Contaminant Management Plan.pdf

Contaminant Management Plan VA Alameda Outpatient Clinic and National Cemetery Alameda, California

Issue Date:

January 2021

Contaminant Management Plan VA Alameda Outpatient Clinic and National Cemetery Alameda County, California

Prepared for:

U.S. Department of Veterans Affairs 201 Walnut Avenue Mare Island, CA 94592

Prepared by:

HDR

2365 Iron Point, Suite 300 Folsom, CA 95630

VA Alameda, Alameda, CA

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Contents Acronyms and Abbreviations ................................................................................................................ iv Executive Summary ......................................................................................................................... ES-1 1 Introduction

1.1 Project Description and Location

1.2 Project Construction

1.3 Purpose and Objectives

2 Background

2.1 Site Location

2.1.1 Geology

2.1.2 Hydrogeology

2.2 VA Development Area History

2.3 Environmental Conditions

2.3.1 Marsh Crust

2.3.2 IR Site 14

2.3.3 IR Site 32

2.3.4 IR Site 34

2.3.5 Petroleum Hydrocarbons

2.3.6 Building Materials

3 Action Levels and Reuse Criteria

3.1 Action Levels

3.1.1 Soil

3.1.2 Groundwater

3.2 Soil Reuse Criteria

4 Contaminated Media by Development Area

4.1 Outpatient Clinic

4.1.1 Soil

4.1.2 Groundwater

4.1.3 Building Materials

4.2 North Access Road

4.2.1 Soil

4.2.2 Groundwater

4.3 National Cemetery

4.4 CMO

5 Soil Management

5.1 Soil Condition Management

5.1.1 Management of Known Soil Conditions

5.1.2 Management of Unknown Soil Conditions

5.1.3 Management of Underground Features

5.2 Soil Characterization

5.2.1 Ex-Situ Waste Characterization

5.2.2 In-Situ Waste Characterization

5.2.3 Chemical Analytical Methods

5.3 Soil Stockpiling

Contaminant Management Plan VA Alameda, Alameda, CA ii | January 2021

5.4 Soil Disposal

5.5 Hazardous Waste Landfill

5.6 Waste Soil Transportation

5.7 Transportation Contingency

5.8 Transportation Record Keeping

6 Groundwater Management

6.1 Groundwater Characterization

6.2 Groundwater Treatment and Discharge

7 Building Material Mitigation Measures

7.1 Building Material Abatement and Disposal

8 Health and Safety

8.1 Anticipated Site Conditions

8.2 Discovery of Unexpected Hazardous Substances

8.3 Activities Involving Contaminated Building Materials

9 Contractor Oversight and Reporting

9.1 Mitigation Monitoring

9.2 Notification Requirements

9.3 Reporting

9.3.1 Site Specific Health and Safety Plan

9.3.2 Discharge Permits

9.3.3 Characterization Reports

9.3.4 Contaminant Management Documentation

10 References

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Tables Table 1. Summary of Hazardous Material Building Survey Table 2. Soil Action Levels Table 3. EBMUD Acceptance Criteria Table 4. Examples of Nearby Nonhazardous Waste Landfills Table 5. Example of Nearby Hazardous Waste Landfill

Figures Figure ES-1. Site Map Figure 1. Site and Project Location Map Figure 2. OPC Rendering and Site Plan Figure 3. CMO Rendering and Site Plan Figure 4. NCA Cemetery and Site Plan Figure 5. IR and Petroleum Hydrocarbon Sites

Appendices Appendix A. Marsh Crust Ordinance Appendix B. Lead and Asbestos Building Survey Appendix C. NPDES Permit Application and EBMUD Wastewater Ordinance iv | January 2021

Acronyms and Abbreviations 1,1-DCE 1,1-dichloroethene 1,2-DCE 1,2-dichloroethene 1,4-DCB 1,4-dichlorobenzene

ACM asbestos-containing material AFD City of Alameda, Fire Department AST aboveground storage tank

BCT BRAC Cleanup Team bgs below ground surface BRAC Base Realignment and Closure BTEX benzene, toluene, ethylbenzene, xylenes

Cal-OSHA California Department of Occupational Safety and Hazard Assessment CCR California Code of Regulations CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act CFR Code of Federal Regulations cis-1,2-DCE cis-1,2-dichloroethene CMO Conservation Management Office CMP Contaminant Management Plan COC constituent of concern

DTSC Department of Toxic Substances Control

EBMUD East Bay Municipal Utility District ECOTOX ECOTOXicolocy knowledgebase EnviroStor EnviroStor database ESL Environmental Screening Level ft/ft feet per foot

GAP generator accumulation point GeoTracker GeoTracker database

HASP Health and Safety Plan HMMP Hazardous Materials Management Plan HSC Health and Safety Code

IC institutional control IR Installation Restoration ISCO in situ chemical oxidation

LBP lead-based paint

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MCL maximum contaminant level MCO Marsh Crust Ordinance mg/kg milligrams per kilogram mg/L milligrams per liter

NAS Naval Air Station Navy Department of Navy NPDES National Pollutant Discharge Elimination System

OPC outpatient clinic OSHA Occupational Safety and Health Administration

PAHs polycyclic aromatic hydrocarbons PCB polychlorinated biphenyl PCE tetrachloroethylene PFC perfluorinated chemical PFOA perfluorooctanoic acid PFOS perfluorooctanesulfonic acid

RA remedial action RAA remedial action area ROD Record of Decision

SFBRWQCB San Francisco Bay Regional Water Quality Control Board STLC Soluble Threshold Limit Concentration SVOC semi-volatile organic compound SWMU solid waste management unit

TCE trichloroethylene TCLP Toxicity Characteristic Leaching Procedure TICH total identifiable chlorinated hydrocarbon TPH total petroleum hydrocarbon TPH-d total petroleum hydrocarbon as diesel TPH-g total petroleum hydrocarbons as gasoline TPH-mo total petroleum hydrocarbon as motor oil trans-1,2-DCE trans-1,2-dichloroethene TtEMI Tetra Tech EMI TTLC Total Threshold Limit Concentration

U.S. EPA United States Environmental Protection Agency UST underground storage tank

VA Veteran Affairs VC vinyl chloride VOC volatile organic compound µg/L micrograms per liter https://en.wikipedia.org/wiki/Perfluorooctanoic_acid vi | January 2021

The interpretations and conclusions contained within this report represent HDR’s professional opinions. These opinions are based on currently available information and were developed in accordance with currently accepted geologic, hydrogeologic, and engineering practices at this time and for this specific site. Other than this, no warranty is implied or intended.

This report has been prepared solely for use by the Veterans Administration. Any reliance on this report by third parties shall be at such parties' own risk. This report was prepared by the staff of HDR under the direct supervision of the Professional Geologist registered with the State of California, whose signature appears below.

12 January 2021 Charles O’Neill, P.G. Date Professional Geologist # 6401

November 2021 | ES-1

Executive Summary The United States Department of Veteran Affairs (VA) plans to construct an outpatient clinic (OPC), a National Cemetery , and a Conservation Management Office (CMO) (collectively, the Project) at the former Naval Air Station (NAS) Alameda in Alameda, California (Figure ES-1). The former NAS Alameda is a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) cleanup site with land use restrictions and contaminants in building materials, soil, and groundwater.

Development of the former NAS for the VA will require building demolition, soil excavation, and potentially dewatering. This Contaminant Management Plan (CMP) was prepared to identify areas within or immediately bordering the Project area that contain contaminants that could present limitations on soil reuse, groundwater discharge, a health risk to construction workers, or future Project users. Contaminants likely to be encountered during Project development are summarized below by media.

Building Materials Six buildings (numbers 26, 52, 53, 118, 119, and 120) will be demolished as part of the Project construction. The location of Buildings 26, 52, 53 and 120 are depicted on Figure ES-1. Buildings 118 and 119 are located approximately one mile south east and outside of the Project area. A lead-based paint (LBP) and asbestos-containing material (ACM) survey was conducted which identified the presence of LBP in each building (Appendix B). The ACM survey identified ACM in each building except for building 119 and building 120. Due to the presence of LBP and ACM, building demolition will need to be conducted by appropriately certified personnel.

Soil The Marsh Crust is an approximately 2- to 6-inch thick layer of sediment contaminated with semi volatile organic compounds (SVOCs), including polycyclic aromatic hydrocarbons (PAHs), and petroleum hydrocarbons which were deposited across Alameda Point from the late 1800s until the 1920s. No other contaminants are documented in the soil within the Project area.

Construction of the OPC will include excavation to 20 feet below ground surface (bgs) to install underground storage tanks (USTs). This excavation is greater than 10 feet bgs; therefore, compliance with the Marsh Crust Ordinance (Appendix A) is required. If the marsh crust is encountered, excavated material may contain SVOCs and petroleum hydrocarbons that require characterization prior to disposal.

Groundwater Groundwater in the vicinity of the OPC is contaminated with perfluorinated chemicals (PFCs) and volatile organic compounds (VOCs) (Figure ES-1). No other contaminants are documented in the groundwater within the Project area.

ES-2 | November 2021

Dewatering of the OPC UST excavation may generate groundwater contaminated with PFCs and VOCs. PFC and VOC concentrations do not exceed the East Bay Municipal Utility District (EBMUD) discharge criteria; therefore, treatment for these contaminants is not necessary. Treatment for other permit requirements, (i.e. sediment) or to meet National Pollutant Discharge Elimination System (NPDES) discharge limitations may be required.

IR 34

IR 14

IR 32

CMO

OPC

Cemetery

North Access Road

North Access Road

IR 32

Subarea

40,000 Gal Sewage Tank 15,000 Gal Fuel Tank

40,000 Gal Domestic Water Tank 30,000 Gal Fire Water Tank

AST 528

Site Map Veterans Affairs

Figure ES-1Alameda, CA

Project No.: 10017671-001 Date: 4 November 2020 File No: Figure_ES-1_Site_Map.mxd Drawn By: HR Checked By: CO

0 700350

Feet Oakland Inner HarborSEE INSET

122121

Legend

Petroleum Site

IR Site Boundary

VA Development Area

Existing Building Planned Building

Underground Storage Tanks (UST's)

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1 Introduction The United States Department of Veteran Affairs (VA) plans to construct an outpatient clinic (OPC), a National Cemetery, and a Conservation Management Office (CMO) (collectively, the Project) at the former Naval Air Station (NAS) Alameda in Alameda, California (Figure 1). The NAS Alameda is an area known to have contaminated soil and groundwater which is undergoing remedial action (RA) under the supervision of the United States Environmental Protection Agency (U.S. EPA) and San Francisco Bay Regional Water Quality Control Board (SFBRWQCB).

This Contaminant Management Plan (CMP) was prepared to identify areas within, or bordering the Project, that contain contaminants that could present limitations on reuse, a risk health to construction workers, or future Project users. The CMP also presents protocols to characterize, manage, and dispose of contaminated soil, groundwater, and building materials and identifies procedures in the event that previously undiscovered waste is encountered.

1.1 Project Description and Location

On June 27, 2014, the Department of Navy (Navy) transferred the former NAS Alameda property to the VA via a Fed-to-Fed transfer. This area is referred to as the VA Transfer Parcel. The VA Transfer Parcel is approximately 624-acres in size and is located in the northwest corner of the former NAS Alameda property. The VA Transfer Parcel is composed of developed and disturbed land that was previously utilized for military, industrial, and aircraft operations. The VA Transfer parcel is located entirely on manmade lands (i.e., fill material imported during the early to mid-20th century), 56 percent of which is situated on the inactive runways, taxiways, and other paved aircraft areas of the former NAS Alameda while the remaining 44 percent of the parcel is undeveloped and/or wetlands (non-hard surface). The proposed VA Development Area, which is the area where the VA would construct buildings and associated infrastructure, is situated on 113 acres of the transfer parcel. The VA Transfer Parcel is surrounded by the San Francisco Bay to the south and west and the Oakland Estuary to the north. The Port of Oakland is situated across the estuary to the north (Figure 1). To the east and south lies the remainder of the former NAS Alameda property, now referred to as Alameda Point.

1.2 Project Construction

Construction of the Project is planned to occur in phases. Phase 1 construction would take approximately 44 months to complete and would include site ground improvements, development of the OPC and associated parking on 20 acres (Figure 2); a north access road and on-site utilities infrastructure on 11 acres; the CMO on 2.5 acres (Figure 3); and the first phase of the cemetery development to include 25,000 columbarium niches and support facilities, including two committal service shelters, internal roads, assembly area, and landscaping on an estimated 20 acres (Figure 4). The remainder of the cemetery area (60 acres) would remain undeveloped until there is a need for additional columbarium niches. Based on this phasing schedule, the final phase of the cemetery would be constructed around the year 2116.

It is anticipated that approximately 260,000 cubic yards of fill material would be needed to surcharge the VA Development Area to prepare for construction, which would include the OPC area, the CMO, the first phase of cemetery development, and on-site access roads. Once the soils have adequately

2 | January 2021 compressed, surcharge materials will be removed and approximately 162,000 cubic yards of material would remain on site to meet designs for the finished grade elevation for the Project.

Dewatering and a geotextile layer may be required for base stability where excavations extend to the shallow water table. The OPC building will have a concrete piles foundation. The CMO will have a structural concrete mat. The cemetery’s columbarium will be constructed with concrete pile foundations.

1.3 Purpose and Objectives

The Navy and the U.S. EPA have identified buildings with lead-based paint and asbestos, contaminated soil and contaminated groundwater beneath or adjacent to the VA Development Area.

The purpose of the CMP is to present a consistent framework that the Project developers and VA’s contractor (Contractor) can use to ensure the proper management of contaminated material. This CMP integrates the following key objectives:

• Identify areas of the VA Development Area where contaminated material may be encountered;

• Identify sampling and analysis, stockpiling, transportation, health and safety and other procedures which contaminated media must be managed in order to meet safety, regulatory and other standards;

• Define how groundwater that will be encountered during Project construction will be characterized, treated and disposed; and

• Identify contaminant concentration thresholds that would prevent the onsite reuse of soil.

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2 Background The following sections present a general description of the VA Development Area and documents the type, magnitude, and extent of constituents of concern (COC) within proximity to the VA Development Area.

2.1 Site Location

The VA Development Area is located on Alameda Point, in the San Francisco Bay Area (Figure 1) on the western end of Alameda Island, which lies on the eastern side of the San Francisco Bay, adjacent to the City of Oakland. The upland portion of Alameda Point is roughly rectangular in shape, approximately 2 miles long east–west and 1 mile wide north–south, and occupies 1,734 acres of upland land (NAVFAC, 2016).

2.1.1 Geology

Surface and near-surface soil in the VA Development Area consists of artificial fill emplaced during historical filling of the tidal marshlands and the sub-tidal area of San Francisco Bay during development of Alameda Island. The fill material consists of sediments that were dredged from the San Francisco Bay and Oakland Inner Harbor and is characterized by sands, clays, and silts dredged from the tidal flats in the region (NAVFAC, 2007).

2.1.2 Hydrogeology

Groundwater beneath the VA Development Area is typically encountered at depths between 2 to 8 feet bgs in the artificial fill. Groundwater flow is highly variable, with seasonal variation caused by precipitation levels, and diurnal variations related to tidal cycles. In general, groundwater in the vicinity of the VA Development Area flows to the north-northeast and discharges to the Oakland Inner Harbor. Groundwater elevation data collected from Installation Restoration (IR) Site 14, located immediately north of the VA Development Area, indicated groundwater flowed north-northeast at a gradient of 0.0016 feet per foot (ft/ft) in January 1992, 0.009 ft/ft in June 1994, and 0.006 ft/ft in June

2001 (NAVFAC, 2007).

2.2 VA Development Area History

Most of the northern portions of Alameda Island were covered by the water and tidal lands of San Francisco Bay. To create Alameda Point, fill material was dredged from San Francisco Bay to create Alameda Point. In 1930, the U.S. Army acquired Alameda Point from the City of Alameda. Prior to 1936, Alameda Point was occupied by a borax processing plant, an oil refinery, and an airport for the City of Alameda. In 1936, the Navy acquired the land and built the former NAS Alameda to support the Navy’s operations in Europe before World War II. From 1940 to 1997, NAS Alameda was operated as an active naval facility. During the history of NAS Alameda, it housed approximately 60 tenant military commands and had a combined military and civilian work force of more than 18,000 personnel (NAVFAC, 2007). The Navy conducted a variety of on-site operations, including aircraft, engine, gun, and avionics maintenance; engine overhaul and repair; fueling activities; and plating, stripping, and painting activities (Sealaska, 2016).

4 | January 2021

In July 1999, Alameda Point was added to the National Priorities List under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). When Alameda Point was listed for closure, responsibility for managing the environmental cleanup program at Alameda Point passed to the Base Realignment and Closure (BRAC) Cleanup Team (BCT). The BCT at Alameda Point is made up of representatives from the Navy, U.S. EPA, California Department of Toxic Substances Control (DTSC), and the SFBRWQCB (Sealaska, 2016).

2.3 Environmental Conditions

Characterization efforts have identified contamination in soil, groundwater, and building materials planned for demolition during Project development. Publically available documents on the State of California Water Resources Control Board’s GeoTracker database (GeoTracker), State of California DTSC EnviroStor database (EnviroStor) and supplied by the Navy were reviewed to obtain information on the disposition and magnitude of contaminants bordering or within the VA Development Area. In general, known contaminants at the VA Development Area generally fit into four categories: 1) Marsh crust, 2) Sites regulated by the U.S. EPA under CERCLA, 3) petroleum hydrocarbon contaminated sites regulated by the SFBRWQCB, and 4) building construction materials which may present worker health and safety considerations regulated by Occupational Safety and Health Administration (OSHA) if demolished, restored, or abated. The following sections summarize the findings from review of this information.

2.3.1 Marsh Crust

The Marsh Crust is an approximately 2- to 6-inch thick layer of sediment contaminated with semi-volatile organic compounds (SVOCs) including polycyclic aromatic hydrocarbons (PAHs), and petroleum hydrocarbons which were deposited across Alameda Point from the late 1800s until the 1920s. The contamination is believed to have resulted from discharges of petroleum products and wastes from former manufactured gas plants and oil refineries to the marshlands and the tidal flats of Alameda Point. Subsurface investigations conducted at these properties for various environmental assessments have encountered the Marsh Crust over a large areal extent at depths ranging from 4 to 20 feet bgs at Alameda Point. The Marsh Crust is believed to exist throughout these properties in a somewhat predictable, planar zone but may not exist as a continuous layer because of the presence of tidal channels and other features affecting their original deposition (Sealaska, 2016).

The fill/native soil interface at which the marsh crust may be present increases in depth at Alameda Point from northeast to southwest, ranging from 4 feet to 15 feet or more bgs. The Marsh Crust Ordinance (MCO), and figure depicting the threshold depth, is provided in Appendix A.

2.3.2 IR Site 14

IR Site 14, Former Fire Training Area, covers 14.2 acres along Oakland Inner Harbor and located beneath the planned OPC and cemetery (Figure 5). IR Site 14 is partially paved, relatively flat, includes five buildings (26, 120, 121, 122, and 388) and open space. Historical use at IR Site 14 includes airfield-related materials and equipment storage, and firefighter training in the northwestern portion of the site.

In 1991, CERCLA investigations were conducted, with follow-on investigations in 1994 and 1998, data gap sampling in 1998, supplemental remedial investigation data gap sampling in 2001, and

January 2021 | 5 removal of soil containing dioxins in 2001. The chemicals detected in soil at IR Site 14 included metals, volatile organic compounds (VOCs), SVOCs, pesticides, polychlorinated biphenyls (PCBs), total petroleum hydrocarbon (TPH), dioxins, and total organic carbon. Most of these chemicals were infrequently detected at concentrations below residential screening levels. Arsenic and iron were the only metals detected at concentrations above residential screening levels (Navy, 2010).

The IR Site 14 Record of Decision (ROD) documents no further action for soil contaminants and selected in situ chemical oxidation (ISCO), groundwater monitoring, and institutional controls (ICs) for vinyl chloride (VC) in groundwater (NAVFAC, 2007). In September 2008, ISCO was initiated and completed in September 2009. Based on the IR Site 14 ROD performance objectives, the ISCO applications achieved approximately 80 percent reduction of VC at the site (Navy, 2011); however, VC remains in groundwater at concentrations greater than the 15 micrograms per liter (µg/L) IC termination criteria. Unless approved by the Federal Facilities Agreement FFA signatories, the IR Site 14 IC area (Figure 5) shall not be used for the following purposes (NAVFAC, 2012):

• A residence, including any mobile home or factory built housing, constructed or installed for use as residence by human habitation,

• A hospital for humans,

• A school for persons under 21 years of age,

• A day care facility for children, and

• A playground or any permanently occupied human habitation other than those used for commercial or industrial properties.

In October 2016, groundwater samples analyzed for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). PFOA was detected at a maximum estimated concentration of

35.2 µg/L and PFOS was detected at a maximum estimated concentration of 302 µg/L. PFCs have been identified as an emerging contaminant in drinking water. Historical use of IR Site 14 as a fire fighting training area indicates the potential for release of compounds known to contain PFCs (Sealaska, 2016).

In October 2016, VOCs detected in groundwater greater than the laboratory reporting limit include 1,1-dichloroethene (1,1-DCE), 1,2-dichloroethane, cis-1,2-dichloropropene, trans-12-dichloroethene, VC, and trichloroethene.

Constituents of Concern

The following contaminants may be present within IR Site 14.

Soil COC Groundwater COC

• Arsenic

• Iron

• VOCs

• PFOS

• PFOA

2.3.3 IR Site 32

IR Site 32, referred to as the northwestern ordnance storage area, is located in the northwestern area of Alameda Point, adjacent to the Oakland inner harbor (Figure 5). Despite its name, no historical information indicates that ordnance was stored at the site. In January 2003, IR Site 32 was https://en.wikipedia.org/wiki/Perfluorooctanoic_acid

6 | January 2021 added to the CERCLA program, based on sampling results from previous investigations that indicated the presence of VOCs in groundwater at concentrations above drinking water maximum contaminant levels (MCLs).

When the chemical and radiological risk evaluations are considered collectively, unacceptable risk was not identified for the site-specific receptors (construction/maintenance worker and recreational user) with the possible exception of benzo[a]pyrene in soil. Benzo[a]pyrene is the only COC that poses a risk in the upper end of the risk management range. Aroclor 1260 and lead were retained as soil COCs based on hot spot evaluations. Given the lack of subsurface data for radionuclides, there remains considerable uncertainty about the nature and extent of radiological contamination in soil greater than 2 feet bgs at IR Site 32 (Trevet, 2017).

2.3.3.1 Constituents of Concern

The following contaminants may be present within IR Site 32.

Soil COC Groundwater COC

• Benzo[a]pyrene

• Arochlor 1260

• VOCs

• Radionuclide (Ra-226)

• Radionuclides

• Lead

2.3.4 IR Site 34

IR Site 34, Naval Air Rework Facility, is a 4.18-acre, partially paved, relatively flat open space formerly used to maintain base equipment, such as scaffolding and other apparatus. IR Site 34 was used primarily for painting services, storage, wood and metal shops, and sand blasting and contained several structures: 12 former buildings and intervening open areas; 7 aboveground storage tanks (ASTs); generator accumulation points (GAPs) 78 and 79; underground storage tank (UST) 473-1, and 15 transformers. Two former solid waste management units (SWMUs), UST 473-1 (also known as Area of Concern 473), and AST 331 (also known as SWMU 331), were addressed under the Petroleum Program along with all of the ASTs (Russell, 2016).

In 1996 and 2000, buildings, ASTs, GAPs, and transformers were removed, except for their concrete pads. Arsenic, lead, 1,4-dichlorobenzene (1,4-DCB), dieldrin, heptachlor epoxide, PCBs and TPH were identified as COCs in soil. In April 2011, the IR Site 34 ROD identified excavation and off-site disposal of the impacted soil (Navy, 2011).

Between May and June 2013, the RA for soil was conducted and the Final Remedial Action Completion Report was completed in February 2014 (Navy, 2014). There are no CERCLA restrictions with respect to IR Site 34 soil and groundwater (DTSC, 2014).

2.3.4.1 Constituents of Concern

It is unlikely that contaminants detected in soil or groundwater at IR Site 34 would present limitations on disposal or onsite reuse.

January 2021 | 7

2.3.5 Petroleum Hydrocarbons

As illustrated on Figure 5, two former petroleum hydrocarbon sites (AST 528 and CAA A) are within, or in the immediate vicinity, of the VA Development Area. The presence of residual petroleum hydrocarbons at these areas is discussed below.

2.3.5.1 AST 528

AST 528 is an open petroleum hydrocarbon site with the SFBRWQCB. AST 528 was a 250-gallon capacity diesel fuel AST. The AST was located west of and was associated with former Building 528, which was a heavy equipment and vehicle maintenance shop. The AST was removed sometime before 1994 (based on a site visit documented at that time), but there are no records available that describe the removal of the tank (Gilbane, 2016). In April 1995, soil samples collected from the area yielded total petroleum hydrocarbons as diesel (TPH-d) at 530 milligrams per kilogram (mg/kg), motor oil at 2,400 mg/kg and lead at 22.8 mg/kg. Analysis of these samples did not yield VOCs and PAHs greater than laboratory reporting limits. In October 1995 and July 2001, TPH-d was detected in groundwater at a maximum concentration of 2,000 µg/L (Gilbane, 2016).

2.3.5.2 Fuel Line CAA A

In 1997 and 1998, approximately 7,300 feet of fuel line was removed from the area depicted on Figure 5 and disposed. During this period an undocumented volume of free product and contaminated groundwater were extracted, treated onsite and discharged to the sanitary sewer (SFBRWQCB, 2007). Most soil excavated as part of the fuel line removal was reused as backfill;

however, based on field screening an undocumented volume of soil was transported and disposed offsite (SFBRWQCB, 2007). Soil and groundwater samples collected after remediation did not yield petroleum hydrocarbons, lead or benzene, toluene, ethylbenzene, xylenes (BTEX) greater than laboratory detection limits. In 2007, the SFBRWQCB closed the site and stated, there is no ongoing source, no free product, the site has been adequately characterized, there is no groundwater impact remaining and the site presents no significant risk to human health or the environment.

2.3.6 Building Materials

Six buildings (numbers 26, 52, 53, 118, 119, and 120) will be demolished as part of the Project construction. The location of Buildings 26, 52, 53 and 120 are depicted on Figure 5. Buildings 118 and 119 are located approximately one mile south east and outside of the Project area. A lead and asbestos survey was conducted and the results documented in the December 30, 2014 Hazardous Material Survey Report (Envirosurvey, 2014) (Appendix B). The results from the survey are summarized in Table 1.

Table 1. Summary of Hazardous Material Building Survey Building Number Lead-Based Paint Asbestos

26 Present Present 52 Present Present 53 Present Present

118 Present Present 119 Present Absent 120 Present Absent

8 | January 2021

3 Action Levels and Reuse Criteria Due to VA Development Area proximity to CERCLA sites and history of military and industrial use, contaminants may be encountered in soil and groundwater during Project development. This section presents screening levels for soil and groundwater, herein referred to as Action Levels, to aid the Contractor in determining whether soil is acceptable to be reused within the VA Development Area and whether water generated during the Project may need treatment prior to discharge.

3.1 Action Levels

3.1.1 Soil

The SFBRWQCB has developed environmental screening levels (ESLs) to enable users to identify contaminant concentrations that may pose a risk to human and ecological receptors. Soil that is adequately characterized with analytical results less than the ESLs, most likely does not pose a chemical threat. For soil where chemical concentrations exceed the ESLs, the soil may pose a chemical threat and require further investigation or evaluation to better assess the threat

(SFBRWQCB, 2019).

This CMP has adopted the commercial ESLs to indicate whether anthropogenic contaminants are present in soil at concentrations sufficient to prevent onsite reuse. For situations where naturally occurring background metal concentrations exceed the ESL, the SFBRWQCB allows the substitution of the background metal concentration for the ESL (SFBRWQCB, 2019). Naturally occurring background metals concentrations, developed for the Alameda NAS (Tetra Tech EMI [TtEMI], 2001), were compared to the commercial soil ESLs and the greater of the two was selected as the Soil Action Level documented in Table 2. If the marsh crust is encountered, this material must be managed as hazardous pursuant to Subsection 13-56-8B of the MCO (Appendix A).

Table 2. Soil Action Levels

Constituent Commercial Soil ESL1 (mg/kg)

Background Soil Concentration (mg/kg)3

Soil Action Level (mg/kg)

Antimony 160 3.1 160 Arsenic 0.31 112 11 Barium 220,000 47.4 220,000 Beryllium 230 0.63 230 Cadmium 1,100 0.80 1,100 Chromium 1,800,000 34.4 1,800,000 Cobalt 350 7.9 350 Copper 47,000 19.1 47,000 Lead 320 41.2 320 Mercury 190 0.12 190 Molybdenum 5,800 NE 5,800 Nickel 11,000 30.5 11,000 Selenium 5,800 NE 5,800 Silver 5,800 4.1 5,800 Thallium 12 NE 12

January 2021 | 9

Table 2. Soil Action Levels (Continued)

Constituent Commercial Soil ESL1 (mg/kg)

Background Soil Concentration (mg/kg)3

Soil Action Level (mg/kg)

Vanadium 5,800 27.2 5,800 Zinc 350,000 55.8 350,000 Benzo(a)pyrene 2.1 NE 2.1

TCE 6.1 NE 6.1

PCE 2.7 NE 2.7

PCBs 0.94 NE 0.94 TPH as diesel 1,200 NE 1,200

Notes:

Bold values indicate source of the Action Level NE = Not Established

1 January 2019 SFBRWQCB Commercial ESL 2 Establishing Background Arsenic in Soil of the Urbanized San Francisco Bay Region (Duverge, 2011) 3 Summary of Background Concentrations in Soil and Groundwater, Alameda Point, Alameda, California (TtEMI, 2001). Background levels 95% UCL of the Mean background sample concentration

3.1.2 Groundwater

The VA Development Area is located within the service area of East Bay Municipal Utility District (EBMUD); therefore, should groundwater be generated, discharge to the sanitary under EBMUD permit is an option. EBMUD has established local limits for industrial discharge in its Wastewater Control Ordinance (EBMUD, 2013) (Appendix C). The EBMUD limitations on discharge are selected as the EBMUD Acceptance Criteria for the Project (Table 3).

Table 3. EBMUD Acceptance Criteria Constituent Concentration (mg/L)

Arsenic 2 Cadmium 1 Total Identifiable Chlorinated Hydrocarbons (TICH) 0.5 Chromium (total) 2 Cyanide 5 Iron 100 Lead 2 Mercury 0.05 Nickel 5 Oil and Grease 100 pH Not less than 5.5 standard units Phenolic compounds 100 Silver 1 Temperature 150ºF Zinc 5

In the event that discharge to the EBMUD sanitary sewer is not technologically or economically feasible, SFBRWQCB Order number R2-2012-0012 allows for the discharge of treated groundwater to surface water or constructed storm drain systems under National Pollutant Discharge Elimination System (NPDES) No. CAG912002. SFBRWQCB Order number R2-2012-0012 will remain in effect

10 | January 2021 until Tentative Order R2-2017-00XX is adopted by the SFBRWQCB. The current and tentative NPDES permit applications and EBMUD Wastewater Control Ordinance are presented in Appendix C.

3.2 Soil Reuse Criteria

When contaminants are detected greater than their Action Level, the soil should be disposed offsite, or site specific screening levels established, with concurrence from the BCT, per the criteria listed below. If off site reuse is desired, further action, with concurrence from VA and BCT, is warranted as follows:

• Calculate an exposure point concentration of the proposed reuse material using the 95 percent upper confidence level of the mean for comparison to the ESL or U.S. EPA Regional Screening Levels selected based on destination of the soil and potential exposure scenario (residential or commercial); or

• Create site specific human health screening levels in accordance with the methods presented in the U.S. EPA’s Risk Assessment webpage (U.S. EPA, 2016a); and

• Use information presented in the U.S. EPA’s ECOTOXicolocy knowledgebase (ECOTOX) database (U.S. EPA, 2016b) to calculate site specific screening levels for potential ecological receptors.

If soils are classified as California hazardous waste per 22 California Code of Regulations (CCR) 66261.24, these soils cannot be reused and are to be disposed to a landfill. California hazardous waste by the toxicity criteria is defined by contaminant concentration equal to or greater than either the Total Threshold Limit Concentration (TTLC) or by the Soluble Threshold Limit Concentration (STLC) values (22 CCR § 66261.24). Federal hazardous waste by the toxicity criteria is defined by contaminant concentration equal to or greater than either the Toxicity Characteristic Leaching Procedure (TCLP) values (40 CFR § 261.24).

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4 Contaminated Media by Development Area This section presents the contaminant type and magnitude likely to be encountered in each of the four development areas (OPC, North Access Road, Cemetery, and CMO) and compares maximum detected contaminant concentrations to the Action Levels and EBMUD Acceptance Criteria presented in Section 3.

4.1 Outpatient Clinic

Construction of the OPC will require the demolition of six buildings, will enter the boundaries IR Site 14, IR Site 34, and CAA A (Figure 5). The OPC site will be graded to approximately 12 inches bgs and a 20 foot bgs excavation to install USTs is planned immediately north of the

OPC.

4.1.1 Soil

Site grading to a planned depth of 12 inches bgs will intersect IR Site 14, IR Site 34 and petroleum hydrocarbon site CAA A. The excavation to install the USTs north of the OPC has a potential to encounter the marsh crust and COCs associated with IR Site 14. Discussions of COCs likely to be encountered in soil during construction of the OPC are presented below.

4.1.1.1 Marsh Crust

The MCO threshold depth at the OPC is 10 feet bgs; therefore, excavation to 20 feet bgs to install the USTs will require permitting in accordance with the MCO (Appendix A).

Conclusion: Excavation greater than 10 feet bgs to install the USTs at the OPC will require permitting as required by the MCO. If the marsh crust is encountered, excavated material may contain SVOCs and petroleum hydrocarbons that require characterization.

4.1.1.2 IR Site 14

Chemicals detected in soil at IR Site 14 included metals, VOCs, SVOCs, pesticides, PCBs, TPH, and dioxins at concentrations less than Action Levels. Arsenic was detected at 18.2 mg/kg in one of the 18 samples, greater than the 11 mg/kg background concentration; however, it was reported that there is no evidence that arsenic was used during historical site activities (TtEMI, 2003).

Conclusion: Anthropogenic chemicals are not present in the OPC Project area that would present restriction on soil disposal or reuse. Arsenic was detected greater than the background concentration and greater than the Action Level in one sample; however, due to the absence of an anthropogenic source and low frequency of detection greater than the Action Level, arsenic detected in soil does not present a limitation for onsite reuse.

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4.1.1.3 IR Site 34

The planned OPC construction limits extend into the southwestern corner of IR Site 34. This portion of IR Site 34 is the location of three remedial action areas (RAAs), (RAA 1, RAA 2, and RAA 3) where soil was excavated to remediate PCB, dieldrin, heptachlor epoxide, and 1,4-DCB contamination. After excavation, confirmation soil samples were collected from sidewalls and analyzed. Maximum detected chemical concentrations in sidewall samples were less than their Action Level.

Conclusion: Residual COC concentrations in soil are less than Action Levels;

therefore, soil in the Project area does not contain COCs that would restrict disposal or reuse.

4.1.2 Groundwater

Groundwater beneath the planned OPC occurs from 2 to 8 feet below ground surface and flows to the north northwest. Dewatering will likely be performed during excavation of the UST pit immediately north of the OPC, in the southern portion of IR Site 14. Groundwater at IR Site 14 is impacted with 1,2-dichloroethane, cis-1,2-dichloroethene (cis-1,2-DCE), trichloroethylene (TCE), cis-1,2-DCE, 1,1-DCE, trans-1,2-dichloroethene (trans-1,2-DCE), VC, and PFCs.

Groundwater IR Site 34 is impacted with TPH-d and total petroleum hydrocarbons as motor oil (TPH-mo). Because construction of the OPC in the vicinity of IR Site 34 only includes an at grade parking lot, groundwater contaminants associated with IR Site 34 are not likely to be encountered. Should groundwater dewatering occur near IR Site 34; characterization and treatment may be necessary to reduce COC concentration to meet the EBMUD Acceptance Criteria or the NPDES limits prior to discharge.

4.1.2.1 IR Site 14

In October 2016, the groundwater monitoring wells at IR Site 14 were sampled and well M14- 06, located nearest among the wells to the planned OPC, yielded 1,1-DCE at 12.8 µg/L, 1,2-dichloroethene (1,2-DCE) at 4.53 µg/L, and trans-1,2-DCE at 1.75 µg/L. In October 2016, VC was not reported greater than the 8.0 µg/L laboratory reporting limit; however, since 2013 VC has been detected up to 13 µg/L in well MW14-06.

As stipulated in the EBMUD Wastewater Control Ordinance, concentrations of VC (13 µg/L), 1-DCE (12.8 µg/L), 1,2-DCE (4.53 µg/L), and trans-1,2-DCE (1.75 µg/L) were summed to yield a TICH concentration of 0.0321 mg/L. The 2007 ROD identified a maximum arsenic concentration of 0.0288 milligrams per liter (mg/L) (NAVFAC, 2007). These COCs are less than the EBMUD Acceptance Criteria Table 3.

Conclusion: COCs likely to be encountered during construction dewatering in the vicinity of IR Site 14 are not greater than the EBMUD Acceptance Criteria and can be discharged under permit to EBMUD without treatment for these contaminants. Treatment for other permit requirements, (e.g. sediment) or to meet NPDES discharge limitations may be required. PFCs have been detected in groundwater; however, the EBMUD and SFBRWQCB have not established waste discharge criteria for these emerging contaminants.

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4.1.3 Building Materials

Six buildings are planned for demolition to construct the OPC. In 2014, a lead-based paint (LBP), asbestos, and universal waste survey was conducted. The survey identified LBP and universal waste in the buildings (Envirosurvey, 2014). Asbestos was not identified in buildings 119 and 120 (Envirosurvey, 2014). The LBP and Asbestos survey is presented in Appendix B.

Conclusion: Due to the presence of LBP and asbestos, California law requires that building demolition be conducted by personnel certified to perform this work.

4.2 North Access Road

The North Access Road is planned to be constructed through IR Site 14, IR Site 34, petroleum hydrocarbon site CAA A, and along the southern boundary of IR Site 32 (Figure 5). The sections below document the contaminant type and magnitude likely to be encountered during construction.

4.2.1 Soil

The North Access Road is planned to be constructed through IR Site 14, IR Site 34, and petroleum hydrocarbon site CAA A (Figure 5). Soil COCs likely to be encountered during construction of the North Access Road are consistent with COCs likely encountered during construction of the OPC; therefore, Section 4.1.1 should be reviewed to identify concentrations of COCs likely to be encountered in soil during construction.

4.2.1.1 IR Site 32

The North Access Road is planned to be constructed adjacent to the southern boundary of IR Site 32. When the chemical and radiological risk evaluations are considered collectively, unacceptable risk was not identified for the site-specific receptors (construction/maintenance worker and recreational user) with the possible exception of benzo[a]pyrene in soil (Trevet, 2017); however, benzo[a]pyrene detected at 1.2 mg/Kg, greater than the 0.29 mg/kg Action Level, was reported in a sample collected approximately 600 feet north of the VA Development Area. Given the lack of subsurface data for radionuclides, there remains considerable uncertainty about the nature and extent of radiological contamination in subsurface soil at IR Site 32 (Trevet, 2017).

Conclusion: COCs detected in surface soil within proximity to the VA Development Area are less than Action Levels; therefore, the soil can be reused onsite. Should soil greater than 2-feet below ground surface be disturbed in areas adjacent to IR Site 32, sampling for radionuclides should be performed prior to disposal or reuse.

4.2.2 Groundwater

Construction of the North Access Road will not require groundwater extraction. Should groundwater be generated, the following COCs may be encountered.

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4.2.2.1 IR Site 14

The North Access Road will be constructed through the center of IR Site 14. COCs in vicinity of the planned North Access Road include arsenic, VC, TCE, cis-1,2-DCE and trans-1,2-DCE. In June 2016, groundwater samples collected from wells in the vicinity of the North Access Road yielded a maximum concentrations of arsenic (40 µg/L), VC (86.1 µg/L), TCE (4.2 µg/L), cis-1,2-DCE (55.9 µg/L), trans-1,2-DCE (2.64 µg/L). These maximum detected concentrations are less than EBMUD Acceptance Criteria.

Conclusion: COCs likely to be encountered during construction dewatering in the vicinity of IR Site 14 are not greater than EBMUD Acceptance Criteria and can be discharged under permit to EBMUD without treatment for these contaminants.

Treatment for other permit requirements, (i.e. sediment) or to meet NPDES discharge limitations may be required.

4.2.2.2 IR Site 32

The North Access Road will be constructed along the southern boundary of IR Site 32. COCs detected in groundwater at Subarea 1 (Figure 5) included benzene, TICH (chlorobenzene, 1,2-DCA, cis-1,2-DCE, TCE, VC, and bis(2-chloroethyl)ether) at a total concentration of 1.58 mg/L, greater than the 0.5 mg/L EBMUD Acceptance Criteria (Table 3).

Conclusion: COCs are not likely to be encountered greater than EBMUD Acceptance Criteria, due to their approximate 500-foot distance from the VA Development Area and hydraulically downgradient location; therefore, groundwater can be discharged under permit to EBMUD without treatment for these contaminants. Treatment for other permit requirements, (i.e. sediment) or to meet NPDES discharge limitations may be required.

4.3 National Cemetery

With the exception of the marsh crust, the planned national cemetery is located in an area that is not known to contain soil or groundwater contamination. Due to the shallow depth of construction, the marsh crust is not likely to be encountered in this area.

4.4 CMO

With the exception of the marsh crust, the planned CMO is located in an area that is not known to contain soil or groundwater contamination. Due to the shallow depth of construction, the marsh crust is not likely to be encountered in this area.

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5 Soil Management The Project will include the following activities that may generate contaminated soil:

• Grubbing and grading to a depth of 12 inches bgs; and

• Excavation up to 20 feet bgs for the installation of USTs associated with the OPC.

The following sections present methods to identify, characterize, stockpile, transport and dispose of contaminated soil.

5.1 Soil Condition Management

This section describes the protocols for managing the three categories of environmental conditions that may be encountered: i) soils with COCs known to exceed the human health risk thresholds for construction workers or Action Levels; ii) soils that are potentially impacted based on field observations; and iii) unexpected underground features (i.e., sumps, clarifiers, tanks).

5.1.1 Management of Known Soil Conditions

With the exception of the marsh crust and arsenic, there are no soil contaminants greater than Action Levels within the VA Development Area (Figure 5). The MCO (Appendix A), requires permit approval by the City of Alameda prior to excavation greater than the threshold depth.

The threshold depth is 10 feet bgs in the VA Development Area; therefore, excavation to 20 feet bgs to install the USTs associated with the OPC will require permitting and management of known soil conditions. Details regarding the characterization and management of soil generated during excavation are required to be provided to the City of Alameda in a permit application.

5.1.2 Management of Unknown Soil Conditions

Conditions that may indicate the presence of environmental impacts to the soil include the following:

• Discolored Soil: Observation of discolored soil (e.g., green, black, dark, multicolored) when compared to the surrounding material may be indicative of the potential presence of metals or petroleum hydrocarbon compounds, especially heavier end hydrocarbons such as diesel, waste oil, or motor oil.

• Odorous Soil: Soil that has a noticeable odor of anything other than a musty odor (which is typically a result of mold) may be indicative of potential solvents and/or petroleum hydrocarbon impacts.

• Elevated Field Measurements: A detection greater than 50 parts per million (sustained) with a field photoionization detector may be indicative of VOC or petroleum hydrocarbon impacts.

• Persistent occurrence of non-soil material or foreign objects: The persistent occurrence of non-soil materials such as paint chips, plastics, friable materials and fibers, or similar items that are not soil-related will require assessment for presence of contamination.

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5.1.3 Management of Underground Features

If an underground feature such as a vault, sump, concrete pit, UST or clarifier is encountered during the earthwork activities, work in that specific location will be temporarily suspended and the Contractor will perform the following initial assessment after notification of the VA:

• If a regulated process tank and/or UST and/or associated piping is encountered, the SFBRWQCB and the City of Alameda Fire Department (AFD) will be immediately notified. The UST removal and disposal will be performed by a registered contractor to meet the requirements of the SFBRWQCB and the AFD.

• If a vault, concrete pit, or clarifier is encountered, it will be removed using appropriate equipment and procedures (e.g., health and safety, shoring, structural integrity).

5.2 Soil Characterization

In areas where the marsh crust will be excavated or previously undiscovered waste is identified;

the following waste characterization methods should be employed.

5.2.1 Ex-Situ Waste Characterization

This method entails excavation, temporary stockpiling, sample collection and laboratory analysis. Sampling and analytical requirements vary depending on the disposal facility. Ex-Situ waste profiling is frequently performed but requires the following considerations:

• Material must be excavated, stockpiled, sampled, stored, and then transported to a disposal facility. Double handling of the contaminated material would present an additional cost and time.

• Stockpiling would need to be performed in accordance with California Health and Safety Code (HSC) 25123.3. Stockpiling of contaminated material would require a large area and manifesting requirements would need to be met if transporting material to and from the excavation and stockpile area via public roads.

5.2.2 In-Situ Waste Characterization

In-situ characterization generally means that samples are collected in place, prior to excavation.