DRAFT ALAMEDA POINT (AP) BASE REALIGNMENT AND CLOSURE (BRAC) CLEANUP TEAM (BCT) MONTHLY TRACKING MEETING

AFTER-ACTION REPORT www.bracpmo.navy.mil August 30, 2012 Meeting Attendees: Navy Derek Robinson Bill McGinnis Mary Parker Matthew Slack Regulatory Agencies Bob Carr Adriana Constantinescu Michelle Dalrymple David Elias James Fyfe Jerry Hensley Chris Lichens Roger Lupo Rajiv Mishra Sophia Serda Karen Toth Xuan-Mai Tran Jeffrey Wong Myriam Zech City of Alameda Peter Russell

Base Realignment and Closure (BRAC) Program Management Office (PMO)-West, Environmental Coordinator (BEC) BRAC PMO-West, Lead Remedial Project Manager (RPM) BRAC PMO-West RPM Navy Radiological Support Office (RASO) (by phone/A.M.)

U.S. Environmental Protection Agency (EPA) ( by phone/A.M.) CA Regional Water Quality Control Board (Water Board) Department of Toxic Substances Control (DTSC) Water Board DTSC California Department of Public Health ([CDPH]) Radiological Health Branch (RHB) EPA CDPH RHB CDPH RHB EPA DTSC EPA CDPH RHB Water Board

Russell Resources/City of Alameda

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Contractors Larry Dudus Pete Everds Dennis Kelly Betty Schmucker Meeting Objectives:

Tetra Tech EC Tetra Tech EC Tetra Tech EM Trevet, Inc.

Finalize July 17, 2012, BCT Meeting Minutes Review Action Items Make Miscellaneous Announcements Discuss CDPH License Exemption Discuss Operable Unit (OU) 5/Fleet and Industrial Supply Center Oakland Alameda Facility/Alameda Annex (FISCA) Installation Restoration (IR)-02 Technical Memorandum Discuss Polynuclear Aromatic Hydrocarbon (PAH) Screening Levels Discuss Look-Ahead Schedule

The meeting agenda is provided in Attachment A. 1. Introductions and Topics: A. B. Introductions Finalize July 17, 2012, BCT Meeting Minutes Introductions were made. Chris Lichens (EPA) announced he is replacing Pankaj Arora on AP. Derek Robinson (Navy) asked for comments on the July 2012 BCT meeting minutes. Jeff Wong (CDPH) had the following comment: C. Page 4 of 6, second paragraph from the bottom: please add EMB after CDPH in the last sentence of the paragraph. Review of Action Items

Mr. Robinson reviewed th e list of new and pending action items from the July B CT Meeting. Action Items 3, 6, 10, 11, and 12 are com plete and Action Item s 5, 8, and 13 are pending. Action Item 11 (list of projects and RPMs) will b e resent and updated with Chris Lichens name for the sites previously assigned to P ankaj Arora. Item 13 (responses to comments [RTCs] for IR-02) will be distributed on September 7 for review in redline/strikeout. D. Miscellaneous Announcements

Karen Toth (DTSC) noted that the DTSC, CD PH/Environmental Management Branch (EMB), Navy, and contractors had a great meeting on A ugust 16, 2012. The team worked through issues on the smelter areas and reported that things are moving forward on clearing buildings.

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Mr. Robinson said the Draft Finding of Suitability to Transfer (FOST) will b e submitted to the agencies for review around September 17, 2012. No open CERCLA sites will be included, except those granted Operating Pr operly and Successfully (OPS) status and portions of OU-2A where institutional controls (ICs) have been decided. Mr. Lichens asked what areas are included in the FOST. Mr. Robinson explained that the FOST covers tho se sites with a Record of Decision (ROD) in plac e or OPS; som e areas w ill be cu t out f or later transfer. J ames Fyfe (DTSC) asked if any radiologically impacted build ings are included in the FOST. Mr. Robinson said only sites determ ined to not need further work are included and sites requiring additional work will be excluded from this FOST. The goal is to transfer the property by December 2012 and everyone is working toward that. Peter Russell (City of Alameda [City]) asked how long the review period will be for the Draft FOST; Mr. Robinson said 30 days. Dr. Russell said that he reviewed the Inter im Removal Action Com plete Report (IRACR) for Sites 6 and 16 and noted that no borings logs were included in one of the appendices. Mr. Robinson said the logs will be sent. Mr. Robinson announced that Mr. McGinnis and J acques Lord (Navy) m et with the Alam eda Point Restoration Advisory Board (RAB) committee to discuss seed selection for vegetating IR Site 2. The m eeting went well and the RAB comm ittee will discuss the meeting results at the upcoming RAB meeting on September 13, 2012. Mr. Robinson said th at an update on IR Site 1 will be p resented at the next R AB meeting. Injections were performed at IR Site 1 but no verified results to report on are available yet. Mr. Robinson asked w hich of the agencies will give the BCT meeting update at the next RAB meeting. Xuan-Mai Tran (EPA) said John West (Water Board) will present the update. Mr. Robinson announced that the Am ericas Cup boats have used the dock in the northeast corner of Seaplane Lagoon. David Elias (W ater Board) announ ced that the agency has, in principle, reached concurrence with the Navy on the beneficial groundwater use exception for the southeast corner of AP. The concurrence letter is about 80- or 90-percent complete, but the Water Board needs to include a few more things. He would like to wait until Jo hn West returns from vacation to com plete the letter. Mr. Robinson asked if having the c oncurrence letter in hand is holding up signing the OU-2A ROD, because the ROD refere nces the letter; if so, then he would like to finish the letter as soon as possible. The OU-2A ROD should be final soon and the Navy is fine with signing the ROD and attach the letter later. Ms. Tran said EPA had comments on the OU-2A ROD that need to be resolved before the docum ent can be signed, and it would be good to have the letter complete before signing the ROD. Bob Carr (E PA) said that even though the OU-2A language is agreed upon at the staff level, internal review is still needed. He did not want the Water Board to feel compelled to have to m eet the Septem ber 10 deadline for the c oncurrence letter. Mr. Robinson said the Navy will proba bly agree with EPAs c omments on the OU-2A ROD, but Navy Legal would like to discuss wording and ICs with EPA Legal. In response to agency comments on the draft OU-2A ROD, Mr. Robinson said that tarry refinery waste (TRW) will not be add ressed under th e AP Petroleum Program. It was pulled into CERCLA some time ago and is being addressed in the OU-2A ROD. TRW was addressed in the OU-2A feasibility study (FS) and it was sampled, as was soil gas. The language in the FS is not
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as tight as the Navy would like, and some clarity was lost in the Proposed Plan; however, the bottom line is th at TRW is a nuisance rather than a risk to hum an health and the environment. The Navy is considering having T RW recycled for use in asphalt road cover. T he Petroleum Program addresses fuels and tanks and TRW does not fit, so it has been handled under CERCLA. Dr. Russell gave a history of TR W at AP. TR W is its own IR site, is well defined in limits and content, and covers a 4-acre footprint. The City recognizes that TRW is a site developm ent and nuisance issue but not a CERCLA issue. Of c oncern is the regulatory attitude toward TRW. Individual components of TRW were evaluated. Thirty-one separate boring logs reported total petroleum hydrocarbons (TPH) at fairly high levels (on th e order of 6,000 parts per m illion [ppm] for TPH-diesel). The City would like to put TRW to bed, administratively speaking. Dr. Russell added that the City review ed the thoroughness of the TRW evaluation and is satisfied. The City will addre ss TRW in its site m anagement plan. The area of AP containing TRW is planned for commercial reuse, although that is not required in the OU- 2A ROD. The City and Navy agree TRW has been extensively studied under CERCLA. Mr. Elias said that TRW needs to be addressed in some way; there is no documentation that runs with the land, no deed restrictions, etc., for TRW. The Water Board is concerned that there is no long-term management strategy for TPH. Mr . Robinson said the C ERCLA Program is an appropriate mechanism for evaluation of TRW a nd, if there is no risk under CERCLA, there is no need for ICs. He noted that polynucl ear aromatic hydrocarbons (PAHs) have been extensively addressed under CERCLA. TRW may pose a nuisance for future developers, but the material is more or less inert. Mr. Elia s asked how CERCLA addre ssed TRW. Mr. McGinnis explained how CERCLA, rather than the Petroleum Program, handled TRW. Mr. Elias and Dr. Russell agreed that Mr. West needs to be present to discuss OU-2A ROD wording for TRW. Mr. Elias said Mr. W est thought TRW was going into the Petroleum Program. It was agreed to schedule a conference call next week when Mr. West is back to disc uss OU-2A ROD wording, which needs to clearly state which way TRW is being addressed (CE RCLA or Petroleum ). September 6 or 7 are tentative dates for the call. Mr. Elias noted that data ar e now available on breakdow n products of diesel, which were probably not evaluated in the past. He said the TRW issue m ay not ne ed to be reopened but should be addressed now. He w ill work with Mr. W est to address fairly inert TRW. A signed ROD could be reopened if the Water Board determines additional work is needed. Ms. Tran said it is preferable to address issu es now, before OU-2A ROD signing. Dr. Russell said the City is better off keeping TRW in the CERCLA Program ra ther than moving to the Petroleum Program, due to the CERCLA warranty. Mr. Carr said he did not necessarily agree with that statement. 1.0 CDPH License Exemption Jerry Hensley (CDPH RHB) gave a presentati on addressing CDPHs process for release of military facilities in California as a result of radiological remediation/cleanup. He noted that this presentation is a work in progress and is not final. A handout with updates would be forthcoming. This presentation was prepared sp ecifically because of Alameda Point and focuses on what is needed for a license exemption. 4 of 9 TRVT-4408-0000-000X

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Mr. Hensley explained the roles of CDPH, t he Environmental Management Branch (EMB) which serves as a consultant to DTSC, and the RHB that regulates cleanup and licensing of radiologic materials on Califor nia. CDPH advises DTSC on cr iteria and acceptable cleanu p levels for property to b e transferred to civ ilian use. Once the prop erty is transferred, CDPH assumes a r egulatory role. Depending on the re sult of radiological rem ediation/cleanup, three options are possible: 1) CDPH may have no future regulatory oversight; 2) CDPH m ay issue a license for radioactive materials; or 3) CDPH m ay issue a licen se exemption defining allowable activities and site uses to ensure pu blic safety and health. Dr. Russell asked if Option 3 would involve recording a land use restriction; Mr. Hensley said yes. In response to Slide 7, Mr. McGinnis asked if a California Radioactive Material License or exemption is issued to the City rather than the Navy, and that CDPH wants the Navy involved up front; Mr. Hensley said yes. Dr. Russell clarified that the property does not need to leave federal hands for CDPH to get involved, and Mr. Hensley said that is correct. In review of slides 8 and 9, Mr. Hensley noted that once a licens e is is sued for rad iological materials (Option 2), it is very hard to get rid of it. Laws and regula tions apply to both licenses and exemptions. Public health and safety are ev aluated before issuing a license exemption. Mr. Robinson asked whether the radiological screening level of 25 millirems is correct. Mr. Hensley said yes, that value agrees with the Nuclear Regulatory Commission and will never exceed 2 5 millirems. Mr. Robins on asked if readings n eed to be tak en on the site, or wheth er CERCLA documentation will suffice. Mr. He nsley said it will depen d but readings may be taken. Chris Lichens (EPA) asked about the extent of work and scrutiny for a license versus an exem ption. Mr. Hensley said less work is required for a license, since a radiological officer is assigned to the case, while more paperwork is re quired for an exemption. He also noted that CDPH is short on qualified staff and suff icient time is needed to review license and exemption requests. Mr. McGinnis asked if ICs are part of both Option 2 and Option 3; Mr. Hensley said yes. Mr. Hensley reviewed the m inimum 14 ite ms involved in a license ex emption application, following California Health and Safety Code and California Code of Re gulations requirements (slides 13 and 14). He also stressed early CDPH involvement, especially in the cas e of landfills where covers are in place to contain radio logical materials. He noted that radiological personnel (health physicists) want to know what is in th e landfill. Ms. Toth asked how to get CDP H involved before covering a landfill. Mr. Hensle y said the earlier the better, and the m ore information available, the better . Restricted-release site is a trigger for CDPH involvem ent. Mr. Robinson asked if it is possib le to scan for a decent representative volume/amount of waste, rather than having to excavate a landfill; Mr. Hensley said yes. Mr. Hensley said that no exem ptions have been i ssued yet as this is a n ew process. Dr. Russell asked how to keep up with process changes. Mr. Hensley said to work through DTSC. He noted that these are draft guid elines and this is an iterative process. CDPH works closely with DTSC and EPA, as well as with the Water Board.

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2.0

OU5/FISCA IR-02 Technical Memorandum

Mary Parker (Navy) gave an introduction to the technical memorandum (tech memo) addressing risk posed by naphthalene at OU5/FISCA IR-02. The tech m emo is under BCT review and comments are due Septem ber 14. Mr. Robinson noted that the tech m emo was prepared in support of a proposed plan and ROD a mendment, which were discussed at the April 2012 BCT meeting. The tech m emo presents the basis for a risk m anagement decision. Mr. Carr said the tech memo outlines the direction the Navy wants to go toward a ROD am endment; however, a tech memo will not support a proposed plan or ROD without a feasibility s tudy. Mr. Robinson clarified that the tech memo was done to evaluate risk before proceeding with CERCLA. Mr. Lichens noted that the toxicity value for na phthalene has changed. Ms. Parker replied that the risk assessment was finalized in 2004 and the value for naphtha lene has not since changed in IRIS (the Integrated Risk Inform ation System). Sophia Serda (EPA) said the naphthalene risk number has not been updated in IRIS but it was determ ined that naphthalene is a known carcinogen, and California toxicity reference data should be used. Dr. Serda said that the California toxicity value is used nationwide. Ms. Park er explained that Hydropunch samples were collected, and con centrations were highe r at dep th (20 feet belo w ground surface) and lower in the shallow levels. The risk assessment was run using the higher values and fell within the risk m anagement range. The h azard index (HI) is also less than 1.0. Ms. Co nstantinescu asked if groundwater well data were also used; Ms. Parker said yes. Mr. Lichens asked if the Marsh Cr ust is the p rimary source of PAHs. He said the increased naphthalene and benzene results from the biospa rging treatment system m ay not be from the Marsh Crust. Ms. Parker explained that multiple lines of evidence point to the Marsh Crust as the source. Mr. Lichens said the results suggest more contaminants are being pulled out of the ground than the Marsh Crust could generate, an d EPA will submit a comment about this. Larry Dudus (TetraTech) explained the pilot test resu lts showed rebound and are probably artificially high. The source was determ ined to be the Marsh Crust based on m ultiple liens of evidence, including fingerprinting of soil and groundwater at several locations. Mr. Dudus presented the tech m emo findings. He not ed that the total dissolved solids data from well sampling showed groundwater is not suita ble for dom estic uses. He presented the conceptual site m odel (CSM) for the contam inant source and resulti ng vertical groundwater contaminant distribution. Ms. Dalrymple said the figure looked familiar and asked if it was used in the Rem edial Investigation/Feasibility Study (RI/FS). Mr. Dudus said this CSM was in the Remedial Design Report and had b een revised since the RI/FS. Based on the risk assessm ent, the tech memo found that vapor intrusion is not currently, or likely to be, an indirect exposure pathway leading to potential indoor air inhalati on risks exceeding the risk m anagement range, and that residential and commercial uses are pr otected without any further action. Mr. Dudus said the path forward proposed is a ROD amendment that selects no further action (NFA). Dr. Serda said a lot has changed since 2004 for c onducting vapor intrusion st udies and that it is rather misleading to say there is no unacceptable risk. She felt that th e analysis of the vapor intrusion work is out of date and said that there are other sources at AP besides the Marsh Crust. Ms. Dalrymple asked if a new risk assessm ent was performed since 2004. Ms. Parker said no, but for the tech m emo additional total dissolve d solids data were evaluated and conservative assumptions used in the original RI/FS risk assessm ent. Ms. Toth said that, based o n EPA and
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DTSC comments a new risk asse ssment may be needed, since now it is known that naphthalene is a carcinogen. Ms. Toth asked how NFA can be se lected if land use restrictions are in pl ace due to the Marsh Crust Ordnance. Mr. Robinson said there is a base-wide Marsh Crust ROD. Mr. Carr said a groundwater use restriction also would be needed , unrelated to the Marsh Crust ROD restriction, and would need to include non-drinking-water exposure to the analysis if the Navy wants to state that the site risk is acceptable for unrestricted use. Mr. Robins on asked Mr. Carr if there were a groundwater beneficial use excepti on, would ICs also be needed to keep people from being exposed to groundwater (not the same as drinking), and w hether ICs for non-intrusive work as stated in the Marsh Crust Ordina nce would take care of it. Mr. Carr said no, the IC would need to mention groundwater. Mr. Robinson said the Navy generally uses EPA values rather than state values for assessing risk. However, the most important factor is protection of human health and the environment and other values are consid ered. He rem inded the BCT that comments on the tech memo are due on September 14. 3.0 PAH Screening Levels Mr. McGinnis said this presenta tion was developed in response to questions arising from the Petroleum Program and the PAH regional screen ing level (RSL) used for CERCLA response. The Water Board would like to formalize the PAH RSL for both the Petroleum and CERCLA Programs so the RSL can be referenced. Mr. McGinnis provided background inform ation on the source of the fill that contains PAHs . Nine fill ev ents from 1903 to 1959 used bay s ediments as fill to create AP. The fill sources included local sediments such as Oakland Inner Harbor and Seaplane Lagoon. Historic industrial activity around the Bay m argins has impacted the sedim ents with PAHs, such as the Marsh Crust. Knowing that sediments were used instead of native fill creates a different CSM, since the sediments reflect anthropogenic activities. Applicable guidance for PAHs us es benzo(a)pyrene (B[a]P) equiva lents. This follows the EPA RSL Users Guide using B(a)P equivalents as a scaling factor. Dr. Russell asked about applying toxicity values to carcinogenic P AHs and th at adding the values can be redundant. BCT members discussed how the toxicity values were achieved. Mr. McGinnis explained the background for reaching the 0.62 parts per million (ppm) RSL. At a May 31, 2000 m eeting, the Navy, DTSC, and the City agreed that a P AH RSL for AP of 0.62 ppm is appropriate. Furthermore, concentrations below 0.62 ppm would be able to be transferred for unrestricted use, concentrations between 0.62 and 1.0 ppm would generally be acceptable and would be further evaluated and discussed w ith the BCT, and concentrations above 1.0 ppm would require a CERCLA evaluation. The 0.62 ppm RSL has been used at the RI stage. Myriam Zech (Water Board) noted that the Water Board was not at that meeting. In 1999, Jim Polisini of DTSC aut hored a tech memo regarding ambient levels for carcinogenic PAHs and provided a perspective on values. Dr. Serda m entioned a 2002 Navy work plan for collection of PAH samples that clearly details the fill sources. Ms. Constantinescu asked if there are data sets for each of the nine fill events ; Mr. McGinnis said he did not think so, and the fill events may have used various sources. 7 of 9 TRVT-4408-0000-000X

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Mr. Elias raised the issue of how the RSL was deve loped. He noted there were several data sets and sources used and recalled a thorough study that resulted in 0.69 ppm as the RSL. But no one could remember it so the risk-based concentr ation of 0.62 ppm for AP fill was settled on. Dr. Russell said he thought the 0.62 ppm value was for one specific site at AP. Mr. Robinson asked the BCT if everyone agreed on 0.62 ppm as the RSL. Dr. Russell explained that the Water Board is trying to understand if 0.62 ppm is appropriate as a background RSL for the Petroleum Program. Ms. Zech said the RS L should be the sam e for both CERCLA and the Petroleum Program. She asked abo ut the cancer risk as sociated with 0. 62 ppm and what that means for future residential development and the need for vapor barriers. Mr. Robinson said the cancer risk falls within the risk management range at 10 -5. He add ed that th e BCT needs to formalize the RSL and get it f ormalized into the Petroleum Management Plan so s ites can b e closed. Mr. McGinnis said the path forward shou ld be that 0.62 ppm, as background, is the RSL for residential and com mercial/industrial reuse at AP. Mr. Elias sugg ested that the 0.62 ppm RSL be for malized, as currently there are only meeting minutes where the RSL was discussed and agreed upon. The Navy agreed to for malize the RSL in technical m emorandum that can be used for reference. 4.0 Look-Ahead Schedule Mr. McGinnis reviewed the Look-Ahead Schedule for active and upcoming fieldwork and recent and upcoming documents. Dr. Russell requested that the boring logs for the OU-1 Sites 6 and 16 Draft IRACR for groundwater be su pplied so review can proceed. Two dates were listed for the OU-2B Draft Proposed Plan; the October 31, 2012, date is correct. Fina l language is being resolved to f inalize the OU-2A ROD, and it is expected to be transm itted on September 10 or later. The RAB will receive an u pdate on th e Site 1 groundwater rem edial action at the September 13 m eeting. Mr. Fyfe said Ms. Dalrymple would like an update on the OU- 2B treatability studies bef ore finalizing the OU- 2B FS Addendum . He will also transm it Ms. Dalrymples comments to the Navy. Ms. Toth asked whether the former smelter area tech memo should be added to the look-ahead. Mr. Robinson said it will be a dded, and he would also like to keep track of the documents under CDPH review that need concur rence. Ms. T ran asked about the base-wide Site Managem ent Plan (SMP) fo r the com ing year. Mr. Robinson said a fe w changes have been m ade and the draft final will be ready soon. Ms. Toth requested the SMP before September 7 i f possible, as that is when DTSCs EnviroStor sys tem locks down for the year.

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5.0

Action Items and Adjournment Action Items Action Item Update Complete (draft emailed 8-29-12; comments expected) Pending; in progress -- should be ready soon

1. Navy (B. McGinnis) to write up results of the OPS discussion between the attorneys and distribute to BCT. 2. Navy (C. Moss) to assess the 20-30 OU-2B monitoring wells and will provide BCT with a summary of MNA information by the second week of July 2012. 3. Navy (C. Moss) to distribute the OU-2B FS Tables 12 + 13 change pages to the BCT with toluene detection levels corrected. 4. Navy (T. Guiang) to look at pH soil data for Site 28 and update the regulatory agencies. 5. Navy (T. Guiang) to e-mail RTCs and draft final Site 28 IRACR in tracked-changes mode to regulatory agencies once they have the opportunity to comment on proposed paragraph. 6. Navy (B. McGinnis) to distribute new list of projects and respective RPMs to the BCT 7. Navy (D. Robinson) to check with the City of Alameda about the Land Use Plan for the OU-2C area.

Complete

Pending Complete

Complete (will resend with C. Lichens name for P. Arora) Complete (confirmed w/J. Ott, City of Alameda, that OU-2C will be commercial; a sentence in the Proposed Plan related to the previous plan for future land use will be deleted accordingly) Pending

8. Navy (D. Robinson) to check with RPM (J. Lord) about the timeline for resolving comments on the IR02 Draft-Final 90% Remedial Design and adjust the SMP schedule accordingly; 9. Navy (D. Robinson) to send IR02 90% Remedial Design RTCs in track changes mode to EPA; EPA to set up conference call or working meeting to discuss 10. Navy to forward boring logs for Sites 6 and 16 IRACR. The BCT meeting was adjourned.
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ATTACHMENT A ALAMEDA POINT BCT MONTHLY MEETING AGENDA July 17, 2012 (1 Page)