FINDING OF SUITABILITY FOR EARLY TRANSFER (FOSET

Transcription

FINDING OF SUITABILITY FOR EARLY TRANSFER
(FOSET)
RIVERBANK ARMY AMMUNITION PLANT
RIVERBANK, CALIFORNIA
Remainder Parcel A and Evaporation/Percolation Ponds
January 2010
CONTENTS
1.0 INTRODUCTION..............................................................................................................6 1.1 1.2 Responsibility for Remedial and Corrective Actions, and Land Use Controls 7 Response Action Schedule .....................................................................................7 2.0 PROPERTY DESCRIPTION ...........................................................................................8 3.0 ENVIRONMENTAL DOCUMENTATION ...................................................................8 4.0 ENVIRONMENTAL CONDITION OF PROPERTY ...................................................8 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11 Environmental Condition of Property Categories ..............................................8 Environmental Remediation Sites ........................................................................9 4.2.1 Groundwater Contamination (RBAAP-03) .............................................9 4.2.2 Landfill (RBAAP-01; SWMUs 10 and 11) .............................................10 4.2.3 Industrial Wastewater Treatment Plant (SWMU 1) ............................11 Storage, Release, and Disposal of Hazardous Substances ................................12 Petroleum and Petroleum Products ...................................................................12 4.4.1. Underground Storage Tanks (USTs) and Above-Ground Storage
Tanks (ASTs) ........................................................................................................12 4.4.2. Non-UST/AST Storage, Release, or Disposal of Petroleum Products ..13 Polychlorinated Biphenyls ..................................................................................13 Asbestos-Containing Materials ...........................................................................13 Lead and Lead-Based Paint (LBP).....................................................................14 Radioactive Material ...........................................................................................14 Radon ....................................................................................................................14 Munitions and Explosives of Concern (MEC) ..................................................14 Other Identified Concerns ..................................................................................15 5.0 ADJACENT PROPERTY CONDITIONS ....................................................................15 6.0 ENVIRONMENTAL REMEDIATION AGREEMENTS ...........................................16 7.0 REGULATORY/PUBLIC COORDINATION AND COMMENTS...........................16 8.0 NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE ...........17 9.0 ENVIRONMENTAL PROTECTION PROVISIONS .................................................17 10.0 STATE LAND USE CONTROLS ..................................................................................17 11.0 DEFERRED WARRANTY.............................................................................................18 12.0 FINDING OF SUITABILITY FOR EARLY TRANSFER .........................................19 ii
CONTENTS (continued)
Figures
1
2
3
4
5
6
7
8
9
Vicinity Map
Parcel Map
IRP Sites, SWMUs, and AOCs
Well Locations
Above Ground Storage Tanks
Under Ground Storage Tanks
Property Categorization Map
Land Use Restrictions
Groundwater Use Restrictions
Plate 1:
RBAAP A/A’ Aquifer Zone Groundwater Elevation Contours with Third Quarter
2009 Chromium and Cyanide Concentrations
Plate 2:
RBAAP B Aquifer Zone Groundwater Elevation Contours with Third Quarter 2009
Chromium and Cyanide Concentrations
Plate 3:
RBAAP C Aquifer Zone Groundwater Elevation Contours with Third Quarter 2009
ENCLOSURES
Enclosure 1 – Environmental Documentation
Enclosure 2 – Figures
Enclosure 3 – Table 1 – Environmental Conditions of the Property
Enclosure 4 – Table 2 – Notification of Hazardous Substance Storage, Release, or Disposal
Enclosure 5 – Table 3 – Notification of Petroleum Product Storage, Release, or Disposal
Enclosure 6 – Table 4 – PCB and PCB-Contaminated Transformers
Enclosure 7 – CERCLA Notice, Covenant, Access Provisions and Deed Restrictions
Enclosure 8 – Environmental Protection Provisions
Enclosure 9 – Public Notice
Enclosure 10 – Responsiveness Summary
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ACRONYMS
µg/L
ACM
AOC
AST
bgs
BRAC
CACA
CERCLA
CERFA
CFR
cy
DMM
DoD
DTSC
EBS
ECP
E/P
EPA
EPP
ESD
FOSET
FOST
Gpm
GWTP
IPRG
IRP
IWTP
LBP
LUC
MCL
MEC
mg/kg
mg/L
MMRP
NPDES
NPL
PBA
PCB
Micrograms per liter
Asbestos containing material
Area of Concern
Aboveground storage tank
Below ground surface
Base Realignment and Closure
Corrective Action Consent Agreement
Comprehensive Environmental Response, Compensation and Liability Act
Community Environmental Response Facilitation Act
Code of Federal Regulation
cubic yards
Discarded Military Munitions
Department of Defense
Department of Toxic Substances Control
Environmental Baseline Survey
Environmental Condition of Property
Evaporation/Percolation
U.S. Environmental Protection Agency
Environmental Protection Provision
Explanation of Significant Differences
Finding of Suitability for Early Transfer
Finding of Suitability for Transfer
Gallons per minute
Groundwater Treatment Plant
Industrial Preliminary Remediation Goals
Installation Restoration Program
Industrial Wastewater Treatment Plant
Lead based paint
Land use control
Maximum Contaminant Level
Munitions and explosives of concern
Milligrams per kilogram
Milligrams per liter
Military Munitions Response Program
National Pollution Discharge Elimination System
National Priorities List
Performance Based Acquisition
Polychlorinated biphenyl
iv
Acronyms (continued)
pCi/L
POTW
ppm
ppb
PRG
RBAAP
RCRA
RI
RLRA
ROD
RLRA
SI
SVOC
SWMU
TSCA
USACE
UST
UXO
VOC
WDR
Picocuries per liter
Publicly Owned Treatment Works
parts per million
parts per billion
Preliminary Remediation Goal
Riverbank Army Ammunition Plant
Resource Conservation and Recovery Act
Remedial Investigation
Riverbank Local Redevelopment Authority
Record of Decision
Riverbank Local Redevelopment Authority
Site Investigation
Semi-volatile organic compound
Solid Waste Management Unit
Toxic Substances Control Act
U.S. Army Corps of Engineers
Underground storage tank
Unexploded ordinance
Volatile organic compound
Waste Discharge Requirements
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FINDING OF SUITABILITY FOR EARLY TRANSFER (FOSET)
RIVERBANK ARMY AMMUNITION PLANT
Remainder Parcel A and
Evaporation/Percolation Ponds
January 2010
1.0
INTRODUCTION
The purpose of this Finding of Suitability for Early Transfer (FOSET) is to document the
environmental suitability of certain parcels at the Riverbank Army Ammunition Plant
(hereinafter referred to as the “Property”) for early transfer consistent with the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 120(h)(3)(C).
CERCLA Section 120(h)(3) requires the United States to provide a covenant in the deed
conveying the property warranting that all remedial action necessary to protect human health and
the environment has been taken prior to the date of transfer. For a Federal facility listed on the
U.S. Environmental Protection Agency (EPA) National Priorities List (NPL), CERCLA Section
120(h)(3)(C) allows the EPA Administrator, with the concurrence of the Governor of the State,
to defer the CERCLA covenant requirement. These types of transfers under CERCLA Section
120(h)(3)(C) are typically called “Early Transfers,” in which the United States will provide the
warranty after transfer of the property when all the response actions necessary to protect human
health and the environment have been taken. The period between the transfer of title and
delivery of this final warranty is known as the “deferral period.” The intent of the Early Transfer
is to facilitate efforts to stimulate the economy through productive reuse of the property while
final remediation work is conducted.
The EPA Administrator, with the concurrence of the Governor of the State in which the property
is located, may defer the CERCLA warranty requirement if they determine that the property is
suitable for transfer on the basis of the following findings:
1) The property is suitable for transfer for the use intended by the transferee, and the
intended use is consistent with protection of human health and the environment;
2) The deed or other agreements proposed to govern the transfer between the United States
and the recipient of the property contains the assurances set forth in CERCLA Section
120(h)(3)(C)(ii), including: (1) the protection of human health and the environment;
(2) no disruption of any pending or ongoing response actions or corrective actions, or
oversight activities; (3) provision for schedules for investigation and completion of
response actions; and (4) the use of covenants/restrictions, as specified in the attached
CERCLA Notice, Covenant, Access Provisions and Deed Restrictions (Enclosure 7), the
attached Environmental Protection Provisions (EPPs) (Enclosure 8), and the State Land
Use Controls (SLUCs) necessary to protect human health and the environment after the
Early Transfer, and to prevent interference with any existing or planned environmental
restoration activities;
3) The Federal agency requesting the deferral has provided notice, by publication in a
newspaper of general circulation in the vicinity of the property, of the proposed transfer
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and of the opportunity for the public to submit, within a period of no less than 30 days
after the date of the notice, written comments on the suitability of the property for
transfer;
4) The deferral and transfer of the property will not substantially delay any necessary
response actions at the property.
In addition, the Department of Defense (DoD) and United States Department of Army (Army)
policy requires that the Military Department proposing to transfer property prepare a FOSET.
This FOSET will be submitted as part of the Covenant Deferral Request, in which the Army will
seek approval by the EPA Administrator and concurrence by the Governor of the State
California.
1.1
Responsibility for Remedial and Corrective Actions, and Land Use Controls
The Army will complete all necessary remediation of the Property, including remediation of
contaminated groundwater, groundwater monitoring, and long-term monitoring of the landfill
cap. Operation of the groundwater treatment system or other approved alternative approach will
continue until the remedial goals described in the Record of Decision (U.S. Army Environmental
Center (USAEC), 1994) are attained. An Explanation of Significant Difference (ESD) is
currently being written to implement in-situ treatment of the groundwater plume. The Army will
also continue to evaluate optimization actions for the monitoring program along with long-term
maintenance of the landfill cap for the life of the permit requirements.
To protect human health and/or the environment after the Early Transfer and to prevent
interference with any existing or planned environmental restoration activities, the Riverbank
Local Redevelopment Authority (RLRA) will be required to implement Land Use Controls
(LUCs) in accordance with the reuse covenants and restrictions specified in the CERCLA
Notice, Covenant, Access Provisions and Deed Restrictions (Enclosure 7); the EPPs (Enclosure
8); and the SLUCs. These LUCs will be in effect until the provisions in the deeds and SLUCs
are either terminated, removed, or modified, as specified in an appropriate CERCLA decision
document, and protectiveness of human health and the environment can be assured by the
modified LUCs or additional LUCs, if necessary
1.2
Response Action Schedule
The Riverbank Army Ammunition Plant (RBAAP) is on the NPL. As required under CERCLA
Section 120, the Army, the EPA Region 9, the California Department of Toxic Substances
(DTSC), and the Central Valley Regional Water Quality Control Board (Central Valley Water
Board) entered into a Federal Facility Agreement (FFA), which became effective June 1990. All
necessary response actions will be taken in accordance with the schedule provided in the FFA.
This schedule will not substantially delay any necessary response actions at the property.
Changes to the schedule may occur as a result of such things as additional sampling requirements
that have not been identified; discovery of additional contamination on the property;
unanticipated conditions during field efforts; and additional review and revision of
documentation such as reports, work plans, designs, etc. Such changes to the schedule will be
made in accordance with the FFA.
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2.0
PROPERTY DESCRIPTION
The RBAAP is located at 5300 Claus Road, Riverbank, Stanislaus County, California, one mile
south of the Stanislaus-San Joaquin County border and approximately five miles northeast of the
city of Modesto (Enclosure 2, Figure 1). The RBAAP occupies a total of 173 acres of land and
consists of two noncontiguous areas represented by the main plant area (approximately 146
acres) and the evaporation/percolation (E/P) ponds (28.8 acres). In general, the plant production
area is mostly paved and consists of one active manufacturing line, areas containing laid away
equipment, process water/groundwater treatment facilities and various buildings used for
maintenance, leased industrial operations, administration, and storage.
The Property for Early Transfer consists of the E/P ponds (28.8 acres) and Remainder Parcel A,
described below (approximately 76.2 acres). The four E/P ponds are approximately 1.5 miles
north of the RBAAP boundary along the Stanislaus River and receive treated water from the
industrial wastewater treatment plant (IWTP) and the groundwater treatment plant (GWTP). The
effluent is discharged to the bermed ponds and evaporates or percolates through the existing
sediments to groundwater. Of the 146 acres of the main plant area, Reminder Parcel A
constitutes approximately 76.2 acres at the center of the installation that is comprised primarily
of the manufacturing area, the landfill, and IWTP (Enclosure 2, Figure 2).
3.0
ENVIRONMENTAL DOCUMENTATION
A determination of the environmental condition of the Property was made based upon the U.S.
Army BRAC 2005, Environmental Condition of Property Phase I Report, Riverbank Army
Ammunition Plant, Riverbank, CA, Final, 17 November 2006 (hereinafter referred to as the “ECP
Report”) and the Final Site Investigation Report, Riverbank Army Ammunition Plant, March
2008. The information provided is a result of a complete search of agency files during the
development of these environmental surveys. These documents delineate all environmental
conditions and remedial decisions for RBAAP.
A complete list of documents providing information on environmental conditions of the Property
is compiled in Enclosure 1.
4.0
ENVIRONMENTAL CONDITION OF PROPERTY
The following sections summarize the environmental investigations and remedial actions
completed to date at RBAAP.
4.1
Environmental Condition of Property Categories
The ECP Report identified ECP Categories for the Property. Since that time, subsequent
environmental investigations have been completed, including the Site Investigation (SI) Report
(CH2M HILL, 2008). As a result, some of the ECP Categories have been updated. A summary
of the current ECP Categories for specific areas, or operable units, and the ECP Category
definitions is provided in Table 1 – Environmental Condition of the Property (Enclosure 3 and
Figure 7).
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4.2
Environmental Remediation Sites
There are seven remediation sites located on the Property. A summary of the environmental
remediation sites on the Property is as follows:
•
•
•
•
•
•
•
Groundwater Contamination (RBAAP-03)
Landfill (RBAAP-01; SWMUs 10 and 11)
Industrial Wastewater Treatment Plant (SWMU 1)
Southeast Storm Reservoir (RBAAP-08/SWMU 21/AOC 16):
E/P Ponds (RBAAP-11/SWMU 23):
Horizontal ASTs – Transformer Oil Storage Tanks (including Transformer Oil
Distribution System) (AOC 8B)
Draw Lube System (Building 178) (AOC 13)
All environmental sites are located on Remainder Parcel A with the exception of the E/P Ponds
(RBAAP-11/SWMU 23), which are located on the E/P Ponds parcel.
All environmental remediation activities at the landfill, the Southeast Storm Reservoir, the E/P
Ponds, the Horizontal ASTs, and the Draw Lube System have been completed. The Property
was not remediated to levels suitable for unrestricted use. The deed will include the following
land use restrictions: no use of groundwater, no residential use, and no soil disturbance of the
landfill cap.
Remediation activities are ongoing for the groundwater contamination (See Section 4.2.1).
Long-term maintenance is ongoing at the landfill (see Section 4.2.2). Further investigation is
required at the Industrial Wastewater Treatment Plant (see Section 4.2.3).
A complete summary of the environmental investigation and remediation sites is provided in
Table 2 –Notification of Hazardous Substance Storage, Release, or Disposal (Enclosure 4).
4.2.1 Groundwater Contamination (RBAAP-03)
The IRP Site RBAAP-03 contains chromium and cyanide groundwater contamination resulting
from leakage associated with the original IWTP. The original IWTP at RBAAP was constructed
to treat the wastewaters generated from the electroplating, cleaning, and metal finishing
processes that are operated on-site. The original storage and equalization tanks used for the
IWTP were made of redwood, which would occasionally leak. From 1973 to 1980, the IWTP
was upgraded and the redwood tanks were replaced with concrete tanks. The upgraded IWTP,
identified as SWMU 1, continues to operate under a RCRA Part B Permit 05-SAC-06.
In 1985, groundwater samples from six wells located west of the RBAAP showed levels of
chromium in excess of the Maximum Contaminant Level (MCL) of 50 micrograms per liter
(μg/L). As a result, the Army installed an interim groundwater treatment system (GWTS) and
provided bottled drinking water to those affected residents followed by the extension of the
Riverbank city water system to all potentially affected residents. The original IWTP redwood
tank area was identified as the major source of chromium contamination. The EPA added the
RBAAP to the NPL on Feb. 21, 1990, primarily due to the presence of groundwater
contamination (cyanide and chromium) detected on and off-post.
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The groundwater contamination was included in the site-wide ROD (USAEC, 1994). The ROD
required expansion of the interim GWTS to fully capture groundwater contamination. The
expanded system began operation in 1997 and is now capturing all contaminated groundwater
and removing contamination from the extracted water by means of ion exchange. The cleanup
goals for chromium and cyanide are 50 μg/L and 200 μg/L, respectively. The treated
groundwater is discharged to the E/P Ponds.
Groundwater monitoring consists of four sampling events per year; two quarterly, one
semiannual and one annual which include specific sets of wells completed in the various A', A,
B, C and D portions of the aquifer. The locations of the monitoring wells is shown in Enclosure
2, Figure 4. The results of the groundwater sampling from the third quarter of 2009 are shown
on Plates 1, 2, and 3 (AHTNA, 2009).
The Army believes the current remedial action captures all contaminated groundwater and is
protective of human health and the environment. There is chromium contamination exceeding
the MCL in the furthest down-gradient monitoring well (MW104C). However, the furthest
down-gradient extraction well (EW104B) is currently in operation and is maintaining capture of
this area of contamination. Unpublished Fourth Quarter 2009 analytical data indicates this by
showing a decline in chromium concentrations in the area.
The Army completed the first Five Year Review in February 2001 (Army, 2001) and the second
Five Year Review in September 2006 (AHTNA, 2006). Both Five Year Reviews concluded that
the groundwater remedy was functioning as intended and was protective of human health and the
environment.
In September 2007, the Army initiated, with regulatory approval, a one-year shutdown of the
groundwater pump and treatment system to study rebound effects. It also conducted an in situ
pilot test of ferrous iron and carbon to determine if this could result in an alternative treatment of
residual hexavalent chromium in the groundwater. As part of this effort, the Army installed four
new monitoring wells (117, 118, 119, and 120) to be included in the monthly monitoring of
rebound effects. The localized contamination and plume stability indicated by the results of the
Rebound Study support localized in situ treatment for the remaining areas of chromium
contamination. The results of the in situ pilot test demonstrated that reductant injections rapidly
reduced dissolved chromium concentrations by precipitating chromium.
The Army is currently preparing an Explanation of Significant Differences (ESD) to conduct insitu treatment to address chromium. The Army is also working on the development of an ESD to
address institutional controls. Remedial actions at RBAAP-03 will continue until remedial goals
have been reached.
4.2.2
Landfill (RBAAP-01; SWMUs 10 and 11)
RBAAP-01 is approximately 4.5 acres and is located in the northern section of the main plant
near the eastern boundary. The landfill was the site of surface and trench disposal and burning
from 1942 to 1966. The disposal operations in this area did not involve typical landfill
operations, but consisted of two discrete disposal trenches and a surface disturbance area.
According to records from 1942 to 1966, the landfill at the RBAAP was used for the incineration
and disposal for paper, dunnage, oils, grease, solvents, hospital wastes, construction debris, and
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industrial sludges. In 1966, onsite disposal operations were discontinued, and the area was filled
with dirt and construction rubble. Wells placed downgradient of the landfill have indicated that
the landfill was a possible source of cyanide and chromium contamination in groundwater.
Cyanide contamination has been potentially linked to pot liner from aluminum reduction
processes, a RCRA-listed waste, and has been found in the southern portion of the landfill. Most
of the pot liner was removed during previous rubble removal efforts. Chromium contamination
was also traced to construction rubble, which contained chromium-contaminated bricks. All
surface debris, including chromium-contaminated bricks, was removed as part of a 1987 rubble
cleanup effort.
The Army installed and maintains a clay cap at the landfill. The final site-wide 1994 ROD
documents this remedial action selection. Implementation of the landfill remedial action began
in June 1995 and initial work was completed in October 1995. Additional seeding was
performed in 1996 with the final landfill cover including, from top to bottom, a two-foot-thick
vegetative cover layer, a one-quarter-inch-thick geosynthetic liner, and a two-foot-thick
foundation layer. The landfill cap was designed and constructed to drain rainfall off and away
from the landfill. After installation of the cap and associated drainage and final grading, the
cover was hydro-seeded with native grass. Some damage was caused in 1997 by construction
activity on the adjoining railroad tracks. This was noted in the first Five Year Review and
repairs were made.
The second Five Year Review was completed in November 2006, and the remedy was found to
be effective. To ensure continued protectiveness, the site requires land use controls described in
Section 10.0.
Annual surveys to assure stability and annual management of a pesticide program to prevent
damage to the completed landfill cap are being conducted.
4.2.3
Industrial Wastewater Treatment Plant (SWMU 1)
The IWTP is a treatment facility for industrial wastewater generated at the installation from
electroplating, cleaning, and metal finishing processes. The primary treatment technologies are
coagulation, flocculation, and clarification. The IWTP is located to the immediate north of the
production plant at the installation. Treated effluent water is discharged to the E/P Ponds.
The IWTP was originally built after the Army acquired the facility in 1951. From 1952 to 1954,
production lines 5 and 6 produced zinc-plated shells for the Navy. Because the zinc was
electroplated from a cyanide solution, a separate system was required to treat waste from this
area. Cyanide solutions were diverted to a special tank in the IWTP where chlorine was added
for neutralization. The neutralized cyanide waste joined the normally treated waste and both
were transported to the E/P Ponds. The cyanide treatment tanks have not been in use since 1954.
Since 1972, numerous upgrades and improvements have been implemented at the IWTP. The
redwood equalization tanks were replaced with a concrete equalization basin in 1980.
Reportedly, when the water level in the redwood tanks was reduced for a period, the upper
portion of the redwood tanks would dry out and the seams would open slightly. When the liquid
level was later raised, the upper portion of the redwood tanks would leak and spill onto the
adjacent ground, which was not paved at the time. This is believed to be the source of the
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chromium and cyanide contamination in the IWTP area. The entire IWTP area is now covered
with concrete or asphalt. A series of concrete drainage trenches captures spills and overflows
and drains to the former influent sump, which is currently used as a secondary containment sump
for the IWTP.
A Phase I RI Program was conducted between January 1987 and November 1998. As part of the
Phase I RI, two borings were advanced in the IWTP. Samples were analyzed for total and
hexavalent chromium, total and free cyanide, and 1,1-dichloroethene. Soil borings SB-14 and
SB-15 were advanced to a depth of 50 feet below ground surface (bgs) in the area where the
former redwood tanks were located. At SB-14, total chromium was detected at a concentration
of 23.5 mg/kg at 40 feet bgs, and 18.0 mg/kg at 50 feet bgs. At SB-15, total chromium was
detected at a concentration of 22.15 mg/kg at 40 feet bgs, and 55.83 mg/kg at 50 feet bgs
(Weston, 1991).
The IWTP remains an active unit treating waste generated by Army operations at the RBAAP.
The DTSC (in a letter dated July 27, 1998) stated that additional characterization of soil at the
IWTP is precluded by existing equipment. Additional characterization of the IWTP is precluded
until permit closure due to the presence of existing system components. The groundwater under
the IWTP is being addressed under the site RBAAP-03.
4.3
Storage, Release, and Disposal of Hazardous Substances
Hazardous substances were stored for one year or more, released, or disposed of on the Property
in excess of reportable quantities specified in 40 Code of Federal Regulations (CFR) Part 373.
All environmental soil and groundwater remediation activities on the property have not yet been
completed. Remediation activities are ongoing for the groundwater contamination (See Section
4.2.1). Long-term maintenance is ongoing at the landfill (see Section 4.2.2). Further
investigation is required at the Industrial Wastewater Treatment Plant (see Section 4.2.3).
A summary of the buildings or areas in which hazardous substance activities occurred is
provided in Enclosure 4, Table 2 - Notification of Hazardous Substance Storage, Release, or
Disposal.
4.4
Petroleum and Petroleum Products
4.4.1. Underground Storage Tanks (USTs) and Above-Ground Storage
Tanks (ASTs)
• Current UST/AST Sites - There is zero underground and one above-ground
petroleum storage tank (UST/AST) on the Property. There is no evidence of a petroleum release
from this site.
• Former UST/AST Sites - There were 7 USTs on the Property that have been
removed or closed in place. There were three ASTs on the Property. One diesel tank was
removed (MascoTech, 1999a). Two vertical ASTs were used to store fuel oil from 1952 through
1958 until they were converted for the temporary storage of treated groundwater from the
groundwater treatment system. There is no evidence of petroleum releases from these sites.
12
Additional information on USTs is contained in a U.S. Army Corps of Engineers (USACE) Huntsville District study in September 1989 entitled "RBAAP Investigation and Evaluation of
Underground Storage Tanks" (USACE, 1989). All USTs were closed at the facility under the
oversight of the Regional Water Quality Control Board during 1994. The DTSC concurred with
the position of the Army (as detailed in the original October 30, 1995, version of the RFI Phase 1
Work Plan) that no further action was required at the USTs under the RCRA program (CH2M
HILL, 2002a).
A summary of the UST/AST petroleum product activities is provided in Table 3 – Notification of
Petroleum Products Storage, Release, or Disposal (Enclosure 5).
4.4.2. Non-UST/AST Storage, Release, or Disposal of Petroleum Products
There was non-UST/AST storage of petroleum products in excess of 55 gallons for one year or
more on the property. The petroleum was used for the following types of activities: industrial
operations and electrical equipment (transformers, substations). Petroleum product release or
disposal in excess of 55 gallons occurred at the following buildings or areas: Buildings 3 East, 4
and 5 (which included Buildings 47, 48, and 49) and Building 10. No follow-up investigations
have been completed. A summary of the non-UST/AST petroleum activities is provided in
Table 3 – Notification of Petroleum Products Storage, Release, or Disposal (Enclosure 5).
4.5
Polychlorinated Biphenyls
Historically, electrical transformers located throughout RBAAP contained PCB dielectric fluid.
Transformers with PCB concentrations less than 50 ppm are defined by the Toxic Substances
Control Act (TSCA) as non-PCB transformers, transformers with PCB concentrations equal to or
greater than 50 ppm but less than 500 ppm are defined as PCB-contaminated, and transformers
with PCB concentrations equal to or greater than 500 ppm are defined as PCB transformers.
Currently, five transformers are PCB-contaminated and five transformers are PCB transformers.
This equipment is operational and properly labeled in accordance with federal and state
regulations. A complete listing of PCB-containing transformers in excess of 50 ppm is presented
in Enclosure 6, Table 4 (NI, 2006a).
Two sites were investigated under the RFI and removal actions completed to address PCB
contamination in soils. These sites include AOC 8-B—Transformer Oil Storage Tanks and
Distribution System and AOC 16—Substation 5 Transformer Pad. See Section 4.2 for
information on these remedial actions.
Five locations were investigated for PCBs in the 2007 SI (CH2M HILL, 2008). These five
locations include Building 11 (Paint and Oil Storage), Structure 95, Structure 97, Structure 101
(Substation Spare), and Structure 145 (Substation No. 17). All results were below TSCA
requirements and no further action is required.
4.6
Asbestos-Containing Materials
There is asbestos-containing material (ACM) in the following buildings: __________
The ACM includes galbestos siding material for the buildings. The ACM does not currently
pose a threat to human health or the environment because all friable asbestos that posed an
13
unacceptable risk to human health has been removed or encapsulated. The deed will include an
asbestos warning and covenant (Enclosure 8).
4.7
Lead and Lead-Based Paint (LBP)
There are approximately 155 buildings at RBAAP. The majority of the buildings are presumed
to contain LBP since they were constructed prior to 1978. The RBAAP has conducted limited
LBP sampling surveys (CH2M HILL, 2006), but it is not comprehensive. The Property was not
used for residential purposes, and the Grantee does not intend to use the Property for residential
purposes in the future. The deed will include a lead-based paint warning and covenant
(Enclosure 8).
4.8
Radioactive Material
According to Army records, RBAAP does not currently use or store any radioactive material.
There is no record of Nuclear Regulatory Commission (NRC) licensed material ever having been
used at RBAAP. The potential for the presence of radioactive material was investigated at three
locations in the 2007 SI (CH2M HILL, 2008):
•
Building 11 Paint & Oil All survey results met the acceptable surface contamination
levels as established by the NRC. The SI recommended no further action at this site
(CH2M HILL, 2008).
•
Building 162 Autodin A.B. Terminal Building - Training Room: The radiological
survey results for Building 162 were well below the screening levels. This survey
confirms the absence of potential radioactive contamination (CH2M HILL, 2008).
•
Building 174 Hazardous Waste Storage Area: The radiation survey results for
Building 174 were well below the screening levels. The SI concluded that Building 174
did not require restrictions resulting from radiological activities (CH2M HILL, 2008.
4.9
Radon
A radon survey was conducted from September 1990 through November 1991 in Buildings 172,
9, 1, 13, 162, 14A, 120, 16A, and 9. Building 162 was the only building with radon above the
EPA residential action level of 4 picocuries of radon per liter of air (pCi/L). Building 162 had a
measured level of 5.2 pCi/L (MascoTech, 1999b).
4.10
Munitions and Explosives of Concern (MEC)
Based on a review of existing records and available information, there is no evidence that
Munitions and Explosives of Concern (MEC) are present on the Property. The installation was
only used for the manufacture of shell casings, which were then shipped to other locations for
filling. An archives search, the Closed Transferring and Transferred Range/Site Inventory
Report, and the Final Historical Records Review (USACE, 2006) detail that there is no record of
munitions-related activities occurring on the Property. The term “MEC” means military
munitions that may pose unique explosives safety risks, including: (A) unexploded ordnance
(UXO), as defined in 10 U.S.C. §101(e)(5); (B) discarded military munitions (DMM), as defined
14
in 10 U.S.C. §2710(e)(2); or (C) munitions constituents (e.g., TNT, RDX), as defined in 10
U.S.C. §2710(e)(3), present in high enough concentrations to pose an explosive hazard.
4.11
Other Identified Concerns
There are no other hazardous conditions on the Property that present an unacceptable risk to
human health and the environment.
5.0
ADJACENT PROPERTY CONDITIONS
Areas to the north and south of the Property are clean parcels at RBAAP that are being
transferred under a Finding of Suitability for Transfer (FOST). These include Parcels 1, 1a, 2,
2a, and B which consist of a total of approximately 63.3 acres over the five parcels. These
parcels are intended to be transferred for industrial/commercial reuse. Parcels 1, 1a, 2, and 2a
will be transferred via public sale. Any transferee(s) purchasing the property will use the
property for industrial/commercial use only and will comply with the land use restrictions.
Parcel B will be transferred to the Local Reuse Authority via an Economic Development
Conveyance. These transfers are consistent with the conditions set forth in the Riverbank Local
Redevelopment Authority’s Base Reuse Plan dated October 30, 2008. A facility-wide
groundwater-monitoring network is in place at RBAAP. The FOST parcels contain monitoring
well clusters with historical detections of chromium and cyanide, but concentrations are below
their respective MCLs. A groundwater use restriction will be placed on these parcels. All soil
and groundwater investigations have been completed and no contaminants above regulatory
limits have been identified. Therefore, the presence of these hazards on adjacent property does
not present an unacceptable risk to human health and the environment.
In addition, on the east side of the E/P Ponds, there are four adjacent properties where
encroachment onto the E/P Pond property has been documented by the U.S. Army. Provided
below are descriptions of the encroachment issues associated with each of the adjacent
properties:
•
Parcel No. 062-008-010: At Parcel No. 062-008-010, a drainage piping was documented
that drains onto the RBAAP E/P Pond property. The property owner has been informed
of the requirement to remove the piping and repair the erosion caused by the piping (U. S.
Army, 2006a).
•
Parcel No. 062-008-005: At Parcel No. 062-008-005, the RBAAP E/P Pond boundary
fence has been removed and replaced by a deck, retaining wall, ornamental plants,
various building materials, and fill dirt. The owner has been informed of the requirement
to remove all personal property, return the slope to its natural contour, and replace the
chain link fence (U. S. Army, 2006b).
•
Parcel No. 062-008-007: At Parcel No. 062-008-007, personal property and debris has
been placed along the RBAAP E/P Pond fence, causing damage to the fence and failure
of the slope. The owner has been informed of the requirement to remove all personal
property from this area, return the slope to its natural contour, and repair the fence
damage (U. S. Army, 2006c). This encroachment issued has been corrected (Army,
2007).
15
•
6.0
Parcel No. 062-008-011: At Parcel No. 062-008-011, a stormwater drainpipe was
observed entering the RBAAP E/P Pond property, as well as oil stains at the foot of a
retaining wall on the RBAAP E/P Pond property. The source of the oil stains is
apparently from a waste oil tank located on Parcel No. 062-008-011. Preliminary soil
samples on the RBAAP E/P Pond property indicated concentrations of 276,000 mg/kg
(U. S. Army, 2006d).
ENVIRONMENTAL REMEDIATION AGREEMENTS
RBAAP was added to the NPL in February 1990. An FFA was signed by the Army, the EPA
Region 9, the California DTSC, and the Central Valley Water Board, effective June 1990.
In addition, the site-wide ROD also applies to the Property (USAEC, 1994). The site-wide ROD
contains two response actions: a groundwater response action and a landfill response action.
Both response actions are currently implemented. Section 4.2 further outlines details on the
landfill and groundwater contamination. The ROD also described two “post-ROD” potential
actions that, although not part of the remedy, might need to be addressed based on future site
conditions or findings (USAEC, 1994). These potential actions include:
•
•
Investigation of the IWTP
Recharge of the A-zone
In June 2002, a CACA (Docket HWCA: P1-99/00-007) was signed between the Army and the
DTSC. The CACA required that the Army perform an RFI on four AOCs and one SWMU:
•
•
•
•
•
AOC 8B – Transformer Oil Storage Tanks and Distribution System
AOC 12 – Industrial Wastewater Collection System
AOC 14 – Zinc-Cyanide Collection System
AOC 16 – Substation 5/Building 11
SWMU 16 – Pesticide Storage Area (Building 165)
The RFI recommended no further action for AOCs 8B, 14, 16, and SWMU 16 and
deferred any additional actions at AOC 12 until base closure (CH2M HILL, 2005a). See Table 1
- Description of Property for additional information on these sites. In a letter from the DTSC,
dated August 10, 2006, the DTSC confirmed that no further action was required at the SWMUs
and AOCs with the exception of SWMU 1 (IWTP). As discussed in Section 4.2.3, additional
characterization of the IWTP is precluded until permit closure due to the presence of existing
system components. The deed will include a provision reserving the Army’s right to conduct
remediation activities (Enclosure 8).
7.0
REGULATORY/PUBLIC COORDINATION AND COMMENTS
The EPA Region IX, the DTSC, and the public were notified of the initiation of this FOSET
(Enclosure 9). The 30-day public review period was from _________, 2010 to _________,
2010. Regulatory/public comments received during the public comment period will be reviewed
and incorporated, as appropriate. A copy of the regulatory/public comments and the Army
Response will be included in Responsiveness Summary (Enclosure 10).
16
8.0
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) COMPLIANCE
The environmental impacts associated with the proposed transfer of the property have been
analyzed in accordance with the National Environmental Policy Act (NEPA). The results of this
analysis are documented in the Environmental Assessment for BRAC 05 Disposal and Reuse of
the Riverbank Army Ammunition Plant, California (Marstel-Day, 2009) and the Finding of No
Significant Impact, signed 13 July 2009. There were no encumbrances or conditions identified
in the NEPA analysis as necessary to protect human health or the environment.
9.0
ENVIRONMENTAL PROTECTION PROVISIONS
In consideration of the intended use of the Property as commercial and industrial reuse, certain
terms and conditions are required for the proposed transfer, including the prohibition on
residential use. These terms and conditions are set forth in Enclosure 7 – CERCLA Deed
Provisions and in Enclosure 8 –Environmental Protection Provisions and will be incorporated in
the deed. These restrictions will be in effect until terminated, removed, or modified.
10.0
STATE LAND USE CONTROLS
With the transfer of this Property, SLUCs will be included to ensure the preservation of controls
put in place to protect human health and the environment at those sites where contamination
remains above levels allowable for unrestricted use. These sites include areas encompassing
groundwater contamination resulting from the former IWTP operations, the landfill site, and
industrial operation areas where contaminants in soil remain above levels allowing for
unrestricted use. The sites will remain subject to regulation under RCRA and CERCLA as long
as the contaminants present a threat to human health and the environment. The controls shall be
implemented to achieve the following objectives:
•
•
•
•
•
•
The continued compliance with all terms and conditions of the 1994 ROD under
CERCLA and with the requirements of the existing RCRA Permit;
Ensure that activities at a site or future uses remain in compliance with the restrictions
outlined in the implementation plan for that site or environmental media;
Prevent excavation and construction that would compromise the integrity of any
protective structures, such as the landfill cap or pavement in the vicinity of the IWTP
with the exception of Army and agency authorized activities;
Prohibit the human consumption of groundwater on-site that exceeds Maximum
Contaminant Levels (MCLs);
Via Stanislaus County Department of Environmental Resources, provide landowners in
the vicinity of the off-post groundwater contamination with annual notifications
regarding the status of the cleanup efforts and advised use restrictions; and
Ensure that routine maintenance activities required to ensure the integrity of the landfill
cap and groundwater treatment/monitoring are performed, including inspections and
maintenance to prevent damage or unauthorized modifications. The area defined as the
E/P Ponds is currently used as a discharge basin for treated water from the GWTP and
IWTP at RBAAP. The ponds receive water from RBAAP via a 3.4-mile underground
pipe. Discharge to the ponds is conducted in accordance with the Regional Water
Quality Control Board Waste Discharge Requirements Order No. 5-01-200 and RCRA
Part B Permit SWMU 23 (Central Valley Water Board, 2001, DTSC, 2006).
17
Land use restrictions, notifications, covenants, conditions, and institutional controls will be
implemented to ensure that the intended use of the Property is consistent with the requirements
of CERCLA Section 120 (h)(3)(C) for the protection of human health and the environment.
These LUCs are necessary for any ongoing or planned environmental restoration activities to
protect human health or the environment after the early transfer. These provisions shall ensure
any required future remedial investigations, response actions, and oversight activities will not be
interrupted. The LUCs will remain in effect until terminated, removed, or modified with EPA
and DTSC concurrence. Enclosure 2, Figures 8 and 9 show the land use and groundwater use
restrictions, respectively, for RBAAP. Provisions describing implementation and enforcement of
these restrictions are included in the SLUCs and described in the EPPs (Enclosure 8).
11.0
DEFERRED WARRANTY
When all response actions necessary to protect human health and the environment with respect to
any hazardous substances remaining on the Property at the time of transfer have been completed,
the Army shall execute and deliver to the purchaser of the Property (or its successor) an
appropriate document containing a warranty that all response actions have been taken.
18
12.0
FINDING OF SUITABILITY FOR EARLY TRANSFER
Based on the above information, I conclude that all DOD requirements to reach a finding of
suitability for early transfer of the Property to the RLRA for industrial and commercial reuse
have been met. These uses of the Property are consistent with the protection of human health
and the environment, subject to inclusion of the covenants and notifications in the EPP
(Enclosure 8) into the deed for the Property. The CERCLA Deed Provisions (Enclosure 7)
includes the CERCLA §120(h)(3)(C) covenant and access provisions.
With the covenants, conditions, and restrictions in the CERCLA Deed Provisions and the EPP,
the Property can be transferred in its present condition for its intended purpose(s) without
unacceptable risk to human health and the environment [CERCLA § 120(h)(3)(C)(i)(I)]. The
deed for the Property will contain the following covenants and access clause:
•
The covenant under CERCLA §120(h)(3)(A)(ii)(II) warranting that any additional
remedial action under CERCLA found to be necessary after the grant of the deferred
warranty with respect to such hazardous substances remaining on the Property at the time
of transfer shall be conducted by the United States.
•
The clause as required by CERCLA §120(h)(3)(A)(iii) granting the United States access
to the Property in any case in which remedial action or corrective action is found to be
necessary after the date of transfer.
As required under CERCLA § 120(h)(1) and DOD FOSET Guidance, a description of
remedial action taken, if any, and notification of hazardous substance activities and petroleum
product activities shall be provided in the deed. See Table 1 - Description of Property, Table 2 Notification of Hazardous Substance Storage, Release, or Disposal, Table 3 - Notification of
Petroleum Product Storage, Release, or Disposal.
Addison D. Davis, IV
Deputy Assistant Secretary of the Army
Environment, Safety, and Occupational Health
19
Enclosures
Enclosure 1: Environmental Documentation
Enclosure 2: Figures
Enclosure 3: Table 1 – Environmental Condition of the Property
Enclosure 4: Table 2 – Notification of Hazardous Substance Storage, Release, or Disposal
Enclosure 5: Table 3 – Notification of Petroleum Product Storage, Release, or Disposal
Enclosure 6: Table 4 – PCB and PCB-Contaminated Transformers
Enclosure 7: CERCLA Notice, Covenant, Access Provisions and Deed Restrictions
Enclosure 8: Environmental Protection Provisions
Enclosure 9: Public Notice
Enclosure 10: Responsiveness Summary
ENCLOSURE 1
Ahtna Government Services Corporation (AGSC). 2006. Draft Second Five Year Review Report
for Riverbank Army Ammunition Plant, City of Riverbank, Stanislaus County, California. July.
CH2M HILL. 2002a. RCRA Facility Investigation Current Conditions Report, Riverbank Army
Ammunition Plant, Riverbank, California. October.
CH2M HILL 2002b. RCRA Facility Investigation, Phase 1 Work Plan. Prepared for the
U.S. Army Corps of Engineers. Final. November.
CH2M HILL, 2003. RCRA Facility Investigation, Phase 1A Work Plan Addendum. Prepared for
the US Army Corps of Engineers, Final. November.
CH2M HILL. 2005a. RCRA Facility Investigation Report. Riverbank Army Ammunition Plant,
Riverbank, California. February 4.
CH2M HILL, 2006. Final U.S. Army BRAC 2005 Environmental Condition of Property Phase I
Report, Riverbank Army Ammunition Plant, Riverbank, California. November.
CH2M HILL. 2008. Final Site Investigation Report. Riverbank Army Ammunition Plant,
Riverbank, California. March.
Department of Toxic Substances (DTSC), 2006. No Further Action Letter (NFA) from the
DTSC for RCRA Current Conditions Report, RBAAP, Stanislaus County. EPA ID No.
CA210020759.
Envirodyne Engineers, Inc. (Envirodyne). 1986. Technical Plan for the Environmental
Contamination Survey of the Riverbank Army Ammunition Plant, Riverbank, California, Phase
II - Version 2. March.
Envirodyne Engineers, Inc. (Envirodyne). 1987. Remedial Investigation of the Riverbank Army
Ammunition Plant, Riverbank, California. April.
Environmental Data Resources Inc (EDR). 2006a. The EDR Radius Map with GeoCheck,
Riverbank AAP. June 12.
Environmental Data Resources Inc (EDR). 2006b. The EDR Aerial Photo Decade Package,
Riverbank AAP. June 12.
Environmental Data Resources Inc (EDR). 2006c. The EDR Radius Map with GeoCheck,
Riverbank E/P Ponds. June 13.
Environmental Data Resources Inc (EDR). 2006d. The EDR Aerial Photo Decade Package,
Riverbank E/P Ponds. June 14.
Environmental Photographic Interpretation Center (EPIC). 1981. Installation Assessment,
Riverbank Army Ammunition Plant, California. September.
Environmental Photographic Interpretation Center (EPIC). 1987. Site Analysis, Riverbank AAP,
Riverbank, California. September.
1
MacDonald and Mack Partnership. 1984. Historic Properties Report, Riverbank Army
Ammunition Plant, Riverbank, California. August.
Marstel-Day, LLC. 2009. Final Environmental Assessment for BRAC 05 Disposal and Reuse of
the Riverbank Army Ammunition Plant, California. Prepared for the U.S. Army Corps of
Engineers: Mobile District. March.
MascoTech. 1999a. Final Tank Disposal for Tank T02. February 23.
MascoTech. 1999b. June 22, 1999 Meeting with Dr. Henry Crain (transmittal of radon
monitoring data for Building 162). Riverbank Army Ammunition Plant, Riverbank, California.
June 23.
NI Industries, Inc. (NI). 2003a. 2003 Pesticide Use Minimization Plan. Riverbank Army
Ammunition Plant (RBAAP), Riverbank, California. January 3.
NI Industries, Inc. (NI). 2003b. Storm Water Pollution Prevention Plan (2003 SWPPP),
Riverbank Army Ammunition Plant, Riverbank, California. March 3.
NI Industries, Inc. (NI). 2003d. Oil Spill Prevention Control and Countermeasure Plan
(SPCCP), Riverbank Army Ammunition Plant, Riverbank, California. March 3.
NI Industries, Inc. (NI). 2004a. Asbestos Management Plan and Survey. Riverbank Army
Ammunition Plant. March 30.
NI Industries, Inc. (NI). 2004b. Installation Pest Management Plan (IPMP) Submission for FY
2004. March 29.
NI Industries, Inc. (NI). 2004d. RCRA Part B Permit. Sections 8 and 13. November.
NI Industries, Inc. (NI). 2005a. 2004 Hazardous Waste Report (DTSC Annual Facility Report).
February 22.
NI Industries, Inc. (NI). 2006a. Additional Documents Requested at the ECP Outbriefing
Meeting. July 24.
NI Industries, Inc. (NI). 2006b. RBAAP Responses to ECP Comments Data Request. September
21.
Norris-Riverbank. 1998a. Environmental Baseline Survey, Phase I Environmental Assessment
Report Tenant: Harbor Oil. Facility: Building 11. January 12.
Norris-Riverbank. 1998e. Environmental Baseline Survey Phase I Environmental Assessment
Report. Facility: Buildings 3 East, 4, and 5. August 13.
Norris-Riverbank. 1998f. Environmental Baseline Survey Phase I Environmental Assessment
Report. Facility: Building 10. September 22.
Norris-Riverbank. 1998h. Environmental Baseline Survey, Phase I Environmental Assessment
Report. Facility: Building 14. November 11.
Norris-Riverbank. 1998i. Environmental Baseline Survey, Phase I Environmental Assessment
Report. Facility: Building 130. November 23.
Norris-Riverbank. 1998j. Closure of Three Cyanide Tanks at Building 4, 5, and 6 Report.
Riverbank Army Ammunition Plant, Riverbank, California. November 25.
2
Norris-Riverbank. 1998n. Environmental Baseline Survey Phase I Environmental Assessment
Report. Facility: Building 169. December 11.
Roy F. Weston, Inc. (Weston). 1991. Riverbank Army Ammunition Plant Remedial Investigation
Report. Prepared for Commander, U.S. Army Toxic and Hazardous Materials Agency,
Aberdeen Proving Ground, Maryland 21010-5401. July.
Roy F. Weston, Inc. (Weston). 1992a. Remedial Investigation (RI) Report – Riverbank Army
Ammunition Plant. February.
Roy F. Weston, Inc. (Weston). 1992b. Riverbank Army Ammunition Plant Remedial
Investigation Report Addendum. Prepared for Commander, U.S. Army Toxic and Hazardous
Materials Agency, Aberdeen Proving Ground, Maryland 21010-5401. April.
Roy F. Weston, Inc. (Weston). 1993b. Feasibility Study (FS) Report – Riverbank Army
Ammunition Plant. June.
SOTA Environmental Technologies, Inc. (SOTA). 1998. RCRA Facility Investigation Phase I
Work Plan Revision No. 4, Riverbank Army Ammunition Plant, Riverbank, California.
September.
Stanislaus County. 1995. Memo Re: UST Closure Report for Riverbank Army Ammunition
Plant, 5300 Claus Road, Riverbank. Department of Environmental Resources, Hazardous
Materials Division. April 28.
State of California. 1997. NPDES Industrial Storm Water Program – Permit. Riverbank Army
Ammunition Plant, Riverbank, California. California Regional Water Quality Control Board,
Central Valley Region. April 17.
State of California. 2001a. Draft MRP 5-01-200 (Amended) Permit Requirements, Riverbank
Army Ammunition Depot, Riverbank, California. Regional Water Quality Control Board,
Central Valley Region. June.
State of California. 2001b. Notice of Adoption of Updated Waste Discharge Requirements for
United States Department of the Army and NI Industries – Waste Discharge Requirements
Order. Riverbank Army Ammunitions Plant, Riverbank, California. California Regional Water
Quality Control Board, Central Valley Region. August 1.
State of California. 2002. Corrective Action Consent Agreement – Health and Safety Code
Section 23157. Riverbank Army Ammunition Plant, Riverbank, California. Environmental
Protection Agency, Department of Toxic Substances Control. June 21.
State of California. 2005. Continuation of Expiring Hazardous Waste Storage and Treatment
Permit, Riverbank Army Ammunition Plant (RBAAP), Stanislaus County. Department of Toxic
Substances Control. Environmental Protection Agency ID No. CA210020759. July 29.
State of California. 2006. Hazardous Waste Facility Permit. California Environmental
Protection Agency, Department of Toxic Substances Control. April 16.
Army. 1980. Installation Assessment of Riverbank Army Ammunition Plant. U.S. Army Toxic
and Hazardous Materials Agency Report No. 144. January.
Army. 1996. Riverbank Army Ammunition Plant, RCRA Facilities Investigation – Phase 1 Work
Plan Revision No. 2. Prepared by Norris Industries and Army staff at RBAAP. April.
3
Army. 2001. First Five-Year Review Report for Riverbank Army Ammunition Plant, City of
Riverbank, Stanislaus County, California. February 20.
Army. 2006a. Riverbank Army Ammunition Plant California; Encroachment on Army Property
from Assessors Parcel No. 062-008-010. Management and Disposal Branch. February 13.
Army. 2006b. Riverbank Army Ammunition Plant California; Encroachment on Army Property
Army. 2006c. Riverbank Army Ammunition Plant California; Encroachment on Army Property
Army. 2006d. Riverbank Army Ammunition Plant California; Encroachment on Army Property
Army. 2006e. Property Information Summary for Riverbank Army Ammunition Plant,
California. http://www.hqda.army.mil/ACSIM/brac/PropertyInformationSummaries/
PropertyInformationSummaryRiverbankAAP.pdf. Base Realignment and Closure Division
(BRACD).
Army. 2007. Letter to Mr. Javier Gonzalez from Jyuji D. Hewitt. July 2.
Army Environmental Center (USAEC). 1994. Record of Decision, Riverbank Army Ammunition
Plant. March.
USAEC. 2005. ECP Workshop Meeting held 8/10/05, Riverbank Army Ammunition Plant.
August.
USAEC. 2006a. U.S. Army BRAC 2005 Environmental Condition of Property Report,
Riverbank Army Ammunition Plant, Riverbank, California. November 17.
USAEC. 2006b. Riverbank Army Ammunition Plant, California, Base Realignment and Closure
Installation Action Plan, FY06. March.
U.S. Army Corps of Engineers (USACE). 1989. RBAAP Investigation and Evaluation of
Underground Storage Tanks. Omaha District. September.
USACE. 2005. NEPA Action Plan. Developed by the USACE Mobile District Corps of
Engineers, NEPA Support Team.
USACE. 2006. Final Historical Records Review, Riverbank Army Ammunition Plant.
Sacramento District. January.
U.S. Army Material Command (USAMC). 2003. Closed Transferring and Transferred
Range/Site Inventory Report, Riverbank AAP. March.
WESTON. 1991a. Riverbank Army Ammunition Plant Remedial Investigation Report. Prepared
for U.S. Army Toxic and Hazardous Materials Agency, Aberdeen Proving Ground, Maryland
21010-5401. July.
WESTON.. 1991b. Riverbank Army Ammunition Plant Remedial Investigation Report
Addendum. Prepared for U.S. Army Toxic and Hazardous Materials Agency, Aberdeen Proving
Ground, Maryland 21010-5401. December.
WIRTH Environmental Services (WIRTH). 1988. An Archeological Overview and Management
Plan for the Riverbank Army Ammunition Plant, Riverbank, California. February 10.
4
ENCLOSURE 2
FIGURES
Figure 1: Vicinity Map
Figure 2: Parcel Map
Figure 3: IRP Sites, SWMUs, and AOCs
Figure 4: Well Locations
Figure 5: Above Ground Storage Tanks
Figure 6: Under Ground Storage Tanks
Figure 7: Property Categorization Map
Figure 8: Land Use Restrictions
Figure 9: Groundwater Use Restrictions
Plate 1:
RBAAP A/A’ Aquifer Zone Groundwater Elevation Contours with Third Quarter
2009 Chromium and Cyanide Concentrations
Plate 2:
RBAAP B Aquifer Zone Groundwater Elevation Contours with Third Quarter 2009
Plate 3:
RBAAP C Aquifer Zone Groundwater Elevation Contours with Third Quarter 2009
1
SOURCE: USACE, 2006
0
600
1,200
Feet
³
LEGEND
RBAAP PROPERTY
BOUNDARY
FIGURE 1
VICINITY MAP
RBAAP Site Investigation Report
Riverbank, California
1. PURPOSE
Remainder Parcel A
Parcel B
Parcel 1
Parcel 2
Parcel
2a
Note: Parcel boundaries shown are approximate.
Parcel 1a
Evaporation/Percolation Ponds
FIGURE 2
PARCEL MAP
ES082006004SCO/BRAC_RB_ECP_FINAL.DOC/062720011 5
4. ENVIRONMENTAL CONDITIONS
FIGURE 3
ES082006004SCO/BRAC_RB_ECP_FINAL.DOC/062720011
4-7
Figure 4
Well Locations
Riverbank, CA
Figure 5
Aboveground Storage Tanks
Riverbank, CA
Figure 6
Underground Storage Tanks
Riverbank, CA
Figure 7
Property Categorization Map
Riverbank, CA
Legend:
Approximate Boundary of the RBAAP General
Production and Operation Areas Subject to Land Use
Restrictions
Buildings
FIGURE 8
RBAAP General
Production and
Operation Areas
Subject to Land Use
Restrictions
FIGURES
Legend:
Approximate Facility Boundary defining Area of On-Site
Groundwater Use Restriction.
Building
FIGURE 9
Area of On-Site
Groundwater Use
Restrictions RBAAP
MADERA CT
PRINCE GEORGE LN
50
Chromium Isoconcentration Line
50
(Historical) Chromium Isoconcentration Line
76.58
Chromium Isoconcentration (µg/L)
NS
ND
Not Sampled
Not Detected
200
Cyanide Isoconcentration Line
200
76.58
(Inferred) Cyanide Isoconcentration Line
Cyanide Concentration (µg/L)
NS
ND
Not Sampled
Not Detected
Predominate GW Gradient
Groundwater elevation data from active extraction wells
is not used to determine groundwater elevation contour locations.
Color Air Photo Source: NAIP 2006, 1 Meter
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12 (13)
15 (ND)
MW 14 A'
73.06
ND
ND
No Measurement Recorded
PRINCE NORMAN WY
!
!
MW 15 A
NSI
NSI
MW 119 A'
75.16
ND
MW 71 A ' 11
72.31
ND
MW 57 A
38
EW 63 A' NSS
70.19
NSS
ND
360
Groundwater Elevation
B
d
R
n
C
y
rlo
a
d
R
n
C
y
rlo
a
B
!
!
!
!
MW 18 A
NSI
NSI
Groundwater Elevation Contour
d
v
u
B
o
M
im
lJ
ra
n
e
G
!
!
!
MW 62 A'
72.84
ND
100
!
!
MW 61 A
NSS
NSS
MW 111 A'
71.24
ND
ND
MW 34 A'
71.92
14
ND MW 51 A
75.01
NSI
NSI
MW 61 A'
73.34
NSS
NSS
PRINCE PHILIP WY
PW 116 A'
71.65
49
47
MW 50 A
77.49
MW 49 A
NSI
74.90 MW 46 A
NSI
74.52
NSI
NSI
NSI
NSI
75
MW 20 A
NSI
NSI
Extraction Well
72
!
MW 107 A'
71.41
NSS
NSS
77
!
!
MW 69 A '
71.67
37
ND
MW 54 A
71.19
NSI
NSI
MW 52 A
74.72
NSI
NSI
(
!
d
G
ls
re
u
a
L
EW 113 A'
71.43
NSP
NSP
!
!
!
!
MW 55 A
NSS
NSS
MW 109 A'
70.94
16
22
PRINCE ANDREW DR
!
!
!
!
PW 115 A'
71.26
ND
ND
74
MW 41 A'
71.71
NSS
NSS
BADGER PASS DR
INCLINE WY
MINNIEAR AVE
71
MW 102 A'
NSD
NSD
MW 117 A'
74.41
33
ND
Monitoring Well
PRINCE EDWARD LN
VAN DUSEN AVE
CLARIBEL RD
!
DAVIS AVE
MW 104 A'
70.38
ND
ND
MW 105 A'
71.37
ND
ND
(
!
76
NR
MW 120 A'
74.10
ND
ND
MW 110 A'
71.23
NSS
NSS
SIERRA VISTA DR
MW 68 A'
73.77
NSS
NSS
MW 16 A
NSI
NSI
Plate 1: RBAAP A/A' Aquifer Zone Groundwater
Elevation Contours with Third Quarter 2009
!
MW 111 B
71.31
13
57
!!
VAN DUSEN AVE
!
!
NR
PRINCE GEORGE LN
50
50
76.58
NS
ND
Not Sampled
Not Detected
200
76.58
NS
ND
Not Sampled
Not Detected
PRINCE NORMAN WY
72
12
NSS
CELESTINO CT
o
h
a
Id
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g
re
O
4
8
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Riverbank Army
Ammunition Plant
MW 45 B
72.31
ND
22
0
7
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MW 5 B
73.64
ND
ND
73
d
o
sR
ram
b
A
!
!
MW 17 B
73.55
NSS
MW 68 B
NSS
73.66
NSS
NSS
MW 14 B
73.44
NSS
NSS
MW 66 B
72.64
ND
NSS
re
12thS
!
!
MW 62 B
72.78
NSS
NSS
h
ta
U
d
va
e
N
d
R
n
C
y
rlo
a
B
EW 72 B
70.52
ND
33
!
!
MW 34 B
71.96
ND
ND
!
!
!
!
MW 61 B
73.29
NSS
NSS
76
d
v
u
B
o
M
im
lJ
ra
n
e
G
!
74
EW 54 B
71.98
ND
ND
d
G
ls
re
u
a
L
!
CLAUS RD
Extraction Well
!
MW 118 B
74.37
100
ND
PRINCE ANDREW DR
!
!
!
!
MW 41 B
71.67
NSS
NSS
MW 102 B
71.21
ND
ND
PRINCE PHILIP WY
MW 107 B
71.44
EW 113 B NSS
71.39
NSS
ND
PW 116 B
11
71.61
NSS
NSS
MW 52 B
MW 105 B
71.30
11
ND
(
!
PRINCE EDWARD LN
MW 109 B
NSP
NSP
PW 115 B
71.19
21 (21)
18 (13)
MW 110 B
66.21
NSS
66
NSS
MADERA CT
BADGER PASS DR
INCLINE WY
71
!
CLARIBEL RD
EW 114 B
70.78
70
ND
Monitoring Well
80
MINNIEAR AVE
DAVIS AVE
!
!
MW 112 B
70.59
ND
ND
MW 104 B
47
ND
(
!
rn
lifo
a
C
5
¦
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§
5
1
¦
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§
0
4
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a
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rizo
A
0
1
¦
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§
0
TEA
Environmental
Consulting
400
800
Feet
Plate 2: RBAAP B Aquifer Zone Groundwater
MW 111 C
71.36
ND
ND
!
PRINCE GEORGE LN
50
76.58
NS
ND
Not Sampled
Not Detected
76.58
NS
ND
Not Sampled
Not Detected
CELESTINO CT
o
h
a
Id
n
o
g
re
O
4
8
¦
¨
§
72
Riverbank Army
Ammunition Plant
0
7
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MW 5 C
73.53
NSS
NSS
8 3
re
S
th
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d
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G
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1
2
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!
MW 66 C
72.71
NSS
NSS
d B
R
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C
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a
B
d
R
n
C
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a
!
MW 14 C
73.12
NSS
NSS
h
ta
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va
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N
d
v
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!
MW 45 C
72.30
NSS
NSS
0
8
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8
6
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H
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G
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!
!
!
MW 62 C
72.63
NSS
NSS
50
PRINCE NORMAN WY
PW 116 C
71.56
NSS
NSS
MW 34 C
71.88
NSS
NSS
!
!
!
MW 17 C
73.52
MW 68 C
NSS
73.66
NSS
NSS
NSS
200
PRINCE PHILIP WY
VAN DUSEN AVE
!
PW 115 C
71.23
EW 113 C
ND
71.35
ND
NSS
NSS MW 107 C
71.36
ND
ND
MW 52 C
71.46
11
16
PRINCE ANDREW DR
71
73
MW 61 C
73.19
NSS
NSS
MADERA CT
BADGER PASS D
MINNIEAR AVE
MW 109 C
70.89
ND
ND
MW 102 C
70.93
ND
ND
!
!
CLAUS RD
Extraction Well
NR
!
!
!
MW 47 C
71.87
MW 54 C ND
ND
71.59
NSS
NSS
(
!
PRINCE EDWARD LN
EW 114 C
70.88
24
ND
MW 105 C
71.35
39
ND
Monitoring Well
76
!
!
CLARIBEL RD
MW 112 C
70.56
ND
ND
(
!
80
!
!
DAVIS AVE
MW 104 C
70.63
83
21
INCLINE WY
79
rn
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C
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Environmental
Consulting
400
800
Feet
Plate 3: RBAAP C Aquifer Zone Groundwater
ENCLOSURE 3
TABLE 1 – ENVIRONMENTAL CONDITION OF THE PROPERTY
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
Landfill
(RBAAP01/SWMUs 10
and 11)
1, 22, 23
5
Waste Salt
Disposal Pit
(RBAAP02/SWMU 18)
2
3
RBAAP-01 is approximately 4.5 acres and is located in the northern section of the
main plant near the eastern boundary. The landfill was the site of surface and
trench disposal and burning from 1942 to 1966. The site was addressed under the
1994 ROD. Remedial activities at the landfill were completed in October 1995.
The final landfill cover consisted of a two-foot-thick vegetative cover layer, a onequarter-inch-thick geosynthetic liner, and a two-foot-thick foundation layer.
Long-term maintenance is required until 2015.
This site is located adjacent to the former landfill. The waste salt pond was
constructed for use as an evaporation basin for wash water from the nitrate molten
salt annealing process. Completed in 1969, it was never used for this purpose
because anticipated orders were never received. According to plant officials, the
waste salt pond was not used for any disposal operations. Sampling of the pond
was not conducted based on this information. The site-wide ROD documented
that no further action is required at this site (USAEC, 1994).
Groundwater
Contamination
(RBAAP-03)
3
5
This site is Category 3 based on groundwater contamination currently present but
below Maximum Contaminant Levels (MCLs).
The IRP Site RBAAP-03 represents chromium and cyanide groundwater
contamination resulting from leakage associated with the original IWTP. The
original storage and equalization tanks used for the IWTP were made of redwood.
From 1973 to 1980, the IWTP was upgraded and the redwood tanks were replaced
with concrete tanks. The upgraded IWTP, identified as SWMU 1, continues to
operate under a RCRA Part B Permit 05-SAC-06.
In 1985, the Army installed an interim groundwater treatment system (GWTS)
and provided bottled drinking water to those affected residents followed by the
Page 1 of 28
TABLE 1 – ENVIRONMENTAL CONDITION OF THE PROPERTY (CONTINUED)
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
extension of the Riverbank city water system to all potentially affected residents.
In March 1994, the EPA Region 9, the DTSC, the Central Valley Water Board,
and the Army signed the ROD. The ROD required expansion of the interim
GWTS. The expanded system began operation in 1997. The cleanup goal for
chromium is 50 μg/L and 200 μg/L for cyanide.
Groundwater monitoring consists of four sampling events per year; two quarterly,
one semiannual and one annual which include specific sets of wells completed in
the various A', A, B, C and D portions of the aquifer. The locations of the
monitoring wells is shown in Enclosure 2, Figure 4. The results of the
groundwater sampling from the third quarter of 2009 are shown on Plates 1, 2, and
3 (AHTNA, 2009).
The Army believes the current remedial action captures all contaminated
groundwater and is protective of human health and the environment. There is
chromium contamination exceeding the maximum contaminant level (MCL) in
the furthest down-gradient monitoring well (MW104C). However, the furthest
down-gradient extraction well (EW104B) is currently in operation and is
maintaining capture of this area of contamination. Unpublished Fourth Quarter
2009 analytical data indicates this by showing a decline in chromium
concentrations in the area.
The Army completed the first Five Year Review in February 2001 (Army, 2001)
and the second Five Year Review in September 2006 (AHTNA, 2006). Both Five
Year Reviews concluded that the groundwater remedy was functioning as
intended and was protective of human health and the environment.
In September 2007, the Army initiated, with regulatory approval, a one-year
shutdown of the groundwater pump and treatment system to study rebound
effects, and an in situ pilot test of ferrous iron and carbon to determine if this
could result in an alternative treatment of residual hexavalent chromium in the
groundwater. As part of this effort, the Army installed four new monitoring wells
Page 2 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
(117, 118, 119, and 120) to be included in the monthly monitoring of rebound
effects. The localized contamination and plume stability indicated by the results
of the Rebound Study support localized in situ treatment for the remaining areas
of chromium contamination. The results of the in situ pilot test demonstrated that
reductant injections rapidly reduced dissolved chromium concentrations by
precipitating chromium.
Building 13
Chromium
Pretreatment
System
(RBAAP-05/
SWMU 5)
IWTP Sulfuric
Acid Spill
(RBAAP-06/
AOC 6)
5
6, 43
3
7
The Army is currently preparing an Explanation of Significant Differences (ESD)
to conduct in-situ treatment to address chromium. The Army is also working on
the development of an ESD to address institutional controls. Remedial actions at
RBAAP-03 will continue until remedial goals have been reached.
This site is located in the southern end of Building 13. The chromium
pretreatment system was installed in 1978 as part of the upgrades to the IWTP.
No direct sampling was conducted around this system because it is an operating
facility. However, the groundwater investigation concluded that the major source
of chromium contamination was the leaking tanks of the IWTP prior to the system
upgrade. The site-wide ROD documented that no further action is required at this
site (USAEC, 1994).
This site is NFA based on the investigation results, but Category 3 based on
groundwater contamination currently present but below Maximum Contaminant
Levels (MCLs).
In 1956, a sulfuric acid spill occurred at the Sulfuric Acid Feed System, adjacent
to the redwood equalization tanks. This site is north of Building 173. The
sulfuric acid spill was a 500-gallon release from a pipe break that was reportedly
neutralized immediately with lime.
Groundwater monitoring for sulfate was conducted. Historically, sulfate
concentrations in groundwater in the IWTP area were present at levels slightly
above the secondary MCL of 250 milligrams per liter (mg/L). Monitoring well
NI-20, downgradient of the spill area, identified sulfate at concentrations of 450
Page 3 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
mg/L during Exploratory Phase 1B sampling in 1985. The groundwater table
receded thereafter, and NI-20 could no longer be sampled. In 1990, the sulfate
concentration was detected at 23.3 mg/L in the shallow groundwater zone A’ and
is no longer considered a groundwater concern in the IWTP area. It is unknown if
the slightly elevated sulfate concentration found during the Exploratory Phase 1B
was the result of the 1956 sulfuric acid spill. The groundwater extraction system
will capture any sulfate contamination in groundwater and the effluent from the
GWTP is monitored for sulfate under the NPDES permit.
In a letter dated July 27, 1998, the DTSC concurred with the position of the Army
(as detailed in the February 1998 Revision 4 of the RFI Phase 1 Work Plan) that
no further action was required for this AOC (CH2M HILL, 2002a).
Building 13
Phosphoric Acid
Spill (RBAAP07/AOC 7)
Southeast Storm
Reservoir
(RBAAP-
7, 44
8
3
4
This site is NFA based on the investigation results, but Category 7 based on its
location within the SMWU 1 boundary.
In 1978, a phosphoric acid spill occurred in the Phosphate Coating Area, upstairs
in the southern end of Building 13. The phosphoric acid spill resulted in
approximately 100 gallons of phosphoric acid being released onto the second
story concrete floor. The acid was washed down the industrial sewer drain, did
not leave the building, and did not contact any soil or groundwater. Because the
spill was contained inside the building, and then in the sewer system, there is no
further action required in this area. In a letter dated June 5, 1996, the DTSC
concurred with the position of the Army (as detailed in the April 15, 1996
Revision 2 of the RFI Phase 1 Work Plan) that no further action was required for
this AOC (CH2M HILL, 2002a).
The Southeast Storm Reservoir is 230-feet long and 44 feet wide with a total
storage capacity of 430,000 gallons. The Southeast Storm Reservoir originally
was constructed in 1954 and has been in use ever since. The Southeast Storm
Page 4 of 28
Property
Description
08/SWMU
21/AOC 16)
ECP Study
Section(s)
ECP
Category
Remedial Actions
Reservoir collects stormwater from the southeast portion of the site and then
pumps the water to the Northwest Storm Reservoir for ultimate discharge offsite.
Stormwater runoff is the only known source to the reservoir. Investigations
during the RI did not indicate contaminants of concern in this area. Based on the
RI’s findings, the ROD (USAEC, 1994) concluded that remedial action was not
warranted in this area.
However, a sample was subsequently collected in the reservoir for PCB analysis
(associated with the investigation of AOC 16 (Substation 5)). PCBs were detected
at 4.5 mg/kg and additional sampling was conducted as part of the RFI at AOC
16. Soil removal was conducted as part of the removal action at AOC 16. The
Final RFI Report recommended no further action for this SWMU (CH2M HIL,
2005a). The DTSC concurred by approving the Final RFI Report.
Percolation/Evap
oration Ponds
(E/P Ponds)
(RBAAP-11/
SWMU 23)
11, 35
4
Industrial
Wastewater
Treatment Plant
(SWMU 1)
13
7
The E/P Ponds occupy 27 acres on the banks of the Stanislaus River
approximately 1.5 miles north of the main installation. The E/P Ponds were
constructed in 1952 for the disposal of treated effluent generated at the RBAAP.
Based on the RI findings, a removal action was completed in 1993 to address
zinc-contaminated soil. The ROD documented this removal action and concluded
that no further action was necessary at the ponds (USAEC, 1994). RBAAP
continues to use the E/P Ponds for discharge of treated water. This discharge is
regulated under Waste Discharge Requirements (WDRs) issued by the Central
Valley Water Board. The WDRs require ongoing groundwater monitoring at the
E/P Ponds.
The IWTP is a treatment facility for industrial wastewater from electroplating,
cleaning, and metal finishing processes. Treated effluent water is discharged to
the facility E/P Ponds. The IWTP was originally built in 1951. Since 1972,
numerous upgrades and improvements have been implemented at the IWTP. The
redwood equalization tanks were replaced with a concrete equalization basin in
1980. The redwood tanks were the source of the chromium and cyanide
contamination in the IWTP area. The entire IWTP area is now covered with
Page 5 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
concrete or asphalt. A series of concrete drainage trenches captures spills and
overflows and drains to the former influent sump, which is currently used as a
secondary containment sump for the IWTP.
The Phase I RI, conducted between January 1987 and November 1998, included
two soil borings at the IWTP. Samples were analyzed for total and hexavalent
chromium, total and free cyanide, and 1,1-DCE. Soil borings SB-14 and SB-15
were advanced to a depth of 50 feet bgs in the area where the former redwood
tanks were located. At SB-14, total chromium was detected at a concentration of
23.5 mg/kg at 40 feet bgs, and 18.0 mg/kg at 50 feet bgs. At SB-15, total
chromium was detected at a concentration of 22.15 mg/kg at 40 feet bgs, and
55.83 mg/kg at 50 feet bgs (Weston, 1991).
Hazardous
Waste Storage
Area (Drum
Storage Facility)
(SWMU 2)
14
5
The IWTP remains an active unit. The DTSC (in a letter dated July 27, 1998)
states that additional characterization of soil at the IWTP is precluded by existing
equipment. Additional characterization of the IWTP is precluded until permit
closure due to the presence of existing system components. The groundwater
under the IWTP is being addressed under the site RBAAP-03.
The Hazardous Waste Storage Area for the 55-gallon containers is located in
Building 174, which is 100 feet long and 50 feet wide. The capacity of the facility
is 300 drums and consists of a concrete slab with three 400-gallon sumps and 6inch curbing for secondary containment. No known spills have been recorded in
this facility. The Hazardous Waste Storage Area is regulated under the RCRA
Part B permit. RCRA closure is required for this unit. The DTSC concurred with
the position of the Army (as detailed in the original October 30, 1995 version of
the RFI Phase 1 Work Plan) that no further action was required for this unit
(CH2M HILL, 2002a).
This site is NFA based on the investigation results, but is ECP Category 5 based
on groundwater contamination currently exceeding MCLs.
Page 6 of 28
Property
Description
Empty Drum
Storage Area
(Railroad Car
Off-Loading
Area) (SWMU
3)
Drum Staging
Area (IWTP)
(SWMU 4)
ECP Study
Section(s)
ECP
Category
Remedial Actions
15
5
The Empty Drum Storage Area is located to the north of Building 11. This area
was a staging and storage area for empty vendor product drums and scrap storage
that were awaiting vendor pickup for reuse. The Empty Drum Storage Area and
scrap storage area was constructed in July 1953 and is 200 feet long by 27 feet
wide with a 6-inch-thick concrete pad capable of holding 1,350 55-gallon drums.
No known waste was stored in the Empty Drum Storage Area, only scrap
materials such as scrap metal product drums and empty product drums. The types
of products from drums include acids, bases, soaps, and cleaners.
16
7
During the RI, this area was suspected as a potential source of contamination and
underwent extensive investigation. Soil sampling results for the area did not
indicate concentrations of inorganic constituents above background levels.
Results of a soil gas survey in this area indicated that any sources of VOC
contamination are not likely to exist in the area. Based on these findings, the
ROD concluded that remedial action was not warranted (USAEC, 1994). In a
letter dated June 5, 1996, the DTSC concurred with the position of the Army (as
detailed in Revision 2 of the RFI Phase 1 Work Plan [U.S. Army, 1996]) that no
further action was required for this area (CH2M HILL, 2002a).
The Drum Staging Area is a temporary holding area (up to 90 days) located in the
southeastern corner of the IWTP. The IWTP Drum Staging Area consists of a 6inch-thick concrete pad, 26 feet in length and 31-feet wide, coated with an epoxy
sealant. The concrete pad is sloped towards a concrete-lined drainage trench on
the north side, which drains to a large sump that is used to contain aboveground
spills or releases in the IWTP area. Secondary containment is provided.
Use of the IWTP Drum Staging Area began in June 1990. Prior to this time,
drums were accumulated elsewhere on site. The Drum Staging Area paved
surface is inspected periodically for cracks or holes. While past spills have
occurred, there is no indication that spills have penetrated through the paved
surface.
Page 7 of 28
Property
Description
Chromium
Reduction Units
(Building 13)
(SWMU 5)
Chromium
Reduction Units
(Building 1)
(SWMU 6)
Coolant
Recovery Unit
(IWTP) (Hyde
Ultrafiltration
ECP Study
Section(s)
17
18
19
ECP
Category
3
5
7
Remedial Actions
Soil samples indicated no detections above background. The Army, in Revision 4
of the RFI Phase 1 Work Plan dated February 1998, presented justification
supporting a finding that no further action is recommended for this unit at this
time (SOTA, 1998). The DTSC (in a letter dated July 27, 1998) concurred with
this recommendation (CH2M HILL, 2002a).
The chromium reduction unit in Building 13 was installed in 1978. The unit
consists of a 1,200-gallon stainless steel tank. Sodium metabisulfide was added to
chromic acid solution to reduce hexavalent chromium to a trivalent state in a batch
process. The wastewater was then piped to the IWTP for further treatment. No
evidence was found that any releases occurred from this unit. DTSC concurred
with the position of the Army, as detailed in the original version of the RFI Phase
1 Work Plan, that no further action was required at the Chromium Reduction
Units in Buildings 13 and 1 (CH2M HILL, 2002a).
The chromium reduction unit in Building 1 was installed in 1978. The unit
consists of a 1,200-gallon stainless steel tank. Sodium metabisulfide was added to
chromic acid solution to reduce hexavalent chromium to a trivalent state in a batch
process. The wastewater was then piped to the IWTP for further treatment. No
evidence was found that any releases occurred from these units. DTSC concurred
with the position of the Army, as detailed in the original version of the RFI Phase
1 Work Plan, that no further action was required at the Chromium Reduction
Units in Buildings 13 and 1 (CH2M HILL, 2002a).
The coolant recovery unit recovers usable coolant from waste machine coolant oil
by separating the waste mixture into usable coolant (soluble oil), water, and
thermally degraded coolant. The coolant recovery unit is located on the south side
of the IWTP area, immediately south of Building 43. The tanks and recovery unit
Page 8 of 28
Property
ECP Study
Description
Section(s)
Unit) (SWMU 7)
ECP
Category
Remedial Actions
are located on a concrete slab surrounded by a 6-inch concrete containment curb
with a small sump and pump that pumps spilled fluid back into a holding tank.
No releases from the coolant recovery unit have been documented. There is no
evidence of spills outside the containment area and no cracks or holes are apparent
in the containment area or sump.
In RFI Phase 1, the small collection sump was steam cleaned and visually
inspected for cracks or holes in the concrete. No cracks or holes were discovered
and the unit was recommended for closure with no further action. In a letter from
the DTSC, dated August 10, 2006, the DTSC confirmed that no further action was
required for SWMU 7 (DTSC, 2006).
Waste Oil
Accumulation
Unit (Waste Oil
Storage Tank)
(SWMU 8)
20
7
The waste oil tank, installed in 1994, is a 6,000-gallon, UL142 API650 approved,
steel AST located on a 6-inch-thick reinforced concrete slab. The tank is visible
on all sides and the bottom. The secondary containment area, coated with an
epoxy sealant coating, is approximately 30 feet by 20 feet by 3 feet. The 6-inch
reinforced concrete containment area is in excellent condition with no observed
cracks or holes. The epoxy sealant coating is intact and in good condition (CH2M
HILL, 2002a). The waste oil storage tank is located in the southern portion of the
IWTP immediately east of the laboratory. Formerly, an upright, steel AST was
used for storage of waste oil. The 30,000-gallon tank was first used to store waste
oil in 1987. During a 1993 tank certification, the AST failed the certification
because of advanced surface pitting. The former tank, situated in the same
location as the existing waste oil tank, was retired in 1994. No evidence of leaks
from this tank was identified at the time of retirement.
The Army, in Revision 4 of the RFI Phase 1 Work Plan dated February 1998,
presented justification supporting a finding that no further action is recommended
for the Waste Oil Accumulation Unit. The DTSC (in a letter dated July 27, 1998)
Page 9 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
concurred with this recommendation (CH2M HILL, 2002a).
Equipment Wash
Facility
(Building 177
Triple Rinse
Area) (SWMU
9)
Incinerator
(Building 123)
(SWMU 13)
Incinerator
(Building 163)
(SWMU 14)
21
25
26
5
5
5
The Equipment Wash Facility is used to triple-rinse drums that originally
contained hazardous materials. The rinse waters are collected in a sump and
pumped to an oil/water separator, then pumped to the IWTP for further treatment.
DTSC concurred with the position of the Army (as detailed in the original October
30, 1995 version of the RFI Phase 1 Work Plan) that no further action was
required for the Equipment Wash Facility (CH2M HILL, 2002a).
The incinerator at Building 123 was in operation from 1948 through 1972. The
incinerator was used to burn paper and small combustible material. Some
infectious material from the RBAAP dispensary could have been burned in the
unit as well. No reported releases have been identified in these areas. DTSC
concurred with the position of the Army, as detailed in the original October 30,
1995 version of the RFI Phase 1 Work Plan, that no further action was required
for the incinerators in Buildings 123 and 163 (CH2M HILL, 2002a).
The incinerator at Building 163 has been in operation from 1974 through the
present. The incinerator is used to burn paper and small combustible material.
Some infectious material from the RBAAP dispensary could have been burned in
the unit as well. No reported releases have been identified in these areas. DTSC
concurred with the position of the Army, as detailed in the original October 30,
1995 version of the RFI Phase 1 Work Plan, that no further action was required
for the incinerators in Buildings 123 and 163 (CH2M HILL, 2002a).
Page 10 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
Pesticide Storage
Area (West of
Building 11)
(SWMU 15)
Pesticide
Storage Area
(Building 165)
(SWMU 16)
27
28
5
5
This pesticide storage area consists of a concrete aboveground bunker. The
bunker dimensions are approximately 9 feet by 15 feet. The floor walls and roof
of this structure are constructed of solid concrete. The exact dates of pesticide
storage are unknown, however, the replacement storage area (Building 165) was
constructed in July 1975. There were no known wastes stored in this building,
only pesticide products. Visual inspection of the structure showed no signs of
structural deterioration and no floor stains inside the building. In a letter dated
June 5, 1996, DTSC concurred with the Army’s position (as detailed in the April
15, 1996 Revision 2 of the RFI Phase 1 Work Plan) that no further action was
required in the Pesticide Storage Area west of Building 11.
Building 165 is a prefabricated metal building sitting on a concrete floor with
dimensions 14 feet by 14 feet. This building stored pesticides for use at the
facility between 1975 and 1979. Currently the building stores miscellaneous signs
and temporary traffic barriers. No wastes were ever stored in Building 165.
Pesticides and herbicides were stored in their original containers. No releases
have been reported for this unit. During previous investigations, no evidence of
spills or releases were noted and the concrete floor was in good condition. This
unit was periodically washed down with a hose.
Soil sampling was conducted in 2001 to assess the potential for historic releases
from the building. Based on these results, additional characterization was
included in the RFI Phase 1 Work Plan submitted to the DTSC in September
2002. The 2002 sampling activities in and immediately around Building 165
reported only trace detections of pesticides on the north side of the building.
None of the reported detections exceeded IPRGs. Subsequent step out and step
down samples collected for pesticide and herbicide analyses contained only trace
Page 11 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
detections (all below IPRGs) of pesticides in one sample. Herbicides were not
detected above reporting limits in any of the samples collected (CH2M HILL,
2002a). Additional soil sampling adjacent to Building 165 confirmed the presence
of chlordane in a composite sample from one side of the building. Based on the
sampling results, the Final RFI Report recommended no further action be taken
for this SWMU (CH2M HILL, 2005a). The DTSC concurred by approving the
Final RFI Report.
Pesticide
Storage Area
(Building 170)
(SWMU 17)
29
5
Since 1979, the pesticide storage area has been located in Building 170, which is a
600 square-foot steel building erected on a concrete pad. The building has
containment and security fencing. All pesticide mixing occurs within this
building. Periodic pesticide rinsate historically generated in the building was
piped to the concrete sump located outside the building. The concrete sump was
removed in December 1994 under the oversight of the Stanislaus County
Environmental Resources Department. During the removal process, the concrete
material of the sump and the surrounding soil was sampled. The soil sample
contained chlordane, so approximately 20 yards of soil were excavated for
disposal. Visual inspection of the concrete sump did not reveal any holes, cracks,
or deterioration of the walls or floor of the sump. Because the concrete floor of
the building was in good condition (without cracks or stains) and the sump had
been removed, no sampling was performed during the RI (NI, 2006b). In a letter
dated June 5, 1996, the DTSC concurred with the position of the Army (as
detailed in the April 15, 1996 Revision 2 of the RFI Phase 1 Work Plan) that no
further action was required at the Pesticide Storage Area in Building 170 (CH2M
HILL, 2002a).
Page 12 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
Waste ZincCyanide Solution
Neutralizing
Tanks (SWMU
19)
31
7
The waste zinc-cyanide neutralization tanks consisted of two aboveground steel
tanks in the IWTP area: the cyanide reaction tank and the cyanide equalization
tank. The two tanks were installed on January 27, 1955 and operated until 1958,
and it is believed that the cyanide reaction tank was not used after 1958. The
cyanide equalization tank was later used for waste oil storage and became SWMU
8. No information is available concerning the condition of the cyanide reaction
tank at closure. No evidence exists that a release ever occurred from this unit in
the short period of operation (1955 through 1958). Both tanks were removed on
September 27, 1994. The Army, in Revision 4 of the RFI Phase 1 Work Plan,
presented justification supporting a finding that no further action is recommended
at the Waste Zinc-Cyanide Solution Neutralizing Tanks. The DTSC (in a letter
dated July 27, 1998) concurred with this recommendation (CH2M HILL, 2002a).
Industrial Waste
Pipe Leak
(SWMU 24)
36
4
Underground
Storage Tanks
(SWMU 25)
37
2
An industrial waste pipe leak occurred in 1990 at the southern end of Building 13.
This pipe carries wastewater from the chromium reduction unit in Building 13 to
the IWTP. The soil was excavated in conjunction with the repairs. The
excavation area was then sampled during the RI to determine if residual
contamination existed. Sample results indicated that elevated levels of inorganics
did not exist in this area. The ROD concluded that remedial action was not
warranted (USAEC, 1994). The DTSC concurred with the position of the Army
(as detailed in the original October 30, 1995 version of the RFI Phase 1 Work
Plan) that no further action was required at the Industrial Waste Pipe Leak (CH2M
HILL, 2002a).
Numerous USTs existed at RBAAP to store petroleum products. No known
releases have been reported. All USTs were closed at the facility under the
oversight of the Regional Water Quality Control Board during 1994. The DTSC
concurred with the position of the Army (as detailed in the original October 30,
1995 version of the RFI Phase 1 Work Plan) that no further action was required at
the USTs under the RCRA program (CH2M HILL, 2002a).
Page 13 of 28
Property
Description
Mortar Line
Accumulation
Area (Building
4) (AOC 1)
Machine Shop
Accumulation
Area (Building
9) (AOC 2)
ECP Study
Section(s)
ECP
Category
Remedial Actions
38
3
The Mortar Line Accumulation Area (Building 4) was located on the west end of
Building 4. The temporary hazardous waste storage area was 30 feet by 45 feet
and had the capability to store 330 55-gallon drums. The accumulation area was
activated in June 1989 and was deactivated in February 1991. The area
temporarily stored the following hazardous waste: spent machine oils, spent
chlorinated oils, spent acids, spent soaps, pickling sludge, spent solvents, zinc
phosphate chips, floor dry mixed with oils, spent chromic acid, waste salts, waste
paints and waste thinners. A site inspection showed the concrete area to be in
good condition with no cracks or staining and there were no known spills or
releases in this area. Therefore, no further action is necessary in this area. In a
further action was required for this AOC (CH2M HILL, 2002a).
39
5
below MCLs.
The Machine Shop Accumulation Area was a satellite storage area for hazardous
waste located in the north end of Building 9. This accumulation area was only 9
feet by 9 feet in size, with a possible storage capacity of 20 55-gallon drums. This
area was in use from June 1989 through March 1992. The following types of
wastes were stored: spent machine oils, spent oils, and waste solvents. A site
inspection showed the concrete area to be in good condition with no cracks or
staining. There were no known spills or releases. Therefore, no further action is
necessary in the Machine Shop Accumulation Area. In a letter dated June 5,
1996, the DTSC concurred with the position of the Army (as detailed in the April
15, 1996, Revision 2 of the RFI Phase 1 Work Plan) that no further action was
required for this AOC (CH2M HILL, 2002a).
on groundwater contamination currently exceeding MCLs contamination.
Page 14 of 28
Property
Description
Vehicle
Maintenance
Accumulation
Area (Building
15) (AOC 3)
Grenade Casing
Line
Accumulation
Area (AOC 4)
Horizontal ASTs
– Propane
Storage Tanks
(AOC 8A)
ECP Study
Section(s)
ECP
Category
Remedial Actions
40
5
The Vehicle Maintenance Accumulation Area is a hazardous waste satellite
storage area located in Building 15. The area is 3 feet by 5 feet and has capacity
for four 55-gallon drums. This site was activated for use in June 1989 and is still
in use. Materials stored include waste oil, spent antifreeze, and waste solvent. A
site inspection showed that the concrete area was in good condition with no cracks
or staining. No known spills or releases have occurred in this area. Based on the
small quantity of drums stored at this site and the lack of evidence of past spills or
releases, no further action is deemed necessary. In a letter dated June 5, 1996, the
DTSC concurred with the position of the Army (as detailed in the April 15, 1996
41
45
5
5
The Grenade Casing Line Accumulation Area was used as hazardous waste
satellite storage area. This 9-foot-by-9-foot accumulation area was located north
of Building 13 and had a storage capacity of 20 55-gallon drums. This area was
used from June 1989 through June 1990 for storage of waste chlorinated oil and
spent caustic cleaner. The site inspection showed the concrete area to be in good
condition with no cracks or staining. No known spills or releases occurred at this
unit. Based on these findings, no further action is necessary in this area. In a
The propane storage area consists of 16 horizontal pressure tanks used for the
storage of propane liquid. The storage area is located in the northeastern end of
RBAAP. Each horizontal steel tank has a 10-foot diameter, and is 50 feet long
with a 30,000-gallon capacity. The propane storage tanks were built in 1952 and
Page 15 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
are currently still in service. The propane storage tank area has been leased to a
commercial propane vendor. No known waste has been placed in the tanks, only
liquid propane, and there have not been any known releases or spills. Because this
area is used only for the storage of propane and the nature of propane would be to
vaporize if a release did occur, no further action is necessary in this area. In a
Horizontal ASTs
– Transformer
Oil Storage
Tanks (including
Transformer Oil
Distribution
System) (AOC
8B)
46
5
AOC 8B currently consists of a pump house (Building 85) and an abandoned
underground pipeline distribution system historically used to transport transformer
coolant oil to transformers. The system originally was built in the 1940s and was
used until 1970. An estimated 3,500 to 4,000 feet of underground supply and
return lines, made of 1.5- to 2.5-inch single-wall steel pipe, are located between
the former tanks, the pump house, the former transformer locations, and Building
15. The pipelines have been cleaned (as requested by the DTSC) and
encapsulated with cement slurry. Originally, three Transformer Oil Storage Tanks
were used for oil storage; the three 8,000-gallon ASTs sat in reinforced concrete
cradles, and all sides and the bottom of the tanks were visible. The three tanks
were cleaned out, tested for PCBs, and removed from the facility. No known
releases or spills occurred from this system. A visual inspection in 1997 of the
tank area and other system components did not show any indication of tank
release. However, during the 1997 inspection, stains of unknown origin were
observed on the floor in Building 85.
Soil samples were collected in 2001 and 2003 in the bermed area that formerly
held the transformer oil storage tanks, adjacent to the pipeline heading to Building
15, and adjacent to the former transformer pads and the main distribution line.
Based on these results, 120 cy of soil contaminated with PCBs (as Aroclor-1260)
Page 16 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
at concentrations greater than industrial preliminary remediation goals (IPRGs)
were removed within the bermed area. Confirmation samples from the excavation
floor were nondetect. Based on these findings, no further action is recommended
at the Oil Storage Tanks location of AOC 8B.
During the 2004 Storage Tank Area Soil Removal, additional samples were
collected adjacent to former transformer pads along the distribution lines. These
sample results were less than IPRGs and, combined with the prior two sets of
sampling results along the distribution system, confirm that significant releases
did not occur along the distribution system. The Final RFI Report recommended
no further action for the transformer oil storage tanks or distribution system
(CH2M HILL, 2005a). The DTSC concurred with this recommendation by
approving the Final RFI Report.
Vertical ASTs –
Fuel Oil Storage
Tanks (AOC 9A)
47
3
There are two ASTs located side by side in the east-central portion of the
installation. The two welded-steel storage tanks are 35 feet in diameter and 34
feet tall with a storage capacity of 250,000 gallons per tank. The tanks were built
in November 1952 and were used through 1958 to store fuel oil. When the
groundwater treatment system was installed in 1991, the tanks were converted for
temporary storage of treated groundwater. The two fuel oil storage tanks were
cleaned and internally inspected in 1991. The results of the visual inspection
showed no signs of leakage. Additionally, the tanks were ultrasonically inspected
in November 1992 and found to be sound. The associated piping is also believed
to be sound. No further investigation is required in this area. In a letter dated
June 5, 1996, the DTSC concurred with the position of the Army (as detailed in
the April 15, 1996 Revision 2 of the RFI Phase 1 Work Plan) that no further
action was required for this AOC (CH2M HILL, 2002a).
Page 17 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
Vertical ASTs –
Fire Sprinkler
Storage Tank
(AOC 9B)
48
1
Loading Racks –
Propane Farm
Loading/Unloadi
ng (AOC 11A)
50
5
The Fire Sprinkler Storage Tank is located in the southeast portion of RBAAP.
This tank is constructed of steel with welded seams with a storage capacity of
1,000,000 gallons. The tank supplies water for the fire sprinkler system and the
high-pressure (150 psi) water distribution system for the main production area.
This tank never has contained waste, just water. The tank and associated piping
show no signs of deterioration (other than weathering) and are believed to be
sound. In a letter dated June 5, 1996, DTSC concurred with the position of the
Army (as detailed in the April 15, 1996 Revision 2 of the RFI Phase 1 Work Plan)
that no further action was required for this AOC.
This AOC consists of the two propane tank-loading racks located at the propane
tank farm. Each rack is 8 feet by 6 feet and equipped with 100-gpm pumps for
pumping propane to the propane tanks from railroad tanker cars. The propane
farm was built in 1952 and has been in use since that time. The level of activity
has varied greatly depending on the amount of onsite propane use. No waste has
ever been placed in the propane farm or the loading/unloading racks. There are no
known releases or spills at the loading racks. Because the physical characteristics
of propane would cause it to vaporize if there was a release, there is no potential
for soil or groundwater to be contaminated. In a letter dated June 5, 1996, the
DTSC concurred with the position of the Army (as detailed in the April 15, 1996
Loading Racks –
Fire Sprinkler
Pumping Station
51
2
The Fire Sprinkler Pumping Station consists of fire pumps and associated
controls, piping, and valves. The Fire Sprinkler Pumping Station is 49 feet by 21
feet and has two 1,000-gpm pumps and two 1,000-gpm propane-powered backup
Page 18 of 28
Property
Description
(AOC 11B)
ECP Study
Section(s)
Industrial
Wastewater
Collection
System (AOC
12)
52
ECP
Category
3
Remedial Actions
pumps. No waste has been placed in the Fire Sprinkler Pumping Station and no
known releases or spills have occurred. In a letter dated June 5, 1996, DTSC
concurred with the position of the Army (as detailed in the April 15, 1996
this AOC.
The IWCS is a system of underground piping and waste sumps that historically
collected industrial wastewater from the production plant and transferred it to the
IWTP. The system consists of an estimated 3,500 to 4,000 linear feet of vitrified
clay and cast iron pipe ranging from 4 inches to 21 inches in diameter. The sumps
that were historically connected to the system were constructed of brick or
concrete. The system was built after the Army acquired the production plant in
1951. The IWCS has been disconnected from the production plant. The
collection sumps were filled with concrete in the late 1990s, when a new, abovegrade collection system was installed.
Soil investigations involving collection of soil samples from within and adjacent
to the sumps and trenches associated with production lines 2, 3, 4, and 5 were
completed in accordance with the DTSC-approved work plans. Soil samples were
collected from both the production line trenches and sumps. The investigations
did not identify contaminants at elevated concentrations in the soil samples.
During the RFI Phase 1, a video survey was conducted on the collection system
pipelines and soil samples were collected near major cracks or breaks observed in
the video survey (CH2M HILL, 2002a). The video survey and subsurface
sampling adjacent to the IWCS did not indicate that significant leaks occurred and
soil analytical results did not contain contaminants that exceeded IPRGs. The
Final RFI recommended that no further action be taken along the IWCS while the
IWTP is still active (CH2M HILL, 2005a). The DTSC concurred with this
recommendation when they approved the Final RFI Report. In a letter from the
DTSC, dated August 10, 2006, the DTSC confirmed that no further action was
required for SWMU 12 (DTSC, 2006).
Page 19 of 28
Property
Description
Draw Lube
System
(Building 178)
(AOC 13)
Zinc-Cyanide
Wastewater
Collection
System (AOC
14)
ECP Study
Section(s)
ECP
Category
Remedial Actions
53
5
The Draw Lube System in Building 178 is a chlorinated oil filter, heating, and
cooling system. The system has an oil storage capacity of 385 gallons. It was
built in 1987 and operated until 1990. In March 1993, during layaway activities
for Building 13, contamination was discovered on the south side of Building 178.
Thirteen soil samples were collected and elevated oil and grease concentrations
were detected at two locations (three total samples). Two additional hand-auger
borings were installed adjacent to Building 178 to confirm the limited extent of
contamination. All samples from these borings were non-detect for TPH. A soil
removal action was taken to address the petroleum-contaminated soil. The upper
3 feet of soil was excavated in an area approximately 6-feet wide by 16-feet long
immediately adjacent to Building 178. Extraction well 54B is located about 100
yards downgradient from Building 178. This well was sampled several times for
oil and grease in the three years following the release with all sample results being
nondetect. In a letter dated June 5, 1996, the DTSC concurred with the position of
the Army (as detailed in the April 15, 1996 Revision 2 of the RFI Phase 1 Work
Plan) that no further action was required for this AOC (CH2M HILL, 2002a).
54
3
The cyanide wastewater collection system operated from 1954 to 1958 and
consists of approximately 1,400 to 1,500 feet of 4-inch to 6-inch diameter iron or
vitrified clay pipe. The use of this system was discontinued due to production
capability changes. The system has been disconnected from the production plant
and the collection sumps filled with concrete in the late 1990s.
Soil samples collected below and near sump 6-11 at depths of 11 to 13 feet did not
identify elevated cyanide contaminant concentrations. The soil investigations
completed for the portions of the cyanide wastewater collection system near
production lines 2 through 5 did not identify any significantly elevated
concentrations (CH2M Hill, 2002). During the RFI Phase 1, a soil boring was
advanced at one point along the line and no visual or analytical indication of
Page 20 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
contamination was found. Coupled with the fact that this waste line only saw
limited operation from 1954 to 1958, the probability of significant releases of
contamination is low. Therefore, the Final RFI recommended no further action
for AOC 14 (CH2M HILL, 2005a). The DTSC concurred with this
recommendation by approving the Final RFI Report. In a letter from the DTSC,
dated August 10, 2006, the DTSC confirmed that no further action was required
for AOC 14 (DTSC, 2006).
Building 13
Temporary
Wastewater Line
(AOC 15)
Substation 5
(AOC 16)
13
53, 1053
3
4
below MCLs.
Building 13 was not originally connected to the IWCS (AOC 12). A temporary
wastewater pipeline was installed to facilitate transmission to the IWTP. The line
was made of polyvinyl chloride (PVC) and operated for a relatively short period
(ending when grenade casing production stopped in 1990). This line has been
removed from Building 13 and is capped outside of the building. There is no
documentation of any spills or releases associated with this unit. DTSC approval
of the Current Conditions Report (CH2M HILL, 2002a) was considered
concurrence that no further action is necessary. In a letter from the DTSC, dated
August 10, 2006, the DTSC confirmed that no further action was required for
AOC 15 (DTSC, 2006).
below MCLs.
Substation 5 is located on the east side of the main installation, just east of the
production area and just south of Building 11. Substation 5 consists of three
transformers sitting on a concrete pad. The concrete pad, approximately 16 feet
by 32 feet, is inside a gated, chain-link-fence enclosure that measures 44 feet by
22 feet. The concrete pad is surrounded by several feet of gravel-covered ground.
Soil samples were collected from the border of the Substation 5 transformer pad in
2001 (CH2M HILL, 2002a). Additional characterization was completed under
Page 21 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
the RFI Phase 1. Soil contaminated with PCBs (as Aroclor-1260) at
concentrations greater than IPRGs has been successfully removed from the gravel
and soil areas surrounding Substation 5 and from the stormwater discharge basin.
Confirmation samples collected in 2003 from the excavation were non-detect.
Therefore, the Final RFI recommended no further action for AOC 16 (CH2M
HILL, 2005a). The DTSC concurred by approving the Final RFI Report. In a
letter from the DTSC, dated August 10, 2006, the DTSC confirmed that no further
action was required for AOC 16 (DTSC, 2006).
Building 1
1001
7
None. Category 7 based on the potential for the soil beneath the remaining sumps
or pits to be impacted by hazardous substances.
Building 6
1006
7
Building 8
1008
7
Paint and Oil
Storage, Oil
Recycling and
Transport
(Building 11)
1011
3
As a part of the EBS (Norris-Riverbank Environmental, 1998a), five near-surface
soil samples were collected from the graveled areas just outside Building 11 along
the southern and western sides. Aroclor 1260 was identified in all five sample
results, in concentrations ranging from 400 μg/kg to 1,000 μg/kg.
This area was further investigated in the 2007 SI (CH2M HILL, 2008). The SI
samples show a single detection of Aroclor 1260 at a concentration of 38 μg/kg,
which is well below the industrial and residential PRGs and TSCA cleanup
requirements. These sampling results indicate that the area of soil contaminated
with PCBs above regulatory screening criteria is localized in nature. Although the
source of the PCBs in soil is not known, two electric substations in close
proximity to the areas sampled have been reported. Since the area is covered with
asphalt, the current contact exposure pathway to soils is minimized and no further
action is recommended. EPA Region 9 concurred with these findings in a letter
dated 14 December 2007.
Page 22 of 28
Property
Description
Boiler House
ECP Study
Section(s)
ECP
Category
Remedial Actions
1012
3
Norris-Riverbank Environmental conducted a Phase I EBS for Building 12 in
1998. This EBS included analysis of six near-surface soil samples obtained from
areas just outside Building 12. Results of this analysis showed evidence of oil and
gas in two of the samples (660 mg/kg and 410 mg/kg), chromium in one sample
(144 mg/kg), and lead in one sample (215 mg/kg). The report concluded that an
additional Phase II investigation was recommended (Norris-Riverbank, 1998a; NI,
2006b).
The ECP Report classified this site as Category 7 and recommended it for
investigation in the SI (CH2M HILL 2006, 2008). However, subsequent analysis
showed the detected concentrations to be below IPRGs; therefore, no further
investigation is required.
Building 95,
Transformer
Area –
Substation
No. 1
1095
3
Building 97,
Transformer
Area –
Substation
No. 1
1097
3
Oil staining was observed on the concrete at the base of the transformer at
Substation No. 1 during the Phase I ECP visual site inspection on June 22, 2006.
A soil sample composited from two locations in the shallow subsurface soils (0.5
to 1 foot bgs) was collected during the 2007 SI (CH2M HILL, 2008). Aroclor
1260 was detected in the composite sample (230 μg/kg) and field duplicate (260
μg/kg). This concentration is below the industrial PRG and slightly above the
residential PRG. Since the future use of the site is industrial use, no further action
was recommended. EPA Region 9 concurred with these findings in a letter dated
14 December 2007.
During the ECP’s visual site inspection, oil staining was observed on the concrete
at the base of two transformers with PCB concentrations of 64 ppm and 33 ppm.
The integrity of the concrete pad was in good condition. A gravel area surrounds
the concrete pad. Staining was not observed on the gravel or in the soil. The ECP
Report classified this site as Category 7 based on the potential for PCBs to have
impacted the soil in the unpaved area.
During the SI, one composite sample was collected from three discrete locations
in surface soil (0 to 0.5 foot bgs) and shallow subsurface soil (0.5 to 1 foot bgs).
Aroclor 1260 was detected in a composite surface soil sample (0 to 0.5 foot bgs)
Page 23 of 28
Property
Description
Building 101,
Transformer
Area –
Substation
Spare
ECP Study
Section(s)
1101
ECP
Category
3
Remedial Actions
at a concentration (330 μg/kg) exceeding the residential PRG but well below the
industrial PRG. The deeper sample collected from 0.5 to 1 foot bgs contained
Aroclor 1260 at a concentration of 23 μg/kg, which is well below the industrial
and residential PRGs. Based on the future industrial use, the SI recommended no
further action for this site. EPA Region 9 concurred with these findings in a letter
During the ECP’s visual site inspection, oil staining was observed on concrete at
the base of one inactive transformer with an unknown PCB concentration. No
staining was observed in the gravel areas adjacent to the concrete pad. The pad
appeared to be good condition. The ECP Report classified this site as Category 7
based on the potential for PCBs to have impacted the soil in the unpaved area.
During the SI, one composite sample was collected from three discrete locations
in surface soil (0 to 0.5 foot bgs) and shallow subsurface soil (0.5 to 1 foot bgs).
Aroclor 1260 was detected in the composite surface soil sample at a concentration
of 1,900 μg/kg, which exceeds industrial and residential PRGs. However, in the
0.5 to 1 foot bgs sample, the Aroclor 1260 concentration of 33 μg/kg is well below
the industrial and residential PRGs.
The SI recommended no further action for this site based on the following factors:
• While exceeding the industrial PRG, the PCB concentration in soil is well
below TSCA requirements. Under TSCA in 40 CFR 761.61, PCB
concentrations may remain in soils up to 50,000 μg/kg in low-occupancy
outdoor electrical substation areas.
• PCB concentrations in deeper soils are well below the industrial and
residential PRGs, indicating that the contamination is superficial.
• Land use is currently industrial and expected to remain industrial.
• Access restrictions limit the potential for exposure to this area.
EPA Region 9 concurred with these findings in a letter dated 14 December 2007.
Page 24 of 28
Property
Description
Building 138,
Transformer
Substation No.
16
Building 139,
Water Storage
Tank
Building 145,
Transformer
Substation No.
17
ECP Study
Section(s)
1138
ECP
Category
1
Remedial Actions
None required.
1139
1
None required.
1145
3
During the ECP’s visual site inspection, oil staining was observed on the concrete
at the base of two transformers with PCB concentrations of 28 ppm and 134 ppm.
The integrity of the concrete pad showed minor cracking. A gravel area surrounds
the concrete pad. The ECP Report classified this site as Category 7 based on the
potential for PCBs to have impacted the soil in the unpaved area and beneath the
concrete pad.
One composite sample (from three discrete points) was collected from surface soil
(0 to 0.5 foot bgs) and shallow subsurface soil (0.5 to 1 foot bgs) along the
northern side of the concrete pad, which slopes toward the north. In addition to
the composite sample, two discrete surface soil (0 to 0.5 foot bgs) and shallow
subsurface soil (0.5 to 1 foot bgs) samples were collected on the north and south
sides of the concrete pad where stained gravel was observed.
Aroclor 1260 was the only PCB detected in samples collected near the substation.
Aroclor 1260 concentrations exceed residential and industrial PRGs in one
discreet surface soil sample at 2,000 μg/kg, and in the composite surface soil
sample at 9,500 μg/kg. In the remaining samples, the Aroclor 1260 concentrations
were below the industrial PRG, or in some cases, below both the industrial and
residential PRGs.
Although the PCB concentrations exceeded the industrial PRG, the results are
well below TSCA requirements of 50,000 μg/kg in low occupancy outdoor
electrical substation areas. Future use of this area is expected to be industrial, and
Page 25 of 28
Property
Description
ECP Study
Section(s)
ECP
Category
Remedial Actions
the substation area access is controlled by a locked fence with signage. The
substation has to be de-energized for access to be permitted and thus, access is
strictly controlled. As a result, the SI recommended no further action for this site.
EPA Region 9 concurred with these findings in a letter dated 14 December 2007.
Category 5 based on groundwater contamination currently exceeding MCLs.
West Parking
2002
5
North Utilities
2004
3
West Utilities
2005
5
Category 3 based on groundwater contamination currently present but below
MCLs.
East Utilities
2006
5
Southeast
Utilities
South Utilities
2007
3
2008
5
MCLs.
North Open
Storage
2009
5
West Open
Storage
Central Storage
2010
3
2011
5
MCLs.
2013
5
2014
5
2015
5
North
Warehouse
Storage
West
Warehouse
Storage
Water Storage
Page 26 of 28
Property
Description
South
Warehouse
Storage
West Railroad
Storage
ECP Study
Section(s)
2016
East Railroad
Storage
Fuel Storage
2018
Hazardous
Waste Storage
Administration
Open Area
Medical Open
Area
Production Open
Area
E/P Ponds Soil
Staining Area
ECP
Category
3
Remedial Actions
MCLs.
2017
3
MCLs.
3
MCLs.
2019
5
2020
5
2021
5
2022
5
2023
5
2024
5
Preliminary soil samples indicated levels of motor oil at concentrations of 276,000
mg/kg. The U.S. Army is investigating and pursuing clean-up efforts for the site.
Category 1: Areas where no release or disposal of hazardous substances or petroleum products has occurred (including no migration
of these substances from adjacent areas).
Category 2: Areas where only release or disposal of petroleum products has occurred.
Category 3: Areas where release, disposal, and/or migration of hazardous substances has occurred, but at concentrations that do not
require a removal or remedial response.
Category 4: Areas where release, disposal, and/or migration of hazardous substances has occurred, and all removal or remedial
actions to protect human health and the environment have been taken.
Category 5: Areas where a release, disposal, and/or migration of hazardous substances has occurred, and removal or remedial actions
Page 27 of 28
are underway but all required remedial actions have not yet taken place.
Category 6: Areas where a release, disposal, and/or migration of hazardous substances has occurred, but required actions have not yet
been implemented.
Category 7: Areas that are not evaluated or require additional evaluation.
Page 28 of 28
ENCLOSURE 4
TABLE 2 – NOTIFICATION OF HAZARDOUS SUBSTANCE STORAGE, RELEASE, OR DISPOSAL
Description
Three, 11,500-gallon steel
ASTs located at Bldgs. 4,5,
and 6.
Name of
Hazardous
Substance(s)
Cyanide
Date of Storage,
Release, or
Disposal
Remedial Actions
Unknown
These tanks were decontaminated, dismantled, and
disposed of. This is documented in the Closure of Three
Cyanide Tanks at Building 4, 5, and 6 Report (NorrisRiverbank, 1998h).
Tank No. G71, a 1,200Hazardous waste
gallon steel tank, is located at
Bldg. 44 (IWTP)
1996 - present
None.
G2 (Bldg. 44)
Equalization Tank
1970s - present
G7 (Bldg. 44)
Reactor Clarifier
1970s - present
Industrial Wastewater Treatment Plant (IWTP) Process
Tank. Investigation of this unit will be conducted at
permit closure.
IWTP Process Tank. Investigation of this unit will be
conducted at permit closure.
G8 (Bldg. 44)
Thickener
1970s - present
Tank No. 6, a 900-gallon
concrete tank (Bldg. 170)
Pesticides
IWTP Process Tank. Investigation of this unit will be
conducted at permit closure.
Unknown – 1994 Tank removed.
Tank No. 12, a 1,300-gallon Slurry water,
steel tank (Bldg. 7)
Asbestos cuttings
Tank No. 22, an 800-gallon
tank, located at Bldg. 1
Unknown – 1973 Tank closed in place.
Paint
Page 1 of 19
TABLE 2 – NOTIFICATION OF HAZARDOUS SUBSTANCE STORAGE, RELEASE,
OR DISPOSAL (CONTINUED)
Description
Tank No. 23, an 800-gallon
tank, located at Bldg. 1
Name of
Hazardous
Substance(s)
Paint
Date of Storage,
Release, or
Disposal
Remedial Actions
Tank No. 24, a 990-gallon
Varnish
steel tank, located at Bldg. 2
Tank No. 25, an 880-gallon Varnish
Tank No. 26, a 1,585-gallon Varnish
steel tank, located at Bldg.
160
Page 2 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
Tank No. T77, a 1,000gallon steel tank, located at
Area 77
Sulfuric Acid
Landfill (RBAAP01/SWMUs 10 and 11)
Spent pot-liner
(cyanide),
chromium
contaminated
bricks,
incineration and
disposal of
industrial sludges
and solid waste,
including paper,
dunnage, oils,
grease,
solvents, hospital
wastes, and
construction
debris
Groundwater Contamination Chromium,
(RBAAP-03)
cyanide
1956 – 1995
1942-1966
1940s – 1970s
Tank removed.
The landfill was addressed under the 1994 ROD.
Remedial activities at the landfill were completed in
October 1995. The final landfill cover consisted of a
two-foot-thick vegetative cover layer, a one-quarterinch-thick geosynthetic liner, and a two-foot-thick
foundation layer. Long-term maintenance is required
until 2015.
The Army installed an interim groundwater treatment
system and provided alternative drinking water sources
to all affected offsite residences. In 1992, the Army
completed the extension of the Riverbank City water
Page 3 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
system, which connected services to all potentially
affected residents. The final sitewide ROD signed in
March 1994 required expansion of the IGWTS to fully
capture groundwater contamination. The expanded
system began operation in 1997 and is now capturing all
contaminated groundwater and has resulted in decreasing
contamination concentration levels. The groundwater
plume has not yet reached the remediation goals of 50
μg/L for chromium and 200 μg/L for cyanide. The
Second Five-Year Review determined that the
groundwater remedial action is currently protective of
human health and the environment (AHTNA, 2006).
The plume is monitored through quarterly groundwater
sampling. The Army is currently preparing an
Explanation of Significant Differences (ESD) to conduct
in-situ treatment to address chromium. Remedial actions
at RBAAP-03 will continue until remedial goals have
been reached.
Building 13 Chromium
Pretreatment System
(RBAAP-05/ SWMU 5)
Chromium
IWTP Sulfuric Acid Spill
(RBAAP-06/AOC 6)
Sulfuric Acid
1978 - present
1956
No direct sampling was conducted around this system
because it is an operating facility. However, the
groundwater investigation concluded that the major
source of chromium contamination was the leaking tanks
of the IWTP prior to the system upgrade. The site-wide
ROD documented that no further action is required at
this site (USAEC, 1994).
A 500-gallon sulfuric acid spill occurred at the Sulfuric
Acid Feed System. Groundwater monitoring for sulfate
was conducted. Historically, sulfate concentrations in
Page 4 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
groundwater in the IWTP area were present at levels
slightly above the secondary MCL of 250 milligrams per
liter (mg/L). Slightly elevated sulfate concentration were
found during the Exploratory Phase 1B, but it is
unknown if they were the result of the 1956 sulfuric acid
spill. The groundwater extraction system will capture
any sulfate contamination in groundwater. The effluent
from the GWTP is monitored for sulfate under the
NPDES permit.
Building 13 Phosphoric Acid Phosphoric Acid
Spill (RBAAP-07/AOC 7)
Southeast Storm Reservoir
(RBAAP-08/SWMU
21/AOC 16)
PCBs
1978
1954 - present
In a letter dated July 27, 1998, the DTSC concurred with
the position of the Army (as detailed in the February
1998 Revision 4 of the RFI Phase 1 Work Plan) that no
further action was required for this AOC (CH2M HILL,
2002a).
In 1978, a phosphoric acid spill occurred in the
Phosphate Coating Area. Because the spill was
contained inside the building, and then in the sewer
system, there is no further action required in this area. In
a letter dated June 5, 1996, the DTSC concurred with the
position of the Army (as detailed in the April 15, 1996
Revision 2 of the RFI Phase 1 Work Plan) that no further
Investigations during the RI did not indicate
contaminants of concern in this area. Based on the RI’s
findings, the ROD (USAEC, 1994) concluded that
remedial action was not warranted in this area.
Page 5 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
However, a sample was subsequently collected in the
reservoir for PCB analysis (associated with the
investigation of AOC 16 (Substation 5)). PCBs were
detected at 4.5 mg/kg and additional sampling was
conducted as part of the RFI at AOC 16. Soil removal
was conducted as part of the removal action at AOC 16.
The Final RFI Report recommended no further action for
this SWMU (CH2M HIL, 2005a). The DTSC concurred
by approving the Final RFI Report.
Percolation/Evaporation
Zinc, TPH
Ponds (E/P Ponds) (RBAAP11/ SWMU 23)
1952 - present
Industrial Wastewater
Chromium,
Treatment Plant (SWMU 1) cyanide
1951 – present
Based on the RI findings, a removal action was
completed in 1993 to address zinc-contaminated soil.
The ROD documented this removal action and
concluded that no further action was necessary at the
ponds (USAEC, 1994). RBAAP continues to use the
E/P Ponds for discharge of treated water. This discharge
is regulated under Waste Discharge Requirements
(WDRs) issued by the Central Valley Water Board. The
WDRs require ongoing groundwater monitoring at the
E/P Ponds.
Since 1972, numerous upgrades and improvements have
been implemented at the IWTP. The redwood
equalization tanks were replaced with a concrete
equalization basin in 1980. The redwood tanks were the
source of the chromium and cyanide contamination in
the IWTP area.
The Phase I RI, conducted between January 1987 and
November 1998, included two soil borings at the IWTP.
Samples were analyzed for total and hexavalent
Page 6 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
chromium, total and free cyanide, and 1,1-DCE. Soil
borings SB-14 and SB-15 were advanced to a depth of
50 feet bgs in the area where the former redwood tanks
were located. At SB-14, total chromium was detected at
a concentration of 23.5 mg/kg at 40 feet bgs, and 18.0
mg/kg at 50 feet bgs. At SB-15, total chromium was
detected at a concentration of 22.15 mg/kg t 40 feet bgs,
and 55.83 mg/kg at 50 feet bgs (Weston, 1991).
The IWTP remains an active unit. The DTSC (in a letter
dated July 27, 1998) states that additional
characterization of soil at the IWTP is precluded by
existing equipment. Additional characterization of the
IWTP is precluded until permit closure due to the
presence of existing system components. The
groundwater under the IWTP is being addressed under
the site RBAAP-03.
Hazardous Waste Storage
Hazardous waste
Area (Drum Storage Facility) drums (flammable,
caustics, and
(SWMU 2)
acids)
Drum Staging
Area (IWTP) (SWMU 4)
Hazardous waste
drums
Unknown
No known spills have been recorded in this facility. The
Hazardous Waste Storage Area is regulated under the
RCRA Part B permit. RCRA closure is required for this
unit. The DTSC concurred with the position of the
Army (as detailed in the original October 30, 1995,
version of the RFI Phase 1 Work Plan) that no further
action was required for this unit (CH2M HILL, 2002a).
1990 - present
There is no indication that has been a release to the
environment through the paved surface. Soil samples
indicated no detections above background. The Army, in
Revision 4 of the RFI Phase 1 Work Plan dated February
Page 7 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
1998, presented justification supporting a finding that no
further action is recommended for this unit at this time
(SOTA, 1998). The DTSC (in a letter dated July 27,
1998) concurred with this recommendation (CH2M
HILL, 2002a).
Chromium Reduction Units
(Building 13) (SWMU 5)
Chromic acid,
sodium
metabisulfide
1978 – present
No evidence was found that any releases occurred from
this unit. DTSC concurred with the position of the
Army, as detailed in the original version of the RFI
Phase 1 Work Plan, that no further action was required at
the Chromium Reduction Units in Buildings 13 and 1
(CH2M HILL, 2002a).
Chromium Reduction Units
Chromic acid,
sodium
metabisulfide
1978 – present
No evidence was found that any releases occurred from
these units. DTSC concurred with the position of the
Army, as detailed in the original version of the RFI
Phase 1 Work Plan, that no further action was required at
the Chromium Reduction Units in Buildings 13 and 1
(CH2M HILL, 2002a).
No releases from the coolant recovery unit have been
documented. In RFI Phase 1, the small collection sump
was steam cleaned and visually inspected for cracks or
holes in the concrete. No cracks or holes were
discovered and the unit was recommended for closure
with no further action. In a letter from the DTSC, dated
August 10, 2006, the DTSC confirmed that no further
action was required for SWMU 7 (DTSC, 2006).
Coolant Recovery Unit
Coolant
(IWTP) (Hyde Ultrafiltration
Unit) (SWMU 7)
Equipment Wash Facility
(Building 177 Triple Rinse
Hazardous waste
drums
1989 – early
1990s
Unknown
The rinse waters are collected in a sump and pumped to
an oil/water separator, then pumped to the IWTP for
Page 8 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Area) (SWMU 9)
Pesticides
Pesticide Storage Area
1975 -1979
Remedial Actions
further treatment. DTSC concurred with the position of
the Army (as detailed in the original October 30, 1995,
version of the RFI Phase 1 Work Plan) that no further
action was required for the Equipment Wash Facility
(CH2M HILL, 2002a).
No releases have been reported for this unit. During
previous investigations of the unit, no evidence of spills
or releases were noted, and the concrete floor was in
good condition. This unit was periodically washed down
with a hose.
Soil sampling was conducted in 2001 to assess the
potential for historic releases from the building. Based
on these results, additional characterization was included
in the RFI Phase 1 Work Plan submitted to the DTSC in
September 2002. The 2002 sampling activities in and
immediately around Building 165 reported only trace
detections of pesticides on the north side of the building.
None of the reported detections exceeded IPRGs.
Subsequent step out and step down samples collected for
pesticide and herbicide analyses contained only trace
detections (all below IPRGs) of pesticides in one sample.
Herbicides were not detected above reporting limits in
any of the samples collected (CH2M HILL, 2002a).
Additional soil sampling adjacent to Building 165
confirmed the presence of chlordane in a composite
sample from one side of the building. Based on the
sampling results, the Final RFI Report recommended no
further action be taken for this SWMU (CH2M HILL,
Page 9 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
2005a). The DTSC concurred by approving the Final
RFI Report.
Pesticides
Pesticide Storage Area
Waste Zinc-Cyanide
Zinc, cyanide
Solution Neutralizing Tanks
(SWMU 19)
1979 - present
1955 - 1958
The concrete sump was removed in December 1994
under the oversight of the Stanislaus County
Environmental Resources Department. During the
removal process, the concrete material of the sump and
the surrounding soil was sampled. The soil sample
contained chlordane, so approximately 20 yards of soil
were excavated for disposal. Visual inspection of the
concrete sump did not reveal any holes, cracks, or
deterioration of the walls or floor of the sump. Because
the concrete floor of the building was in good condition
(without cracks or stains) and the sump had been
removed, no sampling was performed during the RI (NI,
2006b). In a letter dated June 5, 1996, the DTSC
concurred with the position of the Army (as detailed in
the April 15, 1996 Revision 2 of the RFI Phase 1 Work
Plan) that no further action was required at the Pesticide
Storage Area in Building 170 (CH2M HILL, 2002a).
No evidence exists that a release ever occurred from this
unit in the short period of operation (1955 through 1958).
Both tanks were removed on September 27, 1994. The
Army, in Revision 4 of the RFI Phase 1 Work Plan,
presented justification supporting a finding that no
further action is recommended at the Waste ZincCyanide Solution Neutralizing Tanks. The DTSC (in a
letter dated July 27, 1998) concurred with this
recommendation (CH2M HILL, 2002a).
Page 10 of 19
Description
Name of
Hazardous
Substance(s)
Industrial Waste Pipe Leak
(SWMU 24)
Industrial
wastewater
Mortar Line Accumulation
Area (Building 4) (AOC 1)
Spent machine
oils, spent
chlorinated oils,
spent acids, spent
soaps, pickling
sludge, spent
solvents, zinc
phosphate chips,
floor dry mixed
with oils, spent
chromic acid,
waste salts, waste
paints and waste
thinners
Date of Storage,
Release, or
Disposal
Remedial Actions
1990
An industrial waste pipe leak occurred in 1990 at the
southern end of Building 13. This pipe carries
wastewater from the chromium reduction unit in
Building 13 to the IWTP. The soil was excavated in
conjunction with the repairs. The excavation area was
then sampled during the RI to determine if residual
contamination existed. Sample results indicated that
elevated levels of inorganics did not exist in this area.
The ROD concluded that remedial action was not
warranted (USAEC, 1994). The DTSC concurred with
the position of the Army (as detailed in the original
October 30, 1995 version of the RFI Phase 1 Work Plan)
that no further action was required at the Industrial
Waste Pipe Leak (CH2M HILL, 2002a).
A site inspection showed the concrete area to be in good
condition with no cracks or staining and there were no
known spills or releases in this area. Therefore, no
further action is necessary in this area. In a letter dated
June 5, 1996, the DTSC concurred with the position of
the Army (as detailed in the April 15, 1996 Revision 2 of
the RFI Phase 1 Work Plan) that no further action was
required for this AOC (CH2M HILL, 2002a).
1989 - 1991
Page 11 of 19
Description
Name of
Hazardous
Substance(s)
Machine Shop Accumulation Spent machine
Area (Building 9) (AOC 2) oils, spent oils,
and waste solvents
Vehicle Maintenance
Accumulation Area
(Building 15) (AOC 3)
Waste oil, spent
antifreeze, and
waste solvent
Date of Storage,
Release, or
Disposal
Remedial Actions
1989 - 1992
condition with no cracks or staining. There were no
known spills or releases. Therefore, no further action is
necessary in the Machine Shop Accumulation Area. In a
letter dated June 5, 1996, the DTSC concurred with the
A site inspection showed that the concrete area was in
good condition with no cracks or staining. No known
spills or releases have occurred in this area. Based on
the small quantity of drums stored at this site and the
lack of evidence of past spills or releases, no further
action is deemed necessary. In a letter dated June 5,
1996, the DTSC concurred with the position of the Army
(as detailed in the April 15, 1996 Revision 2 of the RFI
Phase 1 Work Plan) that no further action was required
for this AOC (CH2M HILL, 2002a).
condition with no cracks or staining. No known spills or
releases occurred at this unit. Based on these findings,
no further action is necessary in this area. In a letter
dated June 5, 1996, the DTSC concurred with the
AOC 8B currently consists of a pump house (Building
85) and an abandoned underground pipeline distribution
system historically used to transport transformer coolant
1989 – present
Grenade Casing Line
Waste chlorinated
Accumulation Area (AOC 4) oil, spent caustic
cleaner
1989 - 1990
Horizontal ASTs –
Transformer Oil Storage
Tanks (including
1940s - 1970
Coolant oil,
transformer oil
Page 12 of 19
Description
Transformer Oil Distribution
System) (AOC 8B)
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
oil to transformers. The pipelines have been cleaned (as
requested by the DTSC) and encapsulated with cement
slurry. Originally, three Transformer Oil Storage Tanks
were used for oil storage; the three 8,000-gallon ASTs
sat in reinforced concrete cradles, and all sides and the
bottom of the tanks were visible. The three tanks were
cleaned out, tested for PCBs, and removed from the
facility. No known releases or spills occurred from this
system. A visual inspection in 1997 of the tank area and
other system components did not show any indication of
tank release. However, during the 1997 inspection,
stains of unknown origin were observed on the floor in
Building 85.
Soil samples were collected in 2001 and 2003 in the
bermed area that formerly held the transformer oil
storage tanks, adjacent to the pipeline heading to
Building 15, and adjacent to the former transformer pads
and the main distribution line. Based on these results,
120 cy of soil contaminated with PCBs (as Aroclor1260) at concentrations greater than IPRGs were
removed within the bermed area. Confirmation samples
from the excavation floor were nondetect. Based on
these findings, no further action is recommended at the
Oil Storage Tanks location of AOC 8B.
During the 2004 Storage Tank Area Soil Removal,
additional samples were collected adjacent to former
transformer pads along the distribution lines. These
Page 13 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
sample results were less than IPRGs and, combined with
the prior two sets of sampling results along the
distribution system, confirm that significant releases did
not occur along the distribution system. The Final RFI
Report recommended no further action for the
transformer oil storage tanks including the distribution
system (CH2M HILL, 2005a). The DTSC concurred
with this recommendation by approving the Final RFI
Report.
Industrial Wastewater
Industrial
Collection System (AOC 12) wastewater
1951 – 1990s
The IWCS has been disconnected from the production
plant. The collection sumps were filled with concrete in
the late 1990s, when a new, above-grade collection
system was installed.
Soil investigations involving collection of soil samples
from within and adjacent to the sumps and trenches
associated with production lines 2, 3, 4, and 5 were
completed in accordance with the DTSC-approved work
plans. Soil samples were collected from both the
production line trenches and sumps. The investigations
did not identify contaminants at elevated concentrations
in the soil samples. During the RFI Phase 1, a video
survey was conducted on the collection system pipelines
and then soil samples were collected near major cracks
or breaks observed in the video survey (CH2M HILL,
2002a). The video survey and subsurface sampling
adjacent to the IWCS did not indicate that significant
leaks occurred andoil analytical results did not contain
Page 14 of 19
Description
Name of
Hazardous
Substance(s)
Zinc-Cyanide Wastewater
Cyanide
Collection System (AOC 14) wastewater
Date of Storage,
Release, or
Disposal
1954 - 1958
Remedial Actions
contaminants that exceeded IPRGs. The Final RFI
recommended that no further action be taken along the
IWCS while the IWTP is still active (CH2M HILL,
2005a). The DTSC concurred with this recommendation
when they approved the Final RFI Report. In a letter
from the DTSC, dated August 10, 2006, the DTSC
confirmed that no further action was required for SWMU
12 (DTSC, 2006).
The use of the cyanide wastewater collection system was
discontinued due to production capability changes. The
system has been disconnected from the production plant.
The collection sumps were filled with concrete in the late
1990s.
Soil samples collected below and near sump 6-11 at
depths of 11 to 13 feet did not identify elevated cyanide
contaminant concentrations. The soil investigations
completed for the portions of the cyanide wastewater
collection system near production lines 2 through 5 did
not identify any significantly elevated concentrations
(CH2M Hill, 2002). During the RFI Phase 1, a soil
boring was advanced at one point along the line and no
visual or analytical indication of contamination was
found. Coupled with the fact that this waste line only
saw limited operation from 1954 to 1958, the probability
of significant releases of contamination is low.
Therefore, the Final RFI recommended no further action
for AOC 14 (CH2M HILL, 2005a). The DTSC
concurred with this recommendation by approving the
Page 15 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
Final RFI Report. In a letter from the DTSC, dated
August 10, 2006, the DTSC confirmed that no further
action was required for AOC 14 (DTSC, 2006).
Draw Lube System (Building Chlorinated oil,
178) (AOC 13)
grease
Paint and Oil Storage, Oil
Recycling and Transport
(Building 11)
Paint, Oils, PCBs
1987 - 1990
1951 - present
In March 1993, contamination was discovered on the
south side of Building 178. Thirteen soil samples were
collected and elevated oil and grease concentrations were
detected at two locations (three total samples). Two
additional hand-auger borings were installed adjacent to
Building 178 to confirm the limited extent of
contamination. All samples from these borings were
non-detect for TPH. A soil removal action was taken to
address the petroleum-contaminated soil. The upper 3
feet of soil was excavated in an area approximately 6feet wide by 16-feet long immediately adjacent to
Building 178. Extraction well 54B is located about 100
yards downgradient from Building 178. This well was
sampled several times for oil and grease in the three
years following the release with all sample results being
nondetect. In a letter dated June 5, 1996, the DTSC
concurred with the position of the Army (as detailed in
the April 15, 1996 Revision 2 of the RFI Phase 1 Work
Plan) that no further action was required for this AOC
(CH2M HILL, 2002a).
Building 11 is adjacent to Substation No. 5, which
includes three PCB transformers installed in 1951. As a
part of the EBS (Norris-Riverbank Environmental,
1998a), five near-surface soil samples were collected
from the graveled areas just outside Building 11 along
Page 16 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
the southern and western sides. Aroclor 1260 was
identified in all five sample results, in concentrations
ranging from 400 μg/kg to 1,000 μg/kg.
Building 169
Paint
This area was further investigated in the 2007 SI (CH2M
HILL, 2008). The SI samples show a single detection of
Aroclor 1260 at a concentration of 38 μg/kg, which is
well below the industrial and residential PRGs and
TSCA cleanup requirements. These sampling results
indicate that the area of soil contaminated with PCBs
above regulatory screening criteria is localized in nature.
Although the source of the PCBs in soil is not known,
two electric substations in close proximity to the areas
sampled have been reported. Since the area is covered
with asphalt, the current contact exposure pathway to
soils is minimized and no further action is recommended.
EPA Region 9 concurred with these findings in a letter
In 1998, surface soil sampling was conducted on the
north, south, and east building walls. These samples
were analyzed for oil and grease, hexavalent chromium,
zinc and total chromium, lead, VOCs, SVOCs, and pH.
Analytical results indicated elevated levels of benzene,
toluene, ethyl benzene, xylenes (up to 905 mg/kg)
(below the regulatory limits of 1,000 mg/kg). The EBS
recommended a Phase II assessment to determine the
extent of benzene, toluene, ethyl benzene, and total
xylenes (BTEX) contamination (Norris-Riverbank,
1998e). No follow-up investigation has been completed
Page 17 of 19
Description
Name of
Hazardous
Substance(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
(NI, 2006b).
Building 11 (Paint and Oil
Storage)
PCBs
Unknown
Structure 95 (Transformer)
PCBs
Unknown
Structure 97 (2
Transformers)
PCBs
Unknown
Structure 101 (Substation
Spare)
PCBs
Unknown
Structure 145 (Substation
No. 17)
PCBs
Unknown
In 1998, Aroclor 1260 was identified in five near-surface
sample results, in concentrations ranging from 400 μg/kg
to 1,000 μg/kg (Norris-Riverbank Environmental,
1998a). This area was further investigated in the 2007 SI
(CH2M HILL, 2008). All results were below TSCA
requirements and no further action is required. EPA
Region 9 concurred with these findings in a letter dated
14 December 2007.
Sampling was conducted in the SI (CH2M HILL, 2007).
All results were below TSCA requirements and no
further action is required.
During the ECP visual site inspection, oil staining was
observed on concrete at the base of the two transformers.
During the ECP’s visual site inspection, oil staining was
observed on concrete at the base of one inactive
transformer. Sampling was conducted in the SI (CH2M
HILL, 2007). All results were below TSCA
requirements and no further action is required.
During the ECP’s visual site inspection, oil staining was
observed on the concrete at the base of two transformers
with PCB concentrations of 28 ppm and 134 ppm.
Page 18 of 19
* The information contained in this notice is required under the authority of regulations promulgated under section 120(h) of the
Comprehensive Environmental Response, Liability, and Compensation Act (CERCLA or ‘Superfund’) 42 U.S.C. §9620(h). This
table provides information on the storage of hazardous substances for one year or more in quantities greater than or equal to 1,000
kilograms or the hazardous substance’s CERCLA reportable quantity (whichever is greater). In addition, it provides information on
the known release of hazardous substances in quantities greater than or equal to the substance’s CERCLA reportable quantity. See 40
CFR Part 373.
Page 19 of 19
ENCLOSURE 5
TABLE 3 – NOTIFICATION OF PETROLEUM PRODUCT STORAGE, RELEASE, OR DISPOSAL
Site Description
Name of
Petroleum
Product(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
Tank No. G70, a 6,000- Waste Oil
gallon steel AST, is
located at Bldg. 44
(IWTP)
1994 - present
None.
Tank No. USA019634, a Gas/Diesel
450-gallon concrete AST,
is located at Bldg. 189
1995 – present
None.
Tank No. 1, a 10,000
Unleaded Gasoline
gallon steel UST, located
at Bldg. 15
1974-1994
Tank removed.
Tank No. 11A, a 12,000- Bunker “C” Oil
at Bldg. 11 (South)
1952-1993
Tank removed.
Tank No. 12A, an 8,000- Bunker “C” Oil
at Bldg. 12
1952-1993
Tank removed.
Tank No. 12B, a 10,000- Bunker “C” Oil
at Bldg. 12
1952-1993
Tank removed.
Tank No. 15A, a 1,000- Unleaded Gasoline
1954-1989
Tank removed.
Page 1 of 5
TABLE 3 – NOTIFICATION OF PETROLEUM PRODUCT STORAGE, RELEASE,
Site Description
Name of
Petroleum
Product(s)
Date of Storage,
Release, or
Disposal
Unleaded Gasoline
1981-1989
Unknown.
Tank No. T137, a 250- Unleaded Gasoline
at Bldg. 137
1956-1989
Tank removed.
Remedial Actions
at Bldg. 15
Tank No. 15B, a 1,000gallon UST, located at
Bldg. 15
Horizontal ASTs –
Propane Storage Tanks
(AOC 8A)
Propane
Vertical ASTs – Fuel Oil Fuel oil
Storage Tanks (AOC
9A), two welded-steel
storage tanks with a
storage capacity of
250,000 gallons per tank
1952 - present
There have been no known releases or spills. Because
this area is used only for the storage of propane, and the
nature of propane would be to vaporize if a release did
occur, no further action is necessary in this area. In a
letter dated June 5, 1996, the DTSC concurred with the
1952 - 1958
When the groundwater treatment system was installed in
1991, the tanks were converted for temporary storage of
treated groundwater. The two fuel oil storage tanks were
cleaned and internally inspected in 1991. The results of
the visual inspection showed no signs of leakage.
Additionally, the tanks were ultrasonically inspected in
November 1992 and found to be sound. The associated
piping is also believed to be sound. No further
investigation is required in this area. In a letter dated
June 5, 1996, the DTSC concurred with the position of
Page 2 of 5
Site Description
Name of
Petroleum
Product(s)
Date of Storage,
Release, or
Disposal
Remedial Actions
the Army (as detailed in the April 15, 1996 Revision 2 of
the RFI Phase 1 Work Plan) that no further action was
required for this AOC (CH2M HILL, 2002a). These
tanks are still in use for the temporary storage of treated
groundwater.
Loading Racks – Propane Propane
Farm Loading/Unloading
(AOC 11A)
Boiler House, Building
12
Heating oil
1952 - present
There are no known releases or spills at the loading
racks. Because the physical characteristics of propane
would cause it to vaporize if there was a release, there is
no potential for soil or groundwater to be contaminated.
In a letter dated June 5, 1996, the DTSC concurred with
the position of the Army (as detailed in the April 15,
1996 Revision 2 of the RFI Phase 1 Work Plan) that no
further action was required for this AOC (CH2M HILL,
2002a).
Unknown
Norris-Riverbank Environmental collected six nearsurface soil samples from areas just outside Building 12
in 1998. Results of this analysis showed evidence of oil
and gas in two of the samples (660 mg/kg, and 410
mg/kg), chromium in one sample (144 mg/kg), and lead
in one sample (215 mg/kg). The report concluded that
an additional Phase II investigation was recommended
(Norris-Riverbank, 1998a; NI, 2006b). However,
subsequent analysis showed the detected concentrations
to be below industrial preliminary remediation goals;
therefore, no further investigation is required.
Page 3 of 5
Site Description
E/P Ponds Soil Staining
Area
Name of
Petroleum
Product(s)
Motor Oil
Buildings 3 East, 4 and 5, Oil and grease
which included Buildings
47, 48, and 49
Date of Storage,
Release, or
Disposal
Remedial Actions
Unknown
Preliminary soil samples indicated levels of motor oil at
concentrations of 276,000 mg/kg. The U.S. Army is
investigating and pursuing clean-up efforts for the site.
In 1998, Norris–Riverbank Environmental conducted the
cleaning of all sumps, trenches, and pits that drained to
the industrial sewer and the removal of eight
trench/sump systems. During the removal of Sump 4-11,
it was discovered that the soil beneath the sump was
contaminated with oil and grease. The contaminated soil
was removed. Soil sampling indicates that a small lens
of contamination remains below the foundation to the
building and crane support. Soil on the south wall had a
residual oil and grease at a concentration of 140 ppm,
which remained after the excavation. Clean soil was
reached at the bottom of the excavation. It was
recommended that upon closure of the facility, the extent
of the contamination should be defined (NorrisRiverbank, 1998e). No follow-up investigation has been
completed (NI, 2006a). However, the potential for
migration in the soil is limited because of the relatively
low concentration of residual oil and grease that remains
in this area and because the area is beneath the concrete
foundation of the building and crane support.
Unknown
Page 4 of 5
Site Description
Building 10
Name of
Petroleum
Product(s)
Oil and grease
Date of Storage,
Release, or
Disposal
Remedial Actions
Unknown
Sampling that was conducted included a soil sample
outside Building 10 along the southwest and northwest
fenced perimeters. The samples were analyzed for oil
and grease and Title 22 Metals. The results showed
levels of oil and grease at 1,400 mg/kg (above the
regulatory limits of 1,000 mg/kg). The location of this
sample was in an area historically used to store
hydrocarbons. This EBS recommended a Phase II
assessment to determine the extent of the oil and grease
contamination (Norris-Riverbank, 1998f). No follow-up
investigation has been completed (NI, 2006a).
Page 5 of 5
ENCLOSURE 6
TABLE 4 – PCB AND PCB-CONTAMINATED TRANSFORMERS
Unit No.
Serial
Number
Location
Unit Status
PCB
Concentration
(ppm)1
TRANS SUB 1
3400153
Line No. 1, W.
Outside 95
Active
106
1,700
386
TRANS SUB 3-N
3164726
Structure 97 Main
St. and Structure
No. 8
Active
64
-
386
TRANS SUB 5-N
1A71522
-
Active
768
3,060
966
TRANS SUB 13-W
2351391
Structure 54 - X
Cooling Tower
Active
248
TRANS SUB 15-W
1861-1
Structure 100 Line
No. 1 Courtyard
Active
998
3,091
680
TRANS SUB 15-E
1861-2
Structure 100 Line
No. 1 Courtyard
Active
1,514
3,091
680
TRANS SUB 17-E
1A71511
Structure 145
Active
134
4,391
966
TRANS SUB 18
3161095
Structure 146
Active
35,000
4,391
966
OCB 30 CENTER
-
Yard
-
90
-
-
Motor Generator –
Lub A – No. 12831
-
Bldg. 7-Me 2-2
-
4,300
-
-
Page 1 of 1
PCB Quantity (kg) Oil Quantity (gal)
966
ENCLOSURE 7
CERCLA NOTICE, COVENANT, ACCESS PROVISIONS AND DEED RESTRICTIONS
I. Property Covered by Notice, Description, Assurances, Access Rights, and Covenants
Made Pursuant to Section 120(h)(3)(A) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)):
For the Property, the Grantor provides the following notice, description, assurances, and
covenants and retains the following access rights:
A. Notices Pursuant to Section 120(h)(3)(A)(i)(I) and (II)) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. Section
9620(h)(3)(A)(i)(I) and (II):
Pursuant to section 120(h)(3)(A)(i)(I) and (II) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. §9620(h)(3)(A)(i)(I) and (II)),
available information regarding the type, quantity, and location of hazardous substances and the
time at which such substances were stored, released, or disposed of, as defined in section 120(h),
is provided in Exhibit ______ [Note: the exhibit number will be filled in during deed preparation
and will refer to FOSET Enclosure 4, Table 2 – Hazardous Substance, Storage, Release and
Disposal, which should be included as a deed exhibit.], attached hereto and made a part hereof.
B. Description of Remedial Action Taken, if Any, Pursuant to Section 120(h)(3)(A)(i)(III)
of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(42 U.S.C. § 9620(h)(3)(A)(i)(III)):
Pursuant to section 120(h)(3)(A)(i)(III) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. §9620(h)(3)(A)(i)(III)), a description of the
remedial action taken, if any, on the property is provided in Exhibit ____[Note: the exhibit
number will be filled in during deed preparation and will refer to FOSET Enclosure 4, Table 2 –
Hazardous Substance, Storage, Release and Disposal, which should be included as an exhibit in
the final deed], attached hereto and made a part hereof.
C. Covenant Pursuant to Section 120(h)(3)(A)(ii)(II) and (B) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. §
9620(h)(3)(A)(ii)(II) and (B)):
Pursuant to section 120(h)(3)(A)(ii)(II) and (B) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(A)(ii)(II) and (B)),
the United States warrants that any additional remedial action found to be necessary after the
date of this deed shall be conducted by the United States. This warranty shall not apply in any
case in which the person or entity to whom the property is transferred is a potentially responsible
party with respect to such property.
D. Assurances Pursuant to Section 120(h)(3)(C)(ii) of the Comprehensive Environmental
1 of 6
Response, Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(C)(ii)):
Pursuant to section 120(h)(3)(C)(ii) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9620(h)(3)(C)(ii)), the United States
provides the following response action assurances:
A. Pursuant to section 120(h)(3)(C)(ii)(I) and (II) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (42 U.S.C. §9620(h)(3)(C)(ii)(I) and
(II)), the Environmental Protection Provisions at Exhibit ______, attached hereto and
made a part hereof, provide the conditions, restrictions, and notifications necessary to
ensure protection of human health and the environment and to preclude any interference
with ongoing or completed required remedial investigations, response action, and
oversight activities at the Riverbank Army Ammunition Plant.
B. Pursuant to section 120(h)(3)(C)(ii)(III) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. §9620(h)(3)(C)(ii)(III)), all response
actions necessary to protect human health and the environment will be taken with respect
to any hazardous substance remaining on the Property as a result of storage, release, or
disposal prior to the date of transfer. The compliance schedule has been developed in
cooperation with the U.S. Environmental Protection Agency and the State of California.
The schedule will be changed only as circumstances warrant as provided by the
Riverbank Army Ammunition Plant (RBAAP) Federal Facility Agreement (FFA). It is
noted that changes to the schedule may occur as a result of such things as additional
sampling requirements that have not been identified; discovery of additional
contamination on the Property; unanticipated conditions during field efforts; and
additional review and revision of documentation such as reports, work plans, designs, etc.
Pursuant to section 120(h)(3)(C)(ii)(IV) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. §9620(h)(3)(C)(ii)(IV), the Grantor has
submitted, and will continue to submit through its established budget channels to the Director of
the Office of Management and Budget, a request for funds that adequately addresses schedules
for investigation and completion of all response actions required. Expenditure of any Federal
funds for such investigations or response actions is subject to Congressional authorization and
appropriation of funds for that purpose.
E. Access Rights Pursuant to Section 120(h)(3)(A)(iii) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. §
9620(h)(3)(A)(iii)):
The United States retains and reserves a perpetual and assignable easement and right of
access on, over, and through the property, to enter upon the property in any case in which a
remedial action or corrective action is found to be necessary on the part of the United States,
without regard to whether such remedial action or corrective action is on the property or on
adjoining or nearby lands. Such easement and right of access includes, without limitation, the
right to perform any environmental investigation, survey, monitoring, sampling, testing, drilling,
2 of 5
boring, coring, testpitting, installing monitoring or pumping wells or other treatment facilities,
response action, corrective action, or any other action necessary for the United States to meet its
responsibilities under applicable laws and as provided for in this instrument. Such easement and
right of access shall be binding on the grantee and its successors and assigns and shall run with
the land.
In exercising such easement and right of access, the United States shall provide the grantee
or its successors or assigns, as the case may be, with reasonable notice of its intent to enter upon
the property and exercise its rights under this clause, which notice may be severely curtailed or
even eliminated in emergency situations. The United States shall use reasonable means to avoid
and to minimize interference with the grantee’s and the grantee’s successors’ and assigns’ quiet
enjoyment of the property. At the completion of work, the work site shall be reasonably restored.
Such easement and right of access includes the right to obtain and use utility services, including
water, gas, electricity, sewer, and communications services available on the property at a
reasonable charge to the United States. Excluding the reasonable charges for such utility
services, no fee, charge, or compensation will be due the grantee, nor its successors and assigns,
for the exercise of the easement and right of access hereby retained and reserved by the United
States.
In exercising such easement and right of access, neither the grantee nor its successors and
assigns, as the case may be, shall have any claim at law or equity against the United States or any
officer or employee of the United States based on actions taken by the United States or its
officers, employees, agents, contractors of any tier, or servants pursuant to and in accordance
with this clause: Provided, however, that nothing in this paragraph shall be considered as a
waiver by the grantee and its successors and assigns of any remedy available to them under the
Federal Tort Claims Act.
II. OTHER DEED PROVISIONS:
1. “AS IS”
A. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the
Property and accepts the condition and state of repair of the subject Property. The
Grantee understands and agrees that the Property and any part thereof is offered “AS IS”
without any representation, warranty, or guarantee by the Grantor as to quantity, quality,
title, character, condition, size, or kind, or that the same is in condition or fit to be used
for the purpose(s) intended by the Grantee, and no claim for allowance or deduction upon
such grounds will be considered.
B. No warranties, either express or implied, are given with regard to the condition of the
Property, including, without limitation, whether the Property does or does not contain
asbestos or lead-based paint. The Grantee shall be deemed to have relied solely on its
own judgment in assessing the overall condition of all or any portion of the Property,
including, without limitation, any asbestos, lead-based paint, or other conditions on the
Property. The failure of the Grantee to inspect, or to exercise due diligence to be fully
3 of 5
informed as to the condition of all or any portion of the Property offered, will not
constitute grounds for any claim or demand against the United States.
C. Nothing in this “As Is” provision will be construed to modify or negate the Grantor’s
obligation under the CERCLA Covenant or any other statutory obligations.
2. HOLD HARMLESS
A. To the extent authorized by law, the Grantee, its successors and assigns, covenant and
agree to indemnify and hold harmless the Grantor, its officers, agents, and employees
from: (1) any and all claims, damages, judgments, losses, and costs, including fines and
penalties, arising out of the violation of the NOTICES, USE RESTRICTIONS, AND
RESTRICTIVE COVENANTS in this Deed by the Grantee, its successors and assigns;
and (2) any and all any and all claims, damages, and judgments arising out of, or in any
manner predicated upon, exposure to asbestos, lead-based paint, or other condition on
any portion of the Property after the date of conveyance.
B. The Grantee, its successors and assigns, covenant and agree that the Grantor shall not be
responsible for any costs associated with modification or termination of the NOTICES,
USE RESTRICTIONS, AND RESTRICTIVE COVENANTS in this Deed, including
without limitation, any costs associated with additional investigation or remediation of
asbestos, lead-based paint, or other condition on any portion of the Property.
C. Nothing in this Hold Harmless provision will be construed to modify or negate the
Grantor’s obligation under the CERCLA Covenant or any other statutory obligations.
3. POST-TRANSFER DISCOVERY OF CONTAMINATION
A. If an actual or threatened release of a hazardous substance or petroleum product is
discovered on the Property after the date of conveyance, Grantee, its successors or
assigns, shall be responsible for such release or newly discovered substance unless
Grantee is able to demonstrate that such release or such newly discovered substance was
due to Grantor’s activities, use, or ownership of the Property. If the Grantee, it
successors or assigns, believe the discovered hazardous substance is due to Grantor’s
activities, use or ownership of the Property, Grantee will immediately secure the site and
notify the Grantor of the existence of the hazardous substances, and Grantee will not
further disturb such hazardous substances without the written permission of the Grantor.
B. Grantee, its successors and assigns, as consideration for the conveyance of the Property,
agree to release Grantor from any liability or responsibility for any claims arising solely
out of the release of any hazardous substance or petroleum product on the Property
occurring after the date of the delivery and acceptance of this Deed, where such
substance or product was placed on the Property by the Grantee, or its successors,
assigns, employees, invitees, agents or contractors, after the conveyance. This paragraph
shall not affect the Grantor’s responsibilities to conduct response actions or corrective
actions that are required by applicable laws, rules and regulations, or the Grantor’s
indemnification obligations under applicable laws.
4 of 5
4. ENVIRONMENTAL PROTECTION PROVISIONS
The Environmental Protection Provisions are delineated at Enclosure 8, which is attached hereto
and made a part hereof. The Grantee shall neither transfer the Property, lease the Property, nor
grant any interest, privilege, or license whatsoever in connection with the Property without the
inclusion of the Environmental Protection Provisions contained herein, and shall require the
inclusion of the Environmental Protection Provisions in all further deeds, easements, transfers,
leases, or grant of any interest, privilege, or license.
5 of 5
ENCLOSURE 8
ENVIRONMENTAL PROTECTION PROVISIONS
The following conditions, restrictions, and notifications will be attached, in a substantially
similar form, as an exhibit to the deed and be incorporated therein by reference in order to ensure
protection of human health and the environment and to preclude any interference with ongoing
or completed remediation activities at Riverbank Army Ammunition Plant.
1. FEDERAL FACILITIES AGREEMENT
The Grantor acknowledges that the Riverbank Army Ammunition Plant has been identified as a
National Priorities List (NPL) site under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) of 1980, as amended. The Grantee acknowledges
that the Grantor has provided it with a copy of the Riverbank Army Ammunition Plant (RBAAP)
Federal Facility Agreement (FFA) dated April 5, 1990. For so long as the Property remains
subject to the FFA, the Grantee, its successors and assigns, agree that they will not interfere with
United States Department of the Army activities required by the FFA. In addition, should any
conflict arise between the FFA and any amendment thereto and the deed provisions, the FFA
provisions will take precedence. The Grantor assumes no liability to the Grantee, its successors
and assigns, should implementation of the FFA interfere with their use of the Property.
2. LAND USE RESTRICTIONS
A. The United States Department of the Army has undertaken careful environmental
study of the Property and concluded that the land use restrictions set forth below are required to
ensure protection of human health and the environment. The Grantee, its successors or assigns,
shall not undertake nor allow any activity on or use of the Property that would violate the land
use restrictions contained herein.
1) Residential Use Restriction. The Grantee, its successors and assigns, shall use the
Property solely for commercial or industrial activities and not for residential
purposes. For purposes of this provision, residential use includes, but is not limited
to: single family or multi-family residences; child care facilities; nursing home or
assisted living facilities; and any type of educational purpose for children/young
adults in grades kindergarten through 12.
2) Groundwater Restriction. Grantee is hereby informed and acknowledges that the
groundwater under the Property has contamination consisting of chromium and
cyanide at levels exceeding the remediation level State Drinking Water Standard
(DWS) maximum contaminant level (MCL) of 50 ppb for chromium and 200 ppb for
cyanide. The Grantee, its successors and assigns, shall not to access or use ground
water underlying the Property for any purpose without the prior written approval of
United States Department of the Army, the U.S. Environmental Protection Agency,
Region 9, the Department of Toxic Substances Control, and the Regional Water
Quality Control Board, Central Valley Region. For the purpose of this restriction,
"ground water" shall have the same meaning as in section 101(12) of the
Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA).
3) Notice of Groundwater Monitoring Wells. The Grantee is hereby informed and
does acknowledge the presence of 64 [this number to be verified] groundwater
monitoring wells and 7 [this number to be verified] extraction wells on the Property.
The Grantee, its successors and assigns shall not disturb or permit others to disturb
the monitoring wells and extraction wells located on the Property without prior
written approval from the Grantor, the U.S. Environmental Protection Agency,
Region 9, the Department of Toxic Substances Control, and the Regional Water
Quality Control Board, Central Valley Region. Upon the Grantor’s determination
that a well is no longer necessary, the Grantor will close such well at the Grantor’s
sole cost and expense in accordance with applicable laws, regulations, and
ordinances.
4) Excavation and Development Restriction. The Grantee, its successors and assigns,
shall not conduct or permit others to conduct any excavation activities (i.e. digging,
drilling, or any other excavation or disturbance of the land surface or subsurface) at
the landfill. The Grantee, its successors and assigns, or any approved contractor,
shall not construct, make, or permit any alterations, additions, or improvements to the
landfill in any way which may violate the excavation restriction. Implementation and
Enforcement of this Restriction shall be achieved by:
a) Annual review and oversight by the Grantor, the EPA, and the State of California.
b) A State Land Use Control (SLUC) to be entered into between the Grantee and the
State of California, placing restrictions on the transferring property.
c) Grantee’s annual review of the Property with an annual letter report to the
Grantor, the EPA, and the State of California summarizing, for the previous
calendar year, the following:
i. Any significant changes to RBAAP Reuse Plan in the previous calendar year;
ii. The disposition of construction permit applications submitted to the relevant
local jurisdiction for proposed development on the Property; and
iii. Any prohibited activities, as described above, observed by or reported to the
Grantee during the course of the review.
d) Completion of a close-out report by the Grantee documenting that the recurring
reviews and response actions have effectively addressed the risks posed at the
installation.
Page 2 of 5
5) Landfill Restriction. The Grantee, its successors and assigns, shall not conduct, or
permit others to conduct, any excavation activities (i.e. digging, drilling, or any other
excavation or disturbance of the land surface or subsurface) or other activities that
may damage the RBAAP-01 Landfill soil cover and liner.
B. Modifying Restrictions. Nothing contained herein shall preclude the Grantee, its
successors or assigns, from undertaking, in accordance with applicable laws and
regulations and without any cost to the Grantor, such additional action necessary to allow
for other less restrictive use of the Property. Prior to such use of the Property, Grantee
shall consult with and obtain the approval of the Grantor, and, as appropriate, the State or
Federal regulators, or the local authorities in accordance with this Environmental
Protection Provisions and the provisions of the SLUCs. Upon the Grantee’s obtaining the
approval of the Grantor and, as appropriate, State or Federal regulators, or local
authorities, the Grantor agrees to record an amendment hereto. This recordation shall be
the responsibility of the Grantee and at no additional cost to the Grantor.
C. Submissions. The Grantee, its successors and assigns, shall submit any requests for
modifications to the above restrictions to the Grantor, EPA, DTSC, and the Regional
Water Board, by first class mail, postage prepaid, addressed as follows:
a. Grantor:
Commander’s Representative
P.O. Box 670
Riverbank, CA 95367-0670
b. EPA:
Chief, Federal Facility and Site Cleanup Branch
Superfund Division
U.S. Environmental Protection Agency, Region IX
75 Hawthorne Street, Mail Code: SFD-8-3
San Francisco, CA 94105
c. DTSC:
Chief of Northern California Operations
Office of Military Facilities
Department of Toxic Substances Control
8800 Cal Center Drive
Sacramento, CA 95826-3200
d. Regional Water Board:
Executive Officer
State of California
Regional Water Quality Control Board
Central Valley Region
11020 Sun Center Drive, Suite #200
Rancho Cordova, CA 95670-6114
Page 3 of 5
3. NOTICE OF THE PRESENCE OF ASBESTOS AND COVENANT
Applicable to Remainder Parcel A:
A. The Grantee is hereby informed and does acknowledge that friable and non-friable
asbestos or asbestos-containing material (ACM) has been found on the Property, as
described in the Asbestos Management Plan and Survey (30-March-2004) and
summarized in the Environmental Assessment, Asbestos Program (3-March-1998). The
Property may also contain improvements, such as buildings, facilities, equipment, and
pipelines, above and below the ground, that contain friable and non-friable asbestos or
ACM. The Occupational Safety and Health Administration (OSHA) and the U.S.
Environmental Protection Agency (EPA) have determined that unprotected or
unregulated exposure to airborne asbestos fibers increases the risk of asbestos-related
diseases, including certain cancers, that can result in disability or death.
B. Based on an asbestos inventory summary conducted in March 2005, most buildings on
the plant contain suspect asbestos-containing materials (ACM). NOTE: Need to include
friable ACM, if any, here. In addition, Galbestos building material, which contains
asbestos, is a common siding material. The Grantee agrees to undertake any and all
asbestos abatement or remediation in the aforementioned buildings that may be required
under applicable law or regulation at no expense to the Grantor. The Grantor has agreed
to transfer said buildings to the Grantee, prior to remediation or abatement of asbestos
hazards, in reliance upon the Grantee’s express representation and covenant to perform
the required asbestos abatement or remediation of these buildings.
C. The Grantee covenants and agrees that its use and occupancy of the Property will be in
compliance with all applicable laws relating to asbestos. The Grantee agrees to be
responsible for any future remediation or abatement of asbestos found to be necessary on
the Property, to include ACM in or on buried pipelines, that may be required under
applicable law or regulation.
D. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the
Property as to its asbestos and ACM content and condition, and any hazardous or
environmental conditions relating thereto. The Grantee shall be deemed to have relied
solely on its own judgment in assessing the overall condition of all or any portion of the
Property, including, without limitation, any asbestos or ACM hazards or concerns.
4. NOTICE OF THE PRESENCE OF LEAD-BASED PAINT (LBP) AND COVENANT
AGAINST THE USE OF THE PROPERTY FOR RESIDENTIAL PURPOSE
Applicable to Remainder Parcel A:
A. The Grantee is hereby informed and does acknowledge that all buildings on the Property,
which were constructed or rehabilitated prior to 1978, are presumed to contain lead-based
paint. Lead from paint, paint chips, and dust can pose health hazards if not managed
Page 4 of 5
properly. Every purchaser of any interest in Residential Real Property on which a
residential dwelling was built prior to 1978 is notified that there is a risk of exposure to
lead from lead-based paint that may place young children at risk of developing lead
poisoning.
B. The Grantee covenants and agrees that it shall not permit the occupancy or use of any
buildings or structures on the Property as Residential Property, as defined under 24 Code
of Federal Regulations part 35, without complying with this section and all applicable
Federal, State, and local laws and regulations pertaining to lead-based paint and/or leadbased paint hazards. Prior to permitting the occupancy of the Property where its use
subsequent to sale is intended for residential habitation, the Grantee specifically agrees to
perform, at its sole expense, the Army’s abatement requirements under Title X of the
Housing and Community Development Act of 1992 (Residential Lead-Based Paint
Hazard Reduction Act of 1992).
C. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the
Property as to its lead-based paint content and condition and any hazardous or
environmental conditions relating thereto. The Grantee shall be deemed to have relied
solely on its own judgment in assessing the overall condition of all or any portion of the
Property, including, without limitation, any lead-based paint hazards or concerns.
5. PCB NOTIFICATION AND COVENANT
A. The Grantee is hereby informed and does acknowledge that the potential presence of
PCB Paints at the site.
B. The following building(s) on the Property has (have) the potential to contain PCB
Paints: [LIST BUILDINGS]. The Grantee agrees to undertake any and all PCB Paints
abatement or remediation in the aforementioned buildings that may be required under applicable
law or regulation at no expense to the Grantor. The Grantor has agreed to transfer said buildings
to the Grantee, prior to remediation or abatement of PCB Paints, in reliance upon the Grantee’s
express representation and covenant to perform the required PCB Paints abatement or
remediation of these buildings.
C. The Grantee acknowledges that it has inspected or has had the opportunity to inspect the
Property as to PCB Paints condition and any hazardous or environmental conditions relating
thereto. The Grantee shall be deemed to have relied solely on its own judgment in assessing the
overall condition of all or any portion of the Property, including, without limitation, any PCB
Paints concerns.
Page 5 of 5
ENCLOSURE 9
PUBLIC NOTICE
ENCLOSURE 10
RESPONSIVENESS SUMMARY

FINDING OF SUITABILITY FOR EARLY TRANSFER (FOSET

Transcription

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