outfall culverts, and earthen swales. Supplemental drainage in accordance with  the final  cover  design will supplement existing drainage with a total of three turf reinforced mat channels. An existing concrete channel located on the eastern boundary of the site will be maintained throughout construction, and incorporated into the final drainage system.

Concrete channels and earthen swales with turf reinforcement mat collect and divert stormwater runoff. Concrete channels prevent erosion in areas where stormwater flow might accumulate. Proper and adequate inspections of the channels are required to prevent sediment build-up and failure of integrity. Inspections will be conducted annually before the rainy season and  in  the event of heavy precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or

0.25 inch or more within 1 hour. The inspection will  be  in  accordance  with  SOP  004  (Appendix BA).

Concrete channels associated with the landfill cover drainage system will be visually inspected    by walking the length of each channel. Special attention is  required  to  verify sediment  and  debris accumulation along the channels, cracking or fractures of the concrete structure, erosion at joints or along edges, and separation or deterioration of joints between concrete sections.

Drainage pipe cleanout ports and discharge piping will be visually inspected for damage or blockage. Drainage pipe outlets, discharge piping, and riser pipes will be cleared to allow free  flow of water. The pipe outlets will also be inspected for blockage.

Nonconcrete drainage channels and swales will be inspected for erosion and proper functioning. Special attention should be directed to areas of no grass or patchy grass; ripples or swells in the  soil caused by erosion; and settlement that inhibits or prohibits storm water flow.

Stormwater should flow around, off, and away from the landfill cover, with visual flow directly into the concrete channels or other established drainage routes. The perimeter of the cover should be inspected to check that drainage flows around and  away from the cover. The lip and entrance  to concrete drainage channels will also be inspected to  check for areas  where storm water may  not readily enter a channel. Inspection should be made by walking the cover perimeters and drainage channels.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       3-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 


3.2            WETLANDS CULVERT

The wetlands culvert hydraulically connects the North Pond to San Francisco Bay. The culvert will be inspected quarterly and in the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

3.3            GAS COLLECTION

The landfill passive gas collection system consists of a perimeter boundary conveyance trench filled with high permeability sandy soil surrounding a 4-inch perforated pipe. The pipes are connected to gas vents open to the atmosphere at the high end of the trenches.

 

The gas vent pipes will be visually inspected in accordance with SOP 009 (Appendix BA) with extra attention centered on cracks or holes in the riser pipe; missing or damaged screens and end caps; and completely destroyed riser pipes. The gas collection system will be decommissioned if results of methane monitoring indicate that the system is not required based on  results provided   in annual monitoring reports or the 5-Year Rreviews.

3.4            GAS PROBES

Existing soil gas probes located within the landfill boundary will be destroyed prior to multilayer soil cover installation. A network of nine probes will be installed around the perimeter of the landfill in order to establish a compliance plane. The probes  will be monitored  in  accordance  with SOP 008 (Appendix BA).

3.5            MONITORING WELLS

Existing groundwater monitoring wells located within the landfill boundary will be protected during cover construction, where feasible. At the completion of the soil  cover, all  existing wells  at the site will be inventoried. If an existing well is damaged or removed for cover construction purposes, a replacement wells screened at the same intervals will be installed within a 5-ft radius  of the original well. If excess sedimentation is noted, the wells will be redeveloped prior to sampling. Results of the well inventory will be reported in the RACR.

Routine mMonitoring well inspection and maintenance will be performed during sampling activities. The condition of the well vault lid, lid bolds, well cap, and  well ID will be inspected  and noted during each sampling event. Observations will be recorded on field monitoring well sampling forms. Well sampling methodology is included in the current Basewide Groundwater Monitoring Program SAP.

3.6            SETTLEMENT MONUMENTS

Four settlement monuments will be installed on the final cover system as shown in the100% RD (Attachment 1).   Markers  will be located  where the depth  of fill  is  the  greatest  and,  therefore,

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       3-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


settlement potential is the highest. The monuments will be located so that settlement rate and  trends can be monitored and assessed.

 

Monuments will be surveyed annually. Additionally,  topographic surveys  of  the  entire  cover will be conducted every 5 years to evaluate settlement. Annual surveying will include the following:

  • Inspect each monument with respect to the surrounding surface of the cover, noting whether the station appears to be even with the surrounding surface, if it is in a depressed area, or if the area is higher than the surrounding surface.
  • Record all observations.
  • Survey and record the elevations of all four settlement monitoring stations to an accuracy of 0.01 foot vertically against the benchmark.

 

Survey data will  be collected by a California licensed surveyor and the data will be included in   the annual reports and 5-Year Review. If significant settlement is found (typically more than

0.75 foot), a professional engineer will evaluate the situation and  the site operator/manager  will  be notified.

3.7            ACCESS ROADS

Access roads within IR Site 2 will be constructed to provide easy access to  the  site  for  monitoring and maintenance activities. Each road is approximately 24  feet  wide,  constructed  with 12 inches of compacted aggregate over geotextile fabric (100% RD, Attachment 1 to the RAWP, sheet D-4). Inspection of the roads will be conducted in  association  with  other monitoring and maintenance activities. Access road inspection will be in  accordance with  SOP 003 (Appendix BA). Access road maintenance and repair will be conducted in accordance with SOP 006 (Appendix BA).

3.8            SIGNAGE

Maintenance activities will include inspection of general information placards for the perimeter monitoring locations and signs for the public indicating trail use or restoration areas on a semiannual basis to ensure that they have not been damaged. Signs that have been altered, or affected by natural conditions, will be replaced.

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       3-3                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       3-4                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


4.0      OPERATIONS AND MAINTENANCE FOR LANDFILL COVER SETTLEMENT, EROSION, AND VEGETATION

 

 

4.1            DIFFERENTIAL  SETTLEMENT  AND EROSION

Differential settlement is caused by decomposition and/or consolidation of subsurface material, which may result in adverse grade or depression on the surface of the landfill cover. Since the groundwater remedy is MNA and the cover design does not address groundwater, differential settlement that results in ponding of surface water or affects drainage controls may not require corrective action. Erosion is anticipated to be the most common problem that will affect the  landfill cover. Erosion is typically noted at the base of long slopes where water tends to  accumulate due to grading and drainage patterns. Settlement or effects to drainage controls that cause erosion and reduce the thickness of the cover will need to be corrected.

4.1.1       Detection

The IR Site 2 landfill cover will be visually inspected quarterly by the Operations Manager or his/her designee and annually by a registered civil engineer or engineering geologist as described  in SOP 001 (Appendix BA) to ensure the integrity. Landfill cover maintenance activities will include assessment of the landfill cover conditions, vegetation  control  and  restoration,  and animal control. The perimeter of the landfill will be evaluated for areas where surface water is impounded, excessive erosion is evident, or sloughing is apparent on a slope.  Surface  cracks  more than 1 inch wide and 12 inches deep, or longer than 20 feet may indicate slope instability, settlement, or internal thermal activity of the landfill. The quarterly inspection  will  include looking for pieces of geonet material and waste items on the cover  surface that  indicate the  geonet animal intrusion barrier has been breached by burrowing animals. Landfill cover maintenance and repairs will be conducted in accordance with SOP 007 (Appendix BA).

4.1.2       Repairs

For areas where the thickness of the cover has been compromised and repair is warranted, the  cover will be repaired by excavating and stockpiling the top cover soils in  the impacted  area  down to the animal intrusion barrier, and regrading that portion of the cover with material comparable to that used in the original cover design.  Animal burrows  that breach  the geonet  layer will be filled with low-strength concrete slurry. Repairs will need to be inspected by a registered civil engineer.

New fill soils would be placed at the locations designated by the registered civil engineer and compacted to 6 inches below the unaffected surrounding cover and compacted to approximately  90 percent of the Modified Proctor maximum dry density with water content  within  0  to  4 percent of the modified optimum. The area will be re-covered with the removed topsoil cover material, compacted to approximately 85 percent, and scheduled for vegetation restoration.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       4-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 


The final grade will be graded with no more than a 1.5 percent slope and reseeded to match the undisturbed surrounding area. Major repair work will be inspected after completion by  a  registered engineer. The area will be surveyed after repair to obtain a record of the surface elevations of the repaired area.

4.2            VEGETATION

The landfill cover will be hydroseeded with a mixture identified in the Specifications (100% RD Attachment 1 to the RAWP, sheet C-12). Once established, the vegetative cover will appear  similar to local natural open space areas. The vegetative cover will turn green during the rainy season and is expected to fade to brown during the dry season. Since the landfill cover will be hydroseeded, during the rainy season, supplemental irrigation is not anticipated. The cover vegetation will be inspected as described in SOP 005 (Appendix BA).

Reseeding may be required to cover repairs, eroded areas, dead areas, and bald spots.  Supplemental irrigation may be required to help establish  reseeded  areas. Water  will be  applied to re-seeded areas at a sufficient rate to ensure moist soil conditions to a minimum 1 inch depth, while preventing run-off.

4.3            DOCUMENTATION

Inspection of cover settlement should be recorded on the standardized form developed for this purpose provided in SOP 001, Multilayer Soil Cover Inspection.

Information on the form includes:

  • Settlement location with regard to permanent markers
  • Measurements of settlement or erosion

 

4.4            EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND SEAWALL

If a major seismic event occurs, the operation and maintenance contractor or designated alternate will initiate procedures to inspect all landfill systems, including settlement monuments. Initial repairs will be performed within 72 hours. For the purpose of this plan, a major seismic event is defined as one that equals or exceeds Intensity V (as defined by the Modified Mercalli Scale) at  the site.

A major earthquake will require implementation of the following SOPs for inspection of all systems:

  • SOP 001      Multilayer Soil Cover  Inspection
  • SOP 002      Landfill Gas Surface  Monitoring
  • SOP 003      Access Road Inspection
  • SOP 004      Surface Water Management System Inspection and Maintenance

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       4-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 


  • SOP 005      Vegetative Cover Inspection and Maintenance
  • SOP 006      Access Road Maintenance and Repair
  • SOP 007      Multilayer Soil Cover Maintenance and Repair
  • SOP 008      Landfill Gas Probe Monitoring
  • SOP 009      Landfill Perimeter Gas Vent Inspection and Maintenance

 

If the seawall or the berm is damaged, it will be repaired. SOP 007 has procedures for repairing shallow and deep cracks, vertical cracks, cracks with vertical displacement, depressions, and sloughing/slope failure, which  will be used  for berm repair.  For seawall repairs, inspection of   the damage by a qualified engineer will be required  to design  the  repairs including procedures  for completing these repairs. These repairs could include relocating displaced riprap, and the use  of gunite, concrete, or other similar materials to repair cracks and voids. Placement of additional riprap may also be necessary to repair and/or raise the seawall. Surface water that contacts the landfill waste as a result of a major seismic event will be confined and addressed. The PCGMP well network will also be inspected. Resampling of the monitoring wells will be evaluated. If inspection of the systems detects a noncompliance, the  operations  and  maintenance contractor will notify the site management representative, who will notify the EPA, DTSC and the Regional Water Quality Control Board.

 

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       4-3                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       4-4                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 


5.0       MONITORING AND MAINTENANCE OF WETLANDS MITIGATION AREAS

 

 

A baseline vegetation and wildlife survey that will occur immediately prior to construction will establish overall percent cover, document the composition of the vegetative community, and establish average daily use of the reference areas by shorebirds and waterfowl.  Hydrologic  success will also be considered.

5.1             SUCCESS CRITERIA FOR VEGETATION

During the vegetation survey, permanent 1-meter-square reference plots will be established on transects running through the entire mitigation sites. These transects and monitoring plots will be assessed on a yearly basis using the same criteria as those used to establish baseline conditions. The survey will document mortality, weed invasion, and rate of colonization. Success criteria for vegetation are as follows:

  • In the tidal marsh area, existing conditions show a pickleweed community cover  density of approximately 75 to 100 percent in the wetland areas that will be affected. The 5-year monitoring goal is to attain this same density and the same plant  community composition as under existing conditions.  The  Year  1  goal  is  to  show 10 percent pickleweed cover, increasing to 25 percent at Year 2, 50 percent in Year 3, and 75 percent in Year 4. If these goals are not met, the restored area will be assessed  to determine if site conditions are not conducive to plant growth. If needed, corrective actions including planting pickleweed plugs taken from a nearby location will be implemented. Corrective actions would be implemented in Year 2 and beyond if needed.
  • There is no invasive cordgrass or pepperweed in the tidal marsh at this time. Success criteria require that this state be attained and maintained in the mitigation area for the duration of the 5-year monitoring period.
  • In the open water/mudflat habitat, there will be little to no vegetation in the  low-  marsh (mudflat) areas, and the mid- and high-marsh areas are projected  to  be vegetated almost exclusively with pickleweed to reflect current conditions. Success criteria are such that the mudflat area will have less than 10 percent vegetation below

-0.2 feet NGVD29, and this vegetation will be a minimum of 80 percent pickleweed. Above -0.2 feet, pickleweed will increase in density to 75 to 100 percent over 5 years. The pickleweed fringe will be maintained by work crews who will remove cordgrass and pepperweed by hand or other approved method to ensure no  encroachment of  these weed species.

  • If success criteria are not met, corrective action will be taken. For vegetation establishment, this  means that pickleweed plugs will be planted in quantities needed   to attain goals if goals are not met at Years 2 and beyond. For invasive species, this means that all invasive cordgrass or pepperweed will be removed on  a  yearly basis,  on a date preceding normal seedset.

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       5-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


5.2            SUCCESS CRITERIA FOR WILDLIFE

For wildlife, bird counts will occur at the appropriate time of year and will occur over successive tidal cycles. Bird usage of the tidal pond, the mudflats, and freshwater pond will be documented and used to create the baseline conditions against which to measure success. Success criteria for bird use of the mitigation sites is such that bird use would increase incrementally over a 5-year period as the invertebrate community in the substrate increased, and would match the rate of bird use in the reference (adjacent) areas at the end of the 5-year monitoring period.

5.3             SUCCESS CRITERIA FOR HYDROLOGY

Although a detailed hydrologic study of the site has not been completed, success criteria are such that hydrological features found at the reference areas (meaning wetlands directly adjacent to the mitigation areas) will be found in the mitigation areas as well. In the tidal  areas, this means that  the constructed wetlands will be tidally inundated and drained on a diurnal basis on the same intervals as the reference area.

In the open water/mudflat/pickleweed freshwater areas near the South Pond, the mitigation wetlands will have been graded to the same elevation as the reference habitat; therefore, success criteria are such that surface water levels and mudflats will mimic conditions found in the surrounding areas that have the same surface elevation. In general, this means that surface water levels will be highest in the period from December through April, and will diminish thereafter. In dry years, the freshwater open water area and mudflat may dry completely in late summer.

Hydrologic features of the site will not be manipulated during construction; however, if after project implementation hydrological features do not appear to be operating as planned, a hydrologic assessment of the area will be performed by a hydrologist and recommendations for further grading will be made.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       5-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 


6.0       SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE ACTIVITIES

 

 

The proposed schedule is presented on  Figure  6-1.  The schedule assumes  that construction of  the cover will be complete in January 2014. Adjustments  to the schedule may be necessary if  there are changes to the construction schedule. Time frames for activities are approximate and correspond with the frequency of tasks discussed in subsequent sections. Severe damage, catastrophic events, and some minor items, such as watering of the cover  vegetation, have  not been included since these events do not occur on a regular schedule.

6.1            SCHEDULED INSPECTION

IR Site 2 will be inspected quarterly and after major weather (any rain event with 0.5 inch of rain occurring in a 24-hour period) or seismic events (Modified Mercalli Intensity V) for damage, and maintenance will be performed as necessary. Inundation due to gradual sea level rise will be monitored and reported as part of the quarterly inspections. Inspection items and  corrective  actions are described in the following sections. If damage to the cover system is observed during any post-closure inspection, the cause of the damage will be investigated and documented in the inspection log.

6.1.1       Cover Settlement

Inspection of the landfill cover condition and the slopes of the landfill will occur on a quarterly basis and after significant events.

6.1.2       Geonet Animal Intrusion Barrier

The quarterly inspection will include looking for pieces of geonet material and  waste items on    the cover surface that indicate the geonet animal intrusion barrier has been  breached  by  burrowing animals.

6.1.3       Methane Monitoring

Methane monitoring will be conducted quarterly for the first 5 years following the completion of the cover construction, and will be re-evaluated during the 5-year  review.  Methane monitoring will consist of both soil gas probe monitoring and ambient air monitoring at the perimeter of the landfill.

6.1.4       Wetlands Culvert

The culvert connecting San Francisco Bay with the IR Site 2 wetlands area will be inspected on a quarterly basis and after significant events. The Navy will make necessary repairs, modifications  or replacement to maintain tidal circulation as recommended by the structural assessment of the culvert if warranted. In the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       6-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 


6.1.5       Site Structures

The following structures shall be inspected semiannually:

 

  • Signage
  • Landfill perimeter gas vents
  • Settlement monuments

 

Settlement monuments will be surveyed annually. Access roads and surface water management structures will be inspected annually before the rainy season and in the event of heavy  precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour.

6.2            FIELD DOCUMENTATION

SOPs have been included in Appendix BA with documentation forms for field recording of scheduled routine maintenance and monitoring data collection.

6.2.1       Document Corrections

Changes or corrections on any project documentation will be made by crossing out the erroneous item with a single line and initialing (by the person performing the correction) and dating the correction. The original item, although erroneous, must remain legible beneath the  crossed-out line. The new information should be written clearly above the crossed-out item.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       6-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


7.0    REPORT REQUIREMENTS AND DATA MANAGEMENT

 

 

Reporting will occur as a part of this Plan. Reporting will consist of submitting annual reports to the EPA, DTSC, and Regional Water Quality Control Board. The inspection and monitoring program established will be evaluated  annually by an  independent, qualified  engineer registered in California, The inspection will include review of the condition of all surface improvements, drainage facilities, erosion control facilities, vegetative cover, gas control facilities,  and  monitoring facilities. Specifically, the annual report will present:

  • Survey data
  • Site inspection data:

–       Condition of vegetation

–       Erosion

–       Cracking

–       Seepage

–       Slope stability

–       Subsidence

–       Settlement

–       Condition of run-on and run-off control systems

–       Condition of surveyed benchmarks

  • Groundwater monitoring system and analytical results for samples collected in the previous semiannual and current annual sampling events
  • Perimeter landfill gas probe and ambient air monitoring results
  • Trends analyses results

 

Initially (for the first year at a minimum), stand-alone reports will be submitted. A 5-year review will be completed for the site at the time of the basewide 5-year review cycle in 20176.

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       7-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 


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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       7-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


8.0    POST-CLOSURE FINANCIAL ASSURANCE

 

 

A detailed cost estimate for annual operating, maintenance, monitoring, and reporting is included  in Appendix CB. The estimated annual cost for anticipated activities is $101,715 in 2012 dollars. The DON is fiscally responsible for post-closure related costs until such time as the site is transferred to the Office of Veteran Affairs.

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       8-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       8-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

 

 

 

 


9.0    REFERENCES

 

Alameda Agencies (Department of Toxic Substance Control, U.S. Environmental Protection Agency, and Regional Water Quality Control Board), 2013. Installation  Restoration  Site  2, Alameda Point, Long-Term Groundwater Monitoring Evaluation and  Recommendations. Email Correspondence dated May 29, 2013, sent to  the  DON  Alameda Lead RPM, William McGinnis

AMEC (AMEC Earth & Environmental, Inc.). 2010. Draft 2009  Annual  Groundwater  Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point,  Alameda, California. March.

—————. 2011. Final 2010 Annual  Groundwater  Monitoring  Report,  Basewide  Groundwater Monitoring Program, Alameda Point, Alameda, California. June.

Battelle and BBL (Blasland, Bouck, and Lee, Inc.).  2006.  Final  Remedial Investigation  Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. Prepared  for  Base Realignment and Closure, Program Management  Office  West,  San Diego,  CA.  June 23.

—————. 2008. Final Feasibility Study Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. October.

DON (United  States  Department  of  the  Navy).  2010.  Final  Record  of  Decision  (ROD)  for IR Site 2, Former Naval Air Station Alameda, California. August.

 

 

ITSI (Innovative Technical Solutions, Inc.). 2008.  Final  Annual  Groundwater  Monitoring Report, Basewide Groundwater Monitoring Program, Alameda  Point,  Alameda, California. November.

KCH (CH2M HILL Kleinfelder, A Joint Venture). 2011. Preliminary Draft Remedial Design Report, Installation Restoration Site 2, Alameda Point, Alameda, California. December.

SES-TECH, 2011. Final Alameda Point Basewide Groundwater Monitoring Program Work Plan, Alameda Point, Alameda, California. September.

SES-TECH. 2012. Draft Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California (December).

TtEMI (Tetra Tech EM, Inc.). 2009. Draft 2008 Final Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point,  Alameda,  California. March.

 

 

 

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       9-1                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                       9-2                                                                Final PCOMMP IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

APPENDIX A

 

LONG-TERM GROUNDWATER MONITORING EVALUATION

 

(Alameda Agencies, 2013)

 

 

 

Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                                                                                                                                 Final PCOMMP

IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

 

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Attachment  11 PCOMMP Revision 1_MD_mb 10_03                                                                                                                                                                 Final PCOMMP

IR Site 2, Alameda Point, Alameda, California

DCN:  RMAC-0809-0009-0004

CTO No. 0009

 

Response to EPA Comments Provided Via Email Dated November 5, 2013

 

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-----Original Message-----

From: Tran, Xuan-Mai [mailto:Tran.Xuan-Mai@epa.gov] Sent: Tuesday, November 05, 2013 5:33 PM

To: Lord, Jacques P CTR NAVFACHQ, BRAC PMO; Robinson, Derek J CIV NAVFACHQ, BRAC PMO;

McGinnis, William CIV NAVFAC SW, PACO

Cc: John West; Fyfe, James@DTSC; Peter Russell

Subject: EPA's review comments on DF Site 2 RAWP Revision 1 Hi Jacques.

Thank you very much for the RTCs on the redline/strikeout version of Site 2 RAWP, Revision 1, as well as the DF of Site 2 RAWP, Revision 1. We have the following outstanding comments.

 

The first two comments (Responses to General Comments 2 and 3) are administrative comments; please incorporate the responses into the text of the document.

 

The last comment (Response to Specific Comment 5) needs to be addressed before we can concur on this document.

 

Please note that these outstanding comments shouldn't stop the field works. We have no issues with the Navy starting to abandon the old monitoring wells and to install the new monitoring wells at Site

  1. However, the following outstanding comments need to be addressed before EPA concurs on the Final RAWP Revision 1 for Site 2.

 

Here are the outstanding comments:

 

  1. Response to General Comment 2: The response addresses the comment; however, it appears that the information from the response has not been incorporated into the Final Remedial Action Work Plan (RAWP) Revision 1. Please ensure the information in the response regarding preparation of an addendum to the Basewide Groundwater Monitoring Program Sampling and Analysis Plan (SAP) is included in the text of the RAWP Revision 1.

 

 

 

  1. Response to General Comment 3: The response addresses the comment; however, it appears that the information from the second paragraph of the response has not been incorporated into the RAWP Revision 1. Please ensure the information in the second paragraph of the response regarding the inclusion of an inspection checklist and procedures for redevelopment in the addendum to the Basewide Groundwater Monitoring Program SAP is included in the text of the RAWP Revision 1.

 

 

  1. Response to Specific Comment 5: The response partially addresses the comment. Section 2.1.3 of Attachment 11 states "a statistical outlier analysis will be conducted for each data set" and "after the outliers are removed, new trend plots will be created;" however, groundwater analytical data is variable and Section 2.1.3 does not explain the validity of removing potential

 

outliers. It would be more appropriate to plot all of the data. Typically graphs of analyte concentrations over time and Mann-Kendall trend analyses are used together to assess groundwater data trends and both of these are already included in Section 2.1.3, so it is unclear what additional information will be provided by linear regression. Further, it is unclear if linear regression is an appropriate method for assessing groundwater data sets because certain assumptions (e.g., linearity, constant variance, etc.) must be applied during usage of the linear regression method. Please revise Section 2.1.3 to deletethe step that removes outliers from the data set or explain why removal of outliers is necessary for an assessment of groundwater

data. In addition, please omit linear regression or explain why linear regression is appropriate for assessing groundwater data and discuss what additional assessment(s) will be provided by linear regression that cannot be determined using graphs of analyte concentrations over time and Mann-Kendall trend analyses jointly.

 

 

 

 

Response to comment 1 above:

 

The following has been added to Section 4.11 of the RAWP to clarify that post-closure sampling at IR Site 2 will be conducted under the Base-wide Groundwater Monitoring Program SAP Addendum:

 

An addendum to that SAP will be prepared and issued by the Basewide Groundwater Monitoring Program Contractor, detailing the monitoring program for the new wells and vapor probes, the decommissioned wells and vapor probes, and the previously existing wells that have been retained at Site IR 2. Sampling frequency and methods and analytical methods will also be re-established in the Basewide Groundwater Monitoring Program SAP Addendum for Site 2.

 

Response to comment 2 above:

 

The following language will be added to Section 5.8.2.1 of the RAWP

 

Post-cover placement, routine groundwater monitoring well maintenance and repair will be performed during sampling events. An inspection checklist and procedure for redevelopment will be included in the IR Site 2 addendum to the Basewide Groundwater Monitoring Program SAP.

 

 

Response to comment 3a above:

 

The reference to removing outliers has been deleted. All data will be used in the trend analysis. Section

2.1.3 in the PCOMMP has been revised. See strike-out text below.

 

Response to comment 3b above:

 

Reference to linear regression has been deleted. The data will be evaluated using time-series plots and trends will be statistically evaluated using the Mann-Kendall analysis. Section 2.1.3 in the PCOMMP has been revised. See strike-out text below.

 

 

Revised text for Section 2.1.3 of the PCOMMP:

 

Data from all shoreline and interior wells will be used for the trend analysis, as required by the ROD. Data from future analyses will be evaluated using historical data. New wells will be monitored for at least 4 quarters before evaluating trends.

 

Analytical results for each well will be evaluated using a graphical representation of the concentrations trends. A time-series plot will be generated for all wells for the analytes listed above. The plots will be examined to identify obvious trends and outlier data. A minimum of two samples are required for the plots.

 

Next, a statistical outlier analysis will be conducted for each data set using either the Dixon Test (less than 25 samples with a minimum of 3 samples), the Rosner Test (greater than 25 samples and normally/lognormally distributed), or the Discordance Test (3 or more samples and normally/lognormally distributed after outlier removal).

 

After the outliers are removed, new trend plots will be created. Each trend plot will include a first-order linear trend line statistically derived using Microsoft Excel or other comparable software. Non-detect observations will be treated as nil values (i.e., zeros) in the trend plots, which is consistent with the procedure used in the FS Report (Battelle and BBL 2008).

 

A visual, qualitative assessment will be performed on each time-series plot. Professional judgment will be used on the evaluation with an understanding of site conditions and considering inconsistent results and the possible effects of changes in detection limits. A minimum number of two data points are required for the plots.

 

Finally, a Mann-Kendall trend analysis will be performed for each well/analyte. The Mann-Kendall test will determine whether there is an upward, downward, or no trend. The Mann-Kendall test is not affected by large variations in analyte concentration, which can cause erroneous results from methods such as linear regression analysis. A minimum of four samples are required.

 

Groundwater data and trends need to be evaluated with the ROD criteria “to confirm that the contaminants remain within an acceptable range” (DON 2010). This operations and maintenance plan proposes that so long as monitoring results do not trigger a response as defined in Section 2.1.1, the results are within an acceptable range.

 

 

DTSC and EPA Concurrence

 

 

RMAC-0809-0009-0004.R1 Final RAWP Rev 1                                                                                                                                                     Final Remedial Action Work Plan, Revision 1

 

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RMAC-0809-0009-0004.R1 Final RAWP Rev 1.docx                                                                                                                                            Final Remedial Action Work Plan, Revision 1

 

From: Fyfe, James@DTSC [mailto:James.Fyfe@dtsc.ca.gov] Sent: Monday, November 04, 2013 2:42 PM

To: Lord, Jacques P CTR NAVFACHQ, BRAC PMO; Robinson, Derek J CIV NAVFACHQ, BRAC PMO

Cc: Peter Russell; McGinnis, William CIV NAVFAC SW, PACO; Xuan-Mai Tran; West, John@Waterboards; Dalrymple, Michelle@DTSC; Toth, Karen@DTSC; Karla Brasaemle

Subject: Alameda Point - IR Site 2 Remedial Action Work Plan Hello Jacques and Derek,

DTSC has completed the review of the red-line strike-out version of the Final Remedial Action Work Plan, Revision 1, Installation Restoration Site 2, Alameda Point, Alameda, California dated October 2013, including revisions to Attachment 11 - Final Post-Closure Operations, Maintenance, and Monitoring Plan, Revision 1. Michelle Dalrymple of the DTSC Geological Services Unit provided the primary review of the document and she is satisfied that all of her concerns about previous versions of the Work Plan have been adequately addressed.

 

The only other comment I have is to request that my e-mail address in Section 1.3 Points of Contact be updated as follows:

 

james.fyfe@dtsc.ca.gov

 

Thank you, Jim Fyfe

Project Manager

 

James R. Fyfe, P.E.

Hazardous Substances Engineer Department of Toxic Substances Control 700 Heinz Avenue

Berkeley, CA 94710

James.Fyfe@dtsc.ca.gov <mailto:James.Fyfe@dtsc.ca.gov> phone: (510) 540-3850

fax: (510) 540-3819

 

From: Tran, Xuan-Mai [mailto:Tran.Xuan-Mai@epa.gov] Sent: Wednesday, November 13, 2013 9:57 AM

To: Lord, Jacques P CTR NAVFACHQ, BRAC PMO; Robinson, Derek J CIV NAVFACHQ, BRAC PMO;

McGinnis, William CIV NAVFAC SW, PACO

Cc: West, John@Waterboards; Fyfe, James@DTSC; Peter Russell Subject: RE: RTCs for EPA Nov 5 comments for concurrence

 

Hi Jacques.

 

Thank you so much for the responses to EPA's outstanding comments on Site 2 RAWP Revision 1. The Navy has addressed all of our outstanding comments; therefore, we have no further comments on Site 2 RAWP Revision 1.

 

However, please check in w/ DTSC to make sure they also agree w/ the changes since they concurred on the version prior to these changes. John/WB has confirmed that they have no additional comments.

Please follow up w/ DTSC before you finalize this document.

 

Thank you for all your efforts in addressing all of the agencies' comments. XM

 

-----Original Message-----

From: Lord, Jacques P CTR NAVFACHQ, BRAC PMO [mailto:jacques.lord.ctr@navy.mil] Sent: Friday, November 08, 2013 12:40 PM

To: Tran, Xuan-Mai; 'West, John@Waterboards (John.West@waterboards.ca.gov)'; 'Fyfe, James@DTSC (James.Fyfe@dtsc.ca.gov)'; Robinson, Derek J CIV NAVFACHQ, BRAC PMO

Cc: 'kbrasaemle@techlawinc.com'; 'Dalrymple, Michelle@DTSC (Michelle.Dalrymple@dtsc.ca.gov)'; 'Toth, Karen@DTSC (Karen.Toth@dtsc.ca.gov)'; McGinnis, William CIV NAVFAC SW, PACO; 'Everds, Pete (Pete.Everds@tetratech.com)'; 'Binkin, Marianne (Marianne.Binkin@tetratech.com)'

Subject: RTCs for EPA Nov 5 comments for concurrence Dear Xuan-Mai,

The Navy response to your latest comments is appended for your concurrence. Once the Navy has concurrence from EPA we will distribute the RAWP addendum to all the recipients of the RAWP. These RTCs will be included in Attachment 15 with previous comments and responses on this addendum.

 

Best,

 

Jacques P. Lord, CEG

Project Manager, Alameda Point MARRS Services, Inc.

Contracted Support to NAVY BRAC PMO WEST 619-532-0902

 

From: Fyfe, James@DTSC [mailto:James.Fyfe@dtsc.ca.gov] Sent: Wednesday, November 13, 2013 12:49 PM

To: Lord, Jacques P CTR NAVFACHQ, BRAC PMO; Dalrymple, Michelle@DTSC Cc: Binkin, Marianne

Subject: RE: EPA's review comments on DF Site 2 RAWP Revision 1 Hi Jacques,

If EPA is satisfied with your response to their comments, then DTSC is also satisfied. Our concerns have already been addressed.

 

Thanks, Jim Fyfe

 

James R. Fyfe, P.E.

Hazardous Substances Engineer Department of Toxic Substances Control 700 Heinz Avenue

Berkeley, CA 94710 James.Fyfe@dtsc.ca.gov phone: (510) 540-3850

fax: (510) 540-3819

 

-----Original Message-----

From: Lord, Jacques P CTR NAVFACHQ, BRAC PMO [mailto:jacques.lord.ctr@navy.mil] Sent: Wednesday, November 13, 2013 10:11 AM

To: Fyfe, James@DTSC; Dalrymple, Michelle@DTSC

Cc: 'Binkin, Marianne (Marianne.Binkin@tetratech.com)'

Subject: FW: EPA's review comments on DF Site 2 RAWP Revision 1

 

We have responded to the EPA comments (without disagreement). I want you to see the EPA comments to be sure you have no difference of opinion even though they were sent to you. See below.

 

Jacques P. Lord, CEG

Project Manager, Alameda Point MARRS Services, Inc.

Contracted Support to NAVY BRAC PMO WEST 619-532-0902

 

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