Nathaniel Pyron Naval Station Alameda Asset Evaluation Research Document

N00236_004516
ALAMEDA POINT
SSIC NO. 5090.3.B
DRAFT FINAL
Finding of Suitability to Transfer Phase 3A
Former Naval Air Station Alameda
Alameda, California
February 2017
Department of the Navy

BRAC Program Management Office West
33000 Nixie Way, Bldg 50, Second Floor
San Diego, CA 92147
TABLE OF CONTENTS
Acronyms and Abbreviations ..................................................................................................v
1.0 Purpose ..........................................................................................................................1
2.0 Property Description .....................................................................................................1
3.0 Regulatory Coordination...............................................................................................2
3.1 Resource Conservation and Recovery Act Part A or B Permits and Subtitle C
Corrective Action ....................................................................................................3
3.2 Resource Conservation and Recovery Act Subtitle I Corrective Action ...................3
3.3 Comprehensive Environmental Response, Compensation, and Liability Act ........... 4
4.0 Summary of Environmental Conditions and Notifications .........................................4
4.1 CERCLA Program ..................................................................................................5
4.1.1 Storm-Drain Line G (OU-2C) .......................................................................6
4.1.2 AOC 23 (IR Site 35) ....................................................................................6
4.2 Petroleum Products and Derivatives .......................................................................7
4.2.1 Open Petroleum Program Sites ...................................................................7
4.2.2 Closed Petroleum Program Sites ................................................................7
4.3 Asbestos-Containing Material .................................................................................8
4.4 Lead-Based Paint ...................................................................................................8
4.5 Polychlorinated Biphenyls .......................................................................................9
4.6 Munitions and Explosives of Concern ...................................................................10
4.7 Radiological Program............................................................................................10
4.7.1 Naval Nuclear Propulsion Program ...........................................................11
4.7.2 General Radioactive Material ....................................................................11
4.8 Pesticides .............................................................................................................12
4.9 Other Areas Investigated/Issues ...........................................................................12
4.9.1 Perfluorinated Compounds (PFCs)/Polyfluoroalkyl Substances (PFAS) .... 12
5.0 Summary of Restrictions ............................................................................................12
5.1 CERCLA ...............................................................................................................13
5.1.1 Marsh Crust...............................................................................................13
5.2 Petroleum Products and Derivatives .....................................................................13
5.3 Asbestos-Containing Material ...............................................................................14
5.4 Lead-Based Paint .................................................................................................14
6.0 Adjacent Properties.....................................................................................................14
6.1 EnviroStor and GeoTracker Listed Sites ...............................................................15
6.2 Former NAS Alameda Adjacent Property ..............................................................16
6.2.1 IR Site 6 (OU-1) ........................................................................................16
6.2.2 IR Site 21 (OU-2B) ....................................................................................17
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6.2.3 IR Site 35 ..................................................................................................17
6.2.4 Radiological Sites ......................................................................................17
6.2.5 Petroleum Sites .........................................................................................18
7.0 Access Clause .............................................................................................................19
8.0 Covenants ....................................................................................................................19
9.0 Finding of Suitability to Transfer Statement..............................................................20
10.0 References ...................................................................................................................22
Draft Final FOST Phase 3A ii

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Figures
Figure 1 Site Location Map
Figure 2 FOST Parcel
Figure 3 Buildings in or Adjacent to the FOST Parcel
Figure 4 Operable Units, IR Sites, and Areas of Concern
Figure 5 Total Petroleum Hydrocarbons Corrective Action Areas and Areas of Concern
Figure 6 Underground Fuel Line Status
Figure 7 Radiological Sites Within or Adjacent to the FOST Parcel
Tables
Table 1 Property Disposal to Date
Table 2 CERCLA Site Status
Attachments
Attachment 1: Responses to Regulatory Agency Comments
Attachment 2: Hazardous Substances Notification Table
Attachment 3: Regional Water Board NFA Letter for CAA B (1/24/17)
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Draft Final FOST Phase 3A iv

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Acronyms and Abbreviations
§ Section
ACM asbestos-containing material
AOC area of concern
ARRA Alameda Reuse and Redevelopment Authority
BCT BRAC Cleanup Team

BRAC Base Realignment and Closure
CAA Petroleum Program Corrective Action Area

CCR California Code of Regulations
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
City City of Alameda
COC chemical of concern
COPC chemical of potential concern
DERP Defense Environmental Restoration Program

DoD Department of Defense
DTSC California Department of Toxic Substances Control
EBS environmental baseline survey

EDC Economic Development Conveyance
FFA Federal Facility Agreement

FFSRA Federal Facility Site Remediation Agreement
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FL fuel line
FOST finding of suitability to transfer
G-RAM general radioactive material

HRA historical radiological assessment
HSC California Health and Safety Code
IC institutional control
IR Installation Restoration (Program)
LBP lead-based paint

LHA Lifetime Health Advisory
LIFOC Lease in Furtherance of Conveyance
LPL Large Parcel Lease
mg/kg milligrams per kilogram

MEC munitions and explosives of concern
MOA Memorandum of Agreement
Draft Final FOST Phase 3A v

Former NAS Alameda
NACIP Navy Assessment and Control of Installation Pollutants
NAS Naval Air Station
Navy U.S. Department of the Navy
NFA No Further Action
OU operable unit
PAH polycyclic aromatic hydrocarbons

PCB polychlorinated biphenyl
PCE tetrachloroethene
Ra-226 radium-226
RACR Remedial Action Completion Report
RAP remedial action plan
RCRA Resource Conservation and Recovery Act
RFA RCRA facility assessment
RI remedial investigation
ROD Record of Decision
SWMU solid waste management unit
TCRA time-critical removal action
TPH total petroleum hydrocarbons
U.S. EPA United States Environmental Protection Agency

U.S.C. United States Code
UST underground storage tank
VOC volatile organic compound
Regional Water Board Regional Water Quality Control Board (San Francisco Bay)
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1.0 Purpose
The purpose of this Finding of Suitability to Transfer (FOST) is to summarize how the
requirements and notifications for hazardous substances, petroleum products, and other regulated
materials have been satisfied for a portion of the former Naval Air Station (NAS) Alameda by
the U.S. Department of the Navy (Navy) (see Figure 1).
For simplicity, the lands covered by this FOST are referred to hereinafter as the FOST Parcel.
The FOST Parcel is composed of one upland area. Figure 2 shows the FOST Parcel. The land
identified for this FOST is described in Section 2.0.
This FOST provides documentation that a portion of the real property made available through the
closure of NAS Alameda is environmentally suitable for transfer by deed. Note that certain
environmental program activities are ongoing, including the Alameda Point Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Program, as discussed in
Section 4.1 and Alameda Point Petroleum Program activities, as discussed in Section 4.2. A
summary of required restrictions is provided in Section 5.0.
This FOST was prepared in accordance with the Department of Defense (DoD) Base
Redevelopment and Realignment Manual (DoD 2006) and the Navy Base Realignment and
Closure (BRAC) Program Management Office Policy for Processing Findings of Suitability to
Transfer or Lease (Navy 2008c).
2.0 Property Description

Alameda Point is located in the San Francisco Bay Area (see 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. The
FOST Parcel is long and narrow, encompassing approximately 3 acres of upland area along
Ferry Point. Building 544 is the only building in the FOST Parcel as shown on Figure 3.
The FOST Parcel contains a portion of two CERCLA sites: Operable Unit (OU) 2C and
Installation Restoration (IR) site 35, which are located within the central portion of Alameda
Point (Figure 4). Storm Drain Line G, which runs the length of the FOST Parcel, is a part of
Operable Unit (OU) 2C. Storm Drain Line G conveys storm water primarily from Building 5 in
OU-2C to its discharge near the northeast corner of Seaplane Lagoon. The land to the east and
west of Storm Drain Line G is part of IR Site 35. These sites are described in more detail in
Section 4.1.
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Former NAS Alameda
The FOST Parcel area is currently leased by the Navy to the City of Alameda (City) under a
Lease in Furtherance of Conveyance (LIFOC).
Prior to the LIFOC on March 24, 1997, the Navy entered into a Large Parcel Lease (LPL) with
the Alameda Reuse and Redevelopment Authority (ARRA) to allow the ARRA to lease various
property and buildings prior to transfer (Navy and ARRA 1997). In June 2000, the Navy entered
into the aforementioned LIFOC with the ARRA to replace the LPL and to allow the ARRA to
continue to lease property and buildings prior to transfer (Navy and ARRA 2000a). Also in June
2000, the Navy and the ARRA entered into a No Cost EDC Memorandum of Agreement (MOA)
for the conveyance by the Navy of portions of Alameda Point to the ARRA (Navy and ARRA
2000b). The ARRA was dissolved in 2012, and the City, as the recognized Local Redevelopment
Authority, assumed all of ARRA’s rights, duties, assets, and obligations under the LIFOC and
the MOA. To date, the Navy has transferred approximately 89% of the Alameda Point to the City
and other entities. A summary of these transactions is presented in Table 1.
Certain utility and other infrastructure including sanitary sewer, storm drain, fuel lines, and/or
electric power lines are present within the FOST Parcel. The City is responsible for all operation,
maintenance, repair, replacement, and administration of utilities and infrastructure located within
property subject to the LIFOC.
3.0 Regulatory Coordination

In September 1992, the Navy, the State of California Department of Health Services Toxic
Substances Control Program (now referred to as the California Department of Toxic Substances
Control [DTSC]), and the California Regional Water Quality Control Board - San Francisco Bay
(Regional Water Board) entered into a Federal Facility Site Remediation Agreement (FFSRA)
(DTSC 1992a); the United States Environmental Protection Agency (U.S. EPA) was not a
signatory to the FFSRA. The FFSRA defined the Navy’s obligations for corrective action and
response action under the Resource Conservation and Recovery Act (RCRA) and CERCLA for
sites that had been identified in the Navy’s IR Program at Alameda Point. Subsequent to the
execution of the FFSRA and following designation of Alameda Point as a National Priorities List
site in 1999, the Navy and U.S. EPA executed a Federal Facility Agreement (FFA) in July 2001.
Subsequently, DTSC signed the FFA in October 2005, and the Regional Water Board signed it in
November 2005. The FFA superseded the FFSRA and defines the Navy’s corrective action and
response obligations under CERCLA for the RCRA and CERCLA sites that have been identified
at Alameda Point. The U.S. EPA, DTSC, and the Regional Water Board were notified of the
initiation of this FOST and were issued copies for review. Regulatory agency comments to this
FOST are provided in Attachment 1.

Former NAS Alameda
3.1 Resource Conservation and Recovery Act Part A or B Permits
and Subtitle C Corrective Action
This FOST reviews two sites that were evaluated and addressed under the Navy’s CERCLA and
Defense Environmental Restoration Program (DERP) authority, as well as under the corrective
action requirements of RCRA Subtitle C (for solid waste management units [SWMUs]), RCRA
Subtitle I (for underground storage tanks [USTs]), and associated state laws and regulations,
administered by the U.S. EPA, the State of California, and Alameda County. These corrective
action authorities are similar to CERCLA in that they require response/corrective action (i.e.,
cleanup) where necessary to ensure adequate protection of human health and the environment —
see CERCLA Section (§) 121(d); California Health and Safety Code (HSC) § 25296.10(b); and
California Code of Regulations (CCR) Title 23 § 2720 (definition of “corrective action”) and §
2725(c), and Title 22 CCR § 66264.101(a).
The rationale for integrating CERCLA and RCRA corrective action requirements is
straightforward. The cleanup standard for CERCLA is set forth in CERCLA § 121 (Cleanup
Standards), which states in the relevant part of Section 121(b)(1): “…The President shall select a
remedial action that is protective of human health and the environment…” (42 United States
Code [U.S.C.] § 9621(b)(1)). The cleanup standard for RCRA Subtitle C corrective action in the
State of California, as set forth in Title 22 CCR § 66264.101(a), provides: “The owner or
operator of a facility seeking a permit for the transfer, treatment, storage, or disposal of
hazardous waste shall institute corrective action as necessary to protect human health and the
environment for all releases of hazardous waste or constituents from any solid or hazardous
waste management unit at the facility, regardless of the time at which waste was placed in such
unit.” Also see California HSC §§ 25187 and 25200.10(b).
Alameda Point was previously subject to a RCRA permit (CA2170023236), which expired in
July 2003. As part of the RCRA permit closeout activities, a RCRA Facility Assessment (RFA)
was conducted in 1992 and identified numerous SWMUs (which were referred to as “non-
permitted SWMUs” for a period of time) at former NAS Alameda, and which had not been
previously identified in the RCRA permit (DTSC 1992b).
All RCRA-permitted units have been closed (DTSC 2000a, 2000b, 2000c). The FOST Parcel
does not contain any non-permitted units. Both closed and open petroleum sites are present
within the FOST Parcel (see Section 4.2).
3.2 Resource Conservation and Recovery Act Subtitle I Corrective

Action
The Regional Water Board administers the UST corrective action program at Alameda Point
pursuant to RCRA Subtitle I and California HSC §§ 25280-25299.8. The authority of the

Former NAS Alameda
Regional Water Board to require corrective action at UST sites is set forth at Title 23 CCR
Division 3, Chapter 16.
Many of the Petroleum Program sites were originally evaluated as part of a remedial
investigation (RI) completed under CERCLA (Title 42 U.S.C. § 9601 et seq.) at Alameda Point
between 1992 and 1995. However, petroleum and petroleum-related constituents are not
included in the definition of hazardous substances under CERCLA (Title 42 U.S.C. § 9601[14]).
By 1997, sufficient data had been obtained and analyzed for the BRAC Cleanup Team (BCT) to
determine that a number of IR sites only contained petroleum or petroleum-related constituents,
and, therefore, a subset of these sites was moved into the Petroleum Program (Navy 1997). By
letter dated June 20, 1997, DTSC concurred with this decision (DTSC 1997). Petroleum-only
sites and their constituents are being remediated under the 1994 California UST regulation (Title
23 CCR 2720 et seq.), which addresses releases to soil and groundwater from former petroleum
fuel-containing USTs, aboveground storage tanks, and pipelines.
3.3 Comprehensive Environmental Response, Compensation, and

Liability Act
In 1993, the Defense Base Closure and Realignment Commission recommended the closure of
NAS Alameda, which was operationally closed in 1997. In 1999, former NAS Alameda was
added to the National Priorities List. Under Executive Order 12580, the Navy is the lead agency
responsible for cleanup efforts at Navy properties.
CERCLA response actions are initiated at environmental sites where CERCLA hazardous
substances have been or may have been released. The FOST Parcel consists of a portion of two
designated CERCLA sites: OU-2C and IR Site 35. As discussed in Section 4.1, CERCLA
investigations were conducted under the IR Program for these sites.
4.0 Summary of Environmental Conditions and Notifications

This section summarizes the environmental conditions and notifications, as they relate to
CERCLA, petroleum products and derivatives, asbestos-containing materials (ACM), lead-based
paint (LBP), and other regulated materials.
The deed for the CERCLA-impacted FOST Parcel will contain, to the extent such information is
available on the basis of a complete search of agency files, a notification of hazardous substances
stored for 1 year or more, or known to be released, or disposed of within the FOST Parcel, in the
form and manner prescribed by CERCLA (42 U.S.C. § 9620(h)) and Title 40 of the Code of
Federal Regulations Part 373. This notice is provided as Attachment 2, the Hazardous
Substances Notification.

Former NAS Alameda
In addition to the hazardous substance notice, the Base Redevelopment and Realignment Manual
outlines other environmental topics that must be addressed in a FOST (DoD 2006). These topics
are further discussed below, including the environmental conditions and actions taken on the
FOST Parcel; identification of notification requirements related to CERCLA, munitions
response, and petroleum corrective action; and information regarding ACM, LBP,
polychlorinated biphenyls (PCBs), radiological materials, and pesticides.
4.1 CERCLA Program

This section addresses the CERCLA sites within the FOST Parcel. The Navy initiated
environmental investigations at NAS Alameda under the Navy Assessment and Control of
Installation Pollutants (NACIP) Program. Under the NACIP Program, the Navy performed an
initial assessment study in 1982 to assess NAS Alameda for areas posing a potential threat to
human health or the environment due to contamination from historical uses involving hazardous
materials (Ecology and Environment 1983).
On June 6, 1988, the Navy received a Remedial Action Order from the Department of Health
Services (now DTSC) that identified NAS Alameda sites as needing a RI and feasibility study in
accordance with the requirements of CERCLA. In response, the Navy converted its NACIP
Program into the IR Program to be more consistent with CERCLA, and investigations were
conducted in a phased approach.
A comprehensive base closure strategy was developed by the BCT as part of the 1997 BRAC
Cleanup Plan at Alameda Point (Navy 1997). This strategy consolidated the initial 23 IR sites
into four OUs as a management tool to accelerate site investigation. OU-4 was later subdivided
and OU-5 and OU-6 were added when IR Sites 24 through 31 were added to the CERCLA
program. IR Site 18 (Storm Sewers) was reconfigured and eliminated as a separate IR site.
Instead, the associated contamination in the storm sewers was investigated and remediated
within the footprint of individual sites. An additional four new sites, IR Sites 32, 33, 34, and 35,
were added, but were not assigned to an OU.
A portion of two out of 34 Alameda Point IR sites are located within the FOST Parcel (Figure 4).
These sites are a portion of OU-2C (Storm Drain Line G) and a portion of IR Site 35. Storm
Drain Line G, originally part of IR Site 18, was incorporated into OU-2C, where the line
originates, and was further investigated as part of the OU-2C investigations.
Environmental sites within the FOST Parcel have received regulatory agency concurrence for No
Further Action (NFA). The status of the environmental sites within the FOST Parcel is presented
in Table 2. A NFA determination is based on the findings of evaluations or cleanup actions that
the parcel is suitable for transfer as long as the applicable notifications and restrictions, outlined
in Sections 4.0 and 5.0, have been implemented. NFA designations were given to sites either

Former NAS Alameda
because no response action was required to provide adequate protection of human health and the
environment, or the required remedial action has been completed.
Besides the IR sites, the Marsh Crust also was investigated under the CERCLA Program at
Alameda Point. The Marsh Crust is a layer of sediment contaminated with polycyclic aromatic
hydrocarbons (PAHs) that were deposited across the tidelands and the former subtidal areas from
the late 1800s until the 1920s. The contamination is believed to have resulted from former
industrial processes in the area that discharged petroleum products and wastes directly into San
Francisco Bay. The Final Marsh Crust Remedial Action Plan (RAP)/Record of Decision (ROD)
was signed in February 2001 (Navy 2001). The Marsh Crust RAP/ROD identifies restrictions on
excavations that vary by location. Marsh Crust restrictions are required within all of the FOST
Parcel.
A summary of the CERCLA investigations conducted within the FOST Parcel is presented
below.
4.1.1 Storm-Drain Line G (OU-2C)

OU-2C, located in the central portion of Alameda Point is an approximately 53-acre area
consisting of IR Sites 5 (Building 5, Aircraft Rework Facility), 10 (Building 400, Missile
Rework Facility), and 12 (Building 12, Power Plant) (Figure 4). In addition, OU-2C includes
several drain lines, which variously conveyed stormwater, sanitary wastewater, and industrial
wastewater from OU-2C’s cluster of IR sites. The FOST Parcel coincides with a segment of one
of these drain lines: Storm Drain Line G, which flows from Building 5 to its discharge point near
the northeast corner of Seaplane Lagoon (Figure 3). Portions of Petroleum Program Corrective
Action Area (CAA) B and Fuel Line (FL) 125 are located within this portion of OU-2C (Figure
5). No current or former SWMUs are within the footprint of this portion of OU-2C. The
Petroleum Program sites located within the FOST Parcel are discussed in Section 4.2.
The 2016 ROD for OU-2C Drain Lines Located Outside of Buildings 5 and 400 identifies no
contaminant of concern (COC) for the FOST Parcel’s portion of OU-2C (Storm Drain Line G).
Per the ROD, “sediment was removed from within these storm drain lines and subsequent video
surveys, radiological surveys, and sampling did not show any indication of contamination
associated with Storm Drain Lines A, B, and G.” The 2016 ROD documents no further action for
Storm Drain Line G (Navy 2016a).
4.1.2 AOC 23 (IR Site 35)

IR Site 35, the West Housing Area, consists of 23 study areas, occupying about 75 acres of open
space, residences, and commercial/industrial buildings in the northeastern portion of Alameda
Point. Area of Concern (AOC) 23 is part of IR Site 35 (Figure_4). Most of the northern portion
of the FOST Parcel coincides with IR Site 35’s AOC 23. Historically, AOC 23 was used for

Former NAS Alameda
vehicle and equipment parking, and maintenance gear and equipment washdown. Building 544,
located on the FOST Parcel and in AOC 23, was used as a liquid oxygen facility. AOC 23 is an
IR Site 35 study area because initial investigations indicated volatile organic compounds (VOCs)
in groundwater, most prominently vinyl chloride. However, supplemental investigations did not
replicate the presence of vinyl chloride concentrations in groundwater at AOC 23. The ROD
concluded that “risk re-evaluations confirmed that risks associated with other constituents in
groundwater did not warrant further action [at AOC 23]” and thus, that “because there is no
threat to human health or the environment for current and future conditions, no action or no
further action is necessary under CERCLA for IR Site 35” (Navy 2010).
4.2 Petroleum Products and Derivatives

The history and status of the Alameda Point Petroleum Program is documented in the Petroleum
Management Plan (Battelle 2010a) and a subsequent update (Battelle 2012). Unless otherwise
noted, these two documents are the primary sources for the descriptions in the following two
sections.
The Petroleum Program was created to address potential and actual soil and groundwater
contamination related to petroleum products, which are excluded from CERCLA. The Navy
developed a fuel site closure plan in 2001 in cooperation with the Regional Water Board and
DTSC. The Regional Water Board issued a letter in 2001 providing concurrence on the approach
(Regional Water Board 2001).
The Navy identified a variety of CAAs as part of the Petroleum Program (Figure 5). The only
CAA that is wholly or partially within the FOST Parcel is CAA-B. CAA-B consists of 11 fuel
lines. Only FL-023F, FL-071, and FL-109 are partially within the portion of CAA-B that is in the
FOST Parcel. In addition, a short portion of FL-125 is within the FOST Parcel. The CAA-B fuel
lines and FL-125 are shown on Figure 6. All of these fuel lines reportedly transmitted jet fuel.
4.2.1 Open Petroleum Program Sites

The FOST Parcel contains no open Petroleum Program sites.
4.2.2 Closed Petroleum Program Sites

CAA-B and FL-125 are the only closed Petroleum Program sites within the FOST Parcel.
CAA-B: This Corrective Action Area consists of underground steel fuel-conveyance pipelines,
one north/south segment of which previously underlay much of the length of the FOST Parcel
(see Figure 5). The Navy removed this segment (a six-inch steel pipe) in 1998. The Navy
recorded observations and analyzed soil and groundwater samples in conjunction with the fuel
line removal. In 2016, Langan Associates completed a data-gap investigation that included the
portion of CAA-B within the FOST Parcel, and submitted a site closure request to the Regional

Former NAS Alameda
Water Board on behalf of the Navy. In January 2017, the Regional Water Board closed the
portion of CAA-B, including its fuel lines, in the FOST Parcel, subject to three
conditions/requirements: (1) no shallow groundwater use, (2) notification of the Regional Water
Board upon land/groundwater use change, and (3) inclusion of real estate property transfer
disclosures (Regional Water Board 2017). Site-specific land use controls and controls and
covenants restricting shallow groundwater use are not required, due to six considerations the
Regional Water Board identifies in its closure letter. The deed for the FOST Parcel will contain
notifications reflecting the second and third conditions/requirements of the closure, as explained
in Section 5.2.
FL-125: This fuel line consists of the area around a 6-inch steel underground fuel pipeline. The
site was closed with concurrence in 2014 (Regional Water Board 2014) without restrictions. A
very short segment at the west end of FL-125 is in the FOST Parcel.
4.3 Asbestos-Containing Material

DoD policy is to manage ACM in a manner protective of human health and the environment, and
to comply with all applicable federal, state, and local laws and regulations governing ACM hazards
(DoD 1994).
As noted in Section 2, the FOST property was subject to the LPL and is currently subject to the
existing EDC MOA and LIFOC with the City. All available information regarding the existence,
extent, and condition of known ACM was fully identified in Exhibit "B" to the LPL and again in
Exhibit "I" to the EDC MOA. As a result, the City has been responsible for monitoring the
condition of existing ACM in compliance with all applicable federal, state, and local laws
relating to ACM, including prohibiting occupancy of any buildings or structures containing
known ACM prior to abatement of the ACM or demolition of the structure. The Navy is not
responsible for any damages relating to ACM arising out of any activities occurring after the date
of the LIFOC.
A notification regarding the potential presence of ACM within the FOST property, including the
potential for inaccessible underground utilities or structures with ACM, will be included in the
deed. A restriction is required, as discussed in Section 5.3, to ensure ACM is properly handled
after transfer.
4.4 Lead-Based Paint

LBP hazards are defined in the Federal Residential Lead-Based Paint Hazard Reduction Act of
1992 (Title X of Public Law 102550), as codified in 42 U.S.C. § 4822 (the Act) as “any
condition that causes exposure to lead that would result in adverse health effects.” The Act
provides for regulation of the lead hazard from LBP. Hazards include lead-contaminated dust
and soil for target housing only. The Act defines target housing as any housing constructed

Former NAS Alameda
before 1978, except any housing for the elderly or persons with disabilities (unless any child who
is less than 6 years of age resides or is expected to reside in such housing for the elderly or
persons with disabilities) or any zero-bedroom dwelling. Under the Act, the Navy is required to
disclose the presence of known LBP and/or LBP hazards prior to the sale or transfer of property
to a non-federal entity.
In 1998, the Navy conducted a LBP risk assessment for Alameda Point. The Navy found LBP
hazards throughout the interior and exterior of all former housing units surveyed. Notice of the
existence of LBP in the buildings subject to the LIFOC at Alameda Point was provided to the
City in 2000 when the LIFOC was executed. The LIFOC transferred responsibility for LBP
within the lease boundaries from the Navy to the City and required the City to comply with all
applicable federal, state, and local laws.
The LIFOC also notified the City that (1) buildings and other painted structures in the leased
premises potentially contained LBP, and (2) such buildings and structures were not suitable for
occupancy for residential purposes until any inspections and abatement required by applicable
law had been completed.
As a condition of property transfer, the transferee(s) will be required to acknowledge receipt of

the U.S. EPA-approved pamphlet, “Protect Your Family From Lead in Your Home,” (EPA 747-
K-94-001) and to agree that for any improvements on the property defined as target housing by
Title X and constructed before 1978, LBP hazards will be abated or disclosed to future occupants
before use of such improvements as a residential dwelling.
A notification will be provided by the Navy that all buildings at Alameda Point that were
constructed prior to 1978 may contain LBP, and demolition of nonresidential buildings
constructed before 1978 poses the possibility that lead will be found in the soil as a result of
these activities. As a condition of redevelopment, transferees may be required under applicable
law or regulation to evaluate the soil adjacent to the nonresidential buildings for the hazards of
lead in soil.
A restriction is required as discussed in Section 5.4 to carry forward the appropriate LBP
restrictions from the LIFOC.
4.5 Polychlorinated Biphenyls

DoD policy guidance for PCBs is based on the Toxic Substances Control Act regulations found
in Title 40 of the Code of Federal Regulations Part 761. All Navy equipment at Alameda Point
with oil or other dielectric fluids that contained PCBs, such as electrical transformers, capacitors,
and lighting ballasts, had a PCB concentration of less than 40 parts per million; this equipment
was transferred to the Alameda Bureau of Power and Light, currently known as the Alameda
Municipal Power, in 2001.

Former NAS Alameda
4.6 Munitions and Explosives of Concern
Under the Munitions Response Program, the Navy conducted a search to address munitions and
explosives of concern (MEC) and munitions constituents used or released at sites from past on-
site activities.
In 1994, an Environmental Baseline Survey (EBS) was prepared and included a fence-to-fence
inspection, a comprehensive document review, and personnel interviews to establish and
document the history of MEC use, storage, and disposal at Alameda Point. The EBS did not
identify any MEC use, storage, or disposal within the FOST Parcel (ERM-West 1994).
Ordnance was stored and used at Alameda Point throughout its history as a military installation.
Ordnance storage included ship and aircraft weapons systems, combat force weapons, and small
arms and ammunition used by base security personnel. The Navy has removed all stored
ordnance from Alameda Point (EFA-West 1999). A Close-Out Explosives Safety Inspection was
conducted March 4 to March 8, 2013 at Alameda Point, with research and off-site auditing
conducted through September 2013. Based on inspection results, Alameda Point is in compliance
with Termination of Potential Explosion Sites requirements of Naval Sea Systems Command
Ordnance Pamphlet 05 (NOSSA 2013). Explosives safety quantity distance arcs for all potential
explosion sites, not previously cancelled, at Alameda Point, are officially removed (NOSSA
2014). DoD Explosives Safety Board approval for transfer is not required for the specific
property within the FOST Parcel.
No further MEC investigation is required for this FOST Parcel, and no additional notices are
required with respect to MEC.
4.7 Radiological Program

During the basewide EBS, the Navy reviewed on-site records and searched for additional
information on known and potential uses of radiological materials at Alameda Point (ERM-West
1994). Radioactive materials are any materials that are radioactive, except for excluded
radioactive materials as defined in Section 101(22) of CERCLA. Following this, a 1995
radiological survey and a subsequent Historical Radiological Assessment (HRA) were conducted
by the Navy (Tetra Tech 2013).
The results of the HRA were presented as a two-volume set. Volume I addressed radioactivity
associated with the Naval Nuclear Propulsion Program (PHNSY 2000). Volume II addressed
radioactivity associated with general radioactive material (G-RAM), which, for the purposes of
the HRA, is defined as any radioactive material used by the Navy or Navy contractors not
associated with the Naval Nuclear Propulsion Program (Weston 2007). The two volumes were
written by different organizations and published separately because G-RAM and the Naval
Nuclear Propulsion Program are managed by different Naval Sea Systems Command offices.

Former NAS Alameda
4.7.1 Naval Nuclear Propulsion Program
Historically, nuclear-powered ships used NAS Alameda port facilities. Volume I of the HRA
presents the Navy’s investigation of radioactivity associated with the Naval Nuclear Propulsion
Program at former NAS Alameda (PHNSY 2000). The HRA assessed the impact on the
environment from nuclear-powered ship maintenance, overhaul, and refueling. The HRA
concluded that the berthing and maintenance of nuclear-powered ships at NAS Alameda from
1956 to 1997 resulted in no adverse effects on human health or the environment. As noted in the
submittal letter for the Final HRA Volume I; U.S. EPA was satisfied with the HRA draft and no
further response was required, and DTSC had no comments (Navy 2000). Volume I of the HRA
also concluded that an independent review conducted by U.S. EPA was consistent with findings
presented in the Navy report (EFA-West 1999).
No notices or restrictions are required regarding the Naval Nuclear Propulsion Program.
4.7.2 General Radioactive Material

Alameda Point used and stored G-RAM during past base operations. The Volume II HRA
designated historical use sites as either radiologically “impacted” or “non-impacted.” The HRA
defined a site as “impacted” when the site “has or historically had a potential for G-RAM
contamination based on the site operating history or known contamination detected during
previous radiation surveys.” Therefore, an “impacted” site designation identified a site as having
a possibility for contamination based on historical records. Impacted sites include those where:
radioactive materials were used or stored; known spills, discharges, or other instances involving
radioactive materials have occurred; or where radioactive materials might have been disposed of
or buried (Weston 2007).
Of 685 potential G-RAM sites at Alameda Point, the HRA historical review of records indicated
that 23 of the 685 sites are designated as potentially radiologically “impacted.” Of these
impacted sites, two – (1) storm drain lines associated with Buildings 5 and 400 (including Storm
Drain Line G) and (2) Seaplane Ramp and Parking Apron − are partially located within the
FOST Parcel. The radiological site locations and status of each site within the FOST Parcel are
shown on Figure 7.
At Storm Drain Line G, hydro-jetting, video surveys, gamma surveys, and sediment sampling
were conducted in 2012 to address potential radiological contamination within the line and its
sediments (TtECI, 2016). The OU-2C Technical Memorandum, “Operable Unit 2C Drain Lines,
Storm Drain Lines A, B, G and Industrial Waste Line” documents the removal of sediment and
the absence of Ra-226 contamination within Storm Drain Lines A, B, and G (TtECI, 2016).

Former NAS Alameda
Only a very small portion of the Parking Apron at the eastern end of the Seaplane Lagoon is in
the FOST Parcel. As thoroughly discussed in Section 6.2.4, this area does not have unacceptable
levels of radiological material.
4.8 Pesticides
The FOST Parcel may contain residue from pesticides that have been applied in the management
of the property. The Navy knows of no use of any registered pesticide in a manner inconsistent
with its labeling and believes that all applications were made in accordance with the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA), Title 7 U.S.C. § 136, et seq., its
implementing regulations, and according to the labeling provided with such substances. It is the
Navy’s position that it shall have no obligation under the covenants provided pursuant to
Section 120(h)(3)(A)(ii) of CERCLA, Title 42 U.S.C. § 9620(h)(3)(A)(ii), for the remediation of
legally applied pesticides.
4.9 Other Areas Investigated/Issues

4.9.1 Perfluorinated Compounds (PFCs)/Polyfluoroalkyl Substances (PFAS)
Perfluorinated compounds (PFCs) and polyfluoroalkyl substances (PFAS) including
perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are currently classified as
unregulated or “emerging” contaminants, and as such have not been previously included in
basewide groundwater monitoring. In May 2016, the U.S. EPA issued a Lifetime Health
Advisory (LHA) to provide Americans, including the most sensitive populations, with a margin
of protection from a lifetime of exposure to PFOA and PFOS in drinking water (U.S. EPA
2016a). U.S. EPA established the health advisory level at 70 parts per trillion for the combined
concentrations of PFOA and PFOS in drinking water.
Groundwater at the former NAS Alameda is not used as a drinking water source and is not
anticipated to be a future drinking water source (Alameda 2000). However, in October 2016, the
Navy conducted a basewide groundwater monitoring event across the former NAS Alameda,
which included sampling and analysis to confirm the presence or absence of PFCs/PFAS;
specifically, PFOS, PFOA, and perfluorobutane sulfonate (PFBS) at five selected IR sites. None
of the five groundwater sampling locations are on the FOST Parcel. The results of this sampling
are further detailed in Section 6 – Adjacent Properties.
5.0 Summary of Restrictions

This section summarizes the restrictions associated with the FOST Parcel proposed for transfer
related to CERCLA/RCRA sites, petroleum products and derivatives, ACM, and LBP. These
restrictions on certain activities ensure that post-transfer use of the FOST Parcel is consistent
with protection of human health and the environment.

Former NAS Alameda
5.1 CERCLA
As detailed in the following subsection, institutional controls (ICs) will be implemented to
prevent exposures to COCs in soil on the FOST Parcel. ICs will be included in the deed between
the Navy and the property recipient and in Covenant(s) to Restrict Use of Property between the
DTSC and the Navy to limit exposure to contaminated soil. The CERCLA ICs will be
implemented in accordance with remedial design documents for CERCLA sites where the
remedy includes land use restrictions.
5.1.1 Marsh Crust

The Final Marsh Crust RAP/ROD (Navy 2001) was signed in February 2001. The Marsh Crust
RAP/ROD identifies restrictions on excavations within the FOST Parcel.
Excavation within the Marsh Crust and former subtidal area is prohibited, unless proper
precautions are taken to protect worker health and safety and to ensure that excavated material is
managed properly. This prohibition will be implemented with a three-tiered approach following
transfer of the land from the Navy to the transferee(s): 1) a land use covenant will be executed
between DTSC and the transferee(s); 2) an environmental restriction will be included in the
deed; and 3) enforcement of the existing City of Alameda Excavation Ordinance Number 2824
(Navy 2001). The Navy, City, and DTSC will all have enforcement authority for the Marsh Crust
restrictions.
5.2 Petroleum Products and Derivatives

After property transfer, the presence of residual petroleum in some areas of the FOST Parcel will
require implementation of procedures for proper handling and disposal of any potentially
contaminated soil or groundwater encountered during construction or removal from the site.
Accordingly, certain conditions with respect to land use or activity relating to the presence of
residual petroleum contamination will be necessary.
The Federal quitclaim deed for transfer of the FOST Parcel will contain a notice stating that the
property has been investigated and remediated, but contains residual petroleum contamination
that has been investigated and remediated to the satisfaction of the Regional Water Board and
has received regulatory closure, as documented by the Regional Water Board’s No Further
Action Letter and Site Closure Summary Form dated January 24, 2017 (GeoTracker Global ID:
T0600109975). This letter is provided as Attachment 3. The FOST Parcel will be enrolled in the
City of Alameda Land-Use Restriction Tracking and Site Management Plan Program (“City
Program”). Any work conducted on the property that involves soil excavation, trenching, or
groundwater contact shall be conducted in accordance with the City Program. Additionally, the
Regional Water Board shall be notified in writing of any proposed change in land or
groundwater use at the Property.

Former NAS Alameda
5.3 Asbestos-Containing Material
The deed will contain a restriction that the transferee covenants, on behalf of itself, its successors
and assigns, as a covenant running with the land, that it will prohibit occupancy and use of
buildings and structures, or portions thereof, containing known asbestos hazards before
abatement of such hazards. In connection with its use and occupancy of the FOST Parcel,
including, but not limited to, demolition of buildings, structures and inaccessible underground
utilities containing asbestos or ACM, it will comply with all applicable federal, state, and local
laws relating to asbestos and ACM.
In the event that friable, accessible, or damaged asbestos is discovered by the transferee, access,
use, or occupancy is prohibited until either: 1) any necessary ACM abatement has been
completed; or 2) the building, i.e., Building 544, is demolished by the transferee in accordance
with all applicable federal, state, and local laws and other requirements relating to asbestos or
ACM. Until abatement or demolition is complete, the transferee must manage the ACM in
accordance with all applicable federal, state, and local laws and requirements.
5.4 Lead-Based Paint

The deed will contain a restriction that the transferee covenants, on behalf of itself, its successors
and assigns, as a covenant running with the land, in its use and occupancy of the property,
including, but not limited to, demolition of buildings, structures, and facilities, and identification
and evaluation of any LBP hazards, the transferee shall be responsible for managing LBP and
LBP hazards in accordance with applicable federal, state, and local laws, and other requirements
relating to LBP and LBP hazards. Further, the transferee, its successors and assigns will prohibit
residential occupancy and use of buildings and structures, or portions thereof, prior to
identification and/or evaluation of any LBP hazards, and abatement of any hazards identified as
required.
6.0 Adjacent Properties

CERCLA and Petroleum Program sites located immediately adjacent to the FOST Parcel that
could affect the FOST Parcel are discussed in Sections 6.1 and 6.2. Environmental programs at
Alameda Point have progressed to the point where characterization of the extent of
contamination is generally complete, and the CERCLA and petroleum site boundaries have been
established to conservatively encompass all known contamination as well as any anticipated
migration. As a result, these boundaries may be generally relied upon to determine if the FOST
Parcel is impacted by adjacent sites simply by determining if the site boundaries overlap into the
FOST Parcel. A review of CERCLA and Petroleum Program sites adjacent to the FOST Parcel
shows that adjacent sites are not likely to be a potential source of contamination to the FOST
Parcel, as further discussed below.

Former NAS Alameda
6.1 EnviroStor and GeoTracker Listed Sites
The majority of environmental sites adjacent to the FOST Parcel are associated with past Navy
releases, and thus the Navy has the necessary information available to assess potential risks
posed by these sites (Section 6.2). To identify adjacent environmental sites outside of Navy
control, the DTSC EnviroStor and State Water Board GeoTracker databases were reviewed to
determine if any of these types of sites could affect the FOST Parcel. Sites within approximately
a 1 mile radius of the FOST Parcel boundaries were identified from the EnviroStor and
GeoTracker databases. Several properties to the north of former NAS Alameda fell within this
radius, but these properties were located on the other side of the Oakland Inner Harbor and are
not discussed in this section because of the limited potential for soil or groundwater
contamination from these sites to impact the FOST Parcel.
One non-Navy site, Trident Management, was identified based on EnviroStor records. Trident
Management is adjacent to IR Site 17 on the east, and within 500 feet of IR Site 3 to the east of
the FOST Parcel on former Navy property that transferred to the City in 2013 (see Figure 4).
Trident Management is listed as an inactive Tiered Permit holder. EnviroStor does not list any
leaks, spills, or permit violations for the Trident Management site, so the potential for it to
impact the FOST Parcel is low.
The GeoTracker database lists a total of six non-Navy, environmental sites on the Alameda
Peninsula that are within approximately 1 mile of the FOST Property. There are two release sites
under current regulatory oversight and four sites have received regulatory closure and are not
likely to impact the FOST Parcel, so they are not discussed below.
One of the open sites is not related to petroleum releases: Cross Alameda Trail. The Cross
Alameda Trail property is a recently identified former railroad corridor along the south side of
the Ralph Appezzato Memorial Parkway (see Figure 4) that terminates at Main Street, adjacent
to IR Site 3. The chemicals of potential concern (COPCs) include arsenic, lead, PAHs, and total
petroleum hydrocarbons (TPH). Investigations are ongoing; however, the site is not likely to
impact the FOST Parcel because COPCs are in soil and not likely to migrate.
The one remaining open site is a petroleum site: Alameda Gateway Limited, which is on the
south shore of Oakland Inner Harbor, about 500 feet east of IR Site 28 and approximately 3,000
feet to the northeast of the FOST Parcel (see Figure 4). The groundwater flow direction is likely
to the north (Battelle 2010b), so it is not likely to impact the FOST Parcel.
The GeoTracker database lists four closed UST sites east of Main Street, approximately 1,000
feet to the east of the FOST Parcel. The Encinal High School leaking UST site was closed in
1994. It is not expected to impact the FOST Parcel based on the likely direction of groundwater

Former NAS Alameda
flow. The two City sites are not expected to impact the FOST Parcel due to their distance from
the FOST Parcel, the likely direction of groundwater flow, and their closed status.
Two sites including eight USTs, USTs 13-1 through 13-5 and USTs 173-1 through 173-3, are
part of Former NAS Alameda. Site closure letters were issued by the Regional Water Board for
USTs 13-1 through 13-5 in 2001, and USTs 173-1, -2, and -3 in 2014. These two sites with eight
USTs are not expected to impact the FOST Parcel, because the Regional Water Board closed
both sites without restrictions or a requirement for further action, which implies a finding of no
off-site impacts.
6.2 Former NAS Alameda Adjacent Property

Sites located on Alameda Point situated adjacent to the FOST Parcel that are undergoing
evaluation or remedial action are discussed below. No impact is anticipated to the FOST Parcel
from these adjacent sites based on CERCLA contaminants. Storm drain corridors in adjacent
property have been investigated under the CERCLA program and evaluated in conjunction with
the IR Sites with which they are associated. These evaluations do not indicate that the storm
drain corridors impact the FOST Parcel.
PFAS was identified in the 2016 Five Year Review (Navy 2016b) as an emerging contaminant.
In 2016, the Navy sampled groundwater at five separate IR sites at Alameda Point where PFAS
constituents may have been used. The areas include fire fighter training areas, plating shops,
aircraft maintenance shops, and hangars. PFAS was detected above the U.S. EPA 2016 LHA in
at least one groundwater sample at each site. IR Sites 6 and 4 are located west and southeast of
the FOST parcel, respectively (see Figure 4). PFAS has not been delineated at either site,
however, neither site is directly upgradient from the FOST parcel. While the Navy has confirmed
presence of PFAS in groundwater samples above the LHA at adjacent IR Sites Alameda point,
the U.S. EPA’s LHA for PFOA and PFOS are intended to evaluate exposure scenarios involving
drinking water. The shallow groundwater within the FOST parcel is not used for drinking water
and is not anticipated to be used for future drinking water. The presence of PFAS has not been
confirmed within the FOST parcel. Additionally, the FOST parcel is upgradient from both Sites
4 and 6 and is unlikely to be impacted by PFAS.
6.2.1 IR Site 6 (OU-1)

IR Site 6, Aircraft Intermediate Maintenance Facility, is 5.6 acres in size and located west of the
FOST parcel (see Figure 4). No COCs are identified for soil. The selected remedy for
groundwater is In-situ chemical oxidation (ISCO), monitoring natural attenuation and ICs. ISCO
was implemented in May 2010. Plume boundaries for CERCLA contaminants within IR Site 6
do not impact the FOST Parcel.

Former NAS Alameda
6.2.2 IR Site 21 (OU-2B)
IR Site 21 is located east of the FOST Parcel at the northeast corner of Seaplane Lagoon (see
Figure 4). It is about 5.1 acres and located within OU-2B. The site and its surrounding area are
heavily developed. About half of IR Site 21 is covered with asphalt and concrete, and includes
buildings, roads, and parking lots. IR Site 21 includes Building 162, which was constructed in
1945 as a ship and aircraft maintenance shop. No COCs were identified in IR Site 21 soil in the
RI (Navy 2015). The COCs in groundwater at OU-2B were trichloroethene and vinyl chloride.
ICs will be implemented at OU-2B to restrict groundwater use and land use without vapor
intrusion mitigation measures. This site is not expected to impact the FOST Parcel, because it is
cross-gradient from the OU-2B groundwater plume.
6.2.3 IR Site 35
IR Site 35 is composed of 23 study areas, known as AOCs that are located throughout Alameda
Point. One of the AOCs (23) is partially in the FOST Parcel as discussed in Section 4.1.2.
Between 1995 and 1997, a time-critical removal action (TCRA) for storm sewer sediment
removal was completed by the Navy (IT 1997). A portion of this work occurred within IR Site
35. In 2001, a non-time-critical removal action was conducted in AOC 12 to remove lead-
containing soil (Shaw E&I 2003). In 2002, a TCRA was conducted for soil with reported
benzo(a)pyrene equivalent concentrations that exceeded 1.0 milligram per kilogram (mg/kg) in
the top 2 feet of soil in the West Housing Area (IR Site 35, AOCs 4, 5, 7, 9, 13, and 14) (FWC
2004). In 2002, a TCRA was conducted at Building 195 to remove a pesticide/fertilizer shed in
AOC 8 (Shaw E&I 2004). These interim actions were documented in the ROD (Navy 2010) as
being protective of unrestricted site use. The ROD selected excavation and disposal remedies for
AOCs 3, 10, and 12, and documented that the other 20 AOCs required no further action for
unrestricted use.
The remedial action completion report (RACR) documents the remedial actions completed to
remove heptachlor from AOC 3 and lead-impacted soil from AOCs 10 and 12 in IR Site 35
between March and June 2011 (OTIE 2012). U.S. EPA concurred with the Final RACR on
August 27, 2012 (U.S. EPA 2012) and DTSC also concurred on September 6, 2012 (DTSC
2012). The site has progressed through the CERCLA process and remedial actions have been
completed. Portions of the site were transferred in 2013 to the City. This site is not expected to
impact the FOST Parcel, because no known significant soil or groundwater contamination
remains in IR Site 35.
6.2.4 Radiological Sites

Several radiological sites are located adjacent to the FOST Parcel (see Figure 7). As discussed
below, no adjacent radiological sites will impact the FOST Parcel.

Former NAS Alameda
Seaplane Ramp and Parking Apron. The Seaplane Ramp and Parking Apron are included in the
HRA (Weston 2007). HRA Section 6.2.15 states: “It was suspected that workers in Building 400
might have spilled radium paint waste that was being carried from the building to Seaplane
Lagoon. The 1998 100 percent gamma survey of the ramp and parking area yielded no
radioactive anomalies.” The Parking Apron area is adjacent to the FOST Parcel. A small portion
at the eastern end of the Parking Apron is in the FOST Parcel as discussed in Section 4.7.2 (see
Figure 7). The seaplane ramps are cantilevered structures associated with the adjacent apron.
The Seaplane Parking Apron, which is a paved area, has been used as a processing area for
various Navy radiological projects since 2008. In accordance with the work plans for those
projects, the apron has been radiologically surveyed before and after each project prior to down
posting of the area at the end of the project. To date, the last project that used the apron was the
IR Site 17 Seaplane Lagoon remediation, this remediation and post-remediation radiological
surveys are discussed below. The area has since been down posted for unrestricted use.
In January 2011, the entire Seaplane Parking Apron was incorporated into the Radiological
Controlled Area in support of the IR Site 17 Seaplane Lagoon remedial action. As part of the
Navy’s work plan, drying pads were built over the Parking Apron. The Parking Apron was used
for the adjacent remediation area in the northeastern corner of Seaplane Lagoon. While discreet
sources of radioactive materials were found in the sediment from the northeast remediation area,
no loose sediment contamination was found. After the northeast remediation area dredging,
sediment drying and radiological processing of the sediment were completed. The Navy removed
the drying pad on the Parking Apron and conducted radiological surveys in accordance with the
remedial action work plan. No evidence of residual radioactivity from Navy activities was found
on the Parking Apron and no further action was required (Navy 2014). This conclusion was
concurred by both U.S. EPA and DTSC (U.S. EPA 2016b, DTSC 2016). The eastern portion of
the Parking Apron was transferred in 2013.
IR Sites 5 and 10.A TCRA was conducted for IR Sites 5 and 10 (see Figure 4). The TCRA
involved the removal of storm drain lines F and FF that originate in Buildings 5 and 400 in OU-
2C’s IR Sites 5 and 10, respectively, and discharged to Seaplane Lagoon (TtECI 2011). The
removal action was based on an operational history described in the HRA that determined
discharge from these storm drain lines contained radioactive contamination and required a
response action. The removal action occurred between 2008 and 2011. IR Sites 5 and 10 will not
impact the FOST Parcel, because they are nearly 1000 feet or more from the FOST Parcel.
6.2.5 Petroleum Sites

Two petroleum sites are located adjacent to the FOST Parcel and are further discussed below.

Former NAS Alameda
CAA-B. This site consists of the area around three east–west, parallel FLs used to transport jet
fuel, with multiple crossing FLs (about 22,500 feet) that link a series of fueling pits within
portions of IR Site 35. The FLs were abandoned in place in 1998 (Battelle 2010). The site is
adjacent to the FOST Parcel to the north of Seaplane Lagoon. The residual TPH is not expected
to impact the FOST Parcel. CAA-B is partially within the FOST Parcel (see Section 4.2.1).
Fuel Line 155A. This site consists of a former north-west fuel line segment within Ferry Point.
This fuel line was removed in 1998. Recent investigations conducted in the vicinity of the fuel
line have identified petroleum constituents in soil and groundwater. The residual TPH is not
expected to impact the FOST Parcel, because it is cross-gradient from the fuel line.
7.0 Access Clause

The deed(s) will reserve and the transferee shall grant to the United States access to the FOST
Parcel pursuant to CERCLA Section 120(h)(3)(A)(iii). DTSC, the Regional Water Board, and
U.S. EPA and their successors and assigns shall also be granted access to the property to enter
the FOST Parcel in any case in which response action or corrective action is found necessary on
the FOST Parcel after the date of transfer. In addition, the deed(s) will provide for a right of
access for the U.S. to traverse property owned by the transferee to gain access to property still
owned by the U.S.
8.0 Covenants
The deed for transfer of any property on which “any hazardous substance was stored for one year
or more, [or] known to have been released, or disposed…” as a result of former activities
conducted by the United States, will include a covenant made pursuant to CERCLA Section
120(h)(3)(A)(ii) and (B). The covenant will warrant that “all remedial action necessary to protect
human health and the environment with respect to any hazardous substance identified pursuant to
Section 120(h)(3)(A)(i)(I) of the CERCLA of 1980 remaining on the property has been taken
before the date of this deed(s)” and that “any additional remedial action found to be necessary
after the date of such transfer shall be conducted by the United States.” This covenant will not
apply to any remedial action required on the FOST Parcel that is the result of an act or omission
of the transferee that causes a new release of hazardous substances.

Former NAS Alameda
9.0 Finding of Suitability to Transfer Statement
Based on the information contained in this FOST and the notices, restrictions, and covenants that
will be contained in the deed, the FOST Parcel at the Alameda Point is suitable for transfer.
Signature: Date:
Lawrence Lansdale, P.E.
BRAC Environmental Director
By Direction

Former NAS Alameda
10.0 References
Alameda (City of Alameda). 2000. Final EIR for the Reuse of Naval Air Station Alameda and
the Fleet and Industrial Supply Center, Alameda Annex and Facility, Alameda,
California. March.
Battelle. 2010a. Petroleum Management Plan. November 24.
Battelle. 2010b. Final Remedial Design/Remedial Action Work Plan, Installation Restoration
Site 28, Alameda Point, Alameda, California. April.
Battelle. 2012. 2012 Update-Petroleum Management Plan. February 28.
DoD (Department of Defense). 1994. Department of Defense Policy on the Environmental
Review Process to Reach a Finding of Suitability to Transfer for Property Where Release
or Disposal Has Occurred. June 1.
DoD. 2006. Base Redevelopment and Realignment Manual. Office of the Deputy Under
Secretary of Defense (Installations and Environment). March.
DTSC (California Department of Toxic Substances Control). 1992a. Federal Facility Site
Remediation Agreement for Alameda Point. September 29.
DTSC. 1992b. RCRA Facility Assessment, Naval Air Station, Alameda, California. April.
DTSC. 1997. Letter Regarding Analysis of Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) Constituent Analysis at Sites Designated
Petroleum-Only, Alameda Point, Alameda, California. From Daniel E. Murphy, P.E.,
Chief, Closing Bases Unit, Office of Military Facilities. To Ms. Shin-Roei Lee, Leader,
DoD Section, Alameda Bay Water Board. June 20.
DTSC. 2000a. Letter Regarding “Acceptance of Closure Certification Report for Building 13,
Flammable Waste Storage Facility, Naval Air Station Alameda, Alameda, CA EPA ID
No. CA2170023236.” From Mohinder S. Sandhu, Chief, Standardized Permits and
Corrective Action Branch, DTSC. To Steve Edde, BRAC Environmental Liaison Naval
Facilities Engineering Command. February 3.
DTSC. 2000b. Letter Regarding “Acceptance of Closure Certification Reports and Activities for
All Regulated Units in Building 13, Naval Air Station Alameda, Alameda, CA EPA ID
No. CA2170023236.” From Mohinder S. Sandhu, Chief, Standardized Permits and
Corrective Action Branch, DTSC. To Steve Edde, BRAC Environmental Liaison Naval
Facilities Engineering Command. May 4.
DTSC. 2000c. Letter Regarding Closure Certification Acceptance for Area 37 Annex Hazardous
Waste Storage Facility, at the Former U.S. Naval Air Station Alameda, Alameda Point,
California. EPA ID No.: CA2 170 023 236. From Mohinder S. Sandhu, Chief,
Standardized Permits and Corrective Action Branch, DTSC. To Steve Edde, BRAC
Environmental Liaison Naval Facilities Engineering Command. October 10.
DTSC. 2012. Letter Regarding DTSC Concurrence with Final Remedial Action Completion
Report Installation Restoration Site 35 Areas of Concern 3, 10, and 12 in Transfer Parcel

Former NAS Alameda
EDC-5, Alameda Point, Alameda, California. August. From Karen Toth, Unit Chief,
Brownfields and Environmental Restoration Program, DTSC. To Derek J. Robinson,
Navy, BRAC, Program Management Office West. September 6.
DTSC. 2016. Letter Regarding DTSC Concurrence with Final Remedial Action Completion
Report Installation Restoration Site 37, Alameda Point, Alameda, California. April. From
Karen Toth, Unit Chief, Brownfields and Environmental Restoration Program, DTSC. To
Cecily Sabedra, Navy, BRAC, Program Management Office West. April 1.
Ecology and Environment. 1983. Initial Assessment Study of Naval Air Station Alameda. April.
EFA-West (Engineering Field Activity West Naval Facilities Engineering Command). 1999.
Final Environmental Impact Statement for the Disposal and Reuse of NAS Alameda and
the FISC, Alameda Annex, and Facility, Alameda, California. October.
ERM-West (ERM-West, Inc.). 1994. Final Basewide Environmental Baseline
Survey/Community Environmental Response Facilitation Act Report for NAS/Naval
Aviation Depot Alameda. October.
FWC (Foster Wheeler Corporation). 2004. Final Project Close-Out Report. CERCLA Time-
Critical Removal Action at West Housing Area, Alameda Point, Alameda, California.
February 13.
IT. (International Technology Corporation). 1997. Sewer Sampling and Analysis Summary
Report, NAS Alameda, Alameda, California. November.
Navy (Department of the Navy). 1997. BRAC Cleanup Plan for Alameda Point, Alameda,
California. March 1.
Navy. 2000. Letter Regarding Submittal of NAS Alameda Historical Radiological Assessment
(HRA), Volume I, Naval Nuclear Propulsion Program. From Commander, Pearl Harbor
Naval Shipyard and Intermediate Maintenance Facility. To U.S. EPA, Region IX (Attn.
Anna-Marie Cook) and California DTSC, Region 2 (Attn. Mary Rose Cassa). April 19.
Navy. 2001. Final Remedial Action Plan/Record of Decision (ROD) for the Marsh Crust at the
Fleet and Industrial Supply Center Oakland Alameda Facility/Alameda Annex and for the
Marsh Crust and Former Subtidal Area at Alameda Point. February.
Navy. 2008c. Policy for Processing Findings of Suitability to Transfer or Lease. December 12.
Navy. 2010. Final Record of Decision for Installation Restoration Site 35, Areas of Concern in
Transfer Parcel EDC-35, Alameda Point. Alameda, California. February.
Navy. 2014. Final Remedial Action Completion Report, Installation Restoration Site 17,
Seaplane Lagoon, Alameda Point, Alameda, California. September.
Navy. 2015. Final Record of Decision for Operable Unit 2B, Former Naval Air Station,
Alameda, California. March.
Navy. 2016a. Final Record of Decision for OU-2C Drain Lines, Alameda Point, Alameda,
California. December.

Former NAS Alameda
Navy. 2016b. Final Five-Year Review, Alameda Point and Fleet and Industrial Supply Center
Oakland, Alameda Facility/Alameda Annex, Alameda, California. September.
Navy and ARRA (Navy and Alameda Reuse and Redevelopment Authority). 1997. Department
of the Navy (Navy) entered into a Large Parcel Lease (LPL) with the former Alameda
Reuse and Redevelopment Authority (ARRA) to allow the City of Alameda to lease
various property and buildings prior to transfer. March 24.
Navy and ARRA. 2000a. Lease in Furtherance of Conveyance between the United States of
America and the Alameda Reuse and Redevelopment Authority for the Former Naval Air
Station Alameda. June 6 (Amendment #1, November 28, 2000; Amendment #2, March
30, 2009; and Amendment #3, August 23, 2012).
Navy and ARRA. 2000b. Memorandum of Agreement between the United States of America
Acting by and through the Secretary of the Navy United States Department of the Navy
and the Alameda Reuse and Redevelopment Authority for Conveyance of Portions of the
Naval Air Station Alameda from the United States of America to the Alameda Reuse and
Development Authority. June 6 (amended July 31 and January 13, 2012).
NOSSA (Naval Ordnance Safety and Security Activity). 2013. Letter Regarding Close-Out
Explosives Safety Inspection of Naval Air Station Alameda (UIC:00236). From
Commanding Officer, Naval Ordnance Safety and Security Activity. To Director, Navy
BRAC Program Management Office West. October 28.
NOSSA. 2014. Letter Regarding Request to Remove Exclusion Zones and Explosives Safety
Quantity Distance Arcs Established for Magazines, Operating Buildings, and Other Sites
Former Naval Air Station Alameda, Alameda, California [FF-024]. From: Commanding
Officer, Naval Ordnance Safety and Security Activity. To Headquarters, Naval Facilities
Engineering Command, Director, BRAC Program Management Office West
(BPMOW/PAM). February 25.
OTIE. (Oneida Total Integrated Enterprises). 2012. Final Remedial Action Completion Report
Installation Restoration Site 35 Areas of Concern 3, 10, and 12 in Transfer Parcel EDC-5,
Alameda Point, Alameda, California. August 6.
PHNSY (Pearl Harbor Naval Shipyard). 2000. Historical Radiological Assessment, Naval Air
Station Alameda, Volume I, Naval Nuclear Propulsion Program, 1966-1997. April.
Regional Water Board (San Francisco Bay Regional Water Quality Control Board). 2001.
Consensus Letter on the Preliminary Remediation Criteria and Closure Strategy for
Petroleum-Contaminated Sites at Alameda Point from Brad Job, Regional Water Board to
Mike McClelland, Navy. June 11.
Regional Water Board. 2014. Letter Regarding No Further Action for Former Fuel Line Segment
125, Former Alameda Naval Air Station, Alameda County. From Bruce H. Wolfe,
Regional Water Board to Derek J. Robinson (Navy). July 15.
Regional Water Board. 2017. Letter Regarding No Further Action for Fuel Line (FL)-71 and FL-
23F East in CAA B South, Former Alameda Naval Air Station, Alameda County. From
Bruce H. Wolfe, Regional Water Board to Cecily Sabedra (Navy). January 24.

Former NAS Alameda
Shaw E&I (Shaw Environmental and Infrastructure, Inc.). 2003. Site Closure Report. Parcels 79,
98, 105, 106, and 107 Non-Time-Critical Removal Action. Revision O. Alameda Point,
Alameda, California. November 4.
Shaw E&I. 2004. Final Removal Action Site Closeout Report. Revision 1. Time-Critical
Removal Action for Building 195 Pesticide Shed Demolition and Soil Removal. Alameda
Point, Alameda, California. February 5.
SulTech. 2007. Compendium of SWMU Evaluation Reports. June 22.
Tetra Tech (TetraTech EMI). 2013. Final Status Survey Report, Pier 3, Alameda Point, Alameda,
California. October 15.
TtECI (Tetra Tech EC Inc.). 2011. Final Time-Critical Removal Action Completion, IR Sites 5
and 10, Buildings 5 and 400, Storm Drain Line Removal, Alameda Point, Alameda,
California. September.
TtECI. 2016. Final Technical Memorandum, Operable Unit 2C Drain Lines, Storm Drain Lines
A, B, G and Industrial Waste Line, Alameda Point, Alameda, California. January.
U.S. EPA (U.S. Environmental Protection Agency). 2012. Letter Regarding Final Remedial
Action Completion Report, IR Site 35, Alameda Point, Alameda, California. August
2012. From Michael Montgomery, Assistant Director, Superfund Division, Federal
Facilities and Site Cleanup Branch, U.S. EPA. To Derek Robinson, Navy, BRAC,
Program Management Office West. August 27.
U.S. EPA. 2016a. “Lifetime Health Advisories and Health Effects Support Documents for
Perfluorooctanoic Acid and Perfluorooctane Sulfonate”. Federal Register 81, no. 101:
33250. May 25.
U.S. EPA. 2016b. Letter Regarding Final Remedial Action Completion Report, IR Site 17,
Alameda Point, Alameda, California. September 2014. From Angeles Herrera, Assistant
Director, Superfund Division, Federal Facilities and Site Cleanup Branch, U.S. EPA. To
Cecily Sabedra, Navy, BRAC, Program Management Office West. August 27.
Weston (Weston Solutions, Inc.). 2007. Final Historical Radiological Assessment Volume II,
Alameda Naval Air Station, Use of General Radioactive Materials, 1941-2005. June.

Former NAS Alameda
Figures
Draft Final FOST Phase 3A

Former NAS Alameda

Former NAS Alameda
Figure 1 Site Location Map

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
R
MAIN STREET
SEAPLANE
LAGOON
SAN FRANCISCO BAY
VICINITY MAP
LEGEND
Carlson, Barbee
& Gibson, Inc.
FIGURE 1
CIVIL ENGINEERS SURVEYORS PLANNERS
SITE LOCATION MAP
2633 CAMINO RAMON, SUITE 350
SAN RAMON, CALIFORNIA 94583
(925) 866-0322
www.cbandg.com
FINDING OF SUITABILITY TO TRANSFER (FOST) PHASE 3A FORMER NAS ALAMEDA
DATE: DECEMBER, 2016
G:\1087-10\ACAD-10\EXHIBITS\FOST (3A)\FIGURE 1.DWG

Former NAS Alameda
Figure 2 FOST Parcel

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
R
MAIN STREET
WEST TOWER AVENUE
SEAPLANE
LAGOON
SAN FRANCISCO BAY
VICINITY MAP
ORION STREET
LEGEND
WEST ATLANTIC AVENUE

FERRY POINT
SEAPLANE
LAGOON NOTE:
Carlson, Barbee
& Gibson, Inc.
FIGURE 2 200' 0' 100' 200' 400'
FOST PARCEL
2633 CAMINO RAMON, SUITE 350 (925) 866-0322
SAN RAMON, CALIFORNIA 94583 www.cbandg.com
DATE: DECEMBER, 2016 GRAPHIC SCALE


Former NAS Alameda
Figure 3 Buildings in or Adjacent to the FOST Parcel

Former NAS Alameda

Former NAS Alameda
815
816 814 827 831
8 92 78 OAKLA
ND IN
826 NER HARBO
828 R
817 822 835 834
825
819
9 91
821 824 830
836
MAIN STREET
818 820 823
SEAPLANE
LAGOON
271
117 SAN FRANCISCO BAY

544 118
40 41
VICINITY MAP
517
67 393 564
77 13
98 112
264 119
LEGEND
527
399
470
66
398
RAMP 4
SEAPLANE 113 162

LAGOON
360
14
Carlson, Barbee
& Gibson, Inc.
FIGURE 3 200' 0' 100' 200' 400'
BUILDINGS IN OR ADJACENT TO THE FOST PARCEL
DATE: DECEMBER, 2016 GRAPHIC SCALE


Former NAS Alameda
Figure 4 Operable Units, IR Sites, and Areas of Concern

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
R
(Phase 2)
MAIN STREET
SEAPLANE
LAGOON
SAN FRANCISCO BAY
VICINITY MAP
RALPH APPEZZATO
MEMORIAL PARKWAY
INSTALLATION RESTORATION SITE DESCRIPTION
Carlson, Barbee
& Gibson, Inc.
FIGURE 4
OPERABLE UNITS, IR SITES & AREAS OF CONCERN
2633 CAMINO RAMON, SUITE 350
SAN RAMON, CALIFORNIA 94583
(925) 866-0322
www.cbandg.com
DATE: JANUARY, 2017

Former NAS Alameda
Figure 5 Total Petroleum Hydrocarbons Corrective Action Areas and Areas of Concern

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
CAA-2
R
CAA-6
CAA-B
CAA-08
MAIN STREET
CAA-B
CAA-7
CAA-B
CAA-B
CAA-B
CAA-10
CAA-B
CAA-3A CAA-3B
CAA-B
CAA-3C
CAA-11A CAA-4A
SEAPLANE CAA-11B
CAA-4B
LAGOON CAA-13 CAA-4C
CAA-12
TRW
TRW
CAA-13
SAN FRANCISCO BAY CAA-9A
VICINITY MAP
CAA-B LEGEND
AOC 23
CAA-3A CAA-3B
CAA-B
CAA-3C
SEAPLANE
LAGOON
CAA-11A CAA-4A
Carlson, Barbee
& Gibson, Inc.
FIGURE 5 200' 0' 100' 200' 400'
TOTAL PETROLEUM HYDROCARBONS, CAA'S & AREAS OF CONCERN
DATE: FEBRUARY, 2017 GRAPHIC SCALE


Former NAS Alameda
Figure 6 Underground Fuel Line Status

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
R
MAIN STREET
FL-109 SEAPLANE
LAGOON
SAN FRANCISCO BAY
FL-071 VICINITY MAP
LEGEND
FL-023F
FL-125
SEAPLANE
LAGOON
Carlson, Barbee
& Gibson, Inc.
FIGURE 6 200' 0' 100' 200' 400'
UNDERGROUND FUEL LINE STATUS


Former NAS Alameda
Figure 7 Radiological Sites Within or Adjacent to the FOST Parcel

Former NAS Alameda

Former NAS Alameda
OAKLA
ND IN
NER HARBO
R
MAIN STREET
SEAPLANE
LAGOON
SAN FRANCISCO BAY
VICINITY MAP
LEGEND
FORMER SMELTER AREA
BUILDING 66
SEAPLANE RAMP AND PARKING APRON

BUILDING 113
SEAPLANE
LAGOON
Carlson, Barbee
& Gibson, Inc.
FIGURE 7 200' 0' 100' 200' 400'
RADIOLOGICAL SITES WITHIN OR ADJACENT TO THE FOST PARCEL


Former NAS Alameda
Tables

Former NAS Alameda

Former NAS Alameda
Table 1 Property Disposal to Date
Finding of Suitability to Transfer Phase 3A – Former NAS Alameda
Type of Disposal Recipient When Description Acres

NC-EDC City of Alameda 2000 East Housing 75.00
Lease Termination City of Alameda 2000 Lease Termination 161.50
Federal Agency to Federal
U.S. Coast Guard 2008 Marina Village Housing 28.00
Agency
Via U.S. Dept. of Interior (Park &
PBC City of Alameda 2009 44.00
Rec.)
NC-EDC (Phase 1) City of Alameda 2013 June 2013 Conveyance 1,379.21
PBC City of Alameda 2013 Estuary Park 8.00
Federal Agency to Federal
Veterans’ Administration 2014 June 2014 Conveyance 623.6
Agency
NC-EDC City of Alameda 2016 April 2016 Conveyance 183.44
Alameda Unified School Island High School/Woodstock
PBC 2016 6.73
District CDC
Notes:
EDC = Economic Development Conveyance
NC = No Cost
PBC = Public Benefit Conveyance

Former NAS Alameda

Former NAS Alameda
Table 2 CERCLA Site Status
Finding of Suitability to Transfer Phase 3A – Former NAS Alameda
Identification Site Name Status Closure Reference

IR 35 West Housing Area NFA Navy 2010
OU-2C Storm Drain Line G Naval Air Rework Facility NFA Navy 2016a
Notes:
IR = Installation Restoration Site
Navy = Department of the Navy
NFA = No Further Action
OU = Operable Unit

Former NAS Alameda

Former NAS Alameda
Attachment 1: Responses to Regulatory Agency Comments

Former NAS Alameda

Former NAS Alameda
DRAFT RESPONSE TO COMMENTS ON THE DRAFT FINDING OF SUITABILITY TO TRANSFER PHASE 3A
FORMER ALAMEDA NAVAL AIR STATION, ALAMEDA, CALIFORNIA, DECEMBER 16, 2016

Comments from:
United States Environmental Protection Agency, Region IX
Xuan-Mai Tran, Remedial Project Manager
Federal Facilities and Site Cleanup Branch
Comments received January 11, 2017
General Comments
No. Comment Response
EPA’s review of the Draft Finding of Suitability to Transfer
(FOST) Phase 3A for the former Naval Air Station Alameda is
Comment noted. The OU-2C Drain Lines ROD was finalized on
1. based on the expectation that the Record of Decision (ROD) for
January 27, 2017.
the OU-2C drain lines located outside buildings 5 and 400 will be
finalized and/or approved prior to the FOST signature.
EPA notes that Navy policy provides for a 30-day public notice
2 Comment noted.
prior to the signing of the FOST.
Specific Comments
Section 4.1.1, Storm-Drain Line G (OU-2C), Page 6: The first The FOST has been revised as suggested:
sentence in the second paragraph should describe the 2016 ROD
1.
for OU-2C as pertaining to drain lines located outside buildings 5 “The 2016 ROD for OU-2C Drain Lines Located Outside of
and 400, rather than buildings 5 and 10. Buildings 5 and 400 identifies…”
Section 4.1.2’s 2nd sentence has been revised as suggested by this
Section 4.1.2, AOC 23 (IR Site 35), Page 6: To be consistent, comment and DTSC Comment 3:
2.
please change “IR35” to “IR Site 35.”
“Area of Concern (AOC) 23 is part of IR Site 35 (Figure 4).”
Because the Regional Water Board closed the portion of CAA-B
South within the FOST Parcel after the Draft FOST 3A was
Section 4.2.1, Open Petroleum Program Sites, Page 7: To be
prepared, Sections 4.2.1, 4.2.2, and 5.2 and Figures 5 and 6 have
3. consistent, please use “CAA-B” instead of “CAA B” throughout
been substantively revised. The two occurrences of “CAA B” in
this section and the rest of the FOST.
Section 4.2.1, which were the only occurrences in the document,
have been deleted.
1


Section 4.2.2, Closed Petroleum Program Sites, Page 8: Please The FOST has been revised as suggested by converting “Regional
4.
link “Water Board 2014” to its corresponding source. Water Board 2014” to a link to the References section.
The FOST has been revised as suggested:
“…not anticipated to be a future drinking water source (Alameda

2000).”
The shallow groundwater underlying the former NAS Alameda

is not currently used for potable water purposes. It is highly
unlikely that groundwater (from shallow or deep aquifers) will
be used for drinking water because water service in the City is
provided by the East Bay Municipal Utility District (EBMUD).
Section 4.9.1, Perfluorinated Compounds The project area for the redevelopment and reuse of Alameda
(PFCs)/Polyfluoroalkyl Substances (PFAS), Page 12: In the Point is located entirely within EBMUD’s service area, and
first sentence of the second paragraph, please provide a citation during its reuse planning process, the City of Alameda
5.
for the determination that “[g]roundwater at the former NAS submitted a request pursuant to Sections 10910-10915 of the
Alameda is not used as a drinking water source and is not California Water Code to EBMUD to prepare a water supply
anticipated to be a future drinking water source.” assessment for the proposed project. EBMUD determined that
the increased water demand for the Alameda Point project is
accounted for in EBMUD’s water demand projections as
published in EBMUD’s 2010 Urban Water Management Plan.
(EBMUD’s water demand projections account for anticipated
future water demands within EBMUD’s service boundaries.) It
was determined that the City’s redevelopment of Alameda
Point would not change EBMUD’s water demand projection
extending to the year 2040 and would not result in a new
significant increase in water use. The City’s Final certified EIR
(State Clearinghouse # 96022105) documents the City’s
determination that the project would not exceed the existing or
2


projected water supply or result in the need for new or
expanded water treatment facilities.
The City’s reuse planning documents indicate that a new water

distribution system will be installed within the proposed
development area to serve the Alameda Point project and
would connect to the existing EBMUD water facilities. The
existing system, which is now serviced by EBMUD, will
eventually be replaced with a new water system in phases,
consistent with the development build out, and would
adequately accommodate the project's expected water demand.
Accordingly, there is no plan to utilize groundwater for
drinking water or other potable uses at Alameda.
Section 5.1, CERCLA, Page 13: Please spell out “ICs” for the
6.
first time. “As detailed in the following subsection, institutional controls
(ICs) will be …”
Section 6.2.1, IR Site 6 (OU-1), Page 17: To be consistent,
7.
please change “institutional controls” to “ICs”.
“…monitoring natural attenuation and ICs.”
The FOST has been revised to spell out “trichloroethene” and to
remove TCE from the Abbreviations and Acronyms list, because
Section 6.2.2, IR Site 21 (OU-2B), Page 17: Please spell out the word does not appear elsewhere in the FOST.
8.
“TCE” for the first time.
“The COCs in groundwater at OU-2B were trichloroethene and
vinyl chloride.”
Section 6.2.4, Radiological Sites, Page 18: To be consistent,
please change “IR Site 17 (Seaplane Lagoon)” in the fourth
9.
paragraph to “IR Site 17 Seaplane Lagoon” as it was written in
“…in support of the IR Site 17 Seaplane Lagoon remedial action.”
the third paragraph.
3


Section 6.2.5, Petroleum Sites, Page 19: There is a minor
The FOST has been revised as suggested to correct the formatting
10. formatting issue with the heading of the paragraph pertaining to
issue at the beginning of Section 6.2.5’s second paragraph.
Fuel Line 155A.

4


Comments from:
Department of Toxic Substances Control
Emily Mortazavi, Environmental Scientist/Project Manager
Brownfields and Environmental Restoration Program
Comments received January 20, 2017
Please revise the footer on the document to read “Draft The document’s title page and footers throughout have been revised to
1.
FOST Phase 3A” and not “Final FOST Phase 3A”. “Draft Final FOST 3A”.
Section 4.1, page 5, fourth paragraph: For clarity please add
2 the following: "These sites are a portion of OU-2C (Storm The subject sentence has been revised to the suggested wording.
Drain Line G) and a portion of IR Site 35.”
Section 4.1.2:
Section 4.1.2’s 2nd sentence has been revised as suggested by this
a. On page 6, please edit the second sentence to read
comment and USEPA Specific Comment 2 as follows:
“Area of Concern (AOC) 23 is part of IR 35 (Figure
5).”
“Area of Concern (AOC) 23 is part of IR Site 35 (Figure 4).”
The 5th (formerly 4th) sentence of Section 4.1.2 has been revised to
clarify that Building 544 is in AOC 23 as follows:
3.
“Building 544, located on the FOST Parcel and in AOC 23, was used
b. Please clarify if Building 544 is part of AOC 23 and if
as a liquid storage facility.”
VOCs are present in Building 544.
The 960 ft2, 1974-vintage Building 544 is seldom entered. No records
are readily available that document indoor air samples from Building
544 ever having been analyzed.
5


Figure 4 has been revised to clearly show the location of IR Site 35’s
AOC 23, and the figure reference in Section 4.1.2’s 1st sentence has
been changed from Figure 5 to Figure 4. In addition, the following
c. Please clarify the relationship of AOC 23 to the FOST
sentence has been inserted after Section 4.1.2’s 2nd sentence:
Parcel.
“Most of the northern portion of the FOST Parcel coincides with IR
Site 35’s AOC 23.”
Section 4.2.1, second paragraph:
a. Please change the sentence to state: “one north/south
4.
segment which previously underlay much of the length The subject sentence has been revised to the suggested wording.
of the FOST Parcel.”
Section 4.5:
The sentence has been revised as follows to provide the suggested
a. On page 9, please clarify what type of “equipment” is clarification:
meant in the second sentence that reads: “All Navy
5. equipment at Alameda Point with oil or other dielectric “…with oil or other dielectric fluids that contain PCBs, such as
fluids...” electrical transformers, capacitors, and lighting ballasts, had a PCB
concentration of less than…”
b. Please clarify if PCBs were present on the FOST
PCBs have not been detected in soil samples from the FOST Parcel.
parcel.
Section 4.9.1
A sentence has been added after Section 4.9.1’s 2nd paragraph’s 2nd
sentence as follows:
6. a. Please clarify if any of the 5 sites investigated for
PFOA and PFOS were on the FOST parcel.
“None of the five groundwater sampling locations are on the FOST
Parcel.”
7. Section 5.2
6


The subject sentence has been revised as suggested and also to clarify
that the Regional Water Board’s closure letter specifies conditions, not
restrictions:
“Accordingly, certain conditions with respect to land use or activity

a. On page 13, please edit the last sentence of the section
relating to the presence of residual petroleum contamination will be
paragraph to read “Accordingly, land use or activity
necessary.”
restrictions relating... contamination may will be
necessary”.
Note that, because the Regional Water Board closed the portion of
CAA-B South within the FOST Parcel after the Draft FOST 3A was
prepared, Sections 4.2.1, 4.2.2, and 5.2 and Figures 5 and 6 have been
substantively revised. The closure letter has been appended to the
FOST as Attachment 3
Section 6.1
a. On page 16:
i. In the 2nd paragraph: Please revise for clarity the The sentence has been revised for clarity as follows:
last sentence to read “there are two release sites
under current regulatory oversight; and four sites “…two release sites under current regulatory oversight and four sites
have received regulatory...” have received regulatory closure…”
Alameda Gateway Limited is very near IR Site 28, whose groundwater
flow direction is well established and can be used to infer that of the
surrounding area. Figure 4 has been revised to show the approximate
8. location of the Alameda Gateway Limited site. The subject paragraph
ii. In the 4th paragraph: please add a citation or figure has been revised as follows to justify the statement, including a linked
of groundwater flow direction to justify the reference to Figure 4:
statement "The groundwater flow direction is likely
to the north, so it is not likely to impact the FOST “The one remaining open site is a petroleum site: Alameda Gateway
parcel." Limited, which is on the south shore of Oakland Inner Harbor, about
500 feet east of IR Site 28 and approximately 3,000 feet to the
northeast of the FOST Parcel (see Figure 4). The groundwater flow
direction is likely to the north (Battelle 2010b), so it is not likely to
impact the FOST Parcel.”
7


The last sentence of Section 6.1’s final paragraph has been revised as
iii. In the last paragraph of section 6.1 please add follows to provide the requested justification:
language justifying statement of no expected
impact on the FOST parcel, to mirror the previous “These two sites with eight USTs are not expected to impact the FOST
paragraphs (e.g. “This site is not expected to Parcel, because the Regional Water Board closed both sites without
impact the FOST parcel due to...”). restrictions or a requirement for further action, which implies a
finding of no off-site impacts.”
Section 6.2
The 3rd and 4th sentences of Section 6.2 have been expanded as
follows to provide the requested justification:
a. Please justify the statement of "The storm drain
corridors have been determined to not impact the FOST “Storm drain corridors in adjacent property have been investigated
Parcel." Either by citation or by explanation. under the CERCLA program and evaluated in conjunction with the IR
9. Sites with which they are associated. These evaluations do not
indicate that the storm drain corridors impact the FOST Parcel.”
The five Alameda Point sites at which the Navy evaluated
b. Please list all IR site investigate for PFAS in
PFOS/PFOA in groundwater are IR-4, IR-6, IR-14, IR-26, and OU-2C.
groundwater. e.g. “In 2016, the Navy sampled
The FOST does not identify these sites, because they are otherwise
groundwater at five separate IR sites (IR Sites X, X, X,
discussed only incidentally, at most. Please see the response to
X and X) at Alameda Point where PFAS...”.
Comment 6, above.
On page 17, please add a reference to Figure 4 in the
following sentences:
a. “IR Sites 6 and 4 are located west and southeast of
10. A linked reference to Figure 4 has been added as requested.
FOST Parcel, respectively.”
The two linked references to Figure 4 have been added to Sections
b. The 1st sentence of sections 6.2.1 and 6.2.2.
6.2.1 and 6.2.2 as requested.
11. Section 6.2.2
8


The final sentence of Section 6.2.2 has been revised as follows to
clarify why the OU-2B groundwater plume is not expected to impact
a. On page 17, please clarify if the mitigation measures
the FOST Parcel:
and ICs in OU-2B restricting groundwater use and land
use prevent the impact on the FOST Parcel.
“This site is not expected to impact the FOST Parcel, because it is
cross-gradient from the OU-2B groundwater plume.”
Section 6.2.3:
justify the expectation that IR Site 35 does not impact the FOST
a. On page 17, please added a justification to the last
Parcel:
12. sentence of the section to mirror previous sections (e.g.
“This site is not expected to impact the FOST parcel
“This site is not expected to impact the FOST Parcel, because no
due to...”).
known significant soil or groundwater contamination remains in IR
Site 35.”
Section 6.2.4:
a. On page 18, please make the following edit to the
second paragraph: “To date, the last project that use the
13.
apron was the IR site 17 Seaplane Lagoon The subject sentence has been revised to the suggested wording.
Remediation, this remediation and post-remediation
radiological surveys are discussed below”.
Section 6.2.5:
a. On page 19, Please added a justification to the last
justify the expectation that FL-155A does not impact the FOST Parcel:
14. sentence of the section to mirror previous sections (e.g.
“The residual TPH is not expected to impact the FOST
“This residual TPH is not expected to impact the FOST Parcel,
parcel due to...”)
because it is cross-gradient from the fuel line.”
Figures:
a. Figure 5
i. Please clearly label Building 544 Figure 5 has been revised as suggested to clearly label Building 544.
15.
ii. Please make CAA-B more prominent in the figure,
Figure 5 has been revised as suggested to make the labels for CAA-B
as it is the only CAA that is discussed in the
more prominent.
document
9


The locations of Trident Management and of Ralph Appezzato
Memorial Parkway are not within Figure 5’s view. Accordingly, Figure
b. Please provide a figure showing the locations of the
4 has been revised to indicate the Trident Management’s location
Trident Management site adjacent to IR site 17 and of
(1605 Ferry Point). Likewise, Ralph Appezzato Memorial Parkway,
the Ralph Appezzato Memorial Parkway adjacent to IR
which is the eastward, off-base extension of W. Atlantic Avenue, is
site 3, and reference where appropriate.
now labeled on Figure 4. Cites with links to Figure 4 have been
inserted into Section 6.1 at the first mention of each of these two sites.
c. Please provide a figure of the AOCs of IR Site 35 and Figure 4, which already shows IR Site 35’s AOCs, has been revised to
reference where appropriate. highlight and label AOC 23.

10


Comments from:
Regional Water Quality Control Board
Yemia Hashimoto, Project Manager
Comments received January 25 2017
On January 24, 2016 [2017], NFA was granted to FL- Because the Regional Water Board closed the portion of CAA-B South
71 and FL-23F East in CAA B South. This may affect within the FOST Parcel after the Draft FOST 3A was prepared, substantial
1.
text, tables and figures within the FOST regarding the revisions to Sections 4.2.1, 4.2.2, and 5.2 and Figures 5 and 6 have been
status of this now closed petroleum site. made. The closure letter has been appended to the FOST as Attachment 3.
2 We have no other comments on the FOST 3a. Comment noted.

11


Former NAS Alameda
Attachment 2: Hazardous Substances Notification Table

Former NAS Alameda

Former NAS Alameda
ATTACHMENT 2: HAZARDOUS SUBSTANCES NOTIFICATION TABLE
Finding of Suitability to Transfer Phase 3A - Former NAS Alameda
Date Stored
Quantity Stored, (S),
Stored, Released, Released
Reportable RCRA Released, or (R), or
Identification Media/ Hazardous Quantity CAS Waste or Disposed Disposed
a Description Substance b,c (lbs) b Number Code b Disposed d d (D) Action Taken e
Marsh Crust Sediment PAHs NA NA NA Unknown Unknown R A layer of sediment contaminated with PAHs and
referred to as the marsh crust was identified
during environmental investigations between
1993 and 2000. The marsh crust was deposited
across the Alameda Facility/Alameda Annex from
the late 1800s until the 1920s, and is believed to
have resulted from direct discharges of petroleum
products and wastes from former manufactured
gas plants and oil refineries to marshlands that
underlie the current uplands. The ROD selected
land use controls that prohibit excavation within
the marsh crust and former subtidal area, unless
proper precautions are taken to protect worker
health and safety and to ensure that excavated
material is disposed of properly. The property is
subject to a deed restriction, a Covenant to
Restrict Use of Property, and permitting
requirements for excavations in accordance with
the Alameda Marsh Crust Ordinance No. 2824.
Storm Drain Soil Radium 226 1 Curie NA NA Unknown Unknown R The 2016 ROD for OU-2C Drain Lines Located
Line G Outside of Buildings 5 and 10 identifies no
contaminant of concern (COC) for the FOST
Parcel’s portion of OU-2C (Storm Drain Line G).
Per the ROD, “sediment was removed from
within these storm drain lines and subsequent
video surveys, radiological surveys, and
sampling did not show any indication of
contamination associated with Storm Drain Lines
A, B, and G.” The 2016 ROD documents no
further action for Storm Drain Line G (Navy,
2016a).
Notes:
a No chemicals were found to have been stored, disposed, or released within other areas of the FOST Parcel.
b This table was prepared in accordance with 40 CFR 373 and 40 CFR 302.4. The substances which do not have chemical-specific break down (and associated annual reportable quantity) are not
listed in 40 CFR 302.4, and therefore have no corresponding CAS number, no regulatory synonyms, no RCRA waste numbers, and no reportable quantities. Hazardous substances listed in this
table were compiled based on known contamination at the sites and historic activities at specific locations.
Attachment 2, Draft Final FOST Phase 3A Page 1 of 2

Former NAS Alameda
ATTACHMENT 2: HAZARDOUS SUBSTANCES NOTIFICATION TABLE
Finding of Suitability to Transfer Phase 3A - Former NAS Alameda
c The FOST Parcel may contain pesticide residue from pesticides that have been applied in the management of the property. The Grantor knows of no use of any registered pesticide in a manner
inconsistent with its labeling and labeling and believes that all applications were made in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA - 7 U.S.C. Sec. 136, et
seq.), its implementing regulations, and according to the labeling provided with such substances. It is the Grantor’s position that it shall have no obligation under the covenants provided pursuant to
Section 120(h)(3)(A)(ii) of CERCLA, 42 U.S.C. Sections 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides.
d The quantity stored, released, or disposed, and the date stored, released, or disposed, is unknown because documentation related to storage, release, or disposal of these hazardous substances
was not available during records searches for the property.
e References listed in this section are included in FOST as part of Section 10.0, References.
CAS Chemical Abstract System lbs Pounds R Released

CFR Code of Federal Regulations NA Not available RCRA Resource Conservation and Recovery Act
CERCLA Comprehensive Environmental Response, NAS Naval Air Station Alameda ROD Record of decision
Compensation and Liability Act of 1980 Navy United States Department of the Navy S Stored
D Disposed OU Operable unit U.S.C. United States Code
FOST Finding of Suitability to Transfer OWS Oil-water separator
gal Gallon PAH Polycyclic aromatic hydrocarbon
Attachment 2, Draft Final FOST Phase 3A Page 2 of 2

Former NAS Alameda
Attachment 3: Regional Water Board NFA Letter for CAA B (1/24/17)

Former NAS Alameda

Former NAS Alameda
January 24, 2017 (YTH)
GeoTracker Global ID: T0600109975
NAVFAC HQ, BRAC PMO
Attn. Cecily Sabedra
BRAC Environmental Coordinator
33000 Nixie Way, Bldg 50
San Diego, California 92147
via email: cecily.sabedra@navy.com
Subject: No Further Action for Fuel Line (FL)-71 and FL-23F East in CAA B South,
Former Alameda Naval Air Station, Alameda County
Dear Ms. Sabedra:
This letter confirms that based on the available information, and with the provision that the
information provided is accurate and representative of site conditions, site investigation is
complete and no further action (NFA) is required for the former fuel pipelines located in
Corrective Action Area (CAA) B South, summarized below:
Site Name GeoTracker Case ID

FL-71 and FL-23F East in CAA T10000009981
B South
Basis and Assumptions

This NFA status applies only to releases of petroleum fuel and fuel constituents
associated with the site referenced above. While the information provided indicates that
the above-referenced fuel pipeline site is satisfactorily cleaned up to standards consistent
with residential land use, with restrictions on groundwater use, we may reconsider these
findings should new information be discovered regarding previously undetected
contamination.
This NFA is based on the assumption that shallow groundwater beneath the site is not
suitable for drinking water or other potential uses (such as landscape and garden
irrigation), contains residual hydrocarbons, and should not be used, extracted, or
discharged to surface water without further assessment and mitigation of potential risks.
In addition, residual petroleum hydrocarbons are anticipated to degrade over time.
Conditions/Requirements
Residual petroleum contamination remains in the groundwater at concentrations that do not

exceed non-drinking water standards for odor and nuisance; however, to ensure protection of
public health, safety, and the environment, and to be consistent with the land and groundwater
use assumptions above, the following conditions/requirements apply:
1. No shallow groundwater use: Shallow groundwater beneath the site should not be used
for drinking water or other potential uses as per the NFA assumptions above.
No Further Action for FL-71 and FL-23F East
Former Alameda Naval Air Station
2. Notify Regional Water Board – land/groundwater use change: The Regional Water
Board should be notified in writing of any proposed change in land or groundwater use at
the site.
3. Real estate property transfer disclosures: This document shall be included in any subject
site property real estate disclosure documentation, in perpetuity.
Land Use Controls/Covenants
Site-specific land use controls and covenants restricting shallow groundwater use are not
required for the reasons presented below that mitigate the likelihood of shallow groundwater use:
1. Agricultural and domestic water wells require a 20-foot and 50-foot sanitary seal,
respectively, thereby eliminating use of shallow groundwater for agricultural and drinking
water purposes.
2. Domestic water on Alameda Point is currently supplied by East Bay Municipal Utility
District, which is not anticipated to change.
3. Petroleum hydrocarbons present in site soil and shallow groundwater are expected to
naturally degrade over time.
4. Alameda County California Code of Ordinances, Title 6, Chapter 6.88 prohibits

the construction of any water well screened in aquifers producing saline,
contaminated or polluted water.
5. The City of Alameda Site Management Plan provides risk management

measures to be implemented prior to, during, and after site redevelopment.
6. The City of Alameda Ordinance No. 2824 (Marsh Crust Ordinance) restricts
disturbance of soil at the former Alameda NAS between depths of 5 to 15 feet
below ground surface due to potential elevated concentrations of semi-volatile
organic compounds (SVOCs). The restriction requires a City permit, approved
site-specific Health and Safety Plan, and special material handling procedures
whenever disturbing soil at these depths.
Closing
Attached please find the site closure summary. Please contact Yemia Hashimoto of my
staff at (510) 622-2756 or yemia.hashimoto@waterboards.ca.gov if you have any
questions regarding this matter.
Sincerely,
Bruce H. Wolfe
Executive Officer
Attachment: Site Closure Summary Form
Page 2 of 3
No Further Action for FL-71 and FL-23F East
Former Alameda Naval Air Station
cc: Mr. Adam Hill, adam.j.hill@navy.mil

Mr. David Darrow, david.c.darrow.ctr@navy.mil
Ms. Xuan-Mai Tran, tran.xuan-mai@epamail.epa.gov
Ms. Emily Mortazavi, emily.mortazavi@dtsc.ca.gov
Ms. Yemia Hashimoto, yemia.hashimoto@waterboards.ca.gov
Mr. David Elias, delias@waterboards.ca.gov
Mr. Peter Russell, peter@russellresources.com
Page 3 of 3
SITE CLOSURE SUMMARY
FL-71 and FL-23F East in CAA B South
Date: January 24, 2017
1. AGENCY INFORMATION
Agency Name: SF Bay Regional Water Quality Control Board Address: 1515 Clay Street, Suite 1400
City/State/Zip: Oakland, CA 94612 Phone: (510) 622-2300
Responsible Staff Person: Yemia Hashimoto, CHG Title: Engineering Geologist
Division: Groundwater Protection and Waste Containment Program: Dept. of Defense (DoD)
2. SITE AND FILE INFORMATION
Site Name: Alameda Naval Air Station, FL-71 and FL-23F East in CAA B South
Parent Military Base: Alameda Naval Air Station (NAS)
Site Address: 2450 Saratoga Street, Suite 200, Alameda, CA 94501
Site Latitude (decimal degrees): 37.780911348783 Longitude: -122.298795830689
Site Type: Military Cleanup
WB Case No.: 2199.9285 GeoTracker Case ID: T10000009981
WB File No.: 2199.9285 Paperless Office ID: T0600109975 (Alameda NAS Parent ID)
3. RESPONSIBLE PARTY:
Company/Agency: Department of the Navy, BRAC Program Management Office West

Contact Name: Ms. Cecily Sabedra
Contact Title: BRAC Environmental Coordinator
Street Address: 33000 Nixie Way, Bldg 50
City, State, Zip Code: San Diego, CA 92147
Tel. No.: (619) 524-4569
E-mail: cecily.sabedra@navy.mil
4. SITE DESCRIPTION, LAND USE, AND BENEFICIAL USE
Site Size and Description:

Corrective Action Area (CAA) B South is a 13-acre site located immediately north of Seaplane Lagoon (the nearest
surface water body), in the southern portion of Corrective Action Area (CAA) B (T10000001459) (Figure 1). CAA B
South consists of eleven fuel lines, two of which are FL-71 and FL-23F. FL-23F is further subdivided into an eastern
portion labeled FL-23F East. See Figure 2.
Former FL-71 was removed in September 1998. It was partially located in CAA-B South and partially located in CAA
B North. The portion in CAA-B south consisted of 728 linear feet of north to south trending steel fuel conveyance
pipe. The FL-23F East fuel conveyance steel pipeline was closed in place in August 1998. Fl-23F East consists of
the eastern parts of the 17,612 feet long FL-23F pipeline. This includes: approximately one 1,344 foot long west-east
pipeline, two 538 foot long west-east pipelines, nine 180 foot long north-south pipelines, and four 246 foot long
north-south lines, for a total of 5,024 feet of pipeline. See Figure 2.
The FL-71 and FL-23F East areas are currently covered by asphalt and concrete paved areas, which were formerly
used as an aircraft tarmac, fuel truck loading station and aircraft staging, maintenance, and sediments drying areas.
The inactive fuel lines present beneath the former tarmac were used to supply aviation fuel to Alameda NAS aircraft.
Vicinity: FL-71 and FL-23F East are located within CAA B South. They are north of Seaplane Lagoon and south of
West Tower Avenue and buildings 40 and 41. To the east is Ferry Point roadway. FL23F continues to the west into
CAA B South.
Site Plan Map Attached: Figure 1 – Site Location Map; Figure 2 – Site Plan;
Current Site Use(s): Commercial/industrial. Vacant.
Future Land Use(s): Commercial mixed use (includes residential)
Beneficial Uses: Alameda NAS lies within the East Bay Plain groundwater sub-basin (number 2-9.04) of the Santa
Clara Valley groundwater basin (Figure 2-10 of Basin Plan). The existing and potential beneficial uses for
groundwater include industrial process, industrial service, agricultural water supply, municipal and domestic supply
(Table 2-2 of Basin Plan). Note that municipal and domestic supply beneficial uses are unlikely to be utilized as
described in the shallow groundwater beneficial use exception to drinking water policy request discussed in the next
section. The existing and potential beneficial uses for the Lower San Francisco Bay surface water include industrial
service supply; ocean, commercial, and sport fishing; shellfish harvesting; estuarine habitat; fish migration;
preservation of rare and endangered species; fish spawning; wildlife habitat; contact and noncontact water
recreation; and navigation (Table 2-1 of Basin Plan).
Exceptions to Drinking Water Policy: In response to the Navy’s February, July, and August, 2012, exception to
drinking water policy request packages, on September 13, 2012, Regional Water Board staff issued a
concurrence letter indicating that groundwater in the water bearing zones between the ground surface and the
Yerba Buena Mud Aquitard (about 70 to 79 feet bgs) within the Southeast Portion of Alameda NAS meets
exception criteria included in the SWRCB Resolution 88-63 and Regional Water Board Resolution No. 89-39,
“Sources of Drinking Water. “ Only a small southeastern portion of Fl-23F East is located within the area that
meets the exception criteria, but the majority of the site has been formally designated as meeting the
requirements for an exception to the drinking water policy.
5. RELEASE INFORMATION
Source Capacity or Contents How Date Latitude (decimal Longitude (decimal

dimensions Closed? degrees) degrees)
FL-71 6-inch, 728 Jet fuel Removed 9/14/1998 37.7816756130514 -122.298305212067

feet length
FL-23F 4-inch to 6 Jet fuel In-place 8/17/1998 37.7807937349829 -122.299120603608

East inch 5,024
feet length
Page 2 of 8
6. SITE CHARACTERIZATION AND CONCEPTUAL SITE MODEL
Cause and description of release There are no known releases from FL-71 in CAA B South, nor from FL-23F East.
Based on the soil and groundwater samples from investigations collected near FL-71 and FL-23F, historically in
1995, 1998, 2000, and 2016, there is no indication of a significant release from FL-71 and FL-23F East. However,
groundwater concentrations in samples collected during the 2016 investigation did contain residual petroleum
hydrocarbons, PAHs, and lead. The concentrations of TPHd did not exceed non-drinking water odor nuisance ESLs,
and lead concentrations do not exceed saltwater ecotox aquatic habitat ESLs. PAHs were flagged as estimates at
concentrations above the Tier 1 ESLs in three samples, and at reporting limits exceeded the Tier 1 ESLs in 61
samples.
Groundwater (GW) Depth to first GW: Between about 2 to 4 feet below ground surface (bgs).
GW gradient direction: south
GW sampled?: Yes
GW monitoring GW monitoring wells installed?: No

wells
Total number of monitoring wells used in support of closure decision: None
Status of MWs: No groundwater monitoring wells
7. CLEANUP STANDARDS AND SITE REMEDIATION
Describe basis for cleanup standards: Soil: residential ESLs; groundwater: non-drinking water odor nuisance level
ESLs. Typically, samples are compared to residential criteria, even for sites not expected to be developed for
residential use, because sites meeting residential closure can be closed without restrictions.
Describe risk-based approach to develop cleanup standards: The screening criteria are presented in the
September 2009 Final Technical Memorandum, Update to Preliminary Remediation Criteria and Closure Strategy for
Petroleum-Contaminated Sites, Petroleum Program at Alameda Point, Alameda, California (Battelle, 2009) and
updated in the Technical Memorandum Regarding Second Update to the Petroleum Strategy, Alameda Point
(Former Alameda Naval Air Station) (Regional Water Board, November 20, 2015). The criteria include the ESLs (risk-
based and non-risk-based criteria) and background screening strategy for PAHs. Carcinogenic PAHs in soil are
screened using a screening value of 0.62 mg/kg for benzo(a)pyrene (BaP) equivalents as compared to the 95%
UCL of the average, with a not-to-exceed concentration of 1 mg/kg.. The ESLs are used for evaluating residual
concentrations against criteria consistent with the future land use and for evaluating discharge to the bay (marine
ecological receptor) with attenuation factors based on distance from the shoreline.
Describe remediation efforts for soil and groundwater: FL – 71 was removed in 1998 and FL-23F East was
closed in place in 1998.
Page 3 of 8
8. CLOSURE CRITERIA CHECKLIST (include comments as necessary)
1a Pollutant sources are identified and evaluated
√ Leak/spill sources (tanks, sumps, pipelines, etc.) are identified and controlled
√ The pollutant source zone (sorbed/entrained residual pollutants and free product that
sustain groundwater & vapor plumes) is identified and delineated
Comments: Yes. FL-71 was removed and FL-23F East was closed in place. Investigations of soil and
groundwater were conducted at the pipelines in 1995, 1998, 2000, and 2016. No significant release of
petroleum is present, although residual petroleum and lead is present in groundwater.
1b The site is adequately characterized
√ Site history, hydrology, and hydrogeology are characterized
√ The nature & extent (lateral and vertical) of pollutants are characterized in soil,
groundwater & soil gas, as necessary
Comments: Yes, soil and groundwater investigations were conducted in 1995, 1998, 2000, and 2016. At
least 58 soil samples and 67 groundwater samples were collected. Soil and groundwater samples were
analyzed for total petroleum hydrocarbons (TPH) as diesel, as gasoline, as jet fuel and as motor oil,
lead, benzene, ethylbenzene, toluene, xylenes, MTBE, 1,2-dichloroethane and PAHs.
Soil: Residual petroleum hydrocarbons and PAHs in soil exceeded the residential ESLs for historical soil
samples collected in 1995 and 1998. The 47 soil samples collected in 2016 did not have Tier 1
residential ESL exceedances for TPH constituents or PAH. PAH concentrations were also not co-
located with petroleum hydrocarbons. The imported soils used to fill wetlands and create Alameda Point
included sediments dredged from San Francisco Bay that contained PAHs. Therefore, many soil
samples collected from Alameda Point contain PAHs at concentrations exceeding background and are
not associated with the subject petroleum site investigation. PAHs that are not attributable to a specific
point source are referred to as “ambient.” The elevated PAH concentrations at this site are likely
associated with ambient conditions at Alameda Point. Soil samples with detections of petroleum
collected in 2016 have soil concentrations less than those collected from neighboring sample locations
collected in 1995 and 1998, which may indicate natural degradation of petroleum hydrocarbons.
Groundwater: Historical groundwater samples analyzed for BTEX compounds, TPHg and TPHd have had ESL
exceedances, but 2016 samples were nondetect or were detected at concentrations below the appropriate
residential non-drinking water ESLs. PAHs were flagged as estimates at concentrations above the Tier 1
ESLs in three samples, and at reporting limits exceeded the Tier 1 ESLs in 61 samples. Although there is
no screening value specific to Alameda Point for PAHs in groundwater, there is for PAHs in soil. Alameda
Point used imported soils that contain PAHs at concentrations exceeding background and are often not
associated with subject petroleum site investigation, as stated above, and this may contribute to detections
of PAHs in groundwater.
1c Exposure pathways, receptors, and potential risks, threats, and other environmental concerns
are identified and assessed
√ Nearby receptors (wetlands, streams, wells, homes, schools, businesses, etc.) are
identified
√ Groundwater & vapor migration/exposure pathways, natural & artificial (storm drains,
sewer lines, buried channels, abandoned wells, etc.) are assessed
Page 4 of 8
√ Reasonably anticipated land and water use scenarios have been considered
√ Actual and potential risks to receptors and adverse effects to beneficial uses are assessed
Comments: Yes.
2a Pollutant sources are remediated to the extent feasible
√ The technical and economic feasibility of source remediation methods/technologies have

been evaluated
√ Feasible source remediation technologies have been implemented
√ Appropriate source remediation performance monitoring has been conducted
√ Source mass removal has been documented
√ The effects of source remediation on groundwater/vapor plume behavior have been

evaluated
Comments: Yes.
2b Unacceptable risks to human health, ecological health, and sensitive receptors, considering
current and future land and water uses, are mitigated
√ Necessary & appropriate corrective actions have been implemented
√ Confirmation sampling, monitoring, and/or risk management measures demonstrate that

risks are mitigated
Comments: Yes.
2c Unacceptable threats to groundwater and surface water resources, considering existing and
potential beneficial uses, are mitigated
√ Necessary & appropriate corrective actions have been implemented
√ Confirmation sampling, monitoring, and/or risk management measures demonstrate that

threats are mitigated
Comments: Yes.
1
3a Groundwater plumes are stable or decreasing
√ Appropriate plume monitoring has confirmed the lateral and vertical extent over time
√ Spatial and temporal trends for pollutants, including parent and breakdown products, have
been evaluated
√ Spatial and temporal trends for natural attenuation indicators have been evaluated
√ Evidence of breakdown to acceptable end products is documented
√ Plume concentrations are decreasing and the plume is not moving or expanding
Comments: Yes. Based on groundwater samples collected from temporary data points from historical
(1995, 1998, 2000), and recent (2016) investigations, the affected groundwater is delineated and is
Page 5 of 8
stable. Current groundwater concentrations are less than the distance-adjusted aquatic salt water ecotox
ESL criterion.
3b Cleanup standards have been met or can be met in a reasonable timeframe
√ The estimated timeframe to achieve cleanup standards throughout the affected area is
evaluated
√ The anticipated timeframe for beneficial use of the affected and nearby water resources is
evaluated
√ The potential to adversely affect beneficial uses is assessed considering cleanup and
beneficial use timeframes, hydrogeologic conditions, and the CSM
Comments: Yes. The potential to affect nearby surface water resources is evaluated. The residual
petroleum hydrocarbon concentrations present in site soil do not exceed residential non-drinking water
ESLs and are expected to continue to naturally degrade over time. The residual hydrocarbons and lead
in groundwater are below the aquatic salt water ecotox ESLs.
3c Risk management measures are appropriate, documented, and do not require future Water
Board oversight
√ Necessary risk management measures (land use restrictions, engineered vapor barriers,
soil management plans, etc.) are implemented and documented
√ Risk management measures do not require future Water Board oversight
Comments: The City of Alameda ordinance 2824 (Marsh Crust Ordinance) restricts disturbance of soil at the
former Alameda NAS between depths of 5 to 15 feet bgs due to potential elevated concentrations of
semivolatile organic compounds (e.g., PAHs). In the vicinity of this site, the threshold depth applies to
an excavation deeper than five feet.
9. NFA BASIS AND ASSUMPTIONS
This NFA status applies only to releases of petroleum fuel and fuel constituents associated with the site
referenced above. While the information provided indicates that the above-referenced fuel pipeline site is
satisfactorily cleaned up to standards consistent with residential land use, we may reconsider these findings
should new information be discovered regarding previously undetected contamination.
This NFA is based on the assumption that shallow groundwater beneath the site is not suitable for drinking
water or other potential uses (such as landscape and garden irrigation), contains residual hydrocarbons,
and should not be used, extracted, or discharged to surface water without further assessment and
mitigation of potential risks. In addition, residual petroleum hydrocarbons are anticipated to degrade over
time.
Page 6 of 8
10a. NFA CONDITIONS AND REQUIREMENTS
Residual petroleum contamination remains in groundwater at concentrations that do not exceed non-drinking
water standards for odor and nuisance; however, to ensure protection of public health, safety, and
the environment, and to be consistent with the land and groundwater use assumptions above, the following
conditions/requirements apply:
1. No shallow groundwater use: Shallow groundwater beneath the site should not be used for drinking water
or other potential uses as per the NFA assumptions above.
2. Notify Regional Water Board – land/groundwater use change: The Regional Water Board should be
notified in writing of any proposed change in land or groundwater use at the site.
3. Real estate property transfer disclosures: This document shall be included in any subject site
property real estate disclosure documentation, in perpetuity.
10b. LAND USE CONTROLS/COVENANTS

Site-specific land use controls and covenants restricting shallow groundwater use are not required for the reasons
presented below that mitigate the likelihood of shallow groundwater use:
1. Agricultural and domestic water wells require a 20-foot and 50-foot sanitary seal, respectively, thereby
eliminating use of shallow groundwater for agricultural and drinking water purposes.
2. Domestic water on Alameda Point is currently supplied by East Bay Municipal Utility District, which is not
anticipated to change.
3. Petroleum hydrocarbons present in site soil and shallow groundwater are expected to naturally degrade
over time.
4. Alameda County Code or Ordinances, Title 6, Chapter 6.88, prohibits the construction of any water well
screened in aquifers producing saline, contaminated, or polluted water.
5. The City of Alameda Site Management Plan provides risk management measures to be implemented
prior, during, and after site redevelopment.
6. The City of Alameda Ordinance No. 2824 (Marsh Crust Ordinance) restricts disturbance of soil
at the former Alameda NAS between depths of 5 to 15 below ground surface due to potential
elevated concentrations of semi-volatile organic compounds (SVOCs). The restriction requires a
City permit, approved site-specific Health and Safety Plan, and special material handling
procedures whenever disturbing soil at these depths.
11. ADDITIONAL COMMENTS
None.
12. TECHNICAL REPORTS, CORRESPONDENCE, ETC., THAT THIS CLOSURE RECOMMENDATION WAS
BASED UPON
REPORTS ON FILE Where is report(s) filed?: Paperless Office (Place Number T10000001435)
Final Technical Memorandum, Update to Preliminary Remediation Criteria and Closure September 2009
Strategy for Petroleum-Contaminated Sites, Petroleum Program at Alameda Point,
Alameda, California. Battelle.
Concurrence with Request for Beneficial Use Exception for Shallow Groundwater at September 13, 2012
Southeast Portion of the Former Naval Air Station, Alameda Point, Alameda County. CA
Regional Water Quality Control Board, San Francisco Bay.
Page 7 of 8
San Francisco Bay Basin (Region 2) Water Quality Control Plan (Basin Plan). California June 29, 2013
Regional Water Quality Control Board, San Francisco Bay Region.
Technical Memorandum Regarding Second Update to the Petroleum Strategy, Alameda November 20, 2015
Point (Former Alameda Naval Air Station), Regional Water Quality Control Board, San
Francisco Bay.
Data Gaps Investigation Summary Report Petroleum Site CAA-B South Former Alameda July 21, 2016
Naval Air Station, Alameda Point, Alameda, California. Langan Treadwell Rollo.
Attachments: Figure 1 (Site Location Map), Figure 2 (Site Plan),
Notes and Abbreviations (in alphabetical order):

bgs – Below ground surface.
ESL – Environmental screening level (San Francisco Bay Regional Water Quality Control Board,
Environmental Screening Levels, 2016), as agreed per the November 20, 2015 Draft Technical
Memorandum Regarding Second Update to the Petroleum Strategy, Alameda Point (Former Alameda
Naval Air Station).
mg/kg – milligrams per kilogram, or parts per million.
NFA – No further action (aka closure).
PAHs – Polycyclic aromatic hydrocarbons.
SWRCB – State Water Resources Control Board.
TPH – Total Petroleum Hydrocarbons.
TPHd – TPH as diesel
Page 8 of 8
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2. Data displayed is based on figures provided by Clarson, Barbee & Gibson Inc.;
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% 3. Development plan basemap provided by BAR Architects dated 2/23/2015.
% 4. Aerial imagery provided through Langan’s subscription to Nearmap.com. Aerial
imagery flown on February 1, 2016.
5. Map displayed in California State Plane Coordinate System, Zone III, North American
Datum of 1983 (NAD83), US Survey Feet.
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ALAMEDA POINT - SITE A
Alameda, California
CAA-B SOUTH
SITE PLAN
Seaplane
Lagoon Date 7/20/2016 Project 731652101 Figure 2
%ORFN

Nathaniel Pyron Naval Station Alameda Asset Evaluation Research Document

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N00236_004516

Department of the Navy

Draft Final FOST Phase 3A i

Draft Final FOST Phase 3A ii

Draft Final FOST Phase 3A iii

Draft Final FOST Phase 3A iv

BCT BRAC Cleanup Team

CAA Petroleum Program Corrective Action Area

DERP Defense Environmental Restoration Program

EBS environmental baseline survey

FFA Federal Facility Agreement

G-RAM general radioactive material

LBP lead-based paint

mg/kg milligrams per kilogram

Draft Final FOST Phase 3A v

PAH polycyclic aromatic hydrocarbons

U.S. EPA United States Environmental Protection Agency

Draft Final FOST Phase 3A vi

2.0 Property Description

Draft Final FOST Phase 3A 1

3.0 Regulatory Coordination

Draft Final FOST Phase 3A 2

3.2 Resource Conservation and Recovery Act Subtitle I Corrective

Draft Final FOST Phase 3A 3

3.3 Comprehensive Environmental Response, Compensation, and

4.0 Summary of Environmental Conditions and Notifications

Draft Final FOST Phase 3A 4

4.1 CERCLA Program

Draft Final FOST Phase 3A 5

4.1.1 Storm-Drain Line G (OU-2C)

4.1.2 AOC 23 (IR Site 35)

Draft Final FOST Phase 3A 6

4.2 Petroleum Products and Derivatives

4.2.1 Open Petroleum Program Sites

4.2.2 Closed Petroleum Program Sites

Draft Final FOST Phase 3A 7

4.3 Asbestos-Containing Material

4.4 Lead-Based Paint

Draft Final FOST Phase 3A 8

As a condition of property transfer, the transferee(s) will be required to acknowledge receipt of

4.5 Polychlorinated Biphenyls

Draft Final FOST Phase 3A 9

4.7 Radiological Program

Draft Final FOST Phase 3A 10

4.7.2 General Radioactive Material

Draft Final FOST Phase 3A 11

4.9 Other Areas Investigated/Issues

5.0 Summary of Restrictions

Draft Final FOST Phase 3A 12

5.1.1 Marsh Crust

5.2 Petroleum Products and Derivatives

Draft Final FOST Phase 3A 13

5.4 Lead-Based Paint

6.0 Adjacent Properties

Draft Final FOST Phase 3A 14

Draft Final FOST Phase 3A 15

6.2 Former NAS Alameda Adjacent Property

6.2.1 IR Site 6 (OU-1)

Draft Final FOST Phase 3A 16

6.2.4 Radiological Sites

Draft Final FOST Phase 3A 17

6.2.5 Petroleum Sites

Draft Final FOST Phase 3A 18

7.0 Access Clause