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        FOSTER WHEELER ENVIRO'NMe:NTAL COR:PORATION




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                                                    ,?September 25, '1996       J':~
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Mr. Edward Keller
BRAC Environmental Coordinator
Department of the Army
Military Traffic Management Command
HQ. Western Area, Oakland Army Base
Oakland, California 94626-5000

SUBJECT:       FINAL BASEWIDE ENVIRONMENTAL 13A.SB~, stftR~y

Dear Ed:

Please find two copies ofthe Final Basewide Environmental Baseline$utVey~W-EBS) for'
Oakland Army Base. I have included the Response to CQmn1etlti in 'YQwtopi~~, lb~ Corps~~
copies and the agency copies.                 "

I will bring copies to the September 25th RAB meeting for distribution there: I Will also send
agency copies directly to them as indicated on the distribution list below."

                                                     Siltcer~ly,




                                                     John L. Carrier,     lrr
                                                     Program Manager

Enclosures

c:     Henry Wong (CallEP A, 2 copies)
       JamesNusrala(RWQCB, 1 COpy)
       Phillip Ramsey (USEP A, 2 copies)
       Wandell Carltoo (ACOE, 2 copies)




                  2525 NATOMAS PARK DRIVE, SUITE 250, SACRAMENTO, CA 95833-2900
                               TEL: 916-921-2525 FAX: 916-921-5124
CallEPA

Department of
?    .iubstances
Co.arol

700 Heinz Avenue                                     August. 8, 1996
 Suite 200
Berkeley, CA
94710-2737
                   Mr. Edward Keller
                   BRAC Environmental Coordinator
                   Department of the Army
                   Military Traffic Management Command
                   HQ. Western Area, Oakland Army Base
                   Oakland, California 94626-5000

                   BASEWIDE ENVIRONMENTAL BASELINE SURVEY, OAKLAND ARMY BASE

                   Dear Mr. Keller:

                          The Department of Toxic Substances Control (DTSC) has received
                   the draft Basewide Environmental Baseline Survey (EBS) for the
                   Oakland Army Base (OARB) dated July 1996. OARB's consultant Foster
                   Wheeler Environmental Corporation forwarded the draft Basewide EBS on
                   July 8, 1996. DTSC and the Regional Water Quality Control Board
                    (RWQCB) provided comments on the prelirni.nary draft Basewide EBS on
                   May 23, 1996. The draft Basewide EBS is a revision subsequent to the
                   agencies' comments.

                         DTSC appreciates the opportunity to review the draft Basewide
                   EBS and provides the following comments.  Some of the following
                   comments have been made previously and have not yet been addressed.
                   Others refer to new information provided in the revised draft:

                   General Comments:

                   1.          The Comprehensive Environmental Response, compensation and
                               Liability Act (CERCLA) includes radioactive materials and
                               radioactive wastes as hazardous substances. Specifically, the
                               Code of Federal Regulations, Title 40, Section 302.4, Table
                               302.4 lists radionuclides as hazardous substances.
                               Radiological information is not merely a disclosure item and
                               should be reported in the EBS as a category factor.

                               In the past use of radioactive materials, both licensed and
                               nonlicensed, the management and disposal practices for each,
                               are not fully addressed, an expeditious transfer of OARB
                               property will be difficult. Without sufficient Ln f o rma t Lon on
                               radioactive materials, DTSC cannot concur with the Community
                               Environmental Response Facilitation Act (CERFA) uncontaminated
                               parcels (i.e., Base Realignment and Closure (BRAC) Parcels 18
                               and 26) recommended in the EBS.  Please see Specific Comment 19
                               for the specific information needed on radioactive materials.
                               DTSC wants to meet with you to review the information on
                               radioactive materials, in order to expedite the determination
                               of the CERFA uncontaminated parcels.

                   Response: We will move the "Radionuclides and Licensing" section in with the
                   Categorization Factors. Also radiation issues will be incorporated into the EBS to the
                   degree the information is available (see response to Comment 19).

                   OARBIEBSIRTC Draft EBS.doc
                                                                                       Printed 011 Recycled Paper
Mr. Edward Keller
August 8, 1996
Page 2



2.      Oil water separators (OWSs) are designed to separate oil, fuel,
        grease, and sludge from water.  Since oily wastes are
        classified as Resource Conservation and Recovery Act (RCRA)
        hazardous wastes, operation of an OWS requires a RCRA hazardous
        waste facility permit.

        Sections 4.2.1.2 and 4.2.3.4 reveal that OARB has operated nine
        OWSs without a RCRA hazardous waste facility permit.  Failure
        to apply for a permit does not preclude investigation and
        remediation of possible hazardous waste releases from the OWSs.
        Please note that the OWSs are defined as solid waste management
        units, regardless of whether OARB has a hazardous waste
        facility permit or not.

        Pursuant to the Hazardous and Solid Waste Amendments, Section
        3008(h) and the California Health and Safety Code, Section
        25187, OARB shall investigate the OWS sites for possible
        releases and remediate any contamination under the RCRA
        Corrective Action Program. Alternatively, OARB may address the
        potential OWS release under CERCLA.

        Please revise the EBS indicating the appropriate regulatory
        status and cleanup strategy for the OWSs. Environmental
        compliance audits conducted in the 1970s and 1980s indicated
        that OWSs were not properly managed and maintained. Without
        knowing whether hazardous wastes have been released from OWS-3
        in BRAe Parcel 4, it is premature to conclude that BRAC Parcel
        4 is classified as the Department of Defense (DoD) Category 2.

Response: BRAe Parcel 4 has been reclassified as Category 7. To the extent
possible, the additional information requested by DTSC will be developed in future
activities of the preliminary assessment through the remedial investigation phases at
OARB. Cleanup strategies will be addressed in the BRAC Cleanup Plan (BCP),.

Preliminary discussions with DTSC indicated that according to their guidance, OWSs
serving car wash facilities are exempt from permitting. It is anticipated that the BRAC
Closure Team will continue to work together on the entire issue of the oil/water
separators at 0 ARB"
3.      The draft EBS does not include three appendices that were in
        the preliminary draft EBS.       These were Appendices H, I and J on
        Ha z a rdou s Subs tances/Waste Management Practices Summary,
        Underground Storage Tank Summary, and Polychlorinated Biphenyls
        summary, respectively.       Please attach these appendices back to
        the draft EBS.

Response: These appendices will be included in the final draft. A statement will be
included to clarify that these original appendices sections were developed in the
preliminary draft phase of the Basewide EBS and may not reflect current data that has
since been added, clarified or corrected"



OARBIEBSIRTC Draft EBSdoc
Mr. Edward Keller
August 8, 1996
Page 3


4.       The EBS reports that the original fill underlying most of the
         base may be from hydraulic dredging spoils from the Oakland
         Outer Harbor area. The EBS assumes that the original fill may
         itself contain heavy metals and other mining related
         contaminants. Because the underlying soil may contain heavy
         metals, OARB needs to evaluate the metal concentration in the
         soil before deciding future reuse of the base's property.

Response: This will be added as an action item for the BCT. The underlying fill will
      be investigated as part of the Basewide PA/SI.
5.       Section 3.4 of the BRAC Cleanup Plan (BCP), dated July 1996,
         provides rationale for classifying a BRAC parcel into one of
         the seven DoD categories. The EBS does not present this
         pertinent information.  Please include Section 3.4 of the BCP
         in the EBS.

Response: This section of the BCP will be added (and updated). The information
      regarding the CERFA Uncontaminated Parcels will be added to Chapter 5.
      The rest will be added to the appendices.
Specific Comments:

1.       Figures S-1, 4-1, 4-4 and 5-1, Appendix F, CERFA Map:   Please
         revise Figures S-1, 4-1, 4-4 and 5-1 to show the parcel
         boundaries for BRAC Parcels 16 and 17 consistent with those
         delineated in the Large Scale Map (Appendix F). The east
         boundary of BRAC Parcel 16 should be redrawn to include
         Buildings 842, 843 and 844.

Response: Figures S-I, 4-1, 4-4, 5-1, and Appendix F, CERFA Map have been
      revised.
2.       Figures S-1, 4-1, 4-4 and 5-1, Appendix F, CERFA Map:   In
         response to RWQCB's Comment 5, dated May 9, 1996, OARB states
         that the boundaries of BRAC Parcels 4, 5 and 9 have been
         realigned so that the Cypress Reconstruction Area is entirely
         in BRAC Pa rce L 5. However, Figures S-1, 4-1, 4-4, 5-1, and the
         Large Scale Map do not indicate that BRAC ParcelS's boundary
         includes t.he Cypress Reconstruction Area entirely.  Please
         revise the figures.   Figure 2-1 of the BCP depicts the correct
         boundary for BRAC ParcelS.

         Please update the parcels' acreage listed in Tables 5-2 and
         5-3.

Response: Figures S-I, 4-1, 4-4, and 5-1, Appendix F, CERFA Map have been
      revised. Tables 5-2 and 5-3 have also been revised to include the updated
      acreage amounts.
3.       Table 3-3, List of Current Structures at OARB:  Please replace
         the column heading ""Facility" wit.h "Building/Facility." The
         areas for Facilities 809, 814, 844, 845 and 736 and Building



OARB/EBS/RTC Draft EBS.doc
Mr. Edward Keller
August 8, 1996
Page 4


         648 (demolished) are not listed in the table.    Please include
         these areas in Table 3-3. The entries are made for building
         99:  29,624 ft 2 for a vehicle maintenance shop and 10,530 ft 2
         for an electrical maintenance shop.    Please clarify whether
         these maintenance shops should be grouped together under one
         entry for Building 99, or whether these are separate buildings
         and one is misnumbered.

Response: Table 3-3 has been revised. The maintenance shops in Building 99 should
      be grouped together. Facilities 844, 845, and 736 are recreational facilities: a
      handball court, a softball field, and a baseball field, respectively. We will
      estimate their area. The area will also be estimated for Facility 809, the "gas
      station without building" and Facility 814.
4.      Section 3.5.1, RCRA St.atus: The EBS states that there are no
        RCRA permit.ted facilities at the present time. Please indicate
        whether OARB has operated under RCRA permits in the past.   In
        addition, please indicate whether OARB has operated or is
        operating any units under non-RCRA hazardous waste facility
        permits (e.g., standardized permit, permit by rule, tier
        permitting) .

        OARB has been managing waste oil, a RCRA hazardous waste, in
        various underground storage tanks (USTs), aboveground storage
        tanks (ASTs), and OWSs (see Tables 3-4, 4-1, 4-2, and 4-3).
        Has OARB ever received hazardous waste facility permits for
        managing waste oil in these units?

Response: OARB has not operated under RCRA permits in the past nor is OARB
      operating any units under under non-RCRA hazardous facility permits. OARB
      has not received hazardous waste facility permits for managing waste oil in
      these units. OARB operates under 22 CCR 66262.34(a), which allows
      accumulations up to 90 days without a permit.

5.      Section 3.5.7, UST Permits: The EBS indicates that information
        on the UST history and remediation is presented in Section
        4.1.1.  However, Section 4.1.1 cannot be found.  Please provide
        this information.

Response: This was a typographic error.. The section referenced should have been
      Section 4.2.1 1. This error will be corrected..
6.      Table 3-4, UST permi t.s : Table 3-4 lists nine USTs wi th permi.t
        numbers; however, Table 4-2 lists 14 permitted USTs.     Please
        clarify.

Response: Table 3-4 lists all USTs that are currently permitted . The 14 USTs listed
      in Table 4-2, are all those that were permitted in the early 1990s. Text will be
      added to clarify these sections.




OARBIEBS/RTC Draft EBS doc
Mr. Edward Keller
August 8, 1996
Page 5


7.       Section 4.1, New Areas Identified: The EBS states that
         dewatering of dredge spoils occurs in land adjacent to OARB's
         west boundary and drainage migrate onto OARB property.  Please
         specify which BRAC parcels are adjacent to the dewatering area,
         and discuss OARB's plan for investigating the potential surface
         contamination from dewatering practices.

Response: The dewatering observed during the VSI was located to the west of
      BRAC Parcel 10. The Port of Oakland currently tests the dredge tailings prior
      to dewatering. Sampling of this area may be performed during the Basewide
      PAISI.
8.       Table 4-1, AST:     Please provide the tank numbers in Table 4-1.

Response: The ASTs that are permanent (i.e., have piping) have been numbered and
      are listed in the List of Current Structures (Table 3-3). Their numbers will be
      added to Table 4-1. The other ASTs are only considered temporary (i.e., they
      are moveable) and therefore are not numbered.
9        Table 4-2, UST Inventory: The old Tank 19, renumbered to Tank
         12, is listed as "Active;" however, Tank 12 is listed as
         "Inactive." Please clarify.

Response: Tank 12 is now inactive. This discrepancy will be corrected.
10.      Section 4.2.1.2, OWSs: Environmental compliance audi.ts
         conducted in the 1970s and 1980s indicated poor to non-existent
         management and maintenance of the OWSs. Has there been any
         soil sampling conducted to assess the potential for rel.eases?

Response: No soil sampling has been conducted with respect to QWSs. This is a
      matter for the BCT to determine a course of action.
11.      Table 4-3, OWSs: The table provides the OWSs' locations and
         current status.  Please also provide information on the BRAC
         parcel, year installed, capacity, material of construction, any
         impervious coating, aboveground or underground, etc.

Response: This additional information will be provided to the extent available.
12.      Table 4'-4, OARB Spill History:    Please replace "STUDY AREA"
         wit.h O!BRAC PARCEL." Please describe the response action taken
         for:' t.he leakage at Bataan Avenue/Maritime Street. How many
         gallons of diesel leaked from the 2,750-gallon tank?

Response: This spill was actually located in BRAC Parcel 8. The amount spilled was
      estimated between 2 and 20 gallons. The spill log has been updated to include
      more information, A copy of the spill log is attached to the Response to
      Comments.




OARB/EBSIRTC Draft EBS.doc
Mr. Edward Keller
August 8, 1996
Page 6


13.      Section 4.2.2.2, Storm Water Issues: The EBS mentions that
         storm water is discharged at the outfall pipes located under
         piers 5, 6 and 7.   Please show the pier locations in the Large
         Scale Map, Appendi.x F.

Response: These locations will be labeled on the Large Scale Map.

14.      Section 4.2.3.3, Medical/Biological Waste: The EBS states that
         the Veterans Administration is negotiating to move into the
         dispensary (Building 762 in BRAC Parcel 18).  Please note that
         a site-specific EBS and either a Finding of Suitability to
         Transfer (FOST) or a Finding of Suitability to Lease (FOSL)
         need to be prepared before the Veterans Administration can use
         Building 762.

Response: The VA is currently operating the dispensary during the weekdays and the
      Army Reserves will operate it during the weekend. At this point, it is
      anticipated that the Army Reserves will retain the dispensary as part of the
      Reserve Enclave. The Army is committed to having the regulatory agencies
      review all transfer documents.
15.      Section 4.2.3.4, RCRA Facilities/SWMUs: Please identify and
         describe the collection, storage and disposal of all RCRA and
         non-RCRA hazardous wastes that were in existence at OARB.
         Please also identi.fy any units that had stored or are storing
         RCRA or non-RCRA hazardous wastes under generator status (i.e.,
         less than 90 days storage).    For each of these storage units
         operated under generator status, please provide the unit
         description, material of construction, capacity, location, BRAC
         parcel number, spill and release history, any soil sampling
         data supporting the absence of hazardous waste released from
         the unit (or justification for' not taking any soil. samples),
         etc.

Response: GARB has a Hazardous Waste Management Plan that describes all
      hazardous waste storage and handling procedures. Additional information will
      be provided in future studies.
16.      Section 4.3.1, Asbestos: Hall-Kimbrell Environmental Services,
         Incorporated conducted and asbestos survey of some buildings
          (42 buildings as listed in Table 4-5) at OARB. The EBS states
         that the survey report does not describe the condition of the
         asbestos containing materials (ACM), nor if the ACMs are
         friable or nonfriable. Without identifying whether a building/
         facility contains friable or nonfriable ACMs, and the condition
         of the ACMs (e.g., damaged), the Hall-Kimbrell report lacks
         important information that an EBS requires.   DTSC could not
         assess whether the ACMs found in those 42 buildings would pose
         an unacceptable risk to human health or the environment.
         Please include the condition of ACMs in the EBS, and indicate
         that this information will be reported in subsequent site-
         specific EBSs and FOSTs!FOSLs.




OARB/EBS/RTC Draft EBS.doc
Mr. Edward Keller
August 8, 1996
Page 7


Response: This information will be reported in the Site-specific EBS and
      FOSTIFOSL. A sentence will be added stating that this issue will be addressed
      in the Site-specific EBSs.
         The EBS states that only about 50 percent of the buildings were
         surveyed for asbestos.  Please indicate when OARB will complete
         the asbestos survey, and indicate these results will be
         reported in subsequent site-specific EBSs and FOSTs/FOSLs.

Response: The asbestos survey is schedule for completion in September 1996. A
      sentence will be added stating that this issue will be addressed in the Site-
      specific EBSs.
17.      Section 4.3.2, Lead-Based Paint (LBP): The EBS identifies the
         Capehart Quarters as Buildings 670, 674, 675, 676, 680, 689,
         722, and associated playgrounds, and the EM Quarters as
         Building 690 and the adjacent volleyball court. There are
         other buildings (e.g., Buildings 774, 650, etc.) near the above
         listed buildings that mayor may not be included as the
         Capehart or EM Quarters.

         Please provide a complete list of building/facility numbers for
         the Capehart and EM Quarters, and all recreational areas.
         Please define "EM."

         Provide the building numbers for the Capehart housing at 680-M
         at Tenth Street and the EM housing at 775-E Eleventh Street.
         Soils tested in these housing areas were found to have elevated
         concentration of lead (i.e., 1,369 ppm and 435 ppm). The EBS
         states that the Public Works Center recommend soil cleaning by
         removing any paint chips and debris, covering with mulch, and
         planting vegetation. The BRAC Cleanup Team (BCT) needs to
         evaluate the information provided and determine what the proper
         remedy should be.  Please identify this issue for BCT review
         and action.

         The EBS states that the analysis indicates that LBP is present
         in the interior and exterior of the Capehart, EM housing units,
         and playground equipment.  Please provide the building number
         (building/facility number if it is a recreation area) where
         analytical results indicate the presence of LBP.

         The EBS states that Buildings 778 and 650 and Facilities 779
         and 845 were not surveyed for LBP, nor were the soils adjacent
         to these structures sampled and analyzed for lead.  Please
         indicate when LBP survey and soil sampling will be conducted.

Response: Text has been revised, as per comments. Please note that the lead-in-paint
      data provided by Navy Public Works Center was in composite form, not by
      specific building or unit. "EM" is defined as "Enlisted Members," and has been
      added to the acronym list. It will be noted in the EBS that the composite
      sampling occurred. This issue will be added to the BCT action list.



OARB/EBS/RTC Draft EBS..doc
Mr. Edward Keller
August 8, 1996
Page 8



18.      Section 4.3.3, Polychlorinated Biphenyls (PCBs):  Have there
         been any PBCs stored in equipment (e.g., tank, circuit breaker,
         rocker arm, hydraulic lift, etc.) other than transformers? The
         EBS should provide a detailed inventory of all PCB containing
         equipment. This inventory shall include a historical account
         identifying the location, sampling analysis results (if any),
         size, status, leakage, and physical integrity observed for all
         units and equipment containing PCBs.

Response: DARB does not have an inventory of potential PCB-containing equipment
      (other than electrical transformers). Two automotive lifts were located at
      DARB. Both have been removed. Building 648 contained a lift that leaked
      PCBs. This release is discussed further in Section 4.4.2. The other lift that
      was removed was located in Building 830. It is not known whether the
      hydraulic fluid contained PCBs. However, nearby monitoring wells have not
      detected PCBs.

19.      Section 4.3.4, Radionuclides and Licensing: OARB has served as
         a transfer station for radiation-containing materials (or
         radioactive materials) for the overseas military units and the
         DoD installat.ions in the continental United States. OARB could
         have managed significant amounts of radioactive materials since
         1940.

        In the letters forwarded to OARB on March 29 and May 23, 1996,
        DTSC requested that the EBS include radiological information
        pursuant to the Department of Health Services (DHS) guidance.
        However, the EBS has not included any radiologic evaluation.
        All of the following questions shall be answered to complete
        the EBS.   (These questions were forwarded to OARB on March 29,
        1996. ) :

         a.      What were the types and quantities of radionuclides used,
                 stored, or disposed of at your facility? The response
                 should include copies of the current license with any
                 amendments, or a summary of those documents. The
                 response should also address uses of nonlicensed
                 radioactive material  (e.g., radium-226) and its
                 disposition.

         b.       How long has your facility been licensed to use
                  radioactive material? How often did your facility
                  utilize radionuclides during a typical work week, and
                  over what period of time were they used?

         c.      How were radioactive material used at your facility?
                 What were the protocols and procedures required for their
                 use and what were the details of the protocols and
                 procedures? What was the extent of the past and present
                 radiological surveillance program? Examples of
                 documentation supporting the radiological surveillance
                 program should be provided.



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Mr. Edward Keller
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Page 9



         d.       How did utilization of radioactive material change over
                  time? When did you begin controlling uses of nonlicensed
                  radioactive material?

         e.       Discuss and provide data for the ambient radiologic
                  background of your facility within all relevant
                  environmental media. What are the details of your past
                  and present environmental monitoring program?

         f.       Did your facility release any radioactive material to the
                  environment? What data support your response? If
                  releases did occur, what were the details of such
                  releases, and what was your course of action to correct
                  the problem?

         g.       Have you buried nonlicensed radioactive material at your
                  facili ty? What. is the supporting documentation for this
                  response?

         h.       What were the requirements for training users of
                  radioactive material at your facility? What was the
                  chain of command for your radiation safety program? Were
                  personnel monitoring devices used at your facility as
                  part of the radiation safety program?

         i.       Have any of the individuals in your radiation safety
                  program been interviewed regarding the past and present
                  use of radioactive material? What positions did the
                  interviewees hold in the radiation safety program and for
                  how long?

         j.       What is your current inventory of sources of radioactive
                  material and their utilization? What remediation is
                  ongoing, or proposed, at your facility?

         k.       What were and are your plans for the disposition of
                  licensed and nonlicensed radioactive sources? What is
                  the potential for mixed waste (radioactive and hazardous
                  wastes) at your facility?

         1.       In addition to a narrative description of your facility's
                  use of radioactive material, provide a table that
                  identifies each radionuclide, the approximate quantity
                  (in standard units of millicuries or microcuries) per
                  item, as well as the total activity for the inventory of
                  items, the purpose, the years during which the
                  radionuclide was utilized, the location (e.g., parcel and
                  building numbers) of use, storage, or disposal; whether
                  the source was sealed or unsealed, whether its presence
                  was authorized by a specific license or not licensed; and
                  the disposition of the radionuclide (e.g., decayed on
                  site, disposed of on site, stored on site, transferred
                  off site, destination if transferred) .




OARBIEBSIRTC Draft EBS .doc
Mr. Edward Keller
August 8, 1996
Page 10


        m.       Have contacted your military service branch's experts in
                 radiologic matters for help in answering questions you
                 have or resolving issues that concern you? Please
                 identify the organization and specific staff contacted.
                 These contacts would include the Army's Environmental
                 Hygiene Agency at the Aberdeen Proving Ground, Maryland;
                 the Army Corps of Engineers in Omaha, Nebraska, etc.

        The above questions assist OARB in properly documenting the
        radiological history of the base.  If remediation is needed,
        OARB should follow the DRS's Guidance for Cleanup of
        Radioactivity on Closing Military Bases for Unrestricted Public
        Use of Property, dated AprilS, 1994.

Response: Information has been compiled in response to this question. It will be
      added to the EBS.

        Please provide the complete name of the "1302 n d " and spell out
        the acronym "NRC" in Section 4.3.4.

Response: These changes have been made. This section is now 4.2.2.2.

20.     Section 4.3.5, Radon:  Please identify the buildings where
        radon monitoring was conducted. Were all buildings at OARB
        tested for radon? If not, please provide rationale as to why
        some of the buildings were not tested for radon.

Response: Text has been revised to include the buildings tested for radon. Only a
      representative sample of buildings were tested for radon. This methodology is
      consistent with Army policy.

21.     Table 5-1, DoD Categories: Table 5--1 lists BRAC Parcel 23 as
        DoD Category 2 with storage of hazardous substances or
        petroleum products for less than one year.   The BCP, Section
        3.4.1, page 3-15 states that warehouses at OARB generaLLy
        (emphasis added) store materials for less than one year, unless
        the materials ar-e for use at the installation.  OARB has
        presumed that all storage is for less than one year, unless
        records or practices indicate otherwise.

        Please note that in order a parcel can be [sic] nominated as
        CERFA uncontaminated, no hazardous substances or petroleum
        products shall be stored for more than one year.   If OARB plans
        to nominate BRAC Parcel 23 as DoD Category 1, please explicitly
        document that no hazardous substances or petroleum products
        were stor-ed in Buildings 640 and 641 in BRAC Parcel 23 for mor-e
        than one year.

Response: Warehouses at OARB are operated under MTMC Regulation 5669, which
      requires that goods remain no longer that 15 days prior to being shipped to
      their ultimate destination. Conformance with this policy has been confirmed by
      interviews with Grant Ivory, Chief of Container Freight Branch


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Mr. Edward Keller
August 8, 1996
Page 11



22.      Section 5.2.1 and Table 5-2, CERFA Uncontaminated Parcels: The
         EBS documents that 50 to 100 gallons of diesel were spilled in
         the area of 14 t h Street and Maritime Street (BRAC Parcel 26).
         Oakland Fire Department Hazmat Team and OA..~B personnel
         contained the spill to prevent liquid from entering storm
         drains. The Public Work Center spill response contractor,
         Laidlaw, provided the clean-up.

         OARB indicates that this spill was not a release and therefore
         should not disqualify BRAC Parcel 26 as being DoD Category 1.
         OARB further references the United States Environmental
         Protection Agency's (U.S. EPA) memorandum titled Military Base
         Closures: Guidance on EPA Concurrence in the Identificat.ion of
         Uncontaminated Parcels under CERCLA Section 120 (h) (4), dated
         April 19, 1994. The memo gives three examples which U.S. EPA
         would concur an area to be CERFA uncontaminated.   One example
         includes stained roadways where incidental releases of
         petroleum products have occurred, but no indication that such
         release pose a threat to human health or the environment. The
         "incidental releases" sited in the memo refers to oil drips
         from automobiles, and does not apply to the 50 to 100 gallons
         of diesel spill at BRAC Parcel 26.  DTSC will not be able to
         concur that this parcel is CERFA uncontaminated.    Please
         reclassify.

         DTSC has asked OARB the following questions, but the draft EBS
         fails to provide answers to them.  For purposes of spill
         documentation, please provide responses to the following
         questions:  1) Was the spill occurrence on bare soil, asphalt,
         or concrete? 2) What was the duration after noticing the
         release to spill containment and remediation? 3) Have there
         been samples taken to ensure that the spill has not migrated
         into the soil?

Response: This information will be added to the extent it is available. A copy of the
      spill report is appended to this Response To Comments.

         Please note that a roadway is not designed to contain liquid
         spill. Cracks and crevices are commonly found on ground
         surface, providing a pathway for diesel to migrate into the
         underneath soil.  Furthermore, asphalt and concrete are porous
         materials and are inadequate to prevent liquid from seeping
         into the environment.

         Table 4-4 of the EBS documents a second spillage in BRAC Parcel
         26 at. Bataan Avenue/Maritime Street. Diesel leaked from a
         2,750-gallon tank at a rate of about one gallon per minute.
         The EBS does not describe any response action for this spill.
         How many gallons of diesel were spilled onto the ground?
         Please provide the same information requested for the spillage
         at 14 t h Street and Maritime Street.




OARBIEBSIRTC Draft EBS . doc
Mr. Edward Keller
August 8, 1996
Page 12


Response: This spill was actually located in BRAC Parcel 8. The amount spilled was
      estimated between 2 and 20 gallons. The spill log has been updated to include
      more information. A copy of the spill log is attached to the Response to
      Comments.

         A diesel spill on a roadway is a release to the environment,
         regardless of whether the spill was cleaned up.  BRAC Parcel 26
         cannot be classified as DoD Category 1.  Please reclassify this
         parcel to an appropriate DoD Category.

Response: GARB plans to reclassify BRAC Parce126 as DoD Category 4.

23.      Tables    5-1 and 5-2, CERFA Map Summary: The EBS nominates BRAC
         Parcel    4 as DoD Category 2. The northwestern portion of BRAC
         Parcel    4 is identified as a contaminated area site, Berths 8
         and 9    (see Figure 4-4 and the Large Scale Map in Appendix F) .
         Please    clarify.

Response: The area shown on the large-scale map as Berths 8 and 9 is the study area,
      not the area of contamination. The shading will be changed to make this more
      clear.

        As discussed in General Comment. 2, it does not appear that BRAC
        Parcel 4 could be classified as DoD Category 2.   Please
        reclassify the parcel.

Response: Parce14 will be categorized as Category 7.

24.     Table 5-2, page 95 and Appendix C, page A-23, 10,000-gallon
        AST:  OARB has redrawn the boundaries for BRAC Parcels 16 and
        17.  Please present the information on the 10,000-gallon AST in
        the BRAC Parcel 17 section, instead of the BRAC Parcel 16
        section.

Response: This correction will be made.

25.     Table 5-2 and page A-26, PCB Transformer in BRAC Parcel 23:
        There are two large pad-mounted PCB transformers at Building
        640. No secondary transformers at Building 640. No secondary
        containment was observed during the visual si.te inspection.
        What is the physical integrity of the transformers? Have there
        been any spillages or leakages of PCBs from these transformers?

Response: The is no evidence (either documentation or visual) to indicate any spills
      or leaks from these transformers.. This information will be added to the EBS.

26.      Table 5-·1 and 5-2, CERFA Map Summary:  The EBS nominates BRAC
         Parcel 21 as DoD Category 3.   Page A-26 states that potential
         high concentrations of lead may be in the soils surrounding the
         buildings and structures.   Section 4.3.2 documents that the
         soils at BRAe Parcel 21 were tested with lead as high as


OARB/EBSIRTC Draft EBS.doc
Mr. Edward Keller
August 8, 1996
Page 13


        1,369 ppm.  Soil investigation and remediation have not been
        completed at the lead contaminated areas.

        In addition, Tank I was an 1,000-gallon UST removed from
        Building 737 in BRAC Parcel 21.  Investigation is needed to
        determine whether there has been a release of hazardous
        substance or petroleum products from Tank I.

        With these pending investigations and remediation for the lead
        contamination and UST sites, BRAC Parcel 21 should not be
        classified as 000 Category 3.  Please reclassify this parcel to
        an appropriate DoD category.

Response: This Parcel will be reclassified as Category 7.

27.     Section 5.3, Data Gaps:  Please include a statement indicating
        that the data gaps identified in page 102 will be provided in
        subsequent site-specific EBS, FOSL and/or FOST.
Response: That statement will be added.

       RWQCB is currently reviewing the draft Basewide EBS. DTSC will
forward RWQCB's comments by August 15, 1996. We apologize for the
delay.

       DTSC realizes that OARB plans to finalize the EBS by August 22,
1996. With the si.gnifi.cant number of comments provided in this
letter, completion of the final EBS as scheduled may not be feasible.
However, DTSC is available to meet with you to ensure understanding
of the agencies' comments, and to minimize the comment/revision
iteration. Also, DTSC would like to specifically discuss issues
affecting CERFA nominated properties so they can be resolved.    DTSC
is ready to assist you to expedite finalization of the EBS.

      If you have any questions, please feel free to contact me at
(510) 540-3770.

                                           Sincerely,



                                           Henry Wong                      •
                                           Environmental Assessment and
                                              Reuse Specialist
                                           Base Closure and Conversion
                                           Office of Military Facilities

Enclosure




OARB/EBSIRTC Draft EBSdoc
CallEPA

Department of
Toxic Substances
Control

700 Heinz Avenue
                                                  August 13, 1996
 Suite 200
Berkeley, CA
94710-2737
                   Mr. Edward Keller
                   BRAC Environmental Coordinator
                   Department of the Army
                   Military Traffic Management Command
                   HQ. Western Area, Oakland Army Base
                   Oakland, California 94626-5000

                   BASEWIDE ENVIRONMENTAL BASELINE SURVEY, OAKLAND ARMY BASE

                   Dear Mr. Keller:

                         On August 8, 1996, the Department of Toxic Substances
                   Control provided comments on the draft Basewide Environmental
                   Baseline Survey (EBS), dated July 1996, for the Oakland Army
                   Base (OARB). The August 8 letter states that the Regional
                   Water Quality Control Board's (RWQCB) comments will be
                   forwarded within a week. The followings are RWQCB's comments
                   on the draft EBS:

                   RWQCB Comments:

                   1.         Table 4-1, Aboveground Storage Tanks (ASTs):  Please
                              indicate the Department of Defense (000) category of the
                              parcel where the ASTs are/were located. A parcel with
                              an active or removed AST should be classified as 000
                              Category 2 or above, as this would constitute storage of
                              hazardous substances or petroletm products.  Please also
                              depict the AST locations on the Large Scale Map,
                              Appendix F.

                   Response: Appendix F has been revised to include the AST information. As
                         discussed at the August 29, 1996 meeting, the DoD Category is located in
                         Table 5-2. This table will be reviewed to ensure it contains the AST
                         information included in Table 4-1.

                   2.         Table 5-2, Community Environmental Response Facilitation
                              Act (CERFA) Map Summary: Without any evidence that any
                              contaminants related to the oil water separator (OWS-3)
                              have not leaked into the surrounding soils of the
                              stormdrain system, Base Realignment and Closure (BRAC)
                              Parcel 4 should probably be classified as 000
                              category 7.  Please provide the sampling results (if
                              any) to document that hazardous substances or petroleum
                              products have not leaked from OWS-3 and into the
                              environment.



                   OARBIEBS/RTC Draft EBS.doc
                                                           14
Mr. Edward Keller
August 8, 1996
Page 2


Response: Parcel 4 will be categorized as Category 7.

3.         Table 5-2, CERFA Map Summary: The 50 to 100 gallons
           diesel spill that occurred on April 30, 1993 constitutes
           a release of petroleum products into the environment.
           Therefore, BRAC Parcel 26 should not be classified as
           DoD category 1. Please provide confirmation sampling
           results from Laidlaw (if any) to document that the
           diesel spill has not migrated into the soil or the
           stormdrain and eventually to the San Francisco Bay.

Response: See response to CallEPA Specific Comment # 22.

            If you have any questions, please feel free to contact me at
(5I0)       540-3770.

                                          Sincerely,



                                         Henry Wong
                                         Environmental Assessment and
                                            Reuse Specialist
                                         Base Closure and Conversion
                                         Office of Military Facilities




OARB/EBSIRTC Draft EBS doc
                                         2
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                     REGION IX
                                 75 Hawthorne Street
                            San Francisco, CA 94105-3901


VIA FACSIMILE
(510) 466-2066


August 9, 1996

Edward Keller
BRAC Environmental Coordinator
Department of the Army
Military Traffic Management Command
HQ. Western Area, Oakland Army Base
Oakland, CA 94626-5000

Re:        Oakland Army Base Draft Environmental Baseline Survey

Dear Mr. Keller:

     The u.S. Environmental Protection Agency (U.S. EPA)
appreciates the opportunity to provide comments on the
Oakland     Army   Base   (OARB)  Draft   Basewide   Environmental
Baseline Survey (Draft EBS).      The Draft EBS was prepared for
the   U. S.   Army   Corps   of   Engineers  by    Foster  Wheeler
Environmental Corp. dated July 8, 1996.       Comments on a March
1996 Preliminary Draft EBS were provided in U. S. EPA's May
30, 1996, letter.      Based upon u.S. EPA's review of the Draft
EBS, the following comments apply:

1.          section 4.4.1.1,   Subsurface Investigations/Structural
            Damage.  U.S. EPA's May 30, 1996, General Comment No.2,
            references OARB's text stating:

                             "...original fill underlying OARB may itself
                       contain heavy metals and other mining-related
                       contaminant.s that were brought. in with the fill
                       from upstream areas or other parts of the bay
                       area.     Some cont.aminant.s could be from dredging,
                       barging     and   dumping    operations derived  from
                       upstream river channel dredging maintenance of
                       spoils that were previously polluted by activities
                       such as hydraulic mining during the "gold rush"
                       era."

           In your response to u.s. EPA comments, you indicate that
           an examination of the fill material has been budgeted
           for future work at OARB.     u. S. EPA requests that the
           above text be modified to include a statement that some
           metals contamination at OARB could also be site related.



OARBlEBSIRTC Draft EBS.doc
Response: This modification will be made.

2.          section 5.2.1, CERFA Uncontaminated Parcels.    The Draft
            EBS   documents   two  significant,    releases  in  BRAC
            Parcel 26.       U.S.   EPA  has    concurred   with  the
            identification of uncontaminated parcels where petroleum
            products or their derivatives may have been released as
            evidenced by incidental stains on paved areas such as
            parking lots.   However, EPA has not concurred with such
            identifications for areas where specific releases have
            been documented.

Response: This Parcel is being recategorized as Category 4. More information on
      this spills will be included in the EB S and attached to this Response to
      Comments.

3.          U.S. EPA has been concurrently reviewing "Work Plan for
            Remedial   Investigation,  Building  807,  Oakland Army
            Base, "  dated  May    31, 1996.     In   section   2.2.1
            (Background), text states, "[f] rom 1916 through 1936,
            the land was occupied by previously owned industrial
            buildings and associated oil storage tanks."       Please
            provide comment or discussion on how OARB considered
            prior operations in categorizing property at OARB.

Response: All data derived from the records search, review of historical aerial
      photos, visual site inspections, and interviews was considered when
      determining the appropriate category. The statement quoted above was
      evidently referring to property that was acquired by the Army but subsequently
      disposed of Examination of 1936 aerial photos indicate the area presently
      occupied by OARB was wetland without any structures. The oil storage tanks
      that are evidently referred to, are those that were located to the southwest of
      GARB on Petroleum Street.

4.          Table 4-4, OARB Spill History.     This table does not
            include any reference to volatile organic compound (VOC)
            release(s) in the vicinity of Building 807 (BRAC Parcel
            12) and Knight Rail Yard (BRAC Parcel 15).

Response: A reference to the presence of VOCs at Site 807 will be added to the text.
      However, since the release referenced is an IRP site, it has not been included in
      the Spill History,

5.          Figure 4-4,    Known Contamination sites.     Based upon
            current OU characterization data, area of contamination
            illust.rated in the vicinity of Building 807 (BRAC Parcel
            12) should be extended east into the Knight Rail Yard
            (BRAC Parcel 15).




OARBlEBSIRTC Draft EBS.doc
                                           2
Response: The east and west boundaries of this contamination plume have yet to be
      determined. However, the figures will be changed to indicate the plume may
      extend into this area.

     If you have             any questions   please    contact me      at   (415)
744-2365.

                                         Sincerely,


                                         Phillip Ramsey
                                         Remedial Project Manager




OARB/EBSIRTC Draft EBS.doc
                                        3
                                    Attachment 1

                              Cal/EPA's Response to the
                             Draft Response to Comments
                                  (September 9, 1996)




OARBlEBSlRTC Draft EBS.doc
09-10-96 12:40PM FROM   MTMCW~     FAC ENG                                                      P02
                                  CAL-EPA DTSC




                                     Fax Transmittal Sheet
                                 California Environmental Protection Aglncy
                                  Department of Tox1e Substances Control
                                                   Region2 '
                                           ornolofMilitary FacilitIes:
                                       Baa.Closure and Conversion
                                       700 ~Inz Avenue, Suite 200
                                        Berke1ey, Oarlfornia 94710


    -
    Date:        9/3/96                              Numberof Pages Inoluding Cover:        2

    TO:          Edward Keller                        Phone:      (510) 466-3226
                                                      Fax;        (510) 466-2066

    Company:     Oakland Army Base, Mliltary Trafflc Management Command

    From:        Henry Wong                           Phone~      (~10)   540·3770
                                                      Fax:        (510) 540·3819



    Here ere my comments/auggastlons on Fo!ter Wheeler'I' responses to OTSC'. comments.

    MaJgr CQn~emi:

    1.           BRAe Parcel 4: Dunng the August 29 meeting we agreed on csmng BRAe
                 Parcel 4 as Category2. I have then checked with JenniferSmith and other reuse
                 specialists 8tstewide and Phillip Ramey has talked with U.S.EPA's reuse
                 specialist. We have the same reservation of classifying BRAe Parcel 4 ss
                 Category2 based on existIng data do not show evidence of releasRS. The tack of
                 release information Isa result of Incomplete environmental survoy on the oll
                 w.ter separator(OWS..3). An Incomplete aurvoy ie not. velid juetlflcatlCln for
                 oIaaaifying a parcel as Category 2. DTSC requests BRAe Parcel 4 to be
                 classified 18 Category 7.

    2.           BRAe Parcel 17: Storage and mixing of herbicides and peatlcJdea are conduGtad
                 In BuIlding 640. Please prov1de additional Information on the storage and mixing
                 operatlon. VVhat;s the maximum storage capacity for the area? What Is the
                 material of construction and $urface coating en the storage area? 15 there a
                 secondary containment system provided? What is the current condition of the
                 area (stain, crack, etc.)? What is the weekly or monthly quantity of herbicides
                                                        '8
                 and pesticides being mixed? What the management practice to capture and
                 prevent Gpil1age dUring mixing? The BCT needs to review these data gaps
                 before determining whether Category 2 Is appropriate for BRAe Parcel 17.
09-10-96   12:40PM FROM MTMCWA, FAC ENG                                                                  P03

   SEP-03-1996    16:02            CAL-EPA DTSC




     Commeohs on..Egster Wheelers Craft Response to DISC Commenta~

     Reeponse to General Comment 1: Change "August 13" to "August 23."

     Response to General Comment 2: Change KOVVS #4" to "OWS #3."            oree
                                                                             Is not concern
     whether the OWSs are pumped out regularly nor whether they are Itoraga unlts. The OWSs
     are ReRA ha%9rdoU8 waste treatment units. Please contact OTSC'. Permitting Branch
     (510-540·3974) for approprIate permit requlrement81f OARe pJans to continue operating the
     OW6s until base closure,

    Responeo to General Comment 3: Please clarify whether the        finar 8saewide EBB will or will not
    Include Appendices HI I and J.

    Response to General Comment 5: Plesse state that the BOP Section 3.4           will be added as an
    appendix of the final Basewide   eaSt
    Response to Speeific Comment 3: Ph~a8. provide the areas for the building8l1aoilltiee (l.a., 809
    - gas station wtthout bldg., 814. gas cylinder storage shed, 844 - handball court. 845 - softball
    field, 736" b.uiebalf field little leagUt~, 648 - mslntenancs). If the tlrea& are not provided In the
    Hermann Zillgens report, please gath.r the Information by conductin'l a field measurement.

    Response to SpeOific Comment 14: DTSC agrees that no EBS or FOST/FOSL is required tor
    Federul-to-Federal transfer. However, DTSC requests the opportunity to comment on any
    transfer document prepared for transferring BUilding 762 to the Veterans Administration. Suoh
    tranefer may take place several years after the Basewide EBS revlew. Additional review ls
    advisable to ensure that the environmental condition of Bulldlng 762 would not be changed.

    Response to Specific Comment 17: P!easQ Indicate In the EBS that the lead data provided by
    PWC was in composite form, not by !peclfic buildtng or unit.

    Response to Spectfic Comment 18: DTSC did not ask for release infarmstloh at Building 648.
    Please respond to DTSC's originat comment dated 818/96.

    Refiponse to Spectflc Comment 19: Please note that DTSC and the Department of Health
    SeNIOM (DHS) wiU revfew the Information on the radlologiCilI materials. DHS may request
    clarification or expansion on the Information submitted.

    Response to SpeOlfic Comment 23: Please 61180 prOVide the Laldlaw cleanup report either as
    an appendix or under separate subrnlttal. The BCT Would need the lnformatJon to determine
    the cornpleteneas of remedial actions.

    Response to Specific Comment 25: Please include the response statement in the Baaewlde
    E8S, Appendtx c.




                                                                                                   TnTOI    P   C\':l
SEP-20-1996   16:53             CAL-EPA DrSC                                   510 540 3819   P.01/06




                                  Fax Transmittal Sheet
                            California Environmental Protection Agency
                             Department of Toxic Substances Control
                                               Region 2
                                      Office of Military Facilities
                                   BaseClosure and Conversion
                                    700 HeinzAvenue, Suite 200
                                     Berkeley, California.. 94710




 Date:        9/20/96                            Number of Pages Including Cover:         6

 To:          James Nusrala                      Fax:        (510) 286-3986
              Phillip Ramsey                     Fax:        (415) 744-1 917
              Edward Keller                      Fax:        (510) 466-2066
       --~ GIQGn      CariieP                    Fax:        (916) 921-5124

 Company:     RWQCB, USEPA, OARBQOSter Wl1e~

 From:        Henry Wong                         Phone:      (510) 540-3770
                                                 Fax:        (510) 540-3819




 Message:     Here are my draft comments on the Oakland Army Base~5 Response to
              Comments and revised pages on the EBS. Ed Keller plans to distribute
              the final EBS to the RAB members during the 9/25 RAB meeting. In the
              interest of time, I am sharing my comments to you before internal review.

              James, please fax your comments to me for incorporation into the DTSC
              letter.
                                                                               "' '.
                                                                               Q     f
                                                                                         ..


CallEPA
                                       September 24, 1996
Department of                                                                     Pete Wilson
Toxic Substances                                                                    Governor
Control
                                                                             lame ~ M. Strock
700 Heinz Avenue   Mr. Edward Keller                                            Secretary for
 Suite 200         BRAC Environmental Coordinator •                            Environmental
Berkeley, CA       Department of the Army                                           Protection
94710-2737
                   Military Traffic Management Command
                   HQ. Western Area, Oakland Army Base
                   Oakland, California 94626-5000

                   BASEWIDE ENVIRONMENTAL BASELINE SURVEY, OAKLAND ARMY
                   BASE

                   Dear Mr. Keller:

                        The Department of Toxic Substances Control (DTSC)
                   has received the Response to Comments on the draft
                   Basewide Environmental Baseline Survey (EBS) and
                   revised pages of the EBS for Oakland Army Base. OARB's
                   consultant Foster Wheeler Environmental Corporation
                   forwarded the response on September 18, 1996.

                        DTSC appreciates the opportunity to review the
                   above mentioned submittal and provides the following
                   comments:

                   General Comments:

                   1.   OARB states that the warehouses at the base are
                        operated under Military Traffic Management Command
                        (MTMC) Regulation 5669, which requires that goods
                        remain no longer than 15 days prior to being
                        shipped to their ultimate destination. This rule
                        does not apply to hazardous substances or
                        petroleum products that are not a part of the MTMC
                        shipments (e.g., fuel, pesticides, hazardous
                        materials, etc.).  In addition, the rule may allow
                        storage extension beyond the 15-day limit for
                        certain reasons.

                        A parcel is Community Environmental Response
                        Facilitation Act (CERFA) uncontaminated if no
                        hazardous substances or petroleum products were
                        released, disposed of, or stored for more than one
                        year.  If no hazardous substances or petroleum
                        products were' stored in BRAC Parcel 18 (including
                        Buildings 762 and 765) and BRAC Parcel 23
                        (including Buildings 640 and 641) for more than
Mr. Edward Keller
September 24, 1996
Page 2



      one year, please explicitly state so and discuss
      the rationale for this assertion. Without this
      information being presented in the Basewide EBS,
      DTSC would not be able to concur that BRAC Parcels
      18 and 23 as CERFA unconta~inated.

,2.   Storage and mixing of herbicides and pesticides
      are conducted in Building 840 at BRAC Parcel 17.
      Please provide additional information on the
      storage and mixing operation. What is the maximum
      storage capacity for the area? What is the
      material of construction and surface coating on
      the storage area? Is there a secondary
      containment system provided? What is the current
      condition of the area (stain, crack, etc.)? What
      is the weekly or monthly quantity of herbicides
      and pesticides being mixed? What is the
      management practice to capture and prevent
      spillage during mixing? DTSC needs to review
      these data gaps before determining whether
      Department of Defense (DoD) Category 2 is
      appropriate for BRAC Parcel 17.

 3.   The Basewide EBS documents that 50 to 100 gallons
      of diesel were spilled in the area of 14 t h Street
      and Maritime Street (BRAC Parcel 26). Oakland
      Fire Department Hazmat Team and OARB personnel
      contained the spill to prevent liquid from
      entering storm drains. The Public Work Center
      spill response contractor, Laidlaw, provided the
      cleanup. OARB classifies BRAC Parcel 26 as DoD
      Category 4.

      A parcel is classified as DoD Category 4 where a
      release of hazardous substances or petroleum
      products has occurred, and all remedial actions
      necessary to protect human health and the
      environment have been taken.  Please provide any
      documentation (e.g., Laidlaw cleanup report)
      reporting the completion of the diesel spill
      cleanup at BRAC Parcel 26. The spill log provided
      in Attachment 2 does not have sufficient
      information to confirm the success of remedial
      actions.

 Specific Comments:

 1.   OARB Radiological Issues and Responses, Attachment
Mr. Edward Keller
September 24, 1996
Page 3



      3, page 6: The Attachment states that OARB will
      contract with the u.s. Army Center for Health
      Promotion and Preventative Medicine (CHPPM) for
      performing a radiological historical
      investigation. Please in~lude a statement in the
      Basewide EBS indicating that OARB will forward the
      CHPPM radiological historical investigation
      results to DTSC when they are available. The
      Department of Health Services and DTSC are
      interested in CHPPM's responses on this issue.

2.    OARB Radiological Issues and Responses, Attachment
      3:  Please include the subject information in its
      entirety in the Basewide EBS.

3.    Section 4.3.1, Asbestos: Please indicate that
      comprehensive asbestos data will also be included
      in the Finding of Suitability to Lease.

4.    Section 4.4.2, West Grand Overpass:   Please define
      "TOG.1/




5.    Tables S-1 and 5-1, DoD Environmental Condition
      Categories: Please delete BRAC Parcel 2 from DoD
      Category 4. BRAC Parcel 2 has been classified as
      DoD Category 7 already.

6.    Table 5-3, Acreage Summary:   Please indicate BRAC
      Parcel 4 as DoD Category 7.

     If you have any questions r please feel free to
contact me at (510) 540-3770.

                          Sincerely,




                          Henry Won
                          Environmental Assessment
                            and Reuse Specialist
                          Base Closure and Conversion
                          Office of Military Faciliti.es

cc:   See next page.
Mr. Edward Keller
September 24, 1996
Page 4



cc:     Mr. Phillip A. Ramsey
        Environmental Scientist
        U.S. Environmental Protection Agency
        Region IX
        Hazardous Waste Management Division
        75 Hawthorne Street, (H-9-2)
        San Francisco, California 94105

        Mr. James Nusrala
        Project Manager
        Regional Water Quality Control Board
        2101 Webster Street, Suite 500
        Oakland, California 94612

        Mr. Thomas P. Galvin
        Base Transition Coordinator
        Military Traffic Management Command
        Oakland Army Base
        100 Alaska Street, Suite 2214
        Oakland, California 94626-2214

      v/Mr. John L. Carrier, J.D.
        Program Manager
        Foster Wheeler Environmental Corporation
        2525 Natomas Park Drive, Suite 250
        Sacramento, California 95833-2900

        Mr. Wandell Carlton
        U.S. Army Corps of Engineers
        CESPK-ED-M
        1325 J Street, 12th Floor
        Sacramento, California 95814-2922
                                       Attachment 2

                                        Spill Logs for
                                   Martime and 14th Street
                                              and
                             Leaking Diesel AST (BRAe Parcel 8)




OARB/EBSIRTC Draft EBS doc
   Attachment 2 - (Spill Logs)




11. On 30 April 1993, a diesel spill occurred in the area of 14th
Street and Maritime. The spill was caused by a punctured fuel -
tank of a truck owned by Pacific Rim Transport, Inc.
Approximately, 50 - 100 gallons of diesel was spilled on the
roadway.  Oakland Fire Department Haz. Mat. Team was the first to
respond to the spill. They arrived in time to contain the spill
enough to prevent any from entering storm drains. OARB personnel
also responded and helped in the containment effort.   PWC SFB
spill response contractor, Laidlaw, provided clean-up.




   Diesel Spill From Truck (April 30, 1993) Area of 14th Street & Maritime @ BP-26
MTWGA-EN (20Q-la)                                        22 June 1994

MEMORANDUM FOR MTPAL-FE

SUBJECT:    DIESEL SPILL


1.     Reference:   AR 200-1.

2.   Oakland Army Base is in the process of replacing underground
storage tanks.  On 21 June 1994 at 1909 hrs a hazardous materials
spill was reported by the Oakland Army Base Military Police.   See
enclosure for details of incident, response and cleanup. A
steady drip from a temporary storage tank released approximately
20 gallons of diesel fuel onto an asphalt base area. Soil was
placed under the dripping pipes to absorb the fuel.  The release
was contained to a very small area.  The leaking tank was emptied
and fuel was transferred to the underground storage tank.  The
contaminated soil was collected, placed on plastic and covered
with plastic.  The soil and contaminated asphalt will be disposed
of by the contractor as part of the tank removal project.  Brit
Johnson of the Alameda County Health Agency was contacted on
22 June 1994 at 1400 hrs. We were informed that this was not a
reportable spill.


3.     The point of contact is Mr. Mark   ~onsavage,   466-2787.


                                  ,   /       -!


Enel
                                 0~/,p'/ ~"-,
                                i:      ~ ~
                                 . -S'. LEITE
                                Staff Engineer
 10:44:14 10 Aug 1994                         FIRE REPORTING SYSTEM                                            PAGE        1
                                                  INCIDENT REPORT


   JCATION : BATAAN AVENUE/MARITIME STREET
                                              INCIDENT 428136 EXP. 00
                                             DATE 06/20/94 TIME 19: 26...
                                                                  ~ _.._.~--"- .. ~


                                                                LOcftrtDN bF
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rype of situation Found                   49 OTHER HAZARDOUS OR STANDBY
                                                                                                            -------.
Person 1.
 Affiliation          .
 1'1 arne
 Telephone
 Street
            •••••••••••••••••
                                      .
                                      .
 City . . . . . . . . . . . . . • . . .
                                                                                                     --
 State                                .    Zip
:)erson 2.
 Affiliation                          .
 Name                                 .
 Telephone                            .
 ~+----     ...
 JL.. .L,.CC,-    •••••••••••••••

 ci.ty                  .
 S ta te                .  Zip :
Jeneral Property Use ..   63 MILITARY,DEFENSE
)pecific Prorerty Use . : 783 RAIL. EQUIP MFG, ASSEM, REPAIR
10bile Property Involved.
   Property Type        . 98 MOBIL PROP TYPE NOT APPLICABLE
   Vehicle Lie No. .    .
   Vehicle Lie state Yr
   Vehicle Make .•......
   Vehicle Model        .
   Vehicle D.O.T        .
   -Tehicle 10 Number   .
    river's Lic#/State .
 vpe of Action Taken ..
 ire Origin Area        .
 gnition Factor         .
\aterial First Ignited.
   Type                 .
   Form                 .
 stimated Property Loss
 stimated Contents Loss
 vpe Detection System .
 etect. System Perform.
 vpe of Extinguish. . ..
 ivilian Injuries .....   a Civilian Fatali~ies : 0

 eport Completed by                   .   328047 NYLANDER, ROBERT W.
 Eficer in Charge                     .

 ,1C   ident Notes
 ***Notes Added 06/21/94 On Port 068 at 00:53 by NYLANDER, ROBERT W.
 2543 2573 2598 RESPONDED TO REPORTED DIESEL LEAK. ON ARRIVAL FOUND 2750
 -:;ALLON
 POLYURETHENE TANK WITH APPROXIMATELY 1.500 GALLONS LEFT IN IT. DIESEL PRODUCT
 ,vAS LEAKING OUT AT A RATE OF APPROXIMATELY ONE (1.) GALLON A MINUTE. AS MUCH
 ~EMO    FOR RECORD                    o-~1-94


 SUBJECT: 94-0040~ UGST REMOVAL/REPLACEMENT, OAKLAND ARMY BASE
      FUEL LEAK AT TANK .t.§.

       I ARRIVED ON SITE OF TANK #6 AT BUILDING 991 AT 2:05 A.M.
 FINDING THE CONTRACTORS PERSONNEL (2 MEN) DRAINING THE TEMPORARY
 STORAGE TANK BACK INTO TANK #6.   THE TEMPORARY TANK WAS LEAKING
 AT THE FITTING AT THE BOTTOM OF THE TANK~ APPARENTLY AT THE
 THREADS OF THE SCREW IN PIPE.   I WOULD CHARACTERIZE THE LEAK AS A
 STEADY DRIP.   DIRT HAD BEEN PLACED AROUND THE TANK TO PREVENT
 CONTINUED LEAKAGE INTO THE EXCAVATION APPROXIMATELY 20 FEET AWAY.
THE TEMPORARY TANK (PLASTIC) WAS SETTING ON THE ASPHALT WITH NO
CONTAINMENT BURM OF ANY TYPE.    THE CONTRACTOR IS PLANNING TO
PLACE THE CONTAINMENT DIRT ONTO PLASTIC AS SOON AS THE TANK IS
DRAINED AND SECURED AGAINST FURTHER DRIPPING. HE THEN PLANS TO
EXCAVATE AND PLACE THE CONTAMINATED SOIL OF THE EXCAVATION ONTO
THE PLASTIC PRIOR TO REMOVAL FROM SITE.
      I MEASURED THE DRIP TO BE APPROXIMATELY 12 OZ. EVERY 20
MINUTES. ACCORDING ~O THE CONTRACTOR, WHEN THEY LEFT THE SITE
THE AFTERNOON OF THE 20TH, THEY DID NOT NOTICE ANY LEAKAGE AND
THEY LEFT AT APPROXIMATELY 4 P.M.    WHEN THE CONTRACTOR ARRIVED ON
SITE AT APPROXIMATELY 1:15 A.M. OF THE 21ST, THE DIRT HAD ALREADY
BEEN PUT DOWN TO STOP THE TRAVEL INTO THE EXCAVATION. BASED ON
THESE NUMBERS AND THE ASSUMPTION THAT THE LEAKAGE STARTED AT 4
P.M , IT WOULD APPEAR THAT THE LEAKAGE IS LIMITED TO 36 OZ./HOUR
FOR A PERIOD OF 9 HOURS TOTALLING 324 OZ. OR APPROXIMATELY 2.5
GALLONS. THIS WOULD BE CONSISTENT WITH THE APPEARANCE OF THE
STAIN AND SOIL.
      IT SHOULD ALSO BE NOTED THAT THE HYDROCARBON THAT WAS
LEAKING IS IDENTIFIED ON THE PLANS AS DIESEL. BUT THE CONSISTENCY
AND SMELL IS MORE LIKE A CLEANING SOLVENT AND NOT DIESEL.

        AT THIS TIME, THE CONTRACTOR HAS THE PROBLEM UNDER CONTROL.

     THERE ARE SOME QUESTIONS THAT I HAVE REGARDING THE
PROCEDURES AND FINDINGS TO DATE:
     1.   I DID NOT FIND WITHIN THE CONTRACT DOCUMENTS WHY THE
CONTRACTOR WAS SAVING THE PRODUCT.   WAS THIS REQUIREMENT WITHIN
THE ORIGINAL SCOPE OF THE CONTRACT, OR WAS THIS MODIFIED TO AID
THE USER?
     2.   WHY WERE NO PRECAUTIONS TAKEN TO PROVIDE CONTAINMENT OF
THE TEMPORARY TANK?
     3. HAS SAMPLING OF THE PRODUCT BEEN DONE? IF so. WHAT
WERE THE FINDINGS?
     4.   IF THE PRODUCT IS NOT DIESEL. DO THEY STILL NEED THE
ABOVE GROUND DIESEL TANK?
CHRONOLOGY

6-20-94

11:20 P.M. RECEIVED CALL FROM CAMERON, TOLD THAT THERE WAS A
REPORTED LEAK OF A REMOVED TANK FROM THIS CONTRACT, IT WAS
REPORTED THAT THE SPILL WAS APPROX. 500 GAL. BY A MR. MAY THRU
JACK FARLESS.
11:23 P.M. RECEIVED CALL FROM GARY GRONEMEYER REITERATING THE
SAME INFORMATION. GARY ASKED THAT RALPH CALL HIM ONCE RALPH HAD
TALKED TO MR. MAY.

11:40 P.M.   RALPH CALLED BACK HAVING TALKED TO MR. MAY AND GARY.
I WAS TOLD THE CONTRACTOR HAD BEEN CONTACTED AND WAS ON HIS WAY
TO THE SITE.

6-21-94
12:20 A.M.   AFTER MAKING NUMEROUS ATTEMPTS TO CONTACT GEORGE LIU
( HIS LINE-WAS BUSY) I ADVISED RALPH THAT I WOULD GO TO THE JOB
SITE TO REVIEW THE ISSUES.
1:20 A.M.  RECEIVED A CALL FROM RALPH INWHICH HE ADVISED ME THAT
THE CONTRACTOR WAS ON SITE AND THE SPILL WAS LESS THAN 50 GAL.
AND THAT THE PROBLEM APPEARED TO BE A BAD VALVE OR FITTING.
THERE WAS DIRT AROUND THE AREA TO PREVENT FURTHER LEAKAGE INTO
THE EXCAVATION AND THE CONTRACTOR WOULD WORK TO MITIGATE THE
CONDITION.

2:05 A.M.  I ARRIVED ON SITE, WITNESSED THE LEAK, TOOK
MEASUREMENTS AND DISCUSSED THE CIRCUMSTANCES WITH THE CONTRACTORS
MEN.

3:15 A.M.    REVIEWED CONTRACT DRAWINGS AND SPECS




DOUG DELANEY
PROJECT ENGINEER
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                         Attachment 3

               Radiological Issues and Responses




Attachment 3                    o
               OARB RADIOLOGICAL ISSUES & RESPONSES


1. The radiological issues at OARB currently focus on two areas of interest. They
are as follows:

       •   The use of an X-ray machine in the Dispensary or Medical Clinic in Building
           762 (Located in BRAC Parcel 18)

       •   The processing of properly shielded packaged parts and equipment being
           shipped through GARB that have radiological substances, such as radium dial
           paint on them, that is applied to enhance their function (examples include the
           use of radium-226 in the paint solids that was applied to aircraft flight
           instruments to help aviators read instruments more easily in a low-light setting
           and thorium treated lenses to enhance instruments optical qualities, etc.)
           (Located primarily in BRAC Parcel 12, however, DTSC is focused on
           basewide radiological use and practices)

       Note: OARB has never used, or disposed of radio nuclides at the installation.
       Some short-term storage of parts and/or equipment occurs but it is limited to
       periods less than 15 days which is associated with the processing time it takes
       to transport these items through the base and on to their destinations.

A. X-ray Machine: The X-ray machine in the Dispensary or Medical Clinic in Building
762, does not require a permit since it does not contain any radiological source. It is a
General Electric model MST 625-II, X-ray unit manufactured in June 1984
(Attachment 3, Figure 1). It will continue to be certified for proper operation (as it has
been in the past) according to the requirements of the Bureau of Radiological Health.

Contacts regarding past tenants/users and new tenants/users are as follows:

                •   Past tenants/users -- Mr Claudio Cabaccang (408) 242-7583,
                    Equipment Maintenance and Rick Michaels (408) 242-7585, Industrial
                    Hygiene Department, California Medical Detachment, Monterey, CA

                •   New tenants/users - Mark Tourney, (510) 466~3078 and Wilfred
                    Escarda (510) 233-1091, 2 nd Medical Brigade.          (The Veterans
                    Administration will share the facility and equipment '''usage with the
                    Army.)

B. Processing of Properly Shielded Parts and Equipment: DARB has never used or
disposed of radiological substances at the installation. Short-term storage of parts and/or
equipment occurs but it is typically limited to periods less than 15 days which is the time-
limit standard associated with the processing time it takes to transport these items through
the base and on to their destinations


Attachment 3
                                                                  Attachment 3, Figure 1
                                                      Typical X Ray Machine Schematic.




                                   Electron beam

                     Hot filament
                     gives off electrons




                  OC power
                   source                                     Vacuum


  AC
power
source     L..-              --.             High voltage - - - - - - - - - - - - - 1



     X rays are electromagnetic radiations similar to light only of much shorter wavelength.
     X rays are typically formed when cathode rays (electrons) strike a metal target. If a
     higher accelerating voltage is used, the electrons strike the target harder, and X rays of
     higher frequency are produced. With more than a million volts, X rays are produced
     which will penetrate several inches of steel. Such radiation can be used for many
     practical purposes. As just one example, metal castings can be tested for hidden flaws
     by using X rays, however, more typically power in the 80 to 100 't0IA range is used for
     medical diagnostic X rays.
OARB processes properly packaged and shielded parts and/or equipment that are shipped
through the installation for the DoD. The standard time limits for processing and shipping
these parts and equipment through the installation is less than 15 days. Packaging and
shielding of parcels conforms to 49 CFR 173.421, .422 or .424 which are a general class
of "label exempt" packages designated as Department of Transportation (DOT) White I,
DOT Yellow II, or DOT Yellow III. Sample copies of shipping documents are attached,
marked Sample # 1 and #2. Items processed through GARB are not unpacked or
repackaged. They are usually sent by mail or United Parcel Service as "excepted package,
instruments or articles, Class 7, UN 2910, Schedule 2". OARB currently processes
approximately 5 small packages per month in this manner. According to the Radiological
Protection Officer, Grant Ivory, (510) 466-3016, OARB does not require a license for this
processing and shipping activity. All the processing and shipping involving these
radiological packages occurs in building 806, Section 1, (BRAC Parcel 12). Any
packages that are damaged are handled according to DOT Emergency Response
Guidelines (Guideline # 61), which sets forth overpacking procedures and maintains health
and safety standards for workers. To date there have been no such incidents involving
damaged packages of radiological parts and equipment.

2. Shipping and Receiving Activities of Radiological Parts and Equipment at
OARB

The following answers to DHS questions were prepared based upon archival data
searches, reviews of current and past operations procedures, interviews of environmental
and radiological specialists at oARB , and coordination with U.S. Army chain-of-
command representatives. The responses correspond to the current list of questions titled
"California Department of Health Services Information Needed for the Radiological
Evaluation of Military Bases" and the guidance received from DHS (Darice G. Bailey,
Senior Health Physicist) on August 29, 1996.

1. GARB is now, and has been in the past, a Department of Defense transportation center
dedicated to the processing, shipping and receiving of parts, equipment, material, and
personnel for the U S. Army.. OARB has never used, or disposed of radio nuclides at the
installation.. Some short-term storage of parts and/or equipment containing radiological
substances in small quantities occurs, but it is limited to periods less than 15 days which is
the time limit associated with the administrative processing it takes to process these items
through the base and on to their destinations.

Those limited numbers of parcels containing radiological substances that are processed
through 0 ARB to their destinations conform to 49 CFR 173.421, .422, or .424. These
parcels are in the class called "Label Exempt"; Department of Transportation (DOT)
White I, DOT Yellow II, or DOT Yellow IlL Sample copies of shipping documents are
attached and marked as Sample #1, and #2.

Packages processed through GARB are not unpackaged or repackaged. They are usually
sent on by mail or United Parcel Service as "excepted package, instruments or articles,



Attachment 3                                  3
Class 7, UN 2910, Schedule 2". OARB currently processes approximately 5 such small
packages per month. All the parcels held for processing and awaiting shipment are in
Building 806, Section 1, (EBS BRAC Parcel 12). Any packages that are damaged are
handled according to DOT Emergency Response Guidelines (Guideline # 61), which sets
forth overpacking procedures and maintains health and safety standards to workers. To
date there have been no such incidents involving damaged packages of radiological parts
and equipment.

According to the Radiological Protection Officer, (Grant Ivory, telephone number (510)
466-3016), OARB does not require a license for this activity. In addition, there are no
separate activities involving nonlicensed radiological material (e.g. radium-226) used,
stored, or disposed of at OARB outside the processing and shipping of DoD equipment
and parts described previously.

U.. S. Army inspectors in the chain-of-command at the U.S. Army Environmental Hygiene
Agency, Aberdeen Proving Ground, Maryland, have continually conducted site visits to
evaluate the environmental radiation program at OARB. While there have been
deficiencies noted and corrections made to the program, there is no record of any
incidents involving releases to the environment or exposures to workers or the public as a
result of the shipping and receiving activities involving radiological substances.

2. Not Applicable

3.. Not Applicable. There is no record of a radiological surveillance program because
OARB did not have any radiological sources at the installation.

4. Not Applicable

5. There is no record of past radiological surveys other than those required certifications
performed at Building 762 (Dispensary/Medical Clinic) where an X-ray machine (without
a radiological source) was used for diagnostic purposes, and radon surveys were
conducted in the housing area located in the Garrison area of the base. Should the BRAC
Cleanup Team decide to conduct additional radiological surveys, they would be conducted
in future phases of the remedial investigation and characterization process at OARB.

6. There is no information that would indicate that any radiological releases or burial
activities have occurred at OARB. Extensive literature searches (including inquiries
concerning classified government programs to appropriate government employees) and
interviews with the Radiological Protection Officer, a long-time employee at OARB, form
the basis for this finding.

7. Same as # 6. (No. None.)

8. The Radiological Protection Officer (RPO) received 1 week of prescribed training
sanctioned by the U.S. Army Environmental Hygiene Agency, Aberdeen Proving Ground,



Attachment J                                4
Maryland, to undertake this collateral duty to his primary position as Chief of Container
Freight Branch, Cargo Operations Division, 1302nd Major Port Command. No other
chain of command governs the RPO position. Dosimeters were not required but were at
some times used by freight handlers.

9. The RPO has been interviewed on several occasions, and he has provided information
during the course of data gathering and interviewing activities for the OARB BW-EBS.
He has been assigned in this position since 1986.

10. There are no sources of radioactive material currently at OARB, nor are there any
records or interview information that indicates past radiological source usage, release, or
burial activities. There is currently no remediation of radio nuclides proposed or ongoing
at OARB.         The X-ray machine used for medical diagnosis in Building 762 (the
Dispensary/Medical Clinic) is the only equipment using radiological energy permanently
located at OARB.

11. There are no licensed or unlicensed radioactive sources at OARB now or from past
activities. There is no information that would indicate any activities either present or past,
that would have generated mixed waste (radioactive and hazardous wastes) at OARB.

12. OARB is now, and has been in the past, a Department of Defense transportation
center dedicated to the processing, shipping and receiving of parts, equipment, material,
and personnel for the U.S. Army. OARB has never used, or disposed of radio nuclides at
the installation. Some short-term storage of parts and/or equipment containing
radiological substances in small quantities occurs, but it is limited to periods less than 15
days which is the time associated with the administrative processing it takes to transport
these items through the base and on to their destinations. Those limited numbers of
parcels containing radiological substances that are processed through OARB to their
destinations conform to 49 CFR 173.421, .422, or .424. These parcels are in the class
called "Label Exempt"; Department of Transportation (DOT) White I, DOT Yellow II, or
DOT Yellow III. Sample copies of shipping documents are attached and marked as
Sample #1, and #2.

Packages processed through OARB are not unpackaged or repackaged. They are usually
sent on by mail or United Parcel Service as "excepted package, instruments or articles,
Class 7, UN 2910, Schedule 2". OARB currently processes approximately 5 such small
packages per month. All the parcels held for processing and awaiting shipment are in
Building 806, Section 1, (EBS BRAC Parcel 12). Any packages that are damaged are
handled according to DOT Emergency Response Guidelines (Guideline # 61), which sets
forth overpacking procedures and maintains health and safety standards for workers.. To
date there have been no such incidents involving damaged packages of radiological parts
and equipment.

According to the Radiological Protection Officer, (Grant Ivory, telephone number (510)
466-3016), OARB does not require a license for this activity. In addition, there are no


Attachment 3                                  5
separate activities involving nonlicensed radiological material (e.g. radium-226) used,
stored, or disposed of at DARB outside the processing and shipping of DoD equipment
and parts described previously.

U.S. Army inspectors in the chain-of-command at the U.S. Army Environmental Hygiene
Agency, Aberdeen Proving Ground, Maryland, have continually conducted site visits to
evaluate the environmental radiation program at oARB. While there have been
deficiencies noted and corrections made to the program, there is no record of any
incidents involving releases to the environment or exposures to workers or the public as a
result of the shipping and receiving activities involving radiological substances.

13. Contacts and discussions with appropriate U.S. Army chain-of-command personnel at
the U.S. Army Center for Health Promotion and Preventative Medicine (CHPPM), which
was formerly known as the U.S. Army Environmental Hygiene Agency, have been made
to determine if additional information regarding current and past radiological activities
(including government classified information) may be in existence. DARB plans to
contract with CHPPM to perform a radiological historical investigation. In addition, a
copy of these responses is being sent to CHPPM for coordination.




Attachment 3                                6
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                                                       Radioactive Material Shipment
         SHIP TO:                                                                FROM:
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                                                                 Transportation Information
                                       This package conforms to the conditions and limitations specified in:
                  49 CFR 173.421 for excepted radioactive material, limited quantity, not otherwise specified, UN 2910.
                  49 CFR 173.422 for radioactive material, instruments and articles, UN 2910.
                 l,MrCFR 173.424 for radioactive material, articles manufactured from natural-or depleted uranium, or
           V      natural thorium, UN 2910.
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        llil'abel Exempt                    D        DOT White I
                                                                                   D         DOT Yellow II
                                                                                                                       D     DOT Yellow III

         Primary Mode of Shipment:
        D       Truck                       D        Rail                          ~ir                               D      Water IMCa Class 7
         Special Precautions:
         Do not put this package in the same compartment or vehicle with bagged grains, fruits, or other unsealed foods.
         Do not put this package next to packaqes containing film.

         In the event of an emergency or accident, contact the nearest military installation or call the DDSP Radiation
         Protection Officer at (717) 770-8013 during normal duty hours.. After normal duty hours contact the DDRE
         Security Office at (717) 770-6270.

        Packed BY:~
                                           ))L,                                                                              Date:


                                                                                                                                 7 h11Y9(,
         Inspected By:                                                                                                       Date:

                                                                                                                                  MAY 0 8 1996
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         DDHE Form 4155.64 May 94
                FINAL
BASEWIDE ENVIRONMENTAL BASELINE SURVEY
          OAKLAND ARMY BASE
                100 Alaska Street, Bldg. 1
                Oakland, CA 94625-5000




                       Prepared for:


           u.s. Army Corps of Engineers
                  Sacramento District
                Sacramento, California 95814
              Contract No. DACW05-94-D-0019




                        Prepared by:

     FOSTER WHEELER ENVIRONMENTAL CORPORATION
             2525 Natomas Park Drive, Suite 250
                Sacramento, California 95833




                     September 1996
                               CONTENTS
                                                                      Page
CONTENTS                                                                   ii
FIGURES                                                                   iv
TABLES                                                                    iv
ACRONYMS AND ABBREVIATIONS                                                 v
EXECUTIVE SUMMARy                                                        viii
1.0 INTRODUCTION                                                           1
   1.1 AUTHORITY FOR THE EBS                                               1
   1.2 OBJECTIVE                                                           1
      1.2.1 DoD Property Classification                                    1
   1.3 ORGANIZATION OF BASEWIDE EBS                                        2
   1,4 LIMITATIONS                                                         3
2.0 SURVEY .METHODOLOGY                                                    4
   2.1 EXISTING INVESTIGATION DOCU.MENTS                                   4
   2.2 FEDERAL, STATE AND LOCAL GOVERNMENT REGULATORY RECORDS              4
   2.3 INTERVIEWS                                                          5
   2.4 VISUAL SITE INSPECTION                                              6
      2.4.1 Visual Site Inspection Approach                                6
      2.4.2 Purpose of the Visual Site Inspection                          6
     2.4.3 Visual Site Inspection Summary Overview                         7
     2.4.4 Layout ofVSI Documents in the EBS Appendices Section            7
     2.4.5 VSIs of oARB Adjacent Properties                                7
   2.5 TITLE DOCU.MENTS                                                    7
3.0 PROPERTY CHARACTERIZATION                                              9
   3.1 GENERAL PROPERTY INFORMATION                                        9
   3.2 DESCRIPTION OF FACILITIES                                          13
   3.3 PROPERTY HISTORY                                                   13
   3.4 TENANT ACTIVITIES                                                  22
   3.5 PERMITTING STATUS                                                  24
      3.5.1 RCRA Status                                                   24
      3.5.2 CERCLA Status                                                 24
      3.5.3 NPDES/State Permits                                           25
      3.5.4 Solid Waste Permits                                           25
      3.5.5 Air Permits                                                   25
      3.5.6 Water Supply Permits                                          26
      3.5.7 UST Permits                                                   26
   3.6 SURROUNDING ENVIRON.MENT AND LAND USES                             27
      3.6. 1 Demographics                                                 27
      3.6.2 Climatology                                                   27
      3.6.3 Hydrology                                                     27
      3.6.4 Geology and Hydrogeology                                      28
      3.6.5 Sensitive Environments                                        28

Oakland Army Base    Basewide Environmental Baseline Survey            Final
e                                      11                     September 24,1996
      3.6.6 Additional Studies                                                 29
      3.6.7 Aerial Photograph Analysis                                         29
4.0 INVESTIGATION RESULTS                                                      32
   4.1 CATEGORIZATION FACTOR FINDINGS: NEW AREAS IDENTIFIED BY EBS
   INVESTIGATION                                                               32
   4.2 CATEGORIZATION FACTOR FINDINGS: PREVIOUSLY IDENTIFIED SITES             32
     4.2.1 Storage and Use                                                     32
         4.2.1.1 Storage Tanks                                                 32
         4.2.1.2 OillWater Separators                                          33
     4.2.2 Release                                                             40
         4.2.2.1 Hazardous Substances/SpillslWaste Management Practices        40
         4.2.2.2 Radionuc1ides and Licensing                                   43
         4.2.2.3 Surface Water and Storm Water Issues                          43
         4.2.2.4 Sanitary Sewer System                                         45
     4.2.3 Disposal                                                            45
         4.2.3.1 Solid Waste Management.                                       45
         4.2.3.2 Mixed Waste                                                   45
         4.2.3.3 MedicallBiological Waste                                      47
         4.2.3.4 RCRA Facilities/SWMUs                                         47
   4.3 DISCLOSURE FACTOR FINDINGS                                              47
     4.3.1 Asbestos                                                            47
     4.3.2 Lead-Based Paint                                                    53
     4.3.3 PCBs                                                                54
     4.3.4 Radon                                                               54
     4.3.5 Ordnance                                                            54
   4.4 REMEDIATION EFFORTS                                                     56
     4.4.1 General Remediation EffortslIssues                                  59
     4.4.2 Other Site-specific Remediation Efforts                             61
   4.5 ADJACENT OR SURROUNDING PROPERTy                                        62
     4.5.1 Visual Site Inspection Findings                                     62
     4.5.2 Record Search Findings                                              63
5.0 CERFA LETTER REPORT                                                        65
   5.1 EXECUTIVES~Y                                                            65
   5.2 S~YOFFINDINGS                                                           65
      5.2.1 CERFA Uncontaminated Parcels                                       92
      5.2.2 Non-CERFA Parcels                                                  93
      5.2.3 Disclosure Factors                                                 93
   5.3 DATA GAPS                                                               93
APPENDIX A:     REFERENCES                                                   A-1
APPENDIXB:      INTERVIEW S~Y                                                B-1
APPENDIX C:     VISUAL SITE INSPECTION S~Y                                   C-1
APPENDIX D:     STORAGE INVENTORY SHEETS                                     D-1
APPENDIX E:     RESULTS OF ERIIS DATABASE SEARCH                             E-1



Oakland Army Base        Basewide Environmental Baseline Survey             Final
e                                          111                     September 24,1996
APPENDIX F: HAZARDOUS SUBST ANCES/SPILLS/wASTE MANAGEMENT FINDINGS
            BY BRAC PARCEL                                      F-l
APPENDIX G: UNDERGROUND STORAGE TANK FINDINGS BY BRAC PARCEL    G-l
APPENDIX H: PCB FINDINGS BY BRAC PARCEL                         H-l
APPENDIX 1: SUMMARY OF BRAC PARCELS BY DOD CATEGORy             I-I
APPENDIX J: LARGE SCALE MAP OF OARB WITH KEY ELEMENTS           J-l


                                     FIGURES

FIGURE S-I.    CERFA MAP                                                        xi
FIGURE 3-1.    LOCATION MAP                                                    10
FIGURE 3-2.    TRACT ACQUISITION MAP                                           11
FIGURE 4-1.    LOCATION OF OIL/WATER SEPARATORS                                39
FIGURE 4-2.    STORM DRAINAGE SYSTEM AND DISCHARGE AREAS                       44
FIGURE 4-3 .   SANITARY SEWER SySTEM                                           46
FIGURE 4-4.    KNOWN CONTAMINATION SITES                                       57
FIGURE 4-5.    SITES WITHIN ONE MILE OF OARB                                   64
FIGURE 5-1.    CERFAMAP                                                        67


                                      TABLES

TABLE S-I. DOD ENVIRONMENTAL CONDITION CATEGORIES                    x
TABLE 3-1. SIZE OF FUNCTIONAL AREAS AT THE OAKLAND ARMY BASE         9
TABLE 3-2. OARB ACQUISITION TRACT REGISTER                          12
TABLE 3-3. LIST OF CURRENT STRUCTURES AT OARB                       14
TABLE 3-4. UST PERMITS                                              26
TABLE 3-5. DESCRIPTION OF POTENTIAL CONTAMINATION AREAS IDENTIFIED
   BY PHOTOGRAPHIC IMAGERY                                          30
TABLE 4-1. ABOVE GROUND STORAGE TANKS                               33
TABLE 4-2. UNDERGROUND STORAGE TANK INVENTORY                       34
TABLE 4-3 OIL/WATER SEPARATORS                                      40
TABLE 4-4. OARB SPILL HISTORY                                       41
TABLE 4-5. SUMMARY OF ASBESTOS SURVEY INFORMATION                   49
TABLE 4-6. PCB/TRANSFORMERS                                         55
TABLE 4-7. KEY OARB RESPONSE ACTIONS AND SUPPORTING DOCUMENTS       58
TABLE 5-1. DOD ENVIRONMENTAL CONDITION CATEGORIES                   66
TABLE 5-2. CERFAMAP SUMMARy                                         68
TABLE 5-3. ACREAGE SUMMARy                                          94
TABLE B-1. KEY PERSONNEL INTERVIEWED                               B-2
TABLE C-1. VISUAL SITE INSPECTION SUMMARY TABLE                    C-2
TABLE E-1. SUMMARY OF DATABASE SEARCH FINDINGS                     E-2
TABLE G-1. UNDERGROUND STORAGE TANK INVENTORY                      G-2


Oakland Army Base        Basewide Environmental Baseline Survey            Final
4)                                         IV                     September 24, 1996
                      ACRONYMS AND ABBREVIATIONS
AAFES          Army Air Forces Exchange Service
ACM            asbestos containing materials
ADP            automated data processing
ABC            Atomic Energy Commission
AF             Air Force
ASTM           American Society for Testing Materials
BAAQMD         Bay Area Air Quality Management District
BCP            BRAC Cleanup Plan
BEQ            Base Enlisted Quarters
BMPs           best management practices
BRAC           Base Realignment and Closure
CallEPA        California Environmental Protection Agency
Caltrans       California Department of Transportation
CERCLA         Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS        Comprehensive Environmental Response, Compensation, and Liability Act List
CERFA          Community Environmental Response Facilitation Act
CG             Commanding General
crn            Criminal Investigation Division
CHPPM          U.S. Army Center for Health Promotion and Preventative Medicine
CONUS          Continental United States
DoD            U.S. Department ofDefense
DOT            U.S. Department of Transportation
DRMO           Defense Reutilization and Marketing Office
DTSC           Department of Toxic Substance Control
EBMUD          East Bay Municipal Utility District
EBS            Environmental Baseline Survey
EM             Enlisted Members
ERNS           Emergency Response System Notification
ERIIS          Environmental Risk Information and Imaging Services
GO             Government Order
GW             groundwater
HQ             Headquarters
HWS            hazardous waste sites
JANOT          Joint Army-Navy Ocean Terminal
LBP            lead-based paint
LPG            liquefied petroleum gas
LRST           California Leaking Underground Storage Tank Report
LUFT           leaking underground fuel tank
ug/kg          microgram per kilogram
MOTBA          Military Ocean Terminal Bay Area
MTMGWA         Military Traffic Management Command, Western Area
MTMTS          Military Traffic Management and Terminal Service



Oakland Army Base           Basewide Environmental Baseline Survey                         Final
til                                          v                                    September 24,1996
                      ACRONYMS AND ABBREVIATIONS
                              (Continued)

NCO            non-commissioned officer
NEPA           National Environmental Policy Act
NFRAP          no further remedial action planned
NOV            Notice of Violation
NPDES          National Pollutant Discharge Elimination System
NPWC           Navy Public Works Center
NPL            National Priorities List
NRC            Nuclear Regulatory Commission
oARB           Oakland Army Base
OGW            oil and gas well
OWS            oil/water separators
PAiSI          Preliminary Assessment/Site Investigation
PCB            polychlorinated biphenyls
PCi/1          picocuries per liter
POV            privately-owned vehicle
PPE            personal protective equipment
ppm            parts per million
PRGs           Preliminary Remedial Goals
PWC            Navy Public Works Center
QA/QC          Quality Assurance/Quality Control
REA            Registered Environmental Assessor
RCRA           Resource Conservation and Recovery Act
RCRIS          Resource Conservation and Recovery Information    System
RCRIS-LG       Resource Conservation and Recovery Information    System-
                Large Quantity Generators
RCRIS-SG       Resource Conservation and Recovery Information    System-
                Small Quantity Generators
RCRIS-TS       Resource Conservation and Recovery Information    System-
                Treatment, Storage, and Disposal Facilities
RIIFS          Remedial InvestigationIFeasibility Study
ROD            Record of Decision
RPO            Radiological Protection Officer
RST            California Underground Storage Tank Report
RWQCB          Regional Water Quality Control Board
SVE            soil vapor extraction
SWF            California Solid Waste Information System
SWMU           solid waste management unit
SWPPP          Storm Water Pollution Prevention Plan




Oakland Army Base           Basewide Environmental Baseline Survey                  Final
6'                                            VI                           September 24,1996
                      ACRONYMS AND ABBREVIATIONS
                              (Continued)

TCE            trichloroethylene (trichloroethene)
TOG            total oil and grease
TPH            total petroleum hydrocarbons
TPH-D          total petroleum hydrocarbons as diesel
TPH-G          total petroleum hydrocarbons as gasoline
TRPH           total recoverable petroleum hydrocarbons
USACE          U.S. Army Corps of Engineers
USAEC          U. S. Army Environmental Center
USAEHA         U.S. Army Environmental Hygiene Agency
USAMC          U. S. Army Materiel Command
USATHAMA       U.S. Army Toxic and Hazardous Materials Agency
USEPA          United States Environmental Protection Agency
USGS           United States Geological Survey
UST            underground storage tank
UXO            unexploded ordnance
VOCs           volatile organic compounds
VAT            vinyl asbestos tiles
VSI            visual site inspection
WAMTMTS        Western Area Military Traffic Management and Terminal Service
WDR            Western Distribution Region




Oakland Army Base           Basewide Environmental Baseline Survey                      Final
e                                            Vll                               September 24, )996
                                EXECUTIVE SUMMARY

This Environmental Baseline Survey (EBS) has been prepared to document the physical condition
of real property at the Oakland Army Base (OARB), California resulting from the use, storage,
and disposal of hazardous substances and petroleum products (and petroleum derivatives) over
the installation's history, and establish a baseline for use by the Department of the Army in making
decisions concerning real property transactions. The preparation of an EB S is required by
Department of Defense (DoD) policy before any property can be leased, transferred, sold, or
acquired. The EBS is primarily an environmental management benchmark document that will also
be used by the Army in meeting its obligations under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), 42 United States Code Section 9620 (h),
[also referred to as CERCLA Section 120(h)] as amended by the Community Environmental
Response Facilitation Act (CERFA) (Public Law 102-426).

METHODOLOGY

This EB S was developed based on information obtained through a series of records searches,
interviews, and visual inspections conducted during January through March 1996. The records
searches included a review of all available Army and related agency records, including Navy
Public Works records, Army environmental management and compliance documents, audits, an
analysis of aerial photographs; and a review of recorded chain-of-title documents for the property.
Visual inspections of the base property and facilities were conducted under the direction of a
California Registered Environmental Assessor. Interviews of current and former key employees
were also conducted. The EBS also includes an assessment of the environmental condition of off-
base property adjoining the base or property that is near the base boundary that could pose
environmental concern or affect the condition of the base property from hazardous substances
migrating onto the installation. Physical visual inspections were conducted on off-base properties
where access was obtained from the operators or owners.

PROPERTY CLASSIFICATION METHODS

Immediately upon receiving a notice to proceed, data gathering activities, archival research, data
analysis, document management reviews, aerial photography analysis, interviews of current and
former employees, and visual site inspections were conducted at OARB. During the same time
period when data gathering, visual site inspections (VSIs), and interviews were being conducted,
the concurrent development of Base Realignment and Closure (BRAe) Parcel boundaries was
being mapped and partitioned to present the real property within various geographic study areas.
OARB was divided into 26 separate preliminary BRAC Parcels, which were each subsequently
classified into one of the seven DoD categories.

OFF-BASE PROPERTY OBSERVATIONS

The property adjacent to OARB is being operated and used very similar to the way OARB is
being operated and used. Ocean-going transportation of goods both inbound and outbound of the

Oakland Army Base             Basewide Environmental Baseline Survey                              Final
e                                               V111                                     September 24, 1996
port are the dominant commercial operation of the areas surrounding the installation. There is a
considerable amount of construction on the north and east sides of the base due to construction of
the freeway system that forms the approach to the San Francisco-Oakland Bay Bridge. The
construction project of bridge bents, overhead decking and signage is related to reconstruction
and seismic upgrades of the freeway system following the 1989 Lorna Prieta earthquake.

The process of dredging and dewatering from the port areas adjacent to OARB allows any
contaminants that would be found in these sands, soils, and fines to potentially migrate onto the
installation.

There are railroad lines that run along the northern and eastern perimeter of the installation. The
potential for upset conditions, spills, and subsequent migration of contaminants onto the
installation from these bulk transportation sources is possible.

PROPERTY CATEGORIZATION

Oakland Army Base property was analyzed and divided into 26 BRAC Parcels. Each of the 26
BRAC Parcels was categorized into one of the seven DoD categories, based on the results of the
data available at the time this report was prepared. The category definitions have been modified
slightly from the DoD categories described in the 1993 BRAC Cleanup Plan Guidebook (DoD,
1993). The definitions of categories 1 and 2 have been revised to align with the requirements of
CERFA (CERCLA Section 120 (h)(4). The BRAC Parcel categories described in this report are
based on presently available data and may undergo revision in the future if additional data are
obtained. Property categorization factors are hazardous substances or conditions that, if present,
may pose a threat to human health or the environment. These substances or conditions include,
but are not limited to, hazardous substances as defined in CERCLA Section 101(14) and
petroleum substances.

The 26 BRAC Parcels are classified in Table S-l below and presented with color-coded markings
to show the results of the EBS property categorization in Figure S-1.

In addition to property categorization factors, this document also examines facility disclosure
factors. Facility disclosure factors are hazardous substances or petroleum substances that do not
pose a threat to the well being of the human community and environment if properly managed and
maintained. These items include: asbestos, lead-based paints, polychlorinated biphenyls (PCBs),
and radon.




Oakland Army Base             Basewide Environmental Baseline Survey                              Final
e                                               IX                                       September 24, 1996
            TABLE S-1. DOD ENVIRONMENTAL CONDITION CATEGORIES

     Category                                 Definition                                   BRAC Parcel

        1         Areas where no storage for one year or longer, release, or                    18,23
                  disposal of hazardous substances or petroleum products has
                  occurred (including no migration of hazardous substances
                  from adjacent property). Additionally, includes areas where
                  no evidence exists for the release, storage, disposal or
                  migration ofhazardous substances or petroleum products.
        2         Areas where storage of hazardous substances or petroleum
                  products for a year or more has occurred (but no release,
                                                                                                     17
                  disposal, or migration from adjacent areas has occurred).
        3         Areas where storage, release, disposal, and/or migration of
                  hazardous substances or petroleum products has occurred,
                  but at concentrations that do not require a removal or
                  remedial action.
        4         Areas where storage, release, disposal, and/or migration of                    7,26
                  hazardous substances or petroleum products has occurred,
                  and all remedial actions necessary to protect human health
                  and the environment have been taken.
 BRAe Parcels in the following DoD categories are not currently suitable for transfer:

        5         Areas where storage, release, disposal, and/or migration of
                  hazardous substances or petroleum products has occurred,
                  removal and/or remedial actions are under way, but all
                  required remedial actions have not yet been taken.
        6         Areas where storage, release, disposal, and/or migration of                  8, 12, 15
                  hazardous substances or petroleum products has occurred,
                  but required response actions have not yet been implemented.
        7         Areas that are unevaluated or require additional evaluation.            1*,2*,3*,4*, 5*,
                                                                                          6*,9*,10*,11*,
                                                                                         13*, 14*, 16*, 19*,
                                                                                         20*, 21*, 22*, 24*,
                                                                                                25*
*Note: These BRAe Parcels may be reclassified into categories 3 through 6 upon further evaluation.




Oakland Army Base                 Basewide Environmental Baseline Survey                                       Final
6)                                                     x                                              September 24. 1996
                                                                                                                                                                                    Figure 8-1
                                                                                                                                                                                  CERFAMap



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