Final Dust Control and Air Monitoring Plan IR Site 2 – Alameda Point California (TPD1304155)

TABLES

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Page 1 of 1

TABLE 4-1

DERIVED AIRBORNE CONCENTRATIONS FOR RADIONUCLIDES OF INTEREST

Abbreviations and Acronyms:

mCi/mL – microcuries per milliliter CFR – Code of Federal Regulations

DAC – derived air concentration (10 CFR 20 Appendix B)

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FIGURES

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Figure 2-1. Wind Rose Diagram for Alameda Point

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APPENDIX A

MATERIAL SAFETY DATA SHEET

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Soiltac Material Safety Data Sheet

ATTACHMENT 10 WASTE MANAGEMENT PLAN

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

CONTRACT NO. N62473-10-D-0809 CTO NO. 0009

ATTACHMENT 10

FINAL

WASTE MANAGEMENT PLAN

April 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA DCN: RMAC-0809-0009-0004

Prepared by:

1230 Columbia Street, Suite 750 San Diego, California 92101-8530

Prepared by:                                                                                    Jennifer Dessort

Environmental Compliance Manager

Reviewed by:                                                                                                                                                              Hedy Abedi, PhD, PE

Project Manager

PAGE ABBREVIATIONS AND ACRONYMS………………………………………………………………………….. iii

1.0        WASTE MANAGEMENT PLAN…………………………………………………………………………. 1-1

1.1           PROJECT WASTE DESCRIPTIONS…………………………………………………………… 1-1

1.2           WASTE MANAGEMENT………………………………………………………………………….. 1-2

1.2.1           Waste Classification………………………………………………………………………… 1-2

1.2.2           Waste Accumulation and Storage……………………………………………………… 1-4

1.2.3           Soil and Waste Stockpiles and Staging Piles……………………………………….. 1-4

1.2.4           Wastewater and Waste Fluids…………………………………………………………… 1-6

1.2.5           Used Personal Protective Equipment…………………………………………………. 1-7

1.2.6           Container Labeling………………………………………………………………………….. 1-7

1.2.7           Waste Accumulation Areas………………………………………………………………. 1-8

1.2.8           Waste Disposal……………………………………………………………………………….. 1-8

1.2.9           Waste Transportation……………………………………………………………………….. 1-9

1.2.10       Waste Minimization…………………………………………………………………………. 1-9

1.2.11       Waste Management Inspection and Documentation Program……………… 1-10

1.2.12       Inspections……………………………………………………………………………………. 1-10

1.2.13       Documentation……………………………………………………………………………… 1-11

1.2.14       Hazardous Waste Manifests and LDR Certification…………………………… 1-11

1.3           WASTE MANAGEMENT FOR RADIOACTIVE WASTES………………………… 1-12

1.3.1           Waste Classification………………………………………………………………………. 1-12

1.3.2           Waste Accumulation and Storage……………………………………………………. 1-13

1.3.3           Radiological Point Sources…………………………………………………………….. 1-13

1.3.4           Soil, Debris, and Materials……………………………………………………………… 1-13

1.3.5           Wastewater and Waste Fluids…………………………………………………………. 1-14

1.3.6           Labeling and Posting of Containers Containing Radioactive Waste…….. 1-14

1.3.7           Waste Accumulation Areas…………………………………………………………….. 1-14

1.3.8           Waste Disposal……………………………………………………………………………… 1-15

1.3.9           Waste Transportation……………………………………………………………………… 1-15

1.3.10       Waste Minimization……………………………………………………………………….. 1-15

1.3.11       Inspections……………………………………………………………………………………. 1-16

1.3.12       Documentation……………………………………………………………………………… 1-16

1.3.13       Radioactive Waste Manifests………………………………………………………….. 1-17

1.4           HAZARDOUS MATERIAL SECURITY PLAN…………………………………………. 1-17

1.5           UPDATING THE WASTE MANAGEMENT PLAN……………………………………. 1-17

2.0    REFERENCES……………………………………………………………………………………………………. 2-1

Attachment 10 Waste Mgmt Plan.docx                                                                                            i                                                 Final Waste Management Plan IR Site 2, Alameda Point, Alameda, California

DCN: RMAC-0809-0009-0004

CTO No. 0009

(Continued)

TABLES

Table 1-1         Summary of Waste Management, Transportation, and Disposal Requirements

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The purpose of the Waste Management Plan (WMP) is to present the waste management practices and procedures to be followed for the types and quantities of waste expected to be generated during the field activities at Installation Restoration Program (IR) Site 2. The WMP identifies waste management activities conducted during the storage and the preparation and/or disposal of waste (including waste characterization, packaging, storage, and management while in storage). The transportation and disposition of waste materials at appropriate disposal and recycling facilities are also included. It is the responsibility of the Project Manager (PjM) to verify that all project personnel are aware of the requirements stipulated in this WMP.

The WMP provides information on how wastes, including potentially hazardous wastes associated with project activities, will be managed and disposed. In addition, a secondary goal of this section is to ensure that waste minimization practices are followed, to the extent practical, to reduce the volume of waste that will be generated, stored, and removed from the site for disposal.

The WMP is also a primary component of the Tetra Tech EC, Inc. (TtEC), Compliance Program, which includes on-site environmental compliance inspections. The WMP will be revised if the scope of this project or the applicable regulations change.

1.1         PROJECT WASTE DESCRIPTIONS

Construction activities will involve the generation, management, and disposal of various waste streams, which may include:

• Green waste including grass, shrubs, and trees removed prior to grading activities
• Low-level radioactive waste (LLRW) including soil and point sources
• RCRA hazardous, non-RCRA hazardous, and nonhazardous soil
• Nonhazardous solid waste, such as trash, empty calibration gas canisters, and inert construction debris
• Oversized contaminated debris – rock, wood, piping, concrete, and scrap metal
• Wastewater, including impacted stormwater runoff, fluids from equipment and personnel decontamination, and groundwater monitoring well development purge water
• Used oil (including motor oil, hydraulic fluid, greases, antifreeze/coolant, and so forth), oil filters, fuel and air filters from equipment maintenance operations
• Decontamination pad solids/sludges
• Used polyethylene liners from soil stockpiles and/or waste storage areas
• Used personal protective equipment (PPE)

During these activities, the site will be managed under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Area-of-Contamination policy, which allows impacted soil and/or waste to be uncovered, moved, and reconsolidated without triggering the Resource Conservation and Recovery Act (RCRA) land disposal restrictions (LDRs) and minimum technical requirements for a landfill under RCRA.

Table 1-1 presents a summary of applicable waste characterization, containment, storage, transportation, and disposal requirements for each of the aforementioned waste streams.

1.2         WASTE MANAGEMENT

In accordance with the applicable or relevant and appropriate requirements (ARARs) for remedial activities, the substantive requirements of the state and federal hazardous waste generation, characterization, storage, treatment, and management regulations of Title 22 California Code of Regulations (CCR), Sections 66261, 66262, and 66264, and 40 Code of Federal Regulations (CFR), Parts 261, 262 and 264, are applicable to the management of hazardous  wastes  generated  during  the  remedial  action  and  associated  project  activities.   A summary of the key aspects of the waste management program is provided below.

1.2.1        Waste Classification

Federal RCRA hazardous waste determination is necessary to determine whether a waste is subject to RCRA requirements at Title 22 CCR, Division 4.5 and other state requirements at  Title 23 CCR, Division 3, Chapter 15. The first step in the RCRA hazardous waste characterization process is to evaluate contaminated media at the site(s) and determine whether it constitutes a “listed” RCRA waste. The preamble to the National Oil and Hazardous Substances Pollution Contingency Plan states that “…it is often necessary to know the origin of the waste to determine whether it is a listed waste and that, if such documentation is lacking, the lead agency may assume it is not a listed waste” (55 Federal Regulation 8666, 8758 [1990]).

This approach is confirmed in the U.S. Environmental Protection Agency (EPA) guidance for CERCLA compliance with other laws (EPA 1988), as follows: “To determine whether a waste is a listed waste under RCRA, it is often necessary to know the source. However, at many Superfund sites, no information exists on the source of wastes. The lead agency should use available site information, manifests, storage records, and vouchers in an effort to ascertain the nature of these contaminants. When this documentation is not available, the lead agency may assume that the wastes are not listed RCRA hazardous wastes, unless further analysis or information becomes available that allows the lead agency to determine that the wastes are listed RCRA hazardous wastes.”

RCRA hazardous wastes that have been assigned EPA hazardous waste numbers (or codes) are listed in Title 22 CCR, Sections 66261.30 through 66261.33. The lists include hazardous waste codes beginning with the letters “F,” “K,” “P,” and “U.” Knowledge of the exact source of a waste is required for source-specific listed wastes (“K” waste codes). Some knowledge of the nature or source of the waste is required even for listed wastes from non-specific sources, such as spent solvents (“F” waste codes) or commercial chemical products (“P” and “U” waste codes). These listed RCRA hazardous wastes are restricted to commercially pure chemicals used in particular processes such as degreasing. P and U wastes cover only unused and unmixed commercial chemical products, particularly spilled or off-specification products (EPA 1992).  Not every waste containing a P or U chemical is a hazardous waste. To determine whether a CERCLA investigation-derived waste contains a P or U waste, there must be direct evidence of product use. In particular, all the following criteria must be met. The chemicals must be:

• Discarded (as described in 40 CFR, Section 261.2[a][2])
• Either off-specification commercial products or a commercially sold grade
• Not used (soil contaminated with spilled unused wastes is a P or U waste)
• The sole active ingredient in a formulation

Hazardous waste characteristics, as defined in 40 CFR, Sections 261.21 through 261.24, are commonly referred to as ignitable, corrosive, reactive, and toxic. California environmental health standards for the management of hazardous waste set forth in 22 CCR, Division 4.5, were approved by EPA as a component of the federally authorized California RCRA program. Therefore, the characterization of RCRA waste is based on the state requirements.

The characteristics of ignitability, corrosivity, reactivity, and toxicity are defined in 22 CCR, Sections 66261.21 through 66261.24. According to 22 CCR, Section 66261.24(a)(1)(A), waste that exhibits the characteristic of toxicity is assigned a hazardous waste code beginning with the letter “D” to wastes that exhibit the characteristic of toxicity; D waste codes are limited to “characteristic” hazardous wastes.

According to 22 CCR, Section 66261.10, waste characteristics can be measured by an available standardized test method or be reasonably classified by generators of waste based on their knowledge of the waste, provided that the waste has already been reliably tested or if there is documentation of chemicals used.

A waste determined not to be a RCRA hazardous waste may still be considered a state-regulated non-RCRA hazardous waste. The state is broader in scope in its RCRA program in determining hazardous waste. Title 22 CCR, Section 66261.24(a)(2), lists the Total Threshold Limit Concentrations (TTLCs) and the Soluble Threshold Limit Concentrations (STLCs) for non- RCRA hazardous waste. The state applies its own leaching procedure, Waste Extraction Test

(WET), which uses a different acid reagent and has a different dilution factor (tenfold). There  are other state requirements that may be broader in scope than federal ARARs for identifying non-RCRA  wastes  regulated  by  the  state.  See  additional   subsections   of   22   CCR, Section 66261.24. A waste is considered hazardous if its total concentrations exceed the TTLCs or if the extract concentrations from the WET exceed the STLCs. A WET is required when the total concentrations exceed the STLC by a factor of ten, but are less than the TTLCs. California also has additional hazardous waste classification criteria (including 96-hour fish bioassays) that may need to be considered on a case-by-case basis. Wastes determined to be hazardous wastes under California regulations and not under federal regulations are referred to as non-RCRA wastes.

The waste classification requirements also apply to contents from decontamination water generated from daily decontamination activities, collected stormwater, groundwater monitoring well purge water, construction debris, and waste oils and fluids generated from the on-site project equipment. Wastewater resulting from stormwater runoff and decontamination water will be collected and contained within a portable aboveground tank. When the tank or container is approximately half-full or at least every 60 days, whichever occurs first, the tank will be sampled to determine proper disposition of the wastewater. PPE and soil stockpile liners will be characterized based on generator knowledge and will be disposed of at an off-site landfill. Debris will also be characterized based on generator knowledge to determine if it is a potential hazardous waste. Waste oil and other fluids generated during equipment maintenance activities will be collected, contained, and sent off-site for recycling.

1.2.2        Waste Accumulation and Storage

Title 40 CFR, Part 262, 40, and 22 CCR, Section 66262, consist of regulations applicable to the generation, storage, management, and accumulation of RCRA and non-RCRA hazardous wastes, respectively. Specific requirements apply to the accumulation time for hazardous wastes on site and to the accumulation and labeling of hazardous wastes. This project may result in the temporary accumulation of hazardous wastes in staging piles, containers, and tanks. These wastes will be managed, accumulated, and inspected in accordance with the regulations.

Nonhazardous waste is not subject to specific regulatory requirements for accumulation or storage; however, appropriate best management practices (BMPs) will be implemented.

1.2.3        Soil and Waste Stockpiles and Staging Piles

Soil excavated during this project will be stockpiled in inactive areas of the site until such time it is needed for reconsolidation or for use as cover material. During these activities, the soil and refuse will be managed under the CERCLA Area-of-Contamination policy, which allows impacted soil and/or refuse waste to be uncovered, moved, and reconsolidated without triggering the RCRA LDRs and minimum technical requirements for a landfill under RCRA. During

construction, excavated materials and drill cuttings requiring temporary stockpiling prior to reconsolidation will be staged on-site and will not require characterization or off-site disposal. While not anticipated, if refuse is excavated and is not reconsolidated and the material is determined to be RCRA hazardous waste based on representative sampling and analysis data, then the new (effective April 22, 2002) RCRA temporary Corrective Action Management Unit (CAMU) regulations are applicable. These regulations consist of the performance and technical standards for staging piles (Sections 264.554[d][1][i–ii] and [d][2]) and closure requirements for staging piles (Section 264.554[j–k]). Under the new regulations, a temporary CAMU may be designated for temporary (up to 2 years) treatment or storage of solid, non-flowing remediation waste. The RCRA LDRs, the landfill minimum technology requirements, and the waste pile permitting requirements are not applicable to temporary CAMUs for RCRA hazardous wastes. The temporary CAMU regulations also require that the unit:

• The unit will be designed using appropriate measures (for example, liners, soil crusting agents, run-on/runoff controls, groundwater monitoring system) to prevent or minimize releases and cross media transfers of hazardous wastes and constituents (Section 264.554[d][1][ii]).
• For units located in a previously contaminated area of the facility—All remediation wastes, contaminated containment system components, structures, and equipment that are contaminated with waste or leachate must be removed and decontaminated within

180 days (264.554[j]). In addition, contaminated subsoils must be remediated in accordance with an approved plan and schedule, but the 180-day time limit does not apply.

• For units located on uncontaminated areas of the facility—Within 180 days following expiration of the operating term, any remaining contamination (such as, containment system components and subsoils) must be removed in accordance with the clean closure standards for waste piles in 22 CCR, Sections 66264.558(a) or 66265.558(a), and the closure performance standards in 22 CCR, Sections 66264.111 or 66265.111, for permitted and interim status facilities, respectively (264.554[k]).

For non-RCRA hazardous waste, in accordance with Division 20, Chapter 6.5, Section 25123.3 of the California Health and Safety Code, the material  can be stockpiled at the site for up to     90 days without satisfying all substantive requirements of a hazardous waste facility permit, provided the following conditions are met:

• The materials do not contain free liquids.
• The waste is accumulated on an impermeable surface (minimum 20-mil liner).
• The generator controls against wind dispersion and rain runoff.
• The generator inspects the site weekly and after storms to ensure the erosion controls are working properly.
• After final off-site transportation, the accumulation site is inspected and remediated as necessary.
• The site is certified for compliance with these standards by a registered engineer.

A log of all hazardous soil and debris stockpiles (or staging piles) will be maintained and updated on a daily basis. The log will include date of accumulation, date of sampling, analytical results obtained or pending, RCRA hazardous or non-RCRA hazardous designation, and so forth.

In addition to the aforementioned requirements, the State Water Resources Control Board Policy Number 92-08, which pertains to the control of stormwater discharges from construction activities, may also be relevant and appropriate to the temporary storage of stockpiled materials. Appropriate best management practices (BMPs) will be implemented to protect stockpiles from erosion and from stormwater run-on and runoff. These BMPs include erosion control, stormwater drainage control, secondary containment, fugitive emissions and wind dispersion control, and spill prevention. A site-specific Stormwater Pollution Prevention Plan (SWPPP) has been prepared for the project in accordance with ARARs (See Attachment 8 to the RAWP).

1.2.4        Wastewater and Waste Fluids

Title 22 CCR, Section 66264, and 40 CFR, Part 264, contain applicable requirements for facilities that store hazardous wastes in tanks or containers for over 90 days. Decontamination water and stormwater that comes in contact with the hazardous waste stockpiles will be collected and stored on-site in an approved tank of an appropriate capacity. The tank will be installed, managed, and inspected in accordance with the substantive requirements of 22 CCR, Sections 66264.191, 66264.192, 66264.193, and 66264.194. These regulations require specific engineering and design specifications, daily inspections of the tanks, adequate secondary containment (110 percent of the tank volume, plus the maximum rainfall from a 25-year, 24-hour storm event), and closure standards. The contents of the tank will be characterized based on generator knowledge from the project waste streams and/or per the requirements of 22 CCR, Section 66261, to determine appropriate disposal options. In addition, daily inspections of wastewater tanks will be conducted and logged to ensure the integrity of the tanks and secondary containment to check for leaks or spills, and to ensure that labels and markings are in good condition.

Wastewater generated, which may include decontamination water generated from equipment and personnel decontamination and purge water from well development activities, will be collected in 55-gallon drums, or combined in a large temporary storage tank (such as a Baker tank), and labeled as “Potentially Hazardous Decontamination (or Purge) Water.” The drums will be temporarily staged within a pre-designated and secondarily contained on-site waste accumulation area pending characterization and appropriate disposal. When possible, waste fluids generated from heavy equipment maintenance activities will be collected and removed from the site by the maintenance contractor for recycling. If waste fluids are required to be stored on-site, they will

be labeled accordingly, contained within Department of Transportation (DOT)-approved 55-gallon drums, and situated within a pre-designated and properly designed hazardous waste container storage area. Containers of hazardous wastes containing free liquids have stringent secondary containment requirements. These requirements include:

• A base free of cracks or gaps and sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed.
  • The base will be sloped or the containment system will be otherwise designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation. Alternatively, the containers may be elevated on pallets to prevent contact with accumulated liquids.
  • The containment system will have sufficient capacity to contain 10 percent of the volume of containers or the volume of the largest container, whichever is greater, plus the maximum rainfall from a 25-year 24-hour storm event.
  • Spilled or leaked waste and accumulated precipitation will be removed from the sump or collection area in a timely manner to prevent overflow of the collection system.

1.2.5        Used Personal Protective Equipment

Used PPE will be stored in DOT-approved 55-gallons drums or LLRW bins within the designated hazardous waste container storage area or the Radiological Material Area (RMA), respectively. The storage area will be designed and managed in accordance with the substantive requirements of the container management regulations codified in 22 CCR, Sections 66264.170 through 66264.178.

1.2.6        Container Labeling

Containers of potentially hazardous waste will be labeled with indelible ink with the following information: source and location; contents and quantity; potential health, safety, and environmental hazards; accumulation start date; date container sampled; parameters analyzed for; and the words “Analysis Pending – Potentially Hazardous.” If containers are determined to contain nonhazardous waste, they will be labeled accordingly. If containers are determined to contain hazardous waste, they will immediately be labeled with a completed “Hazardous Waste” label, which will include:

• EPA Identification Number of the generator
• Name and address of the generator
• EPA waste code
• DOT shipping name (prior to off-site shipment)
• Description of contents
• Date of generation (date first drop of waste placed in container)

An inventory of waste containers will be maintained for later submittal to the Department of the Navy (DON). In addition, weekly inspections of container storage areas will be conducted and logged while wastes remain in these areas to ensure the integrity of the containers and secondary containment, to check for leaks or spills, and to ensure labels and markings are in good condition.

1.2.7        Waste Accumulation Areas

Hazardous waste storage areas require:

• A sign with the legend, “Danger Hazardous Waste Area-Unauthorized Personnel Keep Out” (written in English and Spanish), will be posted at each 90-day accumulation area and stockpile in sufficient numbers to be seen from any approach. The signs will be legible from a distance of at least 25 feet.
• Aisle space will be maintained to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes.
  • The following emergency equipment will be located or available to personnel during active waste management activities at each accumulation area:

–        A device, such as a telephone or a hand-held two-way radio, capable of summoning emergency assistance will be available.

–        Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment will be available.

–        Water at adequate volume and pressure to supply water hose streams, or foam producing equipment, or automatic sprinklers, or water spray systems.

–        A spill response kit for minor spills. The kit will include a shovel, adsorbent pads and/or “kitty litter,” and a collection container.

Bulk quantities of fuel, oil, or other hazardous materials will not be stored on-site. Equipment fueling and maintenance activities will be performed by an off-site contractor on an as-needed basis.

1.2.8        Waste Disposal

Although not anticipated, soil or refuse that is excavated during this project and that is not reconsolidated will be disposed of off-site at an appropriately permitted waste disposal facility. Non-soil related wastes, which may include wastewater, debris, used PPE, used oil, and impacted stormwater, will be managed in accordance with the regulations and transported off-site for appropriate recycling or disposal. Used PPE will generally be managed as LLRW and disposed of by the LLRW contractor. Each waste stream requiring off-site disposal will be characterized by generator knowledge or sampled and analyzed, as necessary, to ensure that it is properly

characterized and profiled and meets the waste acceptance criteria and packaging requirements for the proposed treatment, storage, and disposal facility (TSDF) prior to transport. Hazardous waste debris generated on site, which has been treated using an alternate treatment technology as indicated in 40 CFR, Part 268.45, and 22 CCR, Section 66268, (decontaminated with a water wash and spray), will be disposed of as nonhazardous solid waste. Used PPE and debris (oversized material, polyethylene liners, polyvinyl chloride piping, and so forth) that is determined to be radiological waste or a hazardous waste and is unsuitable for decontamination, will be transferred to the LLRW contractor or sent off-site to a hazardous waste landfill facility respectively. Waste oil and other fluids generated during equipment maintenance activities will be collected, contained, and sent off-site for recycling.

Non-radiologically impacted hazardous waste will be disposed only at a hazardous waste disposal facility approved by the DON and permitted for the disposal of the particular type of hazardous waste generated. Wastes disposed off-site will be sent to RCRA Subtitle C or RCRA Subtitle D facilities that meet the requirements of 40 CFR, Part 300.440 (CERCLA Off-site Policy).

1.2.9        Waste Transportation

Hazardous wastes sent off-site for disposal or recycling will be done so in accordance with the DOT Hazardous Material Transportation regulations of 49 CFR, Parts 171 through 177,  and    40 CFR, Part 262, Subpart B, and 22 CCR, Section 66262, which involve packaging, placarding, labeling, and manifesting requirements, and  with  appropriate  LDR  certification  notices  per 40 CFR, Part 268, and 22 CCR, Section 66268. Personnel having the required DOT-training will perform all DOT functions. In addition, all transporter and disposal contractors will be subject to the contractor qualification process. Under no circumstances will TtEC personnel sign hazardous waste manifests.

Material that does not exhibit one of the nine DOT hazard class characteristics (explosives, gases, flammable/combustible liquids, flammable solids/spontaneously combustible materials, dangerous when wet materials, oxidizers and organic peroxides, toxic materials and infectious substances, radioactive materials, corrosive materials) is not regulated under DOT rules for hazardous material transportation. If material is suspected to be hazardous, it will be shipped under the appropriate hazard class. All hazardous waste will be transported under DOT hazardous material regulations. Each shipment of a suspected hazardous material will be properly classed using the Hazardous Materials Table in 49 CFR, Part 172.101. DOT-trained personnel will make all determinations.

1.2.10    Waste Minimization

To minimize the volume of waste, the following general guidelines will be followed:

• Waste materials will not be contaminated unnecessarily.
• Work will be planned ahead.
• Materials may be stored in large containers, but the smallest reasonable container will be used to transport the material to the location where it is needed.
• Cleaning and extra sampling supplies will be maintained outside any potentially contaminated area to keep them clean and to minimize additional waste generation.
• Mixing of detergents or decontamination solutions will be performed outside potentially contaminated areas.
• Drop cloths or other absorbent material will be used to contain small spills or leaks.
• Contaminated materials will not be placed with clean materials.
• Wooden pallets inside the exclusion zone will be covered with plastic.
• Material and equipment will be decontaminated and reused when practical.
• Volume reduction techniques will be used when practicable.
• Waste containers will be verified to ensure they are solidly packed to minimize the number of containers.
• Only the size waste containers adequate to contain the volume of waste generated will be used.
• Less hazardous substances will be used whenever possible (only the volume of standard solutions needed for testing will be brought; minimal amounts of decontamination water and solvent rinses will be used).

1.2.11    Waste Management Inspection and Documentation Program

This section presents the waste inspection procedures and documentation program to be employed during the project field activities.

1.2.12    Inspections

While all waste accumulation areas will be informally inspected on a daily basis, formal inspections of all hazardous container accumulation areas will be conducted and recorded at least weekly in accordance with 40 CFR, Part 264, Subpart I, and 22 CCR, Section 66264. However, daily inspections will be conducted for tanks containing hazardous wastewater. In addition, hazardous soil stockpiles will be inspected daily to ensure that liners are in place and the stockpiles are adequately protected. The Project Quality Control Manager or his designee will conduct inspections. Inspections will be logged in a field notebook, and a weekly (daily for tanks) inspection checklist will be completed. The container storage area(s) will be inspected to ensure the following:

• Containers are in good condition. If a container is not in good condition or appears to be leaking, the waste will be transferred to another container.
  • Containers are made of materials that will not react with, and are otherwise compatible with, the hazardous waste to be stored.
  • Containers are closed at all times, except when adding or removing waste.

Tanks used for storage of collected hazardous runoff and decontamination water will be inspected on a daily basis and the inspections will be logged. The inspections will ensure that tanks have adequate secondary containment, are properly labeled, are in good condition (no apparent structural defects or deterioration), and have no visible leaks.

1.2.13    Documentation

Documentation requirements apply to all waste managed during project activities. Field records will be kept of all waste generation activities. All pages of the field data record log will be signed and dated by the supervising field leader who is entering the data. In addition, the following information will be recorded in the log:

• Description of waste generating activities
• Location of waste generation (including depth, if applicable)
• Type and volume of waste
• Date and time of generation
• Description of any waste sampling
• Name of person recording information
• Name of field manager at time of generation

1.2.14    Hazardous Waste Manifests and LDR Certification

All hazardous waste transported from the site will be accompanied by a Hazardous Waste Manifest. DON personnel will be responsible for reviewing and signing all waste documentation, including waste profiles, manifests, and LDR notifications (manifest packages). Prior to signing the manifest, the designated DON official will ensure that pre-transport requirements of packaging, labeling, marking, and placarding are met according to 40 CFR, Parts 262.30 through 262.33, and 49 CFR, Parts 100 through 178.

The DON will receive one copy of the manifest; the remaining copies will be given to the transporter. The manifest will be returned to the DON’s signatory official for the base’s recordkeeping requirements. Copies of all manifests for waste generated at the site will be kept in a compliance file within the project files. (The PjM will provide the DON with the generator’s copies of the manifest.)

An LDR form will accompany the shipment of hazardous waste to the TSDF. The TSDF will be notified prior to the waste being sent. The following items must accompany the notification and are included in one of the following facility-specific forms:

• EPA Hazardous Waste Generator identification number for material flow analysis
• Manifest number, including state disposal application number
• Waste analysis data
• Corresponding concentration-based or technology-based treatment standards will be identified if the waste is also land disposal restricted

RCRA recordkeeping requirements per 40 CFR, Parts 262.20 through 262.44, including  retention of signed copies of manifests from the designated facility that received the waste, will be adhered. Additionally, biennial and exception reporting information will be submitted, as necessary, according to 22 CCR, Sections 66262.41 and 66261.42, and 40 CFR, Parts 262.41  and 262.42. Additional reporting may be required in accordance with 22 CCR, Section 66262.43, and 40 CFR, Part 262.43.

1.3         WASTE MANAGEMENT FOR RADIOACTIVE WASTES

The following subsections address specific control and management practices for LLRW and low-level mixed waste (LLMW), hereafter including low-level contaminated waste (LLCW), that should be followed by the certified waste broker contracted by the Department of Defense (DoD) Executive Agency for LLRW. Disposal of all LLRW and LLMW will be handled through the DON’s LLRW Disposal Program. TtEC has no responsibilities in verifying that the DoD broker adheres to these requirements.

The certified DoD waste broker should be used for all packaging, storage, shipping, manifesting, and disposal of LLRW and LLMW. The waste broker should coordinate closely with the Radiological Affairs Support Office (RASO).

1.3.1        Waste Classification

Radioactive wastes should be classified as specified in 49 CFR and/or disposal facility requirements. These wastes should be categorized as either LLRW or LLMW. Waste characteristics, including the radionuclides present and their associated specific activity, should be measured by an available standardized test method such as gamma spectroscopy, strontium analyses, and/or alpha spectroscopy. Additionally, for LLMW, chemical waste characteristics can be measured by a standardized test method or be reasonably classified by generators of waste based on their knowledge of the waste, provided that the waste has already been reliably tested for acceptance at the waste disposal facility.

A waste determined not to be a RCRA LLMW may still be considered a state-regulated non-RCRA LLCW (low level radioactive and non-RCRA hazardous). The state is broader in scope in its RCRA program in determining hazardous waste.

1.3.2        Waste Accumulation and Storage

As for hazardous waste, specific requirements apply to the accumulation time for LLMW or LLCW on-site and to the accumulation and labeling of LLMW. This project may result in the temporary accumulation of LLMW or LLCW in containers. These wastes should be managed, accumulated, and inspected in accordance with the hazardous waste regulations and may only be stored on-site for less than 90 days. Accumulation time requirements do not apply to LLRW- only waste.

All LLRW, LLMW, and LLCW should be packaged per the direction of a waste broker certified by the DoD Executive Agency for LLRW (Army Field Support Command) in accordance with federal directives and disposal facility requirements. Typical containers that may be used for these wastes include bins, 55-gallon drums, B-25 boxes, and/or covered roll-off containers. Containers should be properly lined, and absorbent should be used if it is considered necessary. All containers should be radiologically surveyed and/or swiped by the DoD broker when received. Each container should be properly inventoried and labeled. Inventories should include material description and isotopic identification, and hazardous components if appropriate. The contents of each container should be recorded in the field logbook, and each container should be assigned a unique identification number. Records should be maintained by the DoD broker.

Containers should be stored in a designated and posted radiological materials storage area under the authority of the DoD broker’s Nuclear Regulatory Commission (NRC) or California Agreement State radioactive materials license. Storage areas may be at the site where the waste originated. Containers should be secured to prevent unauthorized access to the contents of the container. Once filled, all containers should be surveyed and surface radiation measurements collected by the DoD broker using an ion chamber survey meter or equivalent.

1.3.3        Radiological Point Sources

Radiological point sources (such as radium-containing dials) should be packaged in metal drums in accordance with DOT regulations specified in 49 CFR, Subpart I, and should be stored in a posted radiological materials area. The DON is responsible for the transportation and disposal of radiological point sources.

1.3.4        Soil, Debris, and Materials

Soil, debris, and materials classified as LLRW or LLMW may be generated during excavation. When classified as LLRW or LLMW, these wastes should be placed in bins, 55-gallon drums, B-25 boxes, and/or roll-off containers.

1.3.5        Wastewater and Waste Fluids

Wastewater from the radioactive material decontamination area should be maintained separately from hazardous decontamination and dewatering wastewater. If the wastewater chemical characteristics are unknown, wastewater should be managed as LLRW wastewater, until characterized. Known or suspected LLMW or LLCW wastewater should be segregated during accumulation and storage. When decontaminating and dewatering radioactively contaminated material, every effort should be made to minimize the generation of mixed waste.

1.3.6        Labeling and Posting of Containers Containing Radioactive Waste

Each waste container containing LLRW or LLMW should be labeled by the DoD broker. The specific activity contained in each waste container and maximum contact radiation levels should be measured in milliroentgens per hour (mR/hr). Following the surveying and labeling, the waste container should be placed in a designated and posted radioactive material storage area. The waste container should be posted with a “Caution – Radioactive Material” sign. The sign should also note the maximum surface radiation level (measured in mR/hr). An inventory of contents with radionuclide and specific activity (if available) should be posted on the outside of the container or a notice should be posted stating where this information is found. The waste inventories should be managed under DoD NRC or California Agreement State radioactive materials license, including the mixed waste inventory due to the radioactive constituents.

1.3.7        Waste Accumulation Areas

The DoD broker working on this project in conjunction with TtEC should implement, at a minimum, the following requirements for radioactive waste stored on-site within a designated radioactive waste storage area:

• An industry standard placard and barrier materials should be displayed with wording that includes the following, “Caution, Radioactive Materials Area-Unauthorized Personnel Keep Out” (written in English and Spanish), at each radioactive waste storage area sufficient to be seen from any approach. The signs should be legible and clearly conspicuous for outdoor and indoor locations.
  • Aisle space should be maintained to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in an emergency, unless aisle space is not needed for any of these purposes.
  • The areas should be secured to prevent unauthorized access to the material.
  • The following emergency equipment should be located or available to personnel during radioactive waste management activities at each accumulation area:

–        A device, such as a telephone or a hand-held two-way radio, capable of summoning emergency assistance

–        Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment

Filled containers generated during performance of this remedial action should be stored at the site where they were generated, until the contained material can be characterized for packaging and disposal by the DoD waste broker.

1.3.8        Waste Disposal

A certified waste broker contracted by the DoD Executive Agency for LLRW should be used for all packaging, shipping, manifesting, transportation, and disposal of LLRW, LLMW, and LLCW. The certified waste broker should coordinate closely with RASO. LLRW, LLMW, and LLCW inventories once identified by TtEC will be immediately turned over for management to the waste broker. These materials should be managed under the DoD broker’s NRC license because of the radioactive constituents.

The certified waste broker should be responsible for preparing the hazardous waste manifests for the LLMW and the radioactive waste manifests for the LLRW. These manifests should be signed by the certified waste broker. The certified waste broker should also be responsible for coordinating the shipment of LLMW and LLRW and coordinating with the waste disposal facilities.

1.3.9        Waste Transportation

Wastes sent off-site for disposal should be done so in accordance with the DOT Radioactive Material Transportation regulations of 49 CFR, by a certified waste broker contracted by the DoD Executive Agency for LLRW. Personnel having the required DOT training should perform assistance as needed.

The certified waste broker should be responsible for surveying and taking radiation measurements on the outside of the container prior to shipment. The certified waste broker should work with the Caretaker Site Office (CSO) representative to ensure that containers leaving the site meet the release limits for equipment and materials as identified in the Radiological Work Plan (Attachment 2 to the RAWP).

1.3.10    Waste Minimization

To minimize the volume of radioactive waste generated during the project, the following general guidelines will be followed:

• Waste material will not be contaminated unnecessarily.
• Work will be planned ahead.
• Cleaning and extra sampling supplies will be maintained outside any potentially contaminated area to keep them clean and to minimize additional waste generation.
• Mixing of detergents or decontamination solutions will be performed outside potentially contaminated areas.
• When decontaminating radioactively contaminated material, every effort should be made to minimize the generation of mixed waste.
  • Contaminated material will not be placed with clean material.
  • Wooden pallets inside the exclusion zone will be covered with plastic.
  • Material and equipment will be decontaminated and reused when practicable.
  • Volume reduction techniques will be used when practicable.

1.3.11    Inspections

The DoD broker is responsible for LLRW accumulation areas. While all waste accumulation areas should be informally inspected on a daily basis, formal inspections of all container accumulation areas should be conducted and recorded at least weekly in accordance with the DoD broker’s  NRC license requirements. The RTM or designee will conduct inspections. Inspections will be recorded in a dedicated field logbook, and a weekly inspection checklist should be completed. The container storage area(s) should be inspected to ensure the following:

• The containers should be checked for good condition. If a container is not in good condition the certified waste broker will be informed.
• The containers should l be checked to ensure that they remain closed and secured at all times, except when adding or removing waste.
• The container label should be checked to ensure that it is visible and filled out properly.

1.3.12    Documentation

Documentation requirements apply to all waste managed during project activities. Field records should be kept of all waste-generation activities. All pages of the field data record log will be signed and dated by the person who is entering the data. In addition, the following information will be recorded in the log:

• Description of waste-generating activities
• Location of waste generation (including depth, if applicable)
• Type and volume of waste
• Date and time of generation
• Description of any waste sampling
• Name of person recording information
• Name of RTM at time of generation

1.3.13    Radioactive Waste Manifests

All radioactive waste transported from the site should be accompanied by a radioactive waste manifest and/or hazardous waste manifest if necessary. The LLRW/LLMW/LLCW manifests are the responsibility of the certified waste broker. LLRW manifests are signed by the broker.

The CSO and RASO should each receive one copy of the manifest; the remaining copies should be given to the transporter. The manifest should be returned to the DON’s signatory official for the base’s recordkeeping requirements. Copies of all manifests for waste generated at the site should be kept in a compliance file within the DoD broker’s project files.

1.4         HAZARDOUS MATERIAL SECURITY PLAN

If it is determined that placardable DOT hazardous materials will be generated on-site, a DOT Hazardous Material Security Plan will be prepared as a stand-alone document. The Hazardous Material Security Plan will be prepared in accordance with 49 CFR 172, Subpart H, and will guide the management for security purposes of hazardous materials prior to shipment. All site personnel responsible for hazardous materials security will receive both general awareness and plan-specific training. This training will be documented in the project file.

1.5         UPDATING THE WASTE MANAGEMENT PLAN

The WMP will be updated as changes in site activities or conditions or changes in applicable regulations occur. Revisions to the WMP will be reviewed and approved by the DON. All changes to the WMP associated with radioactive or mixed waste will require approval from the RASO.

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2.0     REFERENCES

EPA  (United  States  Environmental  Protection  Agency).    1992.     Guide to Management of Investigation-Derived Wastes. Publication 9345.3-03FS. January 2.

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TABLES

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Abbreviations and Acronyms:

Cal/EPA – California Environmental Protection Agency CFR – Code of Federal Regulations

CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act CSO – Caretaker Site Office

DoD – Department of Defense DON – Department of the Navy

DOT – Department of Transportation LLRW – low-level radioactive waste LDR – land disposal restriction

MEC – munitions and explosives of concern

MPPEH – material potentially presenting an explosive hazard PCB – polychlorinated biphenyl

PPE – personal protective equipment

RCRA – Resource Conservation and Recovery Act RMA – Radiological Material Area

SAP – Sampling and Analysis Plan

STLC – Soluble Threshold Limit Concentration SVOC – semivolatile organic compound

TCLP – Toxicity Characteristic Leaching Procedure TPH – total petroleum hydrocarbons

TSDF – treatment, storage, and disposal facility UXO – unexploded ordnance

VOC – volatile organic compound

ATTACHMENT 11

POST-CLOSURE OPERATIONS, MAINTENANCE, AND MONITORING PLAN

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

CONTRACT NO. N62473-10-D-0809 CTO NO. 0009

ATTACHMENT 11

FINAL

POST-CLOSURE OPERATIONS, MAINTENANCE, AND MONITORING PLAN

Revision 1

November 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA

DCN: RMAC-0809-0009-0004.R1

Prepared by:

1230 Columbia Street, Suite 750 San Diego, California 92101-8536

Pete Everds Technical Lead

Hedy Abedi, PhD, PE Project Manager

TABLE OF CONTENTS

PAGE ABBREVIATIONS AND ACRONYMS…………………………………………………………………………… v

1.0           INTRODUCTION……………………………………………………………………………………………… 1-1

1.1                 SITE DESCRIPTION……………………………………………………………………………… 1-1

1.2                 SITE HISTORY……………………………………………………………………………………… 1-1

1.3                 FUTURE USE………………………………………………………………………………………… 1-2

1.4                 PREVIOUS ACTIVITIES……………………………………………………………………….. 1-2

1.4.1             Remedial Investigation/Feasibility Study……………………………………… 1-2

1.4.2             Record of Decision……………………………………………………………………… 1-2

1.4.3             Remedy for Soil…………………………………………………………………………. 1-2

1.4.4             Remedy for Groundwater……………………………………………………………. 1-3

1.5                 SELECTED REMEDY COMPONENTS………………………………………………….. 1-3

1.5.1             Gas Venting………………………………………………………………………………. 1-3

1.5.2             Subgrade and Foundation Fill………………………………………………………. 1-4

1.5.3             Multilayer Soil Cover…………………………………………………………………. 1-4

1.5.4             Settlement Monuments……………………………………………………………….. 1-5

1.6                 DOCUMENT ORGANIZATION…………………………………………………………….. 1-5

2.0           OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND

METHANE MONITORING……………………………………………………………………………….. 2-1

2.1                 LONG-TERM GROUNDWATER MONITORING WELL EVALUATION…. 2-1

2.1.1             Groundwater Monitoring Well Network and Sampling Frequency…… 2-1

2.1.2             Proposed Analysis and Field Parameters……………………………………….. 2-2

2.1.3             Data Analysis…………………………………………………………………………….. 2-3

2.2                 COMPLIANCE PERIOD………………………………………………………………………… 2-3

2.3                 METHANE MONITORING……………………………………………………………………. 2-4

3.0           OPERATIONS AND MAINTENANCE FOR SITE STRUCTURES………………………… 3-1

3.1                 LANDFILL COVER SURFACE WATER MANAGEMENT SYSTEM……….. 3-1

3.2                 WETLANDS CULVERT………………………………………………………………………… 3-2

3.3                 GAS COLLECTION………………………………………………………………………………. 3-2

3.4                 GAS PROBES……………………………………………………………………………………….. 3-2

3.5                 MONITORING WELLS…………………………………………………………………………. 3-2

3.6                 SETTLEMENT MONUMENTS………………………………………………………………. 3-2

3.7                 ACCESS ROADS…………………………………………………………………………………… 3-3

3.8                 SIGNAGE……………………………………………………………………………………………… 3-3

4.0           OPERATIONS AND MAINTENANCE FOR LANDFILL COVER

SETTLEMENT, EROSION, AND VEGETATION……………………………………………….. 4-1

4.1                 DIFFERENTIAL SETTLEMENT AND EROSION…………………………………… 4-1

4.1.1             Detection…………………………………………………………………………………… 4-1

4.1.2             Repairs……………………………………………………………………………………… 4-1

PAGE 4.2             VEGETATION………………………………………………………………………………………. 4-2

4.3                 DOCUMENTATION……………………………………………………………………………… 4-2

4.4                 EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND

SEAWALL……………………………………………………………………………………………. 4-2

5.0           MONITORING AND MAINTENANCE OF WETLANDS MITIGATION

AREAS……………………………………………………………………………………………………………… 5-1

5.1                 SUCCESS CRITERIA FOR VEGETATION…………………………………………….. 5-1

5.2                 SUCCESS CRITERIA FOR WILDLIFE…………………………………………………… 5-2

5.3                 SUCCESS CRITERIA FOR HYDROLOGY…………………………………………….. 5-2

6.0           SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE

ACTIVITIES……………………………………………………………………………………………………… 6-1

6.1                 SCHEDULED INSPECTION………………………………………………………………….. 6-1

6.1.1             Cover Settlement……………………………………………………………………….. 6-1

6.1.2             Geonet Animal Intrusion Barrier………………………………………………….. 6-1

6.1.3             Methane Monitoring…………………………………………………………………… 6-1

6.1.4             Wetlands Culvert……………………………………………………………………….. 6-1

6.1.5             Site Structures……………………………………………………………………………. 6-2

6.2                 FIELD DOCUMENTATION…………………………………………………………………… 6-2

6.2.1             Document Corrections………………………………………………………………… 6-2

7.0….. REPORT REQUIREMENTS AND DATA MANAGEMENT…………………………………. 7-1

8.0      POST-CLOSURE FINANCIAL ASSURANCE…………………………………………………….. 8-1

9.0      REFERENCES…………………………………………………………………………………………………… 9-1

TABLES

Table 2-1            Proposed Groundwater Monitoring Well Network, Analyses, and Sampling Frequency

Table 2-2            Standard Operating Procedures for Post-Closure Monitoring and Maintenance

FIGURES

Figure 1-1          Site Location Map

Figure 2-1          IR Site 2 Groundwater Monitoring Well Locations Figure 2-2                      Analytical Trends Comparison Flow Chart

Figure 6-1          Proposed Schedule

APPENDICES

Appendix A          Long-term Groundwater Monitoring Evaluation Appendix B           Standard Operating Procedures (on CD only) Appendix C                           Plan Itemized Cost Estimate (on CD only) Appendix D                              Emergency Response Plan (on CD only)

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ABBREVIATIONS AND ACRONYMS

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1.0          INTRODUCTION

Tetra Tech EC, Inc., has prepared this Post-Closure Operations, Maintenance, and Monitoring Plan (Plan) for Installation Restoration (IR) Site 2, former Naval Air Station (NAS) Alameda, Alameda Point, Alameda, California. This Plan was prepared for the Department of the Navy (DON), Base Realignment and Closure Program Management Office West under Contract No. N62473-10-D-0809, Contract Task Order 0009. The purpose of this Plan is to describe the operations, maintenance, and monitoring to be implemented after construction of the multilayer soil cover (cover) on the IR Site 2 landfill. The approach set forth in this Plan was developed based on the description of the selected soil remedy in Record of Decision (ROD) (DON 2010), site conditions described in the Remedial Investigation (RI) Report (Battelle and BBL 2006), and the Feasibility Study (FS) Report (Battelle and BBL 2008), and procedures and recommendations presented in the Long-term Groundwater Monitoring Evaluation (Alameda Agencies, 2013).

1.1              SITE DESCRIPTION

The site covers approximately 110 acres in the southwest corner of the former Alameda NAS, now referred to as Alameda Point (Figure 1-1). The site consists of the former landfill area  (West Beach Landfill), which occupies approximately 60 acres, and a wetland, which covers approximately 33 acres immediately south and west of the landfill. The wetland area includes two surface water features, the north pond and the south pond. The north pond is connected by a culvert to San Francisco Bay. The remaining 17 acres within the site boundary is known as the interior margin and the coastal margin. The site is bound on the south and west by San Francisco Bay and on the east and north by runways and tarmacs.

Additional site background information is presented in Section 2.0 of the Remedial Action Work Plan (RAWP).

1.2              SITE HISTORY

The site was formerly part of the San Francisco Bay and was created by construction of a seawall around the perimeter, filling with dredge materials, and subsequent disposal of wastes generated by former NAS Alameda activities from 1956 through early 1978. Historical disposal methods  at the site generally consisted of trench-and-fill operations and placement of cover soil on an intermittent basis. These operations resulted in waste that is in contact with shallow  groundwater. Alameda Point was included on the National Priorities List of Superfund sites in August 1999, U.S. Environmental Protection Agency (EPA) (Identification: CA2170023236).

After landfill operations ceased in 1978, an earthen berm was constructed around the perimeter of the landfill. The extent of the landfill, as defined in the ROD (DON 2010) and as modified based on the Intermediate Draft Remedial Design Report (KCH 2011), is shown on Figure 1-1.

1.3              FUTURE USE

IR Site 2 has been designated for federal agency (DON) to federal agency (Office of Veterans Affairs) transfer. The proposed future use at IR Site 2 is “undeveloped” with potential for recreational uses such as a perimeter hiking trail.

1.4              PREVIOUS ACTIVITIES

IR Site 2 was used as a landfill. There was no land use at the site prior to 1956, when the perimeter sea wall was constructed and the site was first formed by using dredged fill. Due to its historical use solely as a landfill, no persons have resided or currently reside at the site.

1.4.1        Remedial Investigation/Feasibility Study

The Final RI Report (Battelle and BBL 2006), the FS, and Basewide Groundwater Monitoring Program (BGMP) reports describe in detail the nature and extent of groundwater contamination. The most commonly detected organic contaminants in site groundwater are volatile organic compounds, total petroleum hydrocarbons, and other fuel-related compounds (ITSI 2008). Groundwater contamination is characterized by a relatively widespread pattern of low-level contamination. The source of contamination is attributed to the operation of the site as the principal waste disposal facility for Alameda Point between 1956 and 1978.

1.4.2        Record of Decision

The DON conducted an FS (Battelle and BBL 2008) to evaluate potential remedial alternatives for IR  Site 2 and prepared a ROD (DON 2010) to document the selected remedy for the site.  The DON and the Federal Facility Agreement signatories (the EPA, California Environmental Protection Agency, Department of Toxic Substances Control [DTSC], and the San Francisco Bay Regional Water Quality Control Board) concurred on the selected remedy for the site. The decision agreed to in the ROD is based on information contained in the administrative record file as well as on extensive field investigations, laboratory analyses, interpretation of the data, review of current and future conditions, assessment of the potential human health and ecological risks, and an evaluation of potential remedial alternatives.

1.4.3        Remedy for Soil

The selected remedy for soil, as outlined in the ROD, is Alternative 2, a multilayer soil cover, engineering controls (ECs) and institutional controls (ICs), and monitoring. This alternative consists of installation of an engineered soil cover over the former landfill to isolate buried waste and soil contaminants and prevent animal burrowing; implementation of engineering and land use controls to protect human health and soil cover integrity; provision for any necessary

wetlands mitigation if impacts to wetlands occurs; monitoring of the soil cleanup action and wetlands mitigation to ensure their proper construction and long-term effectiveness; and conduct of methane gas monitoring as necessary.  The RAWP addresses the design of the soil remedy  and includes more details on the ECs and ICs.

1.4.4        Remedy for Groundwater

The selected remedy for groundwater, as outlined in the ROD, is Alternative 2 – Monitored Natural Attenuation (MNA). This alternative consists of regularly monitoring groundwater quality using shoreline groundwater monitoring wells to ensure that there are continued stable to decreasing trends in contaminant concentrations, and protection of the beneficial uses of surface water in San Francisco Bay; and implementation of engineering controls and ICs to protect human health and the groundwater remedy.

The objective of MNA is to verify the occurrence of natural attenuation of groundwater contaminants through monitoring. In accordance with the ROD, contaminants will not be actively remediated, but will be allowed to degrade, adsorb, dilute, or transform according to natural, unaided environmental processes (DON 2010). The groundwater remedy meets the Remedial Action Objective (RAO) described in the ROD to protect beneficial uses of surface water in San Francisco Bay from the potential for discharge of site groundwater (DON 2010).

Because groundwater at the site is not used for drinking water and is not considered a potential drinking water source, numerical standards associated with groundwater (such as maximum contaminant levels for drinking water) do not apply. Instead, chemicals identified during the remedial investigation in excess of California Toxics Rule (CTR) surface water quality criteria were summarized in ROD Table 2.7.

While the CTR criteria are not directly applicable to groundwater, the criteria are appropriate to provide suitable context for evaluating IR Site 2 groundwater relative to groundwater RAOs. Currently, risk to San Francisco Bay surface water from site groundwater is considered negligible.

1.5              SELECTED REMEDY COMPONENTS

1.5.1        Gas Venting

The landfill area was designed with a passive gas venting system to prevent landfill gas buildup which could disrupt the cover. The gas venting trenches are filled with high permeability aggregate and geotextile surrounding a 4-inch perforated pipe. The pipes connect to gas vents open to the atmosphere.

Ten existing landfill gas probes will be destroyed during soil cover construction. Nine new perimeter gas probes will be installed at IR Site 2, as shown in the design drawings presented in

RAWP Attachment 1. These probes will be designed and located as described in the RAWP and attached 100% Remedial Design (RD).

1.5.2        Subgrade and Foundation Fill

The subgrade and foundation fill will consist of common fill materials or natural ground. The primary requirement for this fill material is that it be compatible and provide stable support for the cover. The primary purpose of the subgrade and foundation fill is to build up the original landfill surface to moderate, uniform slopes. Grades established for the cover system will be approximately 1.5 percent to account for potential settlement and maintain positive drainage over the cover system.

1.5.3        Multilayer Soil Cover

The proposed cover will be 2 feet thick to provide required isolation from the waste, and will consist of three distinct layers:

• Animal intrusion barrier consisting of minimum 220-mil high-density polyethylene geonet
• Cover layer of 18 inches of common fill
• Vegetative layer of 6-inch-thick topsoil amended to help establish vegetation

1.5.3.1                 Animal Intrusion Barrier

The animal intrusion barrier will be installed utilizing minimum 220-mil layer of high-density polyethylene geonet. The material will  require  no  specialized  seaming and  will  transverse  the fill.

1.5.3.2                 Cover Layer

After the animal intrusion barrier is placed over a portion of the site, a cover layer will be installed consisting of an 18-inch layer of import material meeting geotechnical specifications and conditioned for moisture.

1.5.3.3                 Vegetative Layer

The vegetative layer is a 6-inch layer that requires only 85 percent compaction and is amended to help establish vegetation. This fill material is similar to the cover material.

1.5.3.4                 Vegetation

The landfill cover will be hydroseeded with a mixture identified in the Specifications in the 100% RD (Attachment 1 to the RAWP).

1.5.3.5                 Surface Water Management System (Drainage and Swale Layer)

Two new earthen swales with turf reinforcement mats are integrated into the cover design. The channels slope from 0.5 to 1 percent and have been placed to maximize the efficiency of collection and transfer of sheet flow from the completed cover. An existing concrete channel located on the eastern boundary of the site will be maintained throughout construction and incorporated into the final drainage system.

1.5.4        Settlement Monuments

Four settlement monuments will be installed on the final cover system as specified in the     100% RD (Attachment 1 of the RAWP). Markers will be located where the depth of fill is the greatest and therefore settlement potential the highest. The monuments will be located so that settlement rate and trends can be monitored and assessed.

1.6              DOCUMENT ORGANIZATION

This Plan is organized as follows:

• Section 1.0 provides the site description, history, previous activities, site remedy components, and document organization.
• Section 2.0describes the requirements for post-closure groundwater and methane monitoring.
  • Section 3.0 describes the operation and maintenance requirements for site structures.
  • Section 4.0 describes the operation and maintenance requirements for the landfill cover settlement.
  • Section 5.0describes the monitoring and maintenance requirements for the wetlands mitigation areas.
    • Section 6.0 provides the proposed schedule.
    • Section 7.0 describes reporting requirements.
    • Section 8.0 provides post-closure financial assurance.
    • Section 9.0 provides post-closure certification.
    • Section 10.0 lists the references cited in the text.
    • Tables and figures follow the text.
    • Appendix A presents the Long-term Groundwater Monitoring Evaluation (GME)
    • Appendix B includes the Standard Operating Procedures (SOPs).
    • Appendix Cpresents the estimated annual cost for operations, maintenance, and monitoring.
      • Appendix D presents the required Emergency Response Plan.

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2.0          OPERATIONS AND MAINTENANCE FOR GROUNDWATER AND METHANE MONITORING

2.1              LONG-TERM GROUNDWATER MONITORING WELL EVALUATION

In accordance with groundwater requirements in the ROD, this section presents the groundwater monitoring methods and criteria for assessing groundwater data trends to confirm that contaminant levels remain within an acceptable range. The monitoring well network, monitoring schedule, analytes, and methods are defined. As part of their technical review and oversight, the regulatory agencies provided recommendations for the long-term groundwater monitoring program for Alameda IR Site 2 (Alameda Agencies, 2013), which are included as Appendix A. These recommendations were based on an evaluation of available historical geologic, hydrogeologic, and analytical data for IR Site 2. Post-closure groundwater monitoring requirements are presented below, incorporating details from the GME (Appendix A).

2.1.1        Groundwater Monitoring Well Network and Sampling Frequency

The long-term monitoring plan has been designed to demonstrate protection of San Francisco Bay (bay) and the North and South Ponds (wetlands) from contamination in groundwater that may migrate beneath IR Site 2 and discharge to these surface water bodies. The long-term groundwater monitoring well network focuses on groundwater potentially influenced by the landfill that is hydraulically connected to the wetlands and the bay. The groundwater monitoring well network includes interior first water-bearing zone (FWBZ) wells that are downgradient of the landfill and upgradient of the wetlands, and shoreline FWBZ wells that are downgradient of the landfill and adjacent to the bay (Figure 2-1). Historical groundwater flow directions support the placement of these monitoring wells. Flow directions will continue to be evaluated to ensure that the monitoring network remains appropriate for its intended purpose.

The monitoring well network utilizes existing upper and lower FWBZ wells that were installed in the mid-1990s and have been sampled since that time, yielding a robust historical data set. As shown on Figure 2-1 and discussed in Section 5.8.3 of the RAWP, four new well clusters, completed in the upper and lower FWBZ, will be constructed and added to the program to enhance coverage of the monitoring network. Existing FWBZ wells on the upgradient perimeter of the site will be used for water level information and to monitor quality of groundwater migrating on to the site. Second water-bearing zone (SWBZ) wells (i.e., within and/or below the BSU) are not included in the monitoring program because data from these wells are not representative of the shallow groundwater water discharging to the wetlands and/or bay, and because they are below the depth of the influence of the landfill. SWBZ wells will be abandoned as shown on Figure 2-1. Well destruction methods are described in Section 5.5.1 of the RAWP.

Table 2-1 identifies the monitoring well, water-bearing zone, proposed analytical methods, and well sampling frequency. A new Sampling and Analysis Plan (SAP) will be prepared for the long-term monitoring program for IR Site 2, in compliance with California Code of Regulations Title 27, Subchapter 3.  Water Monitoring, and Title 22 Chapter 14, Article 6.  The new SAP  will include a field sampling plan and quality assurance project plan along with a complete listing of analytes. As discussed further in Section 3.5, a well inventory will be performed to evaluate the condition of existing monitoring wells that will remain in the program. Corrective measures (such as redevelopment) will be performed as necessary. Well sampling frequency  will be quarterly for the first year for all newly installed wells. After 1 year of monitoring, the frequency may be reduced to semiannual based on criteria described below. Existing wells at the site will continue to be sampled semiannually. In the event that unusual variability is seen in the groundwater results, the frequency of sampling events will be evaluated and potentially increased.

Changes to the sampling frequency will be based on the trend analysis described in Section 2.1.3 and on the Analytical Comparison Flow Chart (Figure 2-2). Decreases to sampling frequency will be considered if:

• Current concentrations continue to show stable or decreasing trends compared to historical results

Increases to sampling frequency will be considered if:

• Concentration trends are found to be increasing (assumption is currently there are none trending upward)
• Concentration of a constituent is greater than the historical maximum in three successive samples
• Concentrations become significantly more variable than seen in the historic data set

Maximum sample frequency will be quarterly. Trends will be evaluated in the annual report based on the methodology described in Section 2.1.3. If an increasing trend is confirmed, the operations and maintenance contractor will notify the DON who will notify DTSC and the Regional Water Quality Control Board. A corrective action plan may be developed as necessary.

2.1.2        Proposed Analysis and Field Parameters

Proposed analytes include those listed in ROD Table 2-7. The list includes metals (arsenic, copper, and nickel), pesticides (aldrin, alpha chlordane, a-hexachlorocyclohexane [HCH], b-HCH, 4,4-dichlorodiphenyldichloroethene, 4,4-dichlorodiphenyltrichloroethane, dieldrin, endrin, gamma chlordane, heptachlor, and heptachlor epoxide), and the semivolatile organic compound/polynuclear aromatic hydrocarbon diethylexyl phthalate. The list was developed to meet the RAOs described in the ROD to protect beneficial uses of surface water in San Francisco

Bay from the potential for discharge of site groundwater (DON 2010). Table 2-1 lists the proposed analyses for each well. A complete list of analytes is included in Worksheet 15A of the Basewide Groundwater Monitoring Program SAP (SES-TECH 2011).

Field parameters including depth to groundwater, pH, conductivity, turbidity, temperature, dissolved oxygen, and oxidation reduction potential will be recorded during post-closure sampling events.

2.1.3        Data Analysis

Data from all shoreline and interior wells will be used for the trend analysis, as required by the ROD. Data from future analyses will be evaluated using historical data. New wells will be monitored for at least four quarters before evaluating trends.

Analytical results for each well will be evaluated using a graphical representation of the concentrations trends. A time-series plot will be generated for all wells for the analytes listed above. The plots will be examined to identify obvious trends. A minimum of two samples are required for the plots.

Non-detect observations will be treated as nil values (i.e., zeros) in the trend plots, which is consistent with the procedure used in the FS Report (Battelle and BBL 2008).

A visual, qualitative assessment will be performed on each time-series plot. Professional judgment will be used on the evaluation with an understanding of site conditions and considering inconsistent results and the possible effects of changes in detection limits. A minimum number of two data points are required for the plots.

Finally, a Mann-Kendall trend analysis will be performed for each well/analyte. The Mann- Kendall test will determine whether there is an upward, downward, or no trend. The Mann- Kendall test is not affected by large variations in analyte concentration. A minimum of four samples are required.

Groundwater data and trends need to be evaluated with the ROD criteria “to confirm that the contaminants remain within an acceptable range” (DON 2010). This operations  and maintenance plan proposes that so long as monitoring results do not trigger a response as defined in Section 2.1.1, the results are within an acceptable range.

2.2              COMPLIANCE PERIOD

The post-closure groundwater monitoring program (PCGMP) is configured as a remedial action monitoring program where the purpose of the monitoring is to assess the performance of the remedial action (Title 22 California Code of Regulations [CCR] Section 66264.100). Because the landfill will be in post-closure, the provision of Section 66264.100 for returning a facility to

detection monitoring (Section 66264.98) is not applicable. The performance of the PCGMP will be evaluated during the 5 year review process. The protectiveness of the groundwater  monitoring remedy along with the cover system and ICs will also be evaluated as part of 5-Year reviews required by EPA.

The first groundwater monitoring event is planned to occur in February 2014 based on the current landfill construction schedule. Groundwater monitoring data will be  reviewed  and results of the trend analyses will be reported coincident with the Basewide Groundwater Program Monitoring Reports and the scheduled 5-Year reviews. If concentration trend data are consistent with pre-closure data or exhibit declining concentrations, groundwater monitoring frequency may be reduced.

2.3              METHANE MONITORING

Methane monitoring will be conducted in accordance with Title 27 CCR, Section 20921 (a), to provide for the protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone and that methane levels in ambient air at the landfill perimeter is in compliance. Nine new monitoring probes will be installed around the landfill perimeter. Methane monitoring probe construction details are included in the 100% RD (Attachment 1 to the RAWP, sheet D-2). Probe locations are shown on sheets C-9 through C-11.

Methane monitoring will be conducted quarterly. Methane will be measured at each probe to evaluate subsurface concentrations. An exceedance of the criterion will be considered verified if concentrations are above 5 percent by volume for any two of three consecutive quarters. If methane concentrations are confirmed, the EPA and the San Francisco Bay Regional Water Quality Control Board will be promptly notified and the gas control system design re-evaluated.

In addition, barometric pressure, atmospheric temperatures, and general weather conditions will be reported at the time of gas collection. It is recommended by the Integrated Waste Management Board to collect landfill gas during barometric low pressures. Depending on the weather, this may be late in the morning or early in the afternoon.

In addition to monitoring the probes, perimeter  monitoring  locations  spaced  approximately 250 feet apart along the boundary of the landfill cover will be used to monitor ambient air at the point of compliance. Establishing the perimeter monitoring locations will be the responsibility  of the post-closure operations and maintenance contractor. Relevant standard operating procedures for landfill probe and surface perimeter monitoring are listed in Table 2-2 and included in Appendix B.

3.0          OPERATIONS AND MAINTENANCE FOR SITE STRUCTURES

The maintenance and monitoring will begin once the landfill soil cover construction is complete, anticipated to be in January 2014.

3.1              LANDFILL COVER SURFACE WATER MANAGEMENT SYSTEM

Existing drainage features include concrete channel, drainage piping and inlets, concrete outfall culverts, and earthen swales. Supplemental drainage in accordance with the final cover design will supplement existing drainage with a total of three turf reinforced mat channels. An existing concrete channel located on the eastern boundary of the site will be maintained throughout construction, and incorporated into the final drainage system.

Concrete channels and earthen swales with turf reinforcement mat collect and divert stormwater runoff. Concrete channels prevent erosion in areas where stormwater flow might accumulate. Proper and adequate inspections of the channels are required to prevent sediment build-up and failure of integrity. Inspections will be conducted annually before the rainy season and in the event of heavy precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or

0.25 inch or more within 1 hour. The inspection will be in accordance with  SOP  004  (Appendix B).

Concrete channels associated with the landfill cover drainage system will be visually inspected by walking the length of each channel. Special attention is required to verify sediment and  debris accumulation along the channels, cracking or fractures of the concrete structure, erosion at joints or along edges, and separation or deterioration of joints between concrete sections.

Drainage pipe cleanout ports and discharge piping will be visually inspected for damage or blockage. Drainage pipe outlets, discharge piping, and riser pipes will be cleared to allow free flow of water. The pipe outlets will also be inspected for blockage.

Nonconcrete drainage channels and swales will be inspected for erosion and proper functioning. Special attention should be directed to areas of no grass or patchy grass; ripples or swells in the soil caused by erosion; and settlement that inhibits or prohibits storm water flow.

Stormwater should flow around, off, and away from the landfill cover, with visual flow directly into the concrete channels or other established drainage routes. The perimeter of the cover  should be inspected to check that drainage flows around and away from the cover. The lip and entrance to concrete drainage channels will also be inspected to check for areas where storm water may not readily enter a channel. Inspection should be made by walking the cover perimeters and drainage channels.

3.2              WETLANDS CULVERT

The wetlands culvert hydraulically connects the North Pond to San Francisco Bay. The culvert will be inspected quarterly and in the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

3.3              GAS COLLECTION

The landfill passive gas collection system consists of a perimeter boundary conveyance trench filled with high permeability sandy soil surrounding a 4-inch perforated pipe. The pipes are connected to gas vents open to the atmosphere at the high end of the trenches.

The gas vent pipes will be visually inspected in accordance with SOP 009 (Appendix B) with extra attention centered on cracks or holes in the riser pipe; missing or damaged screens and end caps; and completely destroyed riser pipes. The gas collection system will be decommissioned if results of methane monitoring indicate that the system is not required based on results provided in annual monitoring reports or the 5-Year Reviews.

3.4              GAS PROBES

Existing soil gas probes located within the landfill boundary will be destroyed prior to multilayer soil cover installation. A network of nine probes will be installed around the perimeter of the landfill in order to establish a compliance plane. The probes will be monitored in accordance with SOP 008 (Appendix B).

3.5              MONITORING WELLS

Existing groundwater monitoring wells located within the landfill boundary will be protected during cover construction, where feasible. At the completion of the soil cover, all existing wells at the site will be inventoried. If an existing well is damaged, a replacement well screened at the same intervals will be installed within a 5-ft radius of the original well. If excess sedimentation  is noted, the wells will be redeveloped prior to sampling. Results of the well inventory will be reported in the RACR.

Routine monitoring well inspection and maintenance will be performed during sampling activities. The condition of the well vault lid, lid bolds, well cap, and well ID will be inspected and noted during each sampling event. Observations will be recorded on field monitoring well sampling forms. Well sampling methodology is included in the current Basewide Groundwater Monitoring Program SAP.

3.6              SETTLEMENT MONUMENTS

Four settlement monuments will be installed on the final cover system as shown in the100% RD (Attachment 1). Markers will be located where the depth of fill is the greatest and, therefore,

settlement potential is the highest. The monuments will be located so that settlement rate and trends can be monitored and assessed.

Monuments will be surveyed annually. Additionally, topographic surveys of the entire cover  will be conducted every 5 years to evaluate settlement. Annual surveying will include the following:

• Inspect each monument with respect to the surrounding surface of the cover, noting whether the station appears to be even with the surrounding surface, if it is in a depressed area, or if the area is higher than the surrounding surface.
• Record all observations.
• Survey and record the elevations of all four settlement monitoring stations to an accuracy of 0.01 foot vertically against the benchmark.

Survey data will be collected by a California licensed surveyor and the data will be included in the annual reports and 5-Year Review. If significant settlement is found (typically more than

0.75 foot), a professional engineer will evaluate the situation and the site operator/manager will be notified.

3.7              ACCESS ROADS

Access roads within IR Site 2 will be constructed to provide easy access to the site for monitoring and maintenance activities. Each road is approximately 24 feet wide, constructed with 12 inches of compacted aggregate over geotextile fabric (100% RD, Attachment 1 to the RAWP, sheet D-4). Inspection of the roads will be conducted in association with other monitoring and maintenance activities. Access road inspection will be in accordance with SOP 003 (Appendix B). Access road maintenance and repair will be conducted in accordance with SOP 006 (Appendix B).

3.8              SIGNAGE

Maintenance activities will include inspection of general information placards for the perimeter monitoring locations and signs for the public indicating trail use or restoration areas on a semiannual basis to ensure that they have not been damaged. Signs that have been altered, or affected by natural conditions, will be replaced.

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4.0        OPERATIONS AND MAINTENANCE FOR LANDFILL COVER SETTLEMENT, EROSION, AND VEGETATION

4.1              DIFFERENTIAL SETTLEMENT AND EROSION

Differential settlement is caused by decomposition and/or consolidation of subsurface material, which may result in adverse grade or depression on the surface of the landfill cover. Since the groundwater remedy is MNA and the cover design does not address groundwater, differential settlement that results in ponding of surface water or affects drainage controls may not require corrective action. Erosion is anticipated to be the most common problem that will affect the landfill cover. Erosion is typically noted at the base of long slopes where water tends to accumulate due to grading and drainage patterns. Settlement or effects to drainage controls that cause erosion and reduce the thickness of the cover will need to be corrected.

4.1.1        Detection

The IR Site 2 landfill cover will be visually inspected quarterly by the Operations Manager or his/her designee and annually by a registered civil engineer or engineering geologist as described in SOP 001 (Appendix B) to ensure the integrity. Landfill cover maintenance activities will include assessment of the landfill cover conditions, vegetation control and restoration, and animal control. The perimeter of the landfill will be evaluated for areas where surface water is impounded, excessive erosion is evident, or sloughing is apparent on a slope. Surface cracks more than 1 inch wide and 12 inches deep, or longer than 20 feet may indicate slope instability, settlement, or internal thermal activity of the landfill. The quarterly inspection will include looking for pieces of geonet material and waste items on the cover surface that indicate the geonet animal intrusion barrier has been breached by burrowing animals. Landfill cover maintenance and repairs will be conducted in accordance with SOP 007 (Appendix B).

4.1.2        Repairs

For areas where the thickness of the cover has been compromised and repair is warranted, the cover will be repaired by excavating and stockpiling the top cover soils in the impacted area down to the animal intrusion barrier, and regrading that portion of the cover with material comparable to that used in the original cover design. Animal burrows that breach the geonet layer will be filled with low-strength concrete slurry. Repairs will need to be inspected by a registered civil engineer.

New fill soils would be placed at the locations designated by the registered civil engineer and compacted to 6 inches below the unaffected surrounding cover and compacted to approximately

90 percent  of  the  Modified  Proctor  maximum  dry  density  with  water  content  within  0  to 4 percent of the modified optimum. The area will be re-covered with the removed topsoil cover material, compacted to approximately 85 percent, and scheduled for vegetation restoration.

The final grade will be graded with no more than a 1.5 percent slope and reseeded to match the undisturbed surrounding area. Major repair work will be inspected after completion by a registered engineer. The area will be surveyed after repair to obtain a record of the surface elevations of the repaired area.

4.2              VEGETATION

The landfill cover will be hydroseeded with a mixture identified in the Specifications (100% RD Attachment 1 to the RAWP, sheet C-12). Once established, the vegetative cover will appear similar to local natural open space areas. The vegetative cover will turn green during the rainy season and is expected to fade to brown during the dry season. Since the landfill cover will be hydroseeded, during the rainy season, supplemental irrigation is not anticipated. The cover vegetation will be inspected as described in SOP 005 (Appendix B).

Reseeding may be required to cover repairs, eroded areas, dead areas, and bald spots. Supplemental irrigation may be required to help establish reseeded areas. Water will be applied to re-seeded areas at a sufficient rate to ensure moist soil conditions to a minimum 1 inch depth, while preventing run-off.

4.3              DOCUMENTATION

Inspection of cover settlement should be recorded on the standardized form developed for this purpose provided in SOP 001, Multilayer Soil Cover Inspection.

Information on the form includes:

• Settlement location with regard to permanent markers
• Measurements of settlement or erosion

4.4              EXTRAORDINARY REPAIRS FOR THE COVER, BERM, AND SEAWALL

If a major seismic event occurs, the operation and maintenance contractor or designated alternate will initiate procedures to inspect all landfill systems, including settlement monuments. Initial repairs will be performed within 72 hours. For the purpose of this plan, a major seismic event is defined as one that equals or exceeds Intensity V (as defined by the Modified Mercalli Scale) at the site.

A major earthquake will require implementation of the following SOPs for inspection of all systems:

• SOP 001      Multilayer Soil Cover Inspection
• SOP 002      Landfill Gas Surface Monitoring
• SOP 003      Access Road Inspection
• SOP 004      Surface Water Management System Inspection and Maintenance
• SOP 005      Vegetative Cover Inspection and Maintenance
• SOP 006      Access Road Maintenance and Repair
• SOP 007      Multilayer Soil Cover Maintenance and Repair
• SOP 008      Landfill Gas Probe Monitoring
• SOP 009      Landfill Perimeter Gas Vent Inspection and Maintenance

If the seawall or the berm is damaged, it will be repaired. SOP 007 has procedures for repairing shallow and deep cracks, vertical cracks, cracks with vertical displacement, depressions, and sloughing/slope failure, which will be used for berm repair. For seawall repairs, inspection of  the damage by a qualified engineer will be required to design the repairs including procedures  for completing these repairs. These repairs could include relocating displaced riprap, and the use of gunite, concrete, or other similar materials to repair cracks and voids. Placement of additional riprap may also be necessary to repair and/or raise the seawall. Surface water that contacts the landfill waste as a result of a major seismic event will be confined and addressed. The PCGMP well network will also be inspected. Resampling of the monitoring wells will be evaluated. If inspection of the systems detects a noncompliance, the operations and maintenance contractor will notify the site management representative, who will notify the EPA, DTSC, and the Regional Water Quality Control Board.

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5.0        MONITORING AND MAINTENANCE OF WETLANDS MITIGATION AREAS

A baseline vegetation and wildlife survey that will occur immediately prior to construction will establish overall percent cover, document the composition of the vegetative community, and establish average daily use of the reference areas by shorebirds and waterfowl. Hydrologic success will also be considered.

5.1                SUCCESS CRITERIA FOR VEGETATION

During the vegetation survey, permanent 1-meter-square reference plots will be established on transects running through the entire mitigation sites. These transects and monitoring plots will  be assessed on a yearly basis using the same criteria as those used to establish baseline conditions. The survey will document mortality, weed invasion, and rate of  colonization. Success criteria for vegetation are as follows:

• In the tidal marsh area, existing conditions show a pickleweed community cover density of approximately 75 to 100 percent in the wetland areas that will be affected. The 5-year monitoring goal is to attain this same density and the same plant community composition as under existing conditions.  The Year 1 goal  is to show   10 percent pickleweed cover, increasing to 25 percent at Year 2, 50 percent in Year 3, and 75 percent in Year 4. If these goals are not met, the restored area will be assessed to determine if site conditions are not conducive to plant growth. If needed,  corrective actions including planting pickleweed plugs taken from a nearby location will be implemented. Corrective actions would be implemented in Year 2  and beyond if needed.
  • There is no invasive cordgrass or pepperweed in the tidal marsh at this time. Success criteria require that this state be attained and maintained in the mitigation area for the duration of the 5-year monitoring period.
  • In the open water/mudflat habitat, there will be little to no vegetation in the low- marsh (mudflat) areas, and the mid- and high-marsh areas are projected to be vegetated almost exclusively with pickleweed to reflect current conditions. Success criteria are such that the mudflat area will have less than 10 percent vegetation below

-0.2 feet NGVD29, and this vegetation will be a minimum of 80 percent pickleweed. Above -0.2 feet, pickleweed will increase in density to 75 to 100 percent over 5 years. The pickleweed fringe will be maintained by work crews who will remove cordgrass and pepperweed by hand or other approved method to ensure no encroachment of these weed species.

• If success criteria are not met, corrective action will be taken. For vegetation establishment, this means that pickleweed plugs will be planted in quantities needed to attain goals if goals are not met at Years 2 and beyond. For invasive species, this means that all invasive cordgrass or pepperweed will be removed on a yearly basis, on a date preceding normal seedset.

5.2              SUCCESS CRITERIA FOR WILDLIFE

For wildlife, bird counts will occur at the appropriate time of year and will occur over successive tidal cycles. Bird usage of the tidal pond, the mudflats, and freshwater pond will be documented and used to create the baseline conditions against which to measure success. Success criteria for bird use of the mitigation sites is such that bird use would increase incrementally over a 5-year period as the invertebrate community in the substrate increased, and would match the rate of bird use in the reference (adjacent) areas at the end of the 5-year monitoring period.

5.3                SUCCESS CRITERIA FOR HYDROLOGY

Although a detailed hydrologic study of the site has not been completed, success criteria are such that hydrological features found at the reference areas (meaning wetlands directly adjacent to the mitigation areas) will be found in the mitigation areas as well. In the tidal areas, this means that the constructed wetlands will be tidally inundated and drained on a diurnal basis on the same intervals as the reference area.

In the open water/mudflat/pickleweed freshwater areas near the South Pond, the mitigation wetlands will have been graded to the same elevation as the reference habitat; therefore, success criteria are such that surface water levels and mudflats will mimic conditions found in the surrounding areas that have the same surface elevation. In general, this means that surface water levels will be highest in the period from December through April, and will diminish thereafter.  In dry years, the freshwater open water area and mudflat may dry completely in late summer.

Hydrologic features of the site will not be manipulated during construction; however, if after project implementation hydrological features do not appear to be operating as planned, a hydrologic assessment of the area will be performed by a hydrologist and recommendations for further grading will be made.

6.0        SCHEDULE FOR ROUTINE OPERATIONS AND MAINTENANCE ACTIVITIES

The proposed schedule is presented on Figure 6-1. The schedule assumes that construction of  the cover will be complete in January 2014. Adjustments to the schedule may be necessary if there are changes to the construction schedule. Time frames for activities are approximate and correspond with the frequency of tasks discussed in subsequent sections. Severe damage, catastrophic events, and some minor items, such as watering of the cover vegetation, have not been included since these events do not occur on a regular schedule.

6.1              SCHEDULED INSPECTION

IR Site 2 will be inspected quarterly and after major weather (any rain event with 0.5 inch of rain occurring in a 24-hour period) or seismic events (Modified Mercalli Intensity V) for damage, and maintenance will be performed as necessary. Inundation due to gradual sea level rise will be monitored and reported as part of the quarterly inspections. Inspection items and corrective actions are described in the following sections. If damage to the cover system is observed during any post-closure inspection, the cause of the damage will be investigated and documented in the inspection log.

6.1.1        Cover Settlement

Inspection of the landfill cover condition and the slopes of the landfill will occur on a quarterly basis and after significant events.

6.1.2        Geonet Animal Intrusion Barrier

The quarterly inspection will include looking for pieces of geonet material and waste items on the cover surface that indicate the geonet animal intrusion barrier has been breached by burrowing animals.

6.1.3        Methane Monitoring

Methane monitoring will be conducted quarterly for the first 5 years following the completion of the cover construction, and will be re-evaluated during the 5-year review. Methane monitoring will consist of both soil gas probe monitoring and ambient air monitoring at the perimeter of the landfill.

6.1.4        Wetlands Culvert

The culvert connecting San Francisco Bay with the IR Site 2 wetlands area will be inspected on a quarterly basis and after significant events. The Navy will make necessary repairs, modifications or replacement to maintain tidal circulation as recommended by the structural assessment of the culvert if warranted. In the potential event that tidal circulation is inhibited or blocked due to culvert failure, the Navy will restore tidal circulation within 7 days.

6.1.5        Site Structures

The following structures shall be inspected semiannually:

• Signage
• Landfill perimeter gas vents
• Settlement monuments

Settlement monuments will be surveyed annually. Access roads and surface water management structures will be inspected annually before the rainy season and in the event of heavy precipitation resulting in either 0.50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour.

6.2              FIELD DOCUMENTATION

SOPs have been included in Appendix B with documentation forms for field recording of scheduled routine maintenance and monitoring data collection.

6.2.1        Document Corrections

Changes or corrections on any project documentation will be made by crossing out the erroneous item with a single line and initialing (by the person performing the correction) and dating the correction. The original item, although erroneous, must remain legible beneath the crossed-out line. The new information should be written clearly above the crossed-out item.

7.0    REPORT REQUIREMENTS AND DATA MANAGEMENT

Reporting will occur as a part of this Plan. Reporting will consist of submitting annual reports to the EPA, DTSC, and Regional Water Quality Control Board. The inspection and monitoring program established will be evaluated annually by an independent, qualified engineer registered in California, The inspection will include review of the condition of all surface improvements, drainage facilities, erosion control facilities, vegetative cover, gas control facilities, and monitoring facilities. Specifically, the annual report will present:

• Survey data
• Site inspection data:

–        Condition of vegetation

–        Erosion

–        Cracking

–        Seepage

–        Slope stability

–        Subsidence

–        Settlement

–        Condition of run-on and run-off control systems

–        Condition of surveyed benchmarks

• Groundwater monitoring system and analytical results for samples collected in the previous semiannual and current annual sampling events
  • Perimeter landfill gas probe and ambient air monitoring results
  • Trends analyses results

Initially (for the first year at a minimum), stand-alone reports will be submitted. A 5-year review will be completed for the site at the time of the basewide 5-year review cycle in 2017.

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8.0    POST-CLOSURE FINANCIAL ASSURANCE

A detailed cost estimate for annual operating, maintenance, monitoring, and reporting is included in Appendix C. The estimated annual cost for anticipated activities is $101,715 in 2012 dollars. The DON is fiscally responsible for post-closure related costs until such time as the site is transferred to the Office of Veteran Affairs.

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9.0    REFERENCES

Alameda Agencies (Department of Toxic Substance Control, U.S. Environmental Protection Agency, and Regional Water Quality Control Board), 2013. Installation Restoration Site 2, Alameda Point, Long-Term Groundwater Monitoring Evaluation and Recommendations. Email Correspondence dated May 29, 2013, sent to the DON Alameda Lead RPM, William McGinnis

AMEC (AMEC Earth & Environmental, Inc.). 2010. Draft 2009 Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. March.

—————. 2011. Final 2010 Annual Groundwater Monitoring  Report,  Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. June.

Battelle and BBL (Blasland, Bouck, and Lee, Inc.). 2006. Final Remedial Investigation Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. Prepared for Base Realignment and Closure, Program Management Office West, San Diego,  CA. June 23.

—————. 2008. Final Feasibility Study Report IR Site 2, West Beach Landfill and Wetlands Alameda Point, California. October.

DON (United  States Department of the Navy).   2010.   Final Record of Decision (ROD) for    IR Site 2, Former Naval Air Station Alameda, California. August.

ITSI (Innovative Technical Solutions, Inc.). 2008. Final Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. November.

KCH (CH2M HILL Kleinfelder, A Joint Venture). 2011. Preliminary Draft Remedial Design Report, Installation Restoration Site 2, Alameda Point, Alameda, California. December.

SES-TECH, 2011. Final Alameda Point Basewide Groundwater Monitoring Program Work  Plan, Alameda Point, Alameda, California. September.

SES-TECH. 2012. Draft Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California (December).

TtEMI (Tetra Tech EM, Inc.). 2009. Draft 2008 Final Annual Groundwater Monitoring Report, Basewide Groundwater Monitoring Program, Alameda Point, Alameda, California. March.

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TABLES

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Notes:

^a – Well to be used for water level measurements only.

^b – Screen intervals for new wells are estimated. Final well completion details will be reported in the RACR.

^c – Estimated depth from surface of soil cover. Wells within the cover will be resurveyed and revised well screen intervals will be reported in the RACR.

Abbreviations and Acronyms:

bgs – below ground surface ft – feet

FWBZ – first water-bearing zone

Q/SA – quarterly for first year after installation; semiannual thereafter SA – semiannual

TABLE 2-2

STANDARD OPERATING PROCEDURES FOR POST-CLOSURE MONITORING AND MAINTENANCE

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FIGURES

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FIGURE 2-2

ANALYTICAL COMPARISON FLOW CHART

APPENDIX A

LONG-TERM GROUNDWATER MONITORING EVALUATION

(Alameda Agencies, 2013)

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Installation Restoration Site 2, Alameda Point

Long-Term Groundwater Monitoring Evaluation and Recommendations

The Purpose of Long-Term Monitoring-Landfill: Detection of any anthropogenic compounds beyond the landfill footprint.

The Purpose of Long-Term Monitoring-Corrective Action Area: 1) Detection of contaminants discharging above applicable regulatory levels to surface water bodies. 2) To meet the needs of a Monitored Natural Attenuation (MNA) remedy.

Definition of Uppermost Aquifer: The uppermost aquifer is defined as the first water- bearing zone (FWBZ) and occurs from the groundwater surface to the low-permeability Bay sediment Unit (BSU). The FWBZ is comprised of artificial fill and landfill waste.

Two intervals are monitored within the FWBZ. “A” wells monitor groundwater at the base of the landfill waste, and “E” wells monitor groundwater just above the BSU. The FWBZ discharges to San Francisco Bay (the Bay). The shallowest interval also discharges to the wetlands (i.e., North and South Ponds).

Groundwater flow directions: Groundwater flow directions in the FWBZ are away from the center of the landfill towards the wetlands and the Bay. In general, a groundwater mound has been found to occur in the vicinity of MW-38A. This feature is particularly pronounced in the 2004 groundwater elevation map, but persists in following years up to the most recent monitoring period. Flow directions are to the northwest, west, west southwest, and south away from this area. Vertical gradients are generally downward from the upper FWBZ to the lower FWBZ. The results of a tidal influence study performed in 2004 show that wells along the shoreline are tidally influenced. Tidal efficiencies are typically greater in the lower FWBZ than in the upper FWBZ.

Historical Detections of COCs: In general, pesticides, volatile organic compounds, (VOCs) and to a lesser extent, metals have been detected above applicable regulatory levels in monitoring wells screened within the uppermost interval of the FWBZ (“A” wells). Higher concentrations of metals and occasionally pesticides have been detected in monitoring wells screened within the lower interval of the FWBZ (“E” wells). However, it is noted that monitoring for organic compounds has not been performed for “E” wells in recent years.

Adequacy of Monitoring Network:

Based on historical flow directions and contaminant distribution in the FWBZ, additional wells are recommended as follows:

1. Well 17A should be abandoned and replaced with two new well clusters (two “A” and two “E” wells), equally spaced between well clusters MW-16A/E and MW- 18A/E. This will provide a more robust network on the southern landfill perimeter to monitor COCs that may be migrating south and southwestward toward the Bay.
2. A new well cluster (“A” and “E” wells) midway between well clusters MW-23A/E and MW-24A/E is needed to provide a more robust network on the western

landfill perimeter to monitor COCs that may be migrating west and northwestward toward the Bay.

1. A new well cluster (“A” and “E” wells) midway between well clusters MW-36A/E and MW-37A/E is needed to provide a more robust network on the northeastern edge of the North Pond to monitor COCs that may be migrating west and southwesterly toward the North Pond. With the addition of this well cluster, monitoring well cluster MW-19A/E is no longer needed and may be abandoned.

Because monitoring is intended to detect migration of COCs into surface water bodies, all monitoring wells screened within or below the Bay Mud (i.e., “B” and “C” wells) are no longer needed and may be abandoned.

Upgradient monitoring wells should be retained for water level measurements to provide continued evaluation of flow directions and gradients.

Sampling and Analysis Plan (SAP): A new SAP must be prepared to provide monitoring requirements for IR Site 2 in compliance with California Code of Regulations Title 27, Subchapter 3. Water Monitoring, and Title 22 Chapter 14, Article 6.

The SAP should include the objectives of sampling, including both detection monitoring and MNA.

A well inventory should be performed to evaluate current condition of monitoring wells that will remain in the program. The construction details should be provided and the current conditions of the wells should be evaluated. Corrective measures (such as redevelopment) should be proposed if deemed necessary.

Compounds of Interest and COCs:

Metals, pesticides, and VOCs should be monitored as follows. Wells along the shoreline should be monitored for pesticides and metals. Interior wells (along the landfill/wetland boundary) should be monitored for metals, pesticides, and VOCs. Shoreline well MW-24A should also be analyzed for VOCs due to historical detections. VOCs are the most mobile of these compounds and may affect the transport of pesticides. VOCs should be monitored to evaluate trends that would indicate plume movement or expansion.

Frequency of Monitoring:

Newly installed monitoring wells should be monitored quarterly for at least one year after which monitoring may be reduced to semiannual pending regulatory notification and approval. Older monitoring wells should be sampled semiannually. Changes to monitoring frequency may be considered during future Five-Year Reviews of remedial actions for Alameda Point. There must be concurrence by Federal Facility Agreement signatories for any changes in monitoring frequency.

APPENDIX B

STANDARD OPERATING PROCEDURES

(on CD only)

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SOP 001

MULTILAYER SOIL COVER INSPECTION

1.0 GENERAL

The multilayer soil cover should remain intact, free of major cracking (defined as cracks 1-inches or wider, deeper than 12-inches, and longer than 20-feet), erosion (deeper than 12-inches) and surface depressions that could cause ponding. The vegetation inspection is described in Standard Operating Procedure (SOP) 005 (Vegetation Cover Inspection and Maintenance).

2.0 TASK DESCRIPTION

The task covered by this SOP is the visual inspection of the cover which guides maintenance and repair planning and implementation. Regular visual inspections of the cover shall be performed quarterly by the Operations Manager or his designee, and annually by a registered civil engineer.

3.0 REQUIRED MATERIALS

The following items are needed to perform a visual inspection:

• A copy of the landfill map (attached)
• Form SOP 001 (Cover Inspection Form)
• Survey stakes
• Measuring tape
• Clipboard
• Pen with indelible ink
• Camera

4.0   TASK PERFORMANCE

Record inspection observations on Form SOP 001. All areas exhibiting the conditions listed below shall be recorded on the form and flagged or staked in the field. The completed form shall be given to the Operations Manager, who will then refer to SOP 007 (Multilayer Soil Cover Maintenance and Repair). The following are guidelines for conditions to be observed and recorded:

• Eroded areas (erosion deeper than 6-inches)
• Landfill cover soil conditions such as sloughing and sliding
• Cracks, fissures, or other features that may potentially allow gas migration or surface water infiltration. Cracks in the cover longer than 20 feet and deeper than 12 inches and wider than 1 inches shall be examined and evaluated by a registered civil engineer.
• Areas of subsidence, depressions, or topography where ponding may occur
• The state of surface water management facilities, failure or malfunction of which could impact cover performance
• Culvert integrity and blockage which would impede flow to wetlands

In addition to regular visual inspections, the landfill cover shall be inspected as soon as it is accessible following the events listed below:

• Significant rainfall (as defined in SOP 004 – Surface Water Management System Inspection). Note in particular erosion, or areas of slope deformation
• Major earthquakes. Note in particular cracks, deformation, or zones of slope instability.
• Failure of the surface water management control system. Note in particular erosion, wet or saturated cover soils, ponding, or areas where there is a potential for increased infiltration.
• An emergency as defined in the Emergency Response Plan

If at any time a condition of cover distress is observed, it shall immediately be reported to the Operations Manager.

FORM SOP 001 COVER INSPECTION

Type of Inspection:

Quarterly Semiannual

Inspector:     Name:                          

Affiliation:                      

Date:                                                        Time                                     Weather Condition:                                 

OBSERVATION TYPE AND DETAILED DESCRIPTION:

Erosion                  Sloughing/Sliding                 Cracks/Fissures                Subsidence/Depression                   Other

LOCATION OF OBSERVATION (Show on map):                                                                         

ACTION TAKEN:                                                                                                                            

REMARKS:                                                                                                                                       

Signature

Operations Manager                                                                                                      Date                                     

Site Manager

(for annual inspection only)                                                                                         Date                                     

STANDARD OPERATING PROCEDURE

Last Revised 11/29/11

SOP 104-4

SOP 002

LANDFILL SURFACE GAS MONITORING

1.0 GENERAL

Landfill surface gas monitoring is performed to evaluate the effectiveness of the landfill cover and the passive gas control system in controlling the movement of methane through the cover. The objective of this Standard Operating Procedure (SOP) is to monitor ambient air at 250 foot intervals around the perimeter of the landfill in order to identify specific locations or areas of the landfill surface with elevated emission rates greater than 50 ppmv. Selection and permanently identifying the monitoring stations will be the responsibility of the Operations and Maintenance contractor.

2.0 TASK DESCRIPTION

Surface gas monitoring will be conducted quarterly during landfill gas probe monitoring activities (SOP 008). Surface gas monitoring will be conducted buy a field technician using hand held instruments.

3.0 REQUIRED MATERIALS

The following equipment and supplies are needed:

• Methane monitoring instrument capable of measuring methane in the PPM range (such as the GasTech Innova or equivalent)
  • Landfill map with monitoring stations

• Clipboard

• Portable wind speed (anemometer) meter

• Thermometer

• Pen with indelible ink

• Safety vest (orange)

• Surface Emission Data Sheet (Form SOP 002-1)

Note: Other safety-related equipment may be required when performing emissions monitoring.

4.0    TASK PERFORMANCE

4.1                  EQUIPMENT STARTUP PROCEDURES

Calibrate instruments in accordance with manufacturer specifications.

4.2                  MONITORING CONDITIONS

The average wind speed suitable for surface gas monitoring is less than 10 miles per hour (mph). Monitoring is terminated when the average wind speed exceeds 10 mph or the instantaneous wind speed exceeds 15 mph. Average wind speed is determined on 15 minute intervals. Suface gas monitoring is conducted when the landfill is dry and no rain is falling. The landfill is considered dry when there has been no rain (>.10 inches) for the preceding 72 hours prior to monitoring. Any delays due to excessive wind speeds, rainfall, construction activities, etc., should be noted.

4.3                  SAMPLING PROCEDURES

At each monitoring locations, the field technician record the temperature, and the average and maximum wind speed. The methane monitoring instrument will be held approximately 3 inches from the landfill surface for 2 to 5 minutes or until methane concentrations (if any) is stabilize. Measurements will be recorded on the Surface Emissions Data Sheet (Form SOP 002-1).

For readings of 50 ppmv or greater description of the suspected cause of the exceedance (i.e., cracking, thin cover, exposed waste) will be recorded on the form.

4.4    EXCEEDANCE ACTION

If a location exceeds 50 ppmv, the location will reported to the Operations Manager for appropriate actions including possible cover repair or modifications to the passive gas collection system. Within 1 day after the repair, the area will be re-monitored to determine if additional remediation is required.

4.5                  REPORTING REQUIREMENTS

In the event of an exceedance, report of findings will be submitted to the DON six weeks after completion of the survey.

Form SOP 002-1 SURFACE EMISSIONS DATA SHEET

Date                                                                   Technician            Initial Calibrated   

Instrument Serial No.:                                          Final Calibrated      

Notes:

SOP 003

ACCESS ROAD INSPECTION

1.0 GENERAL

The access roads provide all-weather access to the landfill. Each road is approximately 24 feet wide, constructed with 12 inches of compacted aggregate over geotextile fabric.

2.0 TASK DESCRIPTION

This SOP addresses the visual inspection of the access roads to note conditions that may require road maintenance and repair. Access Roads will be inspected annually by a registered civil engineer before the rainy season and in the event of heavy precipitation resulting in either .50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour.

3.0 REQUIRED MATERIALS

The following items are needed for a visual inspection:

• Copy of the access road system map
• Copy of the Access Road Inspection Form (Form SOP 003-1)
• Pen with indelible ink
• Clipboard
• Survey stakes
• Ribbons and markers
• Measuring tape
• Camera

4.0 TASK PERFORMANCE

Inspection observations are recorded on Form SOP 003-1. Inspection results will be evaluated against SOP 006 (Access Road Maintenance and Repair). The following are guidelines for conditions to be observed and recorded:

• Adverse grades (that may impede drainage)
• Cracks wider than ½ inch, and longer than 50 feet (cracks wider than 2 inches and deeper than 12 inches and longer than 50 feet shall be examined by a registered civil engineer)
• Localized depressions (that may cause ponding)

• Sloughing
• Excessive erosion (greater and 3 inches) of road surface
• Loss or deterioration of surfacing
• Debris (soil or vegetation) from upgradient slope
• Damaged or missing road signs
• Damaged drainage structures (see SOP 004 – Surface Water Management System Inspection and Maintenance).
  • Deformation of the upgradient or downgradient slope that affects road use (see SOP 001

– Cover Inspection).

• Extensive cracking (deeper than 6 inches)
• Depressions (causing ponding)
• Deep erosion (deeper than 6 inches)
• Adjacent slope instability
• Exposure of a geotextile material or absence of granular road base material.

A registered civil engineer shall establish the need for additional observations, including but not limited to:

• Test pits
• Test trenches
• Settlement or deformation measurements

In addition to annual inspections, access roads shall be inspected after the following:

• Significant rainfall (as defined in 004 – Surface Water Management System Inspection). Note in particular erosion.
• Major earthquakes. Note in particular cracks, deformation, or zones of actual or incipient slope instability.
• Failure of the surface water management control system. Note in particular erosion, wet or saturated soils, ponding, or areas where there is a potential for increased infiltration.
• An emergency as defined in the Emergency Response Plan.

FORM SOP 003-1

ACCESS ROAD INSPECTION FORM

Page 1 of 2

Type of Inspection:

Annual

Other           Inspector:  Name:                           

Affiliation:                    

Date:                                                       Time                                                        Weather                                                             

* Use following codes for observed conditions: 1-adverse grades; 2-cracking; 3-depression; 4-sloughing; 5-erosion; 6-loss of surfacing; 7-debris form upgradient slope; 8-damaged/missing road signs;

9-damaged drainage structures; 10-slope deformation.

Signatures

Operations Manager                                                                                                         Date

Registered Civil Engineer

(for annual inspection only)                                                                                         Date                                     

SOP 004

SURFACE WATER MANAGEMENT SYSTEM INSPECTION AND MAINTENANCE

1.0  GENERAL

The inspection and maintenance of the Surface Water Management (SWM) system are described in this Standard Operating Procedure (SOP). The SWM system provides for surface water drainage, and controls infiltration into and erosion of the landfill cover. SWM components include the concrete channel and three turf reinforced mat channels.

2.0  TASK DESCRIPTION

An annual survey of the SWM system will be conducted prior to the rainy season. The survey will be performed by a registered professional civil engineer or other qualified professional in addition to site personnel. In the event of heavy precipitation resulting in either .50 inch or more of rainfall within 24 hours or 0.25 inch or more within 1 hour, a site inspection will be conducted immediately following the storm event.

3.0   TASK PERFORMANCE

As part of the annual survey, complete Form SOP 004-1. Form SOP 004-2 should be completed during the routine inspections and inspections performed after rain events.

Any breakdown and subsequent repair of the SWM system shall be documented on Form SOP 004-3 and reported to the Operations Manager immediately. Below is a list of procedures associated with SWM system maintenance:

1. Concrete Channel

• Clear debris or vegetation having a stem greater than 1 inch in diameter
• Repair cracks and grout as required to maintain integrity of concrete

1. Turf Reinforced Mats

• Clear debris or other drainage obstructions
• Repair or remove and replace matting as needed due to base soil loss or washouts
• Replace infill as needed to maintain proper grades and/or soil loss
• Re seed to maintain vegetation cover

1. Drop Inlets

• Adjust inlet riser to remain flush with top of geocell
• Repair gaps between pipe and surface completion

1. Sediment Traps/Erosion Control

• Remove silt buildup greater than 6 inches
• Repair as necessary
• Follow maintenance procedures outlined in the SWPPP for the BMPs for Erosion and Sediment Control

1. Discharge Outlets

• Clear debris, vegetation, and other obstructions
• Repair or replace discharge piping or structure as necessary

1. Drainage Pipe

• Clear vegetation and debris
• Remove silt when buildup exceeds 6 inches
• Remove and replace pipe if the integrity of the pipe is impacted

1. Drainage Inlet

• Clean and regrout areas of cracking or spalling
• Remove debris and silt buildup inside box and weep holes
• Clear debris or vegetation from debris rack or grate
• Remove silt buildup greater than 6 inches

FORM SOP 004-1

Surface Water Management System Annual Inspection Checklist

Page 1 of 2

Inspection Performed by:                                                                           Date:                              

Comments                                                                                                                                         

Surface Water Management System Inspection Checklist

Inspection Performed by:                                                                           Date:                              

Comments:                                                                                                                                         

STORM WATER/EROSION CONTROL BREAKDOWN AND REPAIRS FORM

Date:                                                                           Inspector:                                                       

Observations                                                                           Personnel Notified:                            

Type of Breakdown/Failure                                                                                                              

Location (show on map)                                                                                                                    

Action Requested                                                                                                                               

Action Taken                                                                                                                                     

Comments                                                                                                                                          

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

Final Construction As-Built Report,

SOP 005 VEGETATIVE COVER

INSPECTION AND MAINTENANCE

1.0  GENERAL

The vegetative cover provides moisture penetration control, erosion control, and visual enhancement across the landfill slopes and top deck. The vegetative cover selected to provide these results is comprised of California native plants.

Once established the vegetative cover will appear similar to local natural open space areas. The vegetative cover will turn green during the rainy season and is expected to fade to brown during the dry season.

2.0   TASK DESCRIPTION

The vegetative cover shall be visually inspected at the intervals listed in the Post Closure Operations, Maintenance and Monitoring Plan. The frequency of inspection and maintenance may be varied by the Operations Manager to respond to seasonal variations in precipitation and vegetation establishment and growth.

In addition to the landscaping covering the refuse, some areas along the periphery contain native growth areas and wetland that will require inspection which must be inspected and cut back as necessary.

3.0  REQUIRED MATERIALS

The following items are necessary:

• Copy of the Wetlands Mitigation Plan (attachment 7- of the Remedial Action Work Plan)
• Copy of Vegetative Cover Inspection Form (Form SOP 005-1)
• Copy of Landfill Map

4.0  TASK PERFORMANCE

Using the following as guidance record observations, on Form SOP 005-1(Vegetative Cover Inspection Form):

• Weed and fire control – Observe growth of nuisance weeds and plant materials after the end of the rainy season. Nuisance weeds include Mustard, Tumbleweed, Tree Tobacco,

Castor Bean, Pompas Grass, Eucalyptus, Elm, and Bermuda Grass. Other plants that may naturalize should be verified for removal when they occur.

• Reseeding and Soil fertilization program – Determine locations of poor growth for soil analysis in late summer. Evaluate the establishment rate and appearance of the vegetation. Determine areas that require reseeding.
• Rodent control – Evaluate visible signs of burrowing rodents during routine inspections around the site.
• Erosion Control – check for soil erosion

5.0   MAINTENANCE

In cases where an inspection establishes a deficiency in the vegetation that could be repaired by immediate action, such action shall be taken in discussion with the Operations Manager.

Inspections recorded on Form SOP 005-1 shall be considered by the Operations Manager. He shall issue plans and instructions for ongoing vegetation maintenance or replacement. Examples are:

• Weed removal – Remove by hand at first signs of growth. If Mustard and Thistle has spread, removal options include mowing. Foliage removal is another option for Mustard.
• Reseeding and soil fertilization program – Reseed areas of poor growth in late fall or early winter using seed mix specification in Attachment 1 sheet C-12.
• Soil Erosion – Repair per SOP 004 (Surface Water Management System Inspection, Surveillance, and Maintenance Activities.
  • After the end of the rainy season, and after grasses have produced seed, the crown of the landfill will be mowed to control weeds. Other areas of the landscaped portion of the site will be weeded or mowed if practical.
  • Until coverage of seed mixes approaches design values, probably in the second or third growing season post mechanical completion, a landscape consultant will be used seasonally to recommend mixes, amendments, and reseeding techniques.

FORM SOP 005-1 VEGETATIVE COVER INSPECTION FORM

AREA:                                                                        DATE AND TIME:                                     

BOUNDARY ACCESS ROADS:                              INSPECTOR:                                               

GENERAL SOIL CONDITION: WET          

DRY           

WEATHER:                                 

SOP 006 ACCESS ROAD

MAINTENANCE AND REPAIR

1.0   GENERAL

Standard Operating Procedure (SOP) 003 (Access Road Inspection) describes the access and road inspection procedures. The inspection findings are documented on Form SOP 003-1. Based on that information, the Operations Manager will implement maintenance and repair activities as described in this SOP.

2.0  TASK DESCRIPTION

Maintenance includes ongoing, routine, or regular activities necessary to keep the roads in a safe and functional state and protect the cover design.

Repair includes area specific work that may be required from time to time to restore or improve the state or functioning of the roads and the cover.

3.0   TASK PERFORMANCE

The Operations Manager shall review relevant inspection observations and monitoring data, and shall establish the need for and extent of maintenance and repair. Repairs will be done in accordance with RD Attachment 1specifications. The Operations Manager may consult with licensed/registered specialists to compile alternate repair plans or specifications.

4.0   GUIDELINES FOR MAINTENANCE AND REPAIR

Maintenance and repair procedures vary depending on existing conditions such as cracks, adverse grades, depressions, erosion gullies, sloughing or slope failures. Maintenance and repair of the access roads shall be documented on Form SOP 006-1.

1. Cracks

• Cracks wider than ½-inch and longer than 20-feet shall be repaired. Surface cracks shall be evaluated for evidence of vertical displacement across the crack and depth of crack. If crack extends to full depth of road base, the geotextile layer separating the road base and underlying layer may have to be penetrated or removed to evaluate depth of crack. The location of cracks shall be mapped and documented. An up-to-date crack location map shall be maintained to identify areas of chronic cracking.
• Minor cracks less than 6 inches in depth shall be scarified to the depth of crack and recompacted.
• Cracks deeper than 6-inches and with no vertical displacement across the cracks shall be repaired by excavating a 2 to 3 foot wide zone to the depth of crack and replacing the excavated layer with aggregate base to RD Attachment 1 specifications.
• Major cracks (wider than 1 inches and deeper than 1 foot and longer than 20 feet), or cracks with vertical displacement across the crack may be indicative of slope deformation/sliding and shall be first evaluated by a registered civil engineer prior to implementing repair. The repair may include removal and recompaction of a relatively large section of the roads and adjacent slope to stabilize the area. (See also Section 4.0 of SOP 007 – Multilayer Cover Maintenance and Repair).
• In areas of chronic cracking (where cracks reappear on a regular basis) more extensive crack repair/control measures should be considered. Such measures may include but are not limited to excavating a wide area straddling the crack, constructing a reinforced foundation consisting of one or more layers of geogrid below the barrier.
• The designs for repair of major cracks, slope deformations/sliding and areas of chronic cracking as described above shall be prepared by a registered civil engineer. The engineer will develop a number of appropriate standard designs to repair such cracks and will recommend or approve use of same to repair the subject cracks.

1. Surface Depressions:

• Localized minor surface depressions, less than 1 foot deep, shall be repaired by backfilling with the compacted aggregate base per RD attachment 1 specifications.
  • Large surface depressions, greater than 1-foot deep, shall be evaluated to determine if the barrier layer below this road subgrade has been impacted. A test pit may be excavated, geotextile removed, and the animal intrusion barrier inspected to determine evidence of excessive cracking or saturation. If the cover layer has been impacted, repair of the depression will include excavation of the area to the subgrade layer, preparation of cover, and replacement and reconstruction of the multilayered cover system to RD Attachment 1 specifications. If the compacted layer beneath the animal intrusion barrier is found to be intact, repair of the depression area shall include backfilling and compacting of the subgrade repair of geotextile fabric compaction of the aggregate base. At the completion of this repair, a survey of the repaired area shall be performed and recorded in the Record Drawings.

1. Erosion Damage:

• Erosion channels penetrating only the road surface materials shall be repaired by removal of material from the channel sides and bottom to competent material surface, and replacing with compacted aggregate The backfilling and compaction shall be performed

in maximum 6-inch thick layers using the appropriate compactors for the size of the area being worked.

• Deep erosion channels extending to the geotextile and cover layer shall be repaired by excavation and replacement of the different layers of materials used in the original access road section. The cover layer, if affected, shall be excavated to its full depth and replaced with compacted material within design specifications.

1. When repairing the layered cover system below access roads, each layer shall be tied into existing layers of the corresponding material and constructed to project specifications. Replacement geotextile or geonet shall be overlapped a minimum of 24 inches over existing geotextile.

1. Adverse access road grades will be restored by placement of additional subgrade material and replacement of roads surfacing material over the reconstructed part.

FORM SOP 006-1 ACCESS ROAD REPAIR RECORD

Inspector                                                                                          Date:                                         Time:                                 

DEFICIENCY TYPE AND DETAILED DESCRIPTION:                                                              

Cracking                Depressions                   Erosion                  Sloughing                  Adverse Grades                 Other

LOCATION OF REPAIR ACTIVITY (Show on map):                                                                   

ACTION TAKEN (refer to repair detail or design drawings, as appropriate):                                 

ATTACHMENTS (As-Built drawings, compaction reports, etc., as appropriate):                          

REMARKS:                                                                                                                                       

Signature

Operations Manager                                                                                                         Date

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

SOP 007

MULTILAYER SOIL COVER MAINTENANCE AND REPAIR

1.0   GENERAL

The landfill multilayer soil cover consists of a minimum 6 inch compacted soil layer, an animal intrusion (geonet) barrier, an 18 inch compacted soil cover, and an 6 inch vegetative layer. The functions of the multilayer soil cover are to contain refuse, control infiltration, support vegetation, and control gas emissions. These functions are achieved if the cover is intact, free of significant cracking and erosion, maintains specified grades, and supports vegetation. This Standard Operating Procedure (SOP) describes the procedures to maintain or repair the cover.

2.0  TASK DESCRIPTION

The tasks covered by this SOP are maintenance and repair of the cover. Maintenance includes ongoing, routine, or regular activities necessary to keep the cover in a functional state. Repair includes area specific work that may be required from time to time to restore or improve the state or functioning of the cover.

3.0   TASK PERFORMANCE

Maintenance or repair of the landfill cover is undertaken as established pursuant to observations, inspections, or monitoring in accordance with one or more of the following:

• SOP 001 – Multilayer Soil Cover Inspection
• SOP 002 – Landfill Surface Gas Monitoring
• SOP 003 – Access Road Inspection
• SOP 004 – Surface Water Management System Inspection and Maintenance
• SOP 005 – Vegetative Cover Inspection and Maintenance
• SOP 006 – Access Road Maintenance and Repair

The Operations Manager shall review relevant inspection observations and monitoring data, and shall establish the need for and extent of maintenance and repair. Repairs will be done in accordance with Record Drawings and specifications. The Operations Manager may consult with licensed/registered specialists to compile alternate repair plans or specifications.

Repair that involves construction should be undertaken in conformance with construction drawings and specifications.

4.0   GUIDELINES FOR MAINTENANCE AND REPAIR

Maintenance and repair procedures vary depending on existing conditions such as cracks, depressions, erosion gullies, sloughing or slope failures. Maintenance of the cover shall be recorded in daily logs, notebooks, or other reporting formats as may be used on a regular basis.

Following repair to the cover, the repaired areas shall be revegetated in accordance with SOP 005 (Vegetative Cover System Inspection and Maintenance). Repair of the cover shall be documented on Form SOP 007-1. The DON will be notified of start and finish of major repair activities (i.e. those necessary to restore compliance with Performance Standards).

1. Vertical and Near-Vertical Cracks:

• Surface cracks shall be evaluated for length, width, and depth of crack and evidence of any relative vertical displacement (vertical offset) across the crack. Significant cracking (cracks 1 inches or wider, deeper than 12 inches and longer than 20 feet) shall be repaired. Cracks in the cover longer than 20 feet and deeper than 1 foot and wider than 1 inches shall be examined by a registered civil engineer. The engineer will develop a

number of standard designs to repair such cracks and will recommend or approve the use of same to repair the subject cracks. Other cracks, e.g., longer than 20 feet but less than 1 inches wide, will be repaired as necessary by the site forces.

• For shallow cracks (not greater than 1 foot deep) with no vertical offset, the first response is to apply a small quantity of water (water truck application) to the cracked area and use tracked equipment to squeeze the cover materials into cracks and sufficiently repair them. If the cracks aren’t repaired using this method, excavate a 2 to 3 foot wide area straddling the crack to the depth of cracking and replace with cover materials compacted to project specifications. Compaction may be achieved in horizontal lifts with hand compaction equipment or parallel to slope face with sheepsfoot rollers (winched from bench above or mounted on long-reach backhoe arm).
• Deeper cracks (deeper than 1 foot) with no vertical offset shall be repaired as follows:

–        The lower portion of the crack below a depth of 1 foot shall be sealed by grouting.

–        The grout shall consist of a mix of fine or silty sand with approximately 5 percent by weight of bentonite mixed with water to mortar-like consistency. Grouting shall be done at 5-foot centers through a grouting pipe inserted into the crack. At each injection point, grouting shall be performed in 2-foot vertical stages proceeding from the bottom up. Grouting shall continue until a pressure of 5 psi is reached, ground surface movement is observed, the void is substantially filled, or grout is identified at the surface.

–        The upper 2 feet of cover over a 2 foot wide zone straddling the crack shall be reworked by compacting the existing cover to project specifications using compaction methods outlined above.

• Cracks and voids in the cover adjacent to concrete channels or swales shall be repaired by grouting in the same manner described above.
• Major cracks with vertical displacement across the crack, in particular on the slopes along the contours, may be indicative of slope deformation or sliding. The Operations Manager may consult with a specialist to evaluate such conditions and recommend appropriate repair measures. The repair may involve excavation of large areas of the cover material, possibly to the full depth of the multilayer cover including animal intrusion barrier replacement. The area affected shall be excavated making sure that the upper part of the slope showing cracks is excavated first to minimize potential for slope failure. The excavated area shall be backfilled with cover material in 6” thick horizontal lifts, moisture-conditioned, and compacted to project specifications using sheepsfoot compaction equipment. Animal intrusion barrier replacement should be performed according to specifications. The repair design shall be prepared by a registered civil engineer. The Operations Manager may consult with licensed/registered specialists to compile alternative repair plans or specifications.
• Surface Depressions: Surface depressions that could cause ponding shall be repaired by backfilling with cover material. Prior to backfilling, the area of the depression shall be cleared of vegetation and scarified to a minimum depth of 6 inches. Backfill materials shall be placed in 6-inch thick lifts, moisture-conditioned, and compacted to project specifications.
  • Erosion Gullies:
  • 0” to 6” deep: May warrant cosmetic raking or track walking prior to reseeding
  • 6” to 12” deep: Remove loose soil, place cover soil in 6” thick lifts, moisture condition to project specifications, and compact parallel to slope face using sheepsfoot roller.
  • >12” deep: Remove loose soil. Place cover materials moisture conditioned and compacted to project specifications in lifts £ 6” thick. Backfill should be benched into competent in-place fill. Compact with hand held temper or other means in horizontal lifts, tilted slightly into slope
    • If the timely repair of the erosion gullies is not feasible due to continuing wet weather, temporary backfilling of erosion gullies may be performed to minimize potential for enlargement of channels. Such temporary backfilling may be performed using coarse rockfill or sandbags. The rockfill and sandbags shall, however, be removed prior to performing permanent backfilling with cover material.

1. Sloughing/Slope Failures:

• The Operations Manager may consult with a specialist to evaluate the cause of sloughing/slope failure and recommend remedial measures.
• Should sloughing of the cover be shallow (less than 12 inches thick) and occur due to saturation from rains, irrigation line or surface water facility failure, the sloughed material shall be removed and the affected area shall be repaired in a similar manner as surface depressions.
• Should sloughing occur on the slope along the contour, it may be indicative of slope failure. The remedial grading for slope failures shall be performed in a similar manner as for major surface cracks. Repair designs shall be prepared by a registered civil engineer.

FORM SOP 007-1 LANDFILL COVER REPAIR RECORD

Maintenance Technician:                                     Date:                            Time:                         

DEFICIENCY TYPE AND DETAILED DESCRIPTION:

Erosion                  Sloughing/Sliding                 Cracks/Fissures                    Subsidence/Depression               Other

LOCATION OF REPAIR ACTIVITY (Show on map):                                                                   

REPAIR ACTION TAKEN (refer to repair detail or design drawing as appropriate):                     

ATTACHMENTS (As-Built drawings, compaction reports, etc., as appropriate):                           

REMARKS:                                                                                                                                       

Signature

Operations Manager                                                                                                         Date

STANDARD OPERATING PROCEDURE

Last Revised: 10/18/00

Final Construction As-Built Report,

SOP 008

LANDFILL GAS PROBE MONITORING

1.0 GENERAL

Landfill gas probes are monitored for both the pressure and methane gas to provide for the protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone, and that levels are in compliance within ambient air at the landfill perimeter. This Standard Operating Procedure (SOP) addresses routine probe monitoring.

2.0 TASK DESCRIPTION

Landfill gas probes will be monitored quarterly. The condition of the probes is physically inspected prior to monitoring. Probes are monitored for both gas pressure and general composition (i.e., methane – CH₄, carbon dioxide – CO₂, oxygen – O₂, and nitrogen – N₂) using the GEM-500 gas analyzer or equivalent. Probe monitoring is conducted quarterly.

Records will be taken for barometric pressure, atmospheric temperatures, and general weather conditions at the time of gas collection. It is recommended to collect landfill gas during barometric low pressures. Depending on the weather, this may be late in the morning or early in the afternoon.

3.0 REQUIRED MATERIALS

The following materials and equipment are required for this procedure:

• Landtech GEM-500 Gas Analyzer or equivalent
• Dwyer Magnehelic pressure gauge set (Ranges: 0-2 inches of water and 0-100 inches of water and 0-30 psi)
• Form SOP 008-1 (Probe Pressures)

4.0 TASK PERFORMANCE

Before conducting monitoring, inspect each probe for the following conditions:

• Confirm identity of probe.
• Laboratory stopcock or other flow restriction device is fitted and is effective.

• The laboratory stopcock appears to be leak-tight.
• Inventory of manufacturer quick connect fittings for ¼” PVC stopcock.
• Condition of tubing (holes, kinks, water, etc.).
• Condition of probe casing where present.

Adverse conditions are to be repaired if possible and reported to the Operations Manager. Maintenance actions may include the following:

• Replace or repair stopcocks or tubing that are missing or leaking. Record actions taken.
• Record probes that are filled with water. Measurements should not be collected from water-filled probes.
• Repair damaged casing.

Select the Dwyer Magnehelic pressure gauge that is appropriate for the probe by selecting the gauge with the lowest applicable pressure range based on recent pressure readings at the probe. The gauge selected should have the smallest scale range possible without exceeding the scale limit. If the observed pressure reading is outside the pressure range of the selected gauge, use the next larger scale range gauge. Connect the Dwyer Magnehelic pressure gauge to the stopcock with the appropriate tubing. Open the stopcock or flow restriction device. Read and record the pressure in the column marked Static Pressure (in. of H₂O) on the appropriate monitoring form when the gauge stabilizes. Record the time in the Time (hrs) column. Disconnect the Magnehelic gauge and close the stopcock after the reading is completed.

Calibrate the GEM-500 prior to the beginning of monitoring activities according to the manufacturers manual. Note: The GEM-500 should be recalibrated if the temperature changes 30°F from the initial calibration. Perform the following steps:

1. Turn the GEM-500 on and select the Monitoring Probe ID
2. Connect the clear tubing with the external filter/water trap assembly to the sampling port (top left corner) on the GEM-500. The shorter piece of tubing (from the water trap filter hosing) should be connected to the GEM-500. This allows visual of any liquid entering the hose, allowing time to shut the unit down.
3. Ensure inventory of quick connect fittings in order to take field readings from perimeter probes.
4. Connect the GEM-500 to the probe stopcock and turn the pump on to start analyzing for gas composition.
5. Open the probe stopcock and start the reading. The readings will be in percent CH4, CO2, O2, and balance gas. The balance gas is assumed to be N2. Typically the analyzer pump should run until the gas composition readings stabilize.

1. When the gas composition readings stabilize, record and store the data. Stabilization times should vary between 30 seconds and 2 minutes. Sampling period should not exceed 5 minutes.
2. If water is observed in the sample line during the evacuation process, record it in the comment and terminate the measurement
3. When the reading is completed, disconnect the sample line, allow the probe to purge for 30 seconds and close the stopcock valve.
4. Purge the sample train and the gas analyzer in between probe readings.

Do not shut down monitoring equipment unless sample interval between probes is more than 30 minutes.

FORM SOP 008-1 PROBE PRESSURES

DATE:                                     TECH:                                      INSTRUMENT:

SOP 009

LANDFILL PERIMETER GAS VENT INSPECTION AND MAINTENANCE

1.0  GENERAL

The inspection and maintenance of the passive gas control system and components, which include monitoring probes, riser vents, collection pipe and barrier trench described in this Standard Operating Procedure (SOP). The system provides for protection of public health and safety and the environment by demonstrating that methane migration is not occurring in the vadose zone, and that methane levels are in compliance at the landfill perimeter.

2.0   TASK DESCRIPTION

Inspection of passive gas control system components will take place during quarterly gas probe monitoring events.

3.0  TASK PERFORMANCE

As part of the annual survey, complete Form SOP 009-1. Any breakdown and subsequent repair of the gas control system shall be documented on Form SOP 009-2 and reported to the Operations Manager immediately. Below is a list of procedures associated with maintenance:

Gas Monitoring Probe/Vent Riser Inspection and Maintenance

Inspect and Maintain

• Inspect and maintain monitoring probe components to ensure consistent and reliable operation.
  • Ensure the integrity of the PVC riser vent including paint coating and caps.

Document and Repair

• Document damage and wear and tear. Repair components to function as intended. Document and include in quarterly report.

Inspection Frequency

• Inspect monitoring probe as part of each quarterly monitoring event.

Sample Ports

• Inspect sample port(s) and o-rings for cracks and damage. Replace if damaged.
  • Check for tightness and tighten as necessary.

• Ensure sample ports are free of debris and clean as necessary.
• Inspect sample port caps for damage or deterioration. Replace if damaged or deteriorated. It is important that caps are in place on sample ports to prevent deterioration of port and dirt accumulation.

Monitoring Probe Well Casing

• Visually inspect above grade well casings and surrounding areas for signs of damage, deterioration, or potential problems.
• Use below grade inspection techniques when monitoring data warrants (non-routine work).

Surface Completion

• Inspect surface completion for above grade completion details (steel probe cover, well id tag, drain holes).

• Verify that seal between well casing and cement-grout seal is intact.

Surrounding Area

• Visually inspect the surrounding cover surface integrity.

• Pay special attention to the cover located directly around each well casing or riser vent, noting signs that the soil is desiccated or pulling away from the well casing or riser vent.

• Note surface water erosion, ponding, leachate breakouts or staining.

QUARTERLY INSPECTION CHECKLIST

Page 1 of 1

Inspection Performed by:                                                                           Date:                              

Comments                                                                                                                                         

BREAKDOWN AND REPAIR LOG

Date:                                                                           Inspector:                                                       

Observations                                                                           Personnel Notified:                            

1. Missing Equipment
2. Damaged Materials
3. Erosion
4. Settlement

Type of Breakdown/Failure                                                                                                              

Location (show on map)                                                                                                                    

Action Requested                                                                                                                               

Action Taken                                                                                                                                     

Comments                                                                                                                                          

STANDARD OPERATING PROCEDURE

Last Revised: 11/29/11

APPENDIX C

PLAN ITEMIZED COST ESTIMATE

(on CD only)

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TABLE C.1-1

Detailed Annual Operation and Maintenance Costs

Basis of Estimate

Task No.                      Assumption No.                     Description

1                                                                    1                                    One year of PM/adminstrative support.

2                                                                    1                                    Twenty-two groundwater monitoring wells to be sampled annually.

2                                             2                                    The 2 replacement wells will be sampled semiannually for the first year and if the results are consistent with previous results, the well will be sampled annually.

2                                             3                                    Groundwater sampling will be completed for 5 years and a trend analysis conducted during the 5-year review.

2                                             4                                    Site inspections will be conducted quarterly and will include a biologist.

2                                             5                                    Monuments will be surveyed annually and a full survey of the site will be conducted every 5 years.

2                                             6                                    The 2 replacement wells will be surveyed during the final construction.

2                                             7                                    A biologist will conduct quarterly inspections.

2                                                                    8                                    Includes costs for two minor repair events.

3                                                                    1                                    Reports will be three versions: Pre-Draft, Draft, and Final.

3                                             2                                    The LTM contractor will adopt or modify existing basewide documents (SAP/QAPP and HSP) and procedures.

3                                             3                                    Ten copies of each version will be prepared.

Final PCOMMP Final Remedial Action Work Plan, Revision 1 IR Site 2, Alameda Point, Alameda, California DCN: RMAC-0809-0009-0004.R1

CTO No. 0009

TPD1304155

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APPENDIX D

EMERGENCY RESPONSE PLAN

(on CD only)

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

CONTRACT No. N62473-10-D-0809 CTONo.0009

APPENDIX D

FINAL

EMERGENCY RESPONSE PLAN

April 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT, ALAMEDA, CALIFORNIA

DCN: RMAC-0809-0009-0004

Prepared by:

TETRA TECH EC, INC.

1230 Columbia Street, Suite 750 San Diego, California 92101

       e_           

Pete Everds

Project Manager

Program Health and Safety Manager

TABLE OF CONTENTS

PAGE ABBREVIATIONS AND ACRONYMS…………………………………………………………………….. D.iii

1.0    EMERGENCY RESPONSE PLAN …………………………………………………………………… D.1-1

1.1              PRE-EMERGENCY PLANNING………………………………………………………….. D.1-1

1.2              PERSONNEL ROLES, LINES OF AUTHORITY, TRAINING AND COMMUNICATION…………………………………………………………………………….. D.1-2

1.3       EMERGENCY RECOGNITION AND PREVENTION…………………………….. D.1-3

1.4       FIRE PREVENTION AND PROTECTION …………………………………………….. D.1-3

1.5       SPILL CONTROL AND RESPONSE …………………………………………………….. D.1-3

1.6 RELEASE PREVENTION AND MINIMIZATION MEASURES ……………… D.1-4 1.7 SIGNIFICANT VAPOR RELEASE ……………………………………………………….. D.1-5 1.8 EARTHQUAKE RESPONSE ………………………………………………………………… D.1-5 1.9 SAFE DISTANCES AND PLACES OF REFUGE……………………………………. D.1-5 1.10 SITE SECURITY AND CONTROL ……………………………………………………….. D.1-6 1.11 EVACUATION ROUTES AND PROCEDURES …………………………………….. D.1-6 1.12    DECONTAMINATION PROCEDURES ………………………………………………… D.1-6

1.13          EMERGENCY MEDICAL TREATMENT AND FIRST AID……………………. D.1-7 1.13.1 First Aid…………………………………………………………………………………… D.1-7 1.13.2 Minor Injury …………………………………………………………………………….. D.1-7 1.13.3 Medical Emergency…………………………………………………………………… D.1-8 1.13.4 Fatal Injury ………………………………………………………………………………. D.1-8

1.14          EMERGENCY ALERTING AND RESPONSE PROCEDURES ……………….. D.1-9 1.15    PPE AND EMERGENCY EQUIPMENT ………………………………………………… D.1-9

1.16    PROCEDURES FOR HANDLING EMERGENCY INCIDENTS………………. D.1-9

2.0        REFERENCES……………………………………………………………………………………………….. D.2-1

Appx D Emergency Response                                                                                                           D.i                                                Emergency Response Plan Final Remedial Action Work Plan, Revision 1 IR Site 2, Alameda Point, Alameda, California DCN: RMAC-0809-0009-0004.R1

CTO No. 0009

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ABBREVIATIONS AND ACRONYMS

Cal-OSHA                        California Occupational Safety and Health Administration CPR                                          cardiopulmonary resuscitation

DON                                 Department of the Navy

IR                                      Installation Restoration (Program)

NAS                                  Naval Air Station

OSHA                               Occupational Safety and Health Administration

PESM                                Project Environmental Safety Manager

PjM                                   Project Manager

ROICC                             Resident Officer in Charge of Construction

RPM                                  Remedial Project Manager

SSHO                                Site Safety and Health Officer

TtEC                                 Tetra Tech EC, Inc.

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1.0         EMERGENCY RESPONSE PLAN

Tetra Tech EC, Inc. (TtEC) has prepared this Emergency Response Plan to cover the Post- Closure Operations, Maintenance, and Monitoring Plan (Plan) for Installation Restoration (IR) Site 2, former Naval Air Station (NAS) Alameda, Alameda Point, Alameda, California. This Plan was prepared for the United States Department of the Navy (DON), Base Realignment and Closure Program Management Office West, under Contract No. N62473-10-D-0809, Contract Task Order No. 0009.

There are numerous emergency services nearby in the civilian community. This plan describes response activities as they apply to NAS Alameda and as required by the HAZWOPER regulations 29 Code of Federal Regulations 19101.120 (l) and 8 California Code of Regulations 5192 (l).

1.1         PRE-EMERGENCY PLANNING

Prior to performing any work, the Superintendent or Project Manager (PjM) and the Site Safety and Health Officer (SSHO) will verify emergency action plans by ensuring that planned support facilities are available and that emergency contact numbers are valid. The Alameda Fire Department will be notified of planned activities by the SSHO or the Superintendent. As work proceeds, the SSHO will continue to ensure that plans specified in this section can be implemented at all times. Furthermore, the SSHO will ensure that plans are modified as necessary to accommodate changes. The SSHO will coordinate changes with the Project Environmental Safety Manager (PESM). Upon arrival at the site, the Superintendent will ensure that personnel know the system for communication of emergency situations and how to use a radio or nearby phone to summon emergency assistance. A vehicle must be available  to transport personnel to a safe location or to a hospital. All personnel on this project will know how to use a portable fire extinguisher. All personnel will know the location of emergency equipment and supplies. The SSHO will ensure that emergency equipment is available in the work areas and that the equipment is inspected for compliance with the regulations:

• Fire extinguishers – monthly, annual refill and servicing, 12-year hydrostatic test.
  • First aid kits – weekly as required by the Occupational Safety and Health Administration (OSHA).
  • Eyewashes, capable of delivering 0.4 gallon per minute for 15 minutes – weekly (If preservative is used, eyewash water may be changed every 4 months; otherwise, water must be changed weekly.) Only potable water may be used for eyewashes.

1.2         PERSONNEL ROLES, LINES OF AUTHORITY, TRAINING AND COMMUNICATION

The Superintendent or PjM is the primary emergency coordinator for the project. In the absence of either or both the Superintendent and the PjM, the SSHO is the emergency coordinator. The emergency coordinator will take charge and determine, direct, and delegate personnel and resources to manage the emergency. Key responsibilities of the emergency coordinator are to:

• Initiate evacuation, if needed.
• Initiate emergency response agency notification.
  • Evaluate and assess emergency situations to ensure that response activities are commensurate with the level of the emergency and, as discussed in this Plan, are implemented.
  • Interface and coordinate with outside agencies responding to on-site emergencies.

Project supervisors and forepersons will account for all their personnel and report their count to the emergency coordinator. They will follow the directions of the emergency coordinator. If directed by the emergency coordinator, the supervisors will direct workers to evacuate the area and report to the assembly area.

All workers will follow the instructions of the emergency coordinator.

All workers have had training for various emergency situations. For this project, workers will have had training in spill containment and control, fighting incipient stage fires, use of eyewashes, and basic rescue techniques for moving and carrying personnel in danger situations. There will always be personnel at the work site who can provide cardiopulmonary resuscitation (CPR) and first aid.

Personnel will maintain verbal communication. The following communication systems will be available during site activities:

• Cellular telephone or access to a land phone for emergency purposes
• Handheld radios, as needed
• Compressed air horn (signals emergency evacuation only)
• Hand signals (if used, will be diagrammed and posted)
• Posted location of evacuation assembly area(s)
• Posted route to the hospital located nearest the project site
• Posted emergency phone numbers

1.3         EMERGENCY RECOGNITION AND PREVENTION

All personnel have received training on the potential hazards on this project. There are hazards that are commonly expected on any project site such as adverse weather, electrical hazards, traffic, and equipment hazards, chemical exposures, physical hazards, etc. These have been addressed in theSite Safety and Health Plan. If someone has been affected by a hazard, all personnel are trained on how to respond to an emergency. The first thing anyone is told to do is notify by radio or phone as noted above. There are other procedures to prevent emergencies by following the directions below.

1.4         FIRE PREVENTION AND PROTECTION

Fire prevention and protection measures require preplanning. At least one 20-pound dry  chemical ABC fire extinguisher will be located at each work area. A mounted fire extinguisher  is required in every vehicle including heavy equipment. Extinguishers mounted on heavy equipment will be a minimum 5-pound ABC dry chemical type. Fire extinguishers inside the  cab of pickup trucks will be 2 ½-pound dry chemical ABC. Fire extinguishers in the cabs of all vehicles must be mounted or secured. Fire extinguishers in the beds of all pickup trucks must be mounted or secured. Employees will follow safe work practices to include proper storage of flammable and combustible liquids. Smoking is permitted only in those areas designated specifically by the PjM, Superintendent, or SSHO and posted as smoking areas.

Personnel will follow hot work procedures to ensure that work is performed in a safe environment. In the event of a fire or explosion, the Fire Department will be summoned immediately, a head count will be taken, and evacuation procedures will be implemented. Smoking is not permitted inside buildings.

1.5         SPILL CONTROL AND RESPONSE

All spills, leaks, and fires involving oil or hazardous substances at former NAS Alameda must be reported to the DON Remedial Project Manager (RPM) and the PESM. The person reporting the leak or spill is required to provide the following information:

• His/her name
• Location of spill and facility number, if known
• Number of injured personnel and nature of injuries, if known
• Substance spilled
• Estimated amount spilled
• Extent of spill
• Estimated rate at which the substance is currently being released
• Estimated time the spill occurred
• Any other pertinent information

The RPM, in coordination with  the  PjM,  will  manage  notifications  to  regulatory  agencies. In addition, all spills will be reported to the Environmental Compliance Manager or the PESM. Project personnel will not report spills directly to any agency unless specifically requested by the RPM or the Contracting Officer.

A minor spill would involve no immediate threat to human health or the environment. It would cause only minimal property damage and not exceed the reportable quantity for that material. In the event of a minor spill, the appropriate response action is for the responsible person to notify the RPM and the PjM and supply the responders with as much information as possible. In the case of a spill of contaminated or hazardous materials, the following procedures will be followed:

• Notify the Superintendent, the PjM, and the PESM.
• Identify protective clothing or equipment required to respond.
• Contain the spill.
• Neutralize and/or solidify any product.
• Transfer material into 55-gallon drums.
• Document the incident.

1.6         RELEASE PREVENTION AND MINIMIZATION MEASURES

In addition to training, the following procedures will be implemented to prevent and minimize releases of hazardous materials:

• Do not conduct hazardous materials operations when the weather could cause significant risk to the surrounding area if a spill should occur.
• Transfer all materials in or over a bermed or “protected” area. A protected area is one that is covered with an impermeable material, such as polyethylene.
• Dike temporary storage tanks containing hazardous wastes or potentially hazardous wastes to contain potential releases.
• Maintain a supply of basic spill response materials and protective equipment on-site to include:

–        Absorbent sheets, pillows, booms, or other absorbent material

–        Open top 55-gallon drums or other containers with lids

–        Brooms, shovels, and other tools, such as squeegees

1.7         SIGNIFICANT VAPOR RELEASE

Any project activity that releases significant amounts of vapor must be reported immediately, as described in the spill release procedure. Every attempt to mitigate the release must be taken if it can be safely performed. For example, during excavations, vapor releases may be controlled by simply replacing the cover on the excavation. Downwind evacuation procedures may be required. These will be initiated through coordination with former NAS Alameda emergency coordinators.

1.8         EARTHQUAKE RESPONSE

If an earthquake should occur during the course of site activities, take the following action:

• Stop working. Remain calm and do not panic.
  • Do not use or do anything that might be a source of ignition (smoking, cutting, or welding).
  • Avoid power lines, power poles, and windows.
  • If in a vehicle, stay in the vehicle until the earthquake is over.
    • If in a building, take cover under a heavy piece of furniture or leave the building if possible.

After the earthquake is over:

• Prepare for aftershocks. Stay out of severely damaged buildings.
• Meet for a head count at a location designated by the Superintendent.
  • Check for injuries. Do not move seriously injured personnel, unless remaining where they are would create danger of further injury.
  • Check  vehicles,  equipment,  and  buildings  for any obvious damage.    Do not enter buildings until their structural integrity has been evaluated.
  • Check  utility  lines for damage.    Switch off power, water, and gas until a utility official has inspected the buildings and operational area and determined it is safe.
  • If driving, watch carefully for hazards created by the earthquake (undermined roads, weak bridges or overpasses, fallen power lines or poles, and so forth).

1.9         SAFE DISTANCES AND PLACES OF REFUGE

On this project, after an emergency inside the building is identified, the building will be evacuated. Only personnel authorized by the emergency coordinator will be allowed to return into the building depending on the nature of the emergency and whether the personnel have the training, the ability, and the need to return to the building. As noted below, personnel will assemble in the project trailer/offices. This area is several hundred feet from the buildings.

Immediately evacuate to an area located at least 50 feet from the building as an alternate area identified by the SSHO.

1.10     SITE SECURITY AND CONTROL

There are no buildings on-site. The site is secured by fencing on the north and east sides.

1.11     EVACUATION ROUTES AND PROCEDURES

In the event of an emergency situation such as fire or explosion, the SSHO or a supervisor will activate an air horn for approximately 15 seconds indicating the initiation of evacuation procedures. All personnel in both the restricted and non-restricted areas will evacuate and assemble near the support zone or other safe area identified by the SSHO. Prior to starting work, the SSHO will identify and mark the location of an evacuation assembly area. The location should be upwind of the site.

For efficient and safe site evacuation and assessment of the emergency situation, the Superintendent or SSHO will have authority to initiate proper action if outside services are required. Under no circumstances will incoming personnel or visitors be allowed to proceed into the area once the emergency signal has been given. The SSHO must ensure that access is provided for emergency equipment and that equipment that may cause combustion has been shut down once the alarm has been sounded. As soon as possible, and while the safety of all personnel is confirmed, emergency agency notification will commence. The SSHO will brief  site personnel each day as to the location of the evacuation assembly area. After gathering at the local site assembly point, and depending on the nature of the emergency, workers will be given further instructions.

Before starting work, the SSHO will establish safe egress routes from the site to the evacuation assembly area. The SSHO will prepare a drawing or map that diagrams these safe egress routes. The SSHO will use this same map to diagram egress from the evacuation assembly area to the facility gate to be used as an exit.

An evacuation exercise will be practiced within 1 week of the start of the project and randomly during the course of the project. After the practice drill or after any actual evacuation, all involved site personnel will attend a briefing to evaluate the evacuation. The employees will discuss the evacuation and anything that could be done to improve or change future evacuations. The results of this briefing will be documented on a safety meeting attendance form. A copy of the evaluation report will be sent to the PESM.

1.12     DECONTAMINATION PROCEDURES

Any personnel requiring emergency medical attention will be evacuated immediately from exclusion zones and contamination reduction zones. Personnel will not enter the area to attempt

a rescue if their own lives would be threatened. The decision whether or not to decontaminate a victim prior to evacuation is based on the type and severity of the illness or injury and the nature of the contaminant.

For some emergency victims, immediate decontamination may be an essential part of life-saving first aid.  For others,  decontamination  may aggravate the injury or delay life-saving treatment.  If decontamination does not interfere with essential treatment, it should be performed.

If decontamination can be performed:

• Wash external clothing and cut it away.
• Wrap the victim in a clean blanket or towel if necessary.

If decontamination cannot be performed:

• Wrap the victim in blankets or plastic to reduce contamination of other personnel.
  • Alert emergency and off-site medical personnel to potential contamination; instruct them regarding specific decontamination procedures.

Send along site personnel familiar with the incident.

1.13     EMERGENCY MEDICAL TREATMENT AND FIRST AID

The following procedures should be observed if an accident with injury occurs.

1.13.1    First Aid

Only qualified personnel will provide first aid and stabilize an individual needing assistance.  Life support techniques such as CPR and treatment of life-threatening problems such as airway obstruction and shock will be given top priority. At least two persons certified in first aid techniques and CPR will be on each work site at all times; EHS 4-1, Bloodborne Pathogens, will be followed when first aid/CPR are administered. The SSHO will be current in first aid and CPR and bloodborne pathogen training. Professional medical assistance will be obtained at  the earliest possible opportunity. Ensure that WorkCare^® has been contacted  at  (800) 455-6155. The hospital and clinic located nearest to former NAS Alameda are shown on a map that is part of every Site Safety and Health Plan. A general map to the nearest clinic and hospitals is  attached to this plan. Notify the PjM and the PESM.

1.13.2    Minor Injury

• Contact a supervisor or “buddy.”
• Have qualified first aid personnel treat the injury.
  • Record the injury and include the name of the injured person, nature of injury, and treatment given.
  • Notify the PjM and the PESM.

1.13.3    Medical Emergency

In the event of a medical emergency when actual or suspected serious injury occurs, the following procedures will be implemented:

• Survey the scene and evaluate whether the area is safe for entry.
• Remove the exposed or injured person(s) from immediate danger.
  • Render first aid if necessary. Decontaminate affected personnel after critical first aid is provided.
  • Obtain paramedic services or ambulance transport to local hospital. This procedure will be followed even if there is no visible injury.
  • Call 911 from phones at former NAS Alameda. Calling 911 from cell phones will notify California Highway Patrol who will notify county Emergency Medical Service. If using a cell phone, call Alameda (510) 337-2100. Preprogram cell phones with this emergency number.
  • Identify the location by the number of the nearest building, request medical assistance, and provide a name and telephone number.
  • Request assistance from emergency medical service and/or additional assistance.
    • Other personnel in the work area will be evacuated to a safe distance until the Superintendent determines that it is safe for work to resume. If there is any doubt about the condition of the area, work will not commence until all hazard control issues are resolved.
    • Notify the PjM and the PESM.
      • Notify the Resident Officer in Charge of Construction (ROICC) of the incident and fill out accident reporting forms and associated documents.

1.13.4    Fatal Injury

If a fatal injury occurs, the following additional steps will be followed:

• Notify the Superintendent and PjM immediately.
  • Notify the PESM, who will initiate contact with the California Occupational Safety and Health Administration (Cal-OSHA).
  • Notify the ROICC.
  • Stop all work activities on the project for 24 hours.
  • Assist Cal-OSHA as directed.

1.14     EMERGENCY ALERTING AND RESPONSE PROCEDURES

This plan has identified the emergency alerting devices available to the project. While inside the buildings, the use of the air horn is most effective in alerting personnel. However, if personnel are located a distance from where the emergency occurred, the horn should be tested to ensure that personnel in all areas can hear the horn. When necessary, the on-site supervisor will give each work team an air horn. The supervisor will know the assigned area of each work team. The use of radios with each team can also provide information regarding the precise location of the emergency. Upon alarm, the first response is made by the emergency coordinators who will direct the activities required to respond to the emergency. This plan has described  many potential response procedures.

1.15     PPE AND EMERGENCY EQUIPMENT

The following emergency equipment will be stationed near each work area:

• Fire extinguisher (minimum one 20-pound dry chemical ABC type in the contamination reduction corridor at the edge of the exclusion zone).
  • Industrial first aid kit (outside the building entrance). The kit must be filled as required by EM 385-1-1, Table 3-1 (USACE 2008) and 8 CCR 5812.
  • Portable eye wash (capable of supplying 15 minutes of water at 0.4 gallon per minute and protected from direct sunlight in the support area, at the edge of the support zone).
  • Air horn (at the support area, at the edge of the support zone).
    • Spill control material (absorbent pillows or absorbent material and shovels, plastic sheeting, and 55-gallon drum[s] in the support zone by the contamination reduction corridor entrance).

The following equipment will be available at the support trailer/offices for use in an emergency situation:

• Industrial first aid kit
• Blanket

The need for specialized personal protective equipment is not anticipated for this project.

1.16          PROCEDURES FOR HANDLING EMERGENCY INCIDENTS

This Plan has incorporated prevention procedures with procedures on how to handle the emergency event. After the emergency event is over, or during the course of the emergency  when possible, the SSHO will notify the PESM by telephone. Should an accident or incident occur, the Superintendent or PjM and the SSHO will immediately investigate the cause, notify the PESM, and promptly complete the following:

• Incident Report Form – Details of the incident will be documented within 24 hours and copies of the report will be forwarded to the RPM and the PESM. Reports of serious incidents will also be faxed to the Program Manager by the Superintendent or PjM.
• Incident Investigation Report – The Incident Investigation Report will have the same distribution as the Incident Report Form and must be completed within 3 days of the incident.
• Contractor’s Significant Incident Report – If the accident/incident involves injuries requiring more than first aid or property damage greater than $2,000, a Contractor Significant Incident Report will be prepared and submitted to the ROICC as soon as possible after the incident but no later than 5 days after. The originals will be sent to the TtEC records coordinator for maintenance and distribution. Copies will be distributed to the PESM, Superintendent, subcontractor employees, if appropriate,  and the Contracting Officer. A copy of the completed forms will be kept in the  project file.

Any recommended additional hazard control measures must be discussed with the Superintendent, SSHO, and PESM and meet their approval prior to implementation. Corrective actions will be implemented as soon as reasonably practical. Any occupational injuries and illnesses will be recorded, if applicable, on an OSHA Form No. 300. The SSHO will report immediately to the PESM any serious injury or illness requiring hospitalization, or death of an employee occurring in a place of employment or in connection with any employment. The  PESM will immediately notify the closest CalOSHA office in Oakland at:

1515 Clay Street, Ste. 1301

Oakland, California 94612

Phone (510) 622-2916

Fax (510) 622-2908

Immediately means as soon as practically possible, but not longer than 8 hours after the incident. Records of all site accidents and first aid treatments will be maintained by the SSHO.

Emergency contact names and phone numbers will be posted. Maps showing egress routes, evacuation assembly areas, and the route to the clinic and hospitals will also be posted. The contact names, phone numbers, and maps will be placed on the dashboard of every project vehicle.

This plan also describes practice drills for emergencies. When there is an actual emergency event, similar to the practice drill, a project team debriefing will be held to review the event and discuss measures for improving or changing the response plan to correct deficiencies that may have been noted.

2.0   REFERENCES

USACE   (U.S.   Army    Corps    of   Engineers).     2008.     Safety   and   Health   Requirements Manual. Engineering Manual (EM) 385-1-1. September 15.

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ATTACHMENT 12

LAND-USE CONTROL REMEDIAL DESIGN

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Base Realignment and Closure Program Management Office West 1455 Frazee Road, Suite 900

San Diego, California 92108-4310

CONTRACT No. N62473-10-D-0809 CTONo.0009

ATTACHMENT 12

FINAL

LAND-USE CONTROL REMEDIAL DESIGN

April 2013

INSTALLATION RESTORATION SITE 2 ALAMEDA POINT

ALAMEDA, CALIFORNIA DCN: RMAC-0809-0009-0004

Prepared by:

TETRA TECH EC, INC.

1230 Columbia Street, Suite 750 San Diego, California 92101-8530

:rJ-el

Hedy Abed i, PhD, PE

Project Manager

Pete Everds Senior Project Manager

PAGE ABBREVIATIONS AND ACRONYMS………………………………………………………………………… iii

1.0       PURPOSE………………………………………………………………………………………………………. 1-1

2.0              SITE DESCRIPTION………………………………………………………………………………………. 2-1

2.1              SITE BACKGROUND………………………………………………………………………….. 2-1

2.2              CURRENT AND POTENTIAL FUTURE SITE USES……………………………… 2-2

2.3              BASIS FOR REMEDIAL ACTION………………………………………………………… 2-2

2.4              DESCRIPTION OF SELECTED REMEDY…………………………………………….. 2-3

3.0              INSTITUTIONAL CONTROLS……………………………………………………………………….. 3-1

3.1              FEDERAL-TO-FEDERAL PROPERTY TRANSFER………………………………. 3-1

3.2              PROPERTY TRANSFER TO A NONFEDERAL ENTITY……………………….. 3-1

4.0…… AREA REQUIRING INSTITUTIONAL CONTROLS………………………………………… 4-1

5.0              INSTITUTIONAL CONTROL PERFORMANCE OBJECTIVES, LAND USE RESTRICTIONS, AND ACTIVITY RESTRICTIONS…………………………………………………………………… 5-1

5.1              LAND USE RESTRICTIONS………………………………………………………………… 5-1

5.2              GENERAL ACTIVITY RESTRICTIONS……………………………………………….. 5-1

5.3              ADDITIONAL ACTIVITY RESTRICTIONS RELATED TO RADIONUCLIDES        5-2

5.4              ACCESS………………………………………………………………………………………………. 5-2

6.0              REMEDY IMPLEMENTATION ACTIONS………………………………………………………. 6-1

6.1              RESPONSIBILITIES OF THE DON WITH RESPECT TO IC

INSPECTIONS, REPORTING, AND ENFORCEMENT…………………………… 6-1

6.2              DON RESPONSIBILITIES……………………………………………………………………. 6-1

6.3              RESPONSIBILITIES OF THE PROPERTY OWNER(S) AND SUCCESSORS WITH RESPECT TO IC INSPECTIONS AND

REPORTING……………………………………………………………………………………….. 6-5

7.0       DOCUMENT REVIEWS…………………………………………………………………………………. 7-1

8.0              REFERENCES………………………………………………………………………………………………… 8-1

FIGURES

Figure 2-1             Site Location Map

Attachment 12 Land Use Controls RD.doc                                                                                      i                                       Final Land-Use Control Remedial Design IR Site 2, Alameda Point Alameda, California

DCN: RMAC-0809-0009-0004

CTO No. 0009

(Continued)

APPENDICES

Appendix A    Land-Use Control Remedial Design Distribution List

Appendix B     Institutional Controls Compliance Monitoring Report and Compliance Certificate

ABBREVIATIONS AND ACRONYMS

ARIC                          area requiring institutional controls Cal. Code Regs.                  California Code of Regulations

CDPH                         California Department of Public Health

CERCLA                    Comprehensive Environmental Response, Compensation, and Liability Act

COC                            contaminant of concern

CRUP                         Covenant to Restrict Use of Property

DoD                            Department of Defense

DDD                           dichlorodiphenyldichloroethane

DDE                            dichlorodiphenyldichloroethene

DDT                            dichlorodiphenyltrichloroethane

DDx (total)                  sum of total dichlorodiphenyldichloroethane DON                                    Department of the Navy

DTSC                          California Department of Toxic Substances Control

EPA                            U.S. Environmental Protection Agency

FFA                             Federal Facility Agreement

GIS                             geographic information system

IC                                institutional control

IR                                Installation Restoration (Program)

LUC                            land-use control

MOA                           memorandum of agreement

MOU                           memorandum of understanding

NAS                            Naval Air Station

NCP                            National Contingency Plan

OEW                           ordnance and explosives waste

PCB                            polychlorinated biphenyl

RD                              remedial design

ROD                           Record of Decision

Water Board               San Francisco Bay Regional Water Quality Control Board yd³                                    cubic yard

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1.0   PURPOSE

The Land-Use Control (LUC) Remedial Design (RD) for Installation Restoration (IR) Site 2, Alameda Point, Alameda, California, addresses the institutional controls (ICs) (including land use and activity restrictions) required by Section 2.9.2 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Record of Decision (ROD) for IR Site 2 issued in August 2010. The ROD requires the implementation of land use and activity restrictions to limit exposure of future landowner(s) and/or user(s) of the property to hazardous substances, and to maintain the integrity of the remedial action until remediation is complete and remedial goals have been met.

This LUC RD is a component of the RD for IR Site 2, a primary document under the Alameda Point Federal Facility Agreement (FFA). This LUC RD was prepared in accordance with the Navy Principles and Procedures for Specifying Monitoring and Enforcement of Land Use Controls and Other Post-ROD Actions attached to the January 16, 2004, Department of Defense (DoD) Memorandum titled CERCLA ROD and Post-ROD Policy.

The Alameda Point “FFA Signatories” consist of the Department of the Navy (DON), the U.S. Environmental Protection Agency (EPA), the State of California through the Department of Toxic Substances Control (DTSC), and the San Francisco Bay Regional Water Quality Control Board (Water Board). If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedy for IR Site 2 property from DON to another federal agency, the DON’s responsibilities under this LUC RD shall be assumed by the federal transferee, and DON will no longer be responsible for them. In the event of such an amendment the term “FFA Signatories” as used in this LUC RD report shall be construed to include EPA, DTSC, Water Board, and the federal transferee.

The California Department of Public Health (CDPH) regulates activities related to remediation of radionuclides on non-federally owned property. CDPH is involved in the IR Site 2 remediation as described in the ROD.

The inspections and reporting requirements described herein will be effective immediately upon approval of this LUC RD by EPA, DTSC, and the Water Board. The IR Site 2 property (“the property”) is currently owned by the DON and is not subject to a lease. The IC objectives will be met by access controls until the time of transfer of the property from DON ownership. The IC land use and activity restrictions described in this LUC RD report will be incorporated into a Memorandum of Understanding (MOU) or other agreement between the DON and the federal transferee if the property is transferred to another federal agency, or Quitclaim Deeds (deed[s]) and Covenant to Restrict Use of Property (CRUP) if the property is transferred to a nonfederal entity, and will take effect upon transfer of the property and issuance of those documents.

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2.0        SITE DESCRIPTION

IR Site 2 is located on the southwest corner of Alameda Point in Alameda, California (Figures 1 and 2). Alameda Point is approximately 2 miles long east-west and 1 mile wide, north-south, and occupies 1,734 acres of onshore land. IR Site 2 is approximately 110 acres in size (Figure 2-1).

The site consists of the former landfill, which occupies approximately 60 acres, and wetlands, which covers approximately 33 acres immediately south and west of the landfill. The remaining 17 acres within the IR Site 2 boundary is represented by areas known as the interior and coastal margins. The site is bounded to the south and west by the San Francisco Bay and to the east and north by runways and tarmacs. The former landfill was reportedly used for disposal of wastes generated by former Naval Air Station (NAS) Alameda activities from 1956 through early 1978. After landfill operations ceased in 1978, an earthen berm was constructed around the perimeter of the landfill site.

Previous site use has contaminated the soil with cadmium, chromium, lead, molybdenum, zinc, total DDx (sum of total dichlorodiphenyldichloroethane [DDD], dichlorodiphenyldichloroethene [DDE], and dichlorodiphenyltrichloroethane [DDT]), polychlorinated biphenyls (PCBs), benzo(a)pyrene, and radium-226 at concentrations that may pose a risk to human health and ecological receptors under a recreational use scenario, a proposed future reuse of IR Site 2. The selected remedy, a multilayer soil cover (cover) over the former landfill to isolate buried waste and soil contaminants, has been selected to protect human health and to address concentrations in soil and soil gas above the established remedial goals. The remediation strategy is described in the Proposed Plan (DON 2009) and in the Final ROD (DON 2010).

2.1         SITE BACKGROUND

Former NAS Alameda was an active military installation from the 1930s to the 1990s, which primarily provided facilities and support for fleet aviation activities. The area of present day IR Site 2 was originally open water until 1956 when a sea wall was constructed along the southern and western shorelines to confine and protect the area. Dredged fill was hydraulically placed within the seawall creating the area encompassed by IR Site 2.

The IR Site 2 landfill, also called the West Beach Landfill, was used as the main disposal area for the Alameda Point from approximately 1952 through 1978. An estimated 1.6 million tons of waste was deposited (E&E 1983). Historical waste disposal methods at the site generally consisted of trench-and-fill operations. Wastes included municipal solid waste, waste chemical drums (contents unknown), solvents, oily waste and sludge, paint waste, plating wastes, industrial strippers and cleaners, acids, mercury, polychlorinated biphenyl (PCB)-containing liquids, batteries, low-level radioactive waste (LLRW) including but not limited to radioluminescent dials and dial painting, scrap metal, inert ordnance, asbestos, several pesticides

(solid and liquid), tear gas agent, biological waste from the Oak Knoll Naval Hospital, creosote, dredge spoils, and waste medicines and reagents (E&E 1983). Ordnance and explosives waste (OEW) may have also been deposited in the 2.5-acre (approximate) Possible OEW Burial Site located in the southern part of the landfill. Previously identified areas of buried waste are shown on Figure 2-1.

In 1978, the DON developed plans to close the landfill in accordance with the requirements of the Water Board’s Minimum Criteria for Proper Closure of Class II Solid Waste Disposal Sites (Resolution No. 77-7). In 1983, the Water Board issued Order No. 83-35 to implement a final cover, leachate cutoff barrier, methane gas control, earthquake damage control, drainage control, and erosion control, and to generate compliance reports for the former landfill. Between 1983 and 1995, the DON responded by placing a partial clay-soil cover, installing an 820-foot-long, 2-foot-wide and 20- to 30-foot-deep slurry wall to restrict potential contaminant migration to San Francisco Bay. A gas venting system was installed for methane gas control, and repairs were made to the seawall also during this time period. In 1986, 20,000 cubic yards of imported fill soil was spread on the former landfill, which was insufficient in achieving a uniform cover layer of appropriate thickness over the landfill area. Also in 1986, the landfill was graded to prevent ponding, and an earthen perimeter berm was constructed around the landfill.

In August 1999, IR Site 2 was officially added to the EPA’s National Priority List of Superfund sites and assigned Comprehensive Environmental Response, Compensation, and Liability Information System identification number CA2170023236.

2.2         CURRENT AND POTENTIAL FUTURE SITE USES

IR Site 2 was used as a landfill between the mid-1950s and the latter part of the 1970s. No land use occurred at the site prior to 1956 when the perimeter sea wall was constructed and the site was first formed using dredged fill. Due to its sole historical use as a landfill, no persons have resided or currently reside at the site. Because it has never been used for full-time residence or occupancy, no above- or belowground utilities (e.g., potable water, electric, or telephone) exist at the site.

As stated in the ROD, the future use of the Site is to be restricted to open space and recreational uses. Please refer to the ROD, Table 2-13, Land Use Restrictions, for specific land use prohibitions.

2.3         BASIS FOR REMEDIAL ACTION

Potentially significant risk to human and ecological receptors due to exposure to contaminants of concern (COCs) (cadmium, chromium, lead, molybdenum, total DDx, total PCBs, benzo[a]pyrene, and radium-226) for the landfill area and lead, zinc, and radium-226 in the wetland area in soil, a recreational use scenario is the basis for the CERCLA remedial action

being undertaken by the DON. The FFA signatories considered the factors in accordance with the remedy selection criteria and concluded that a remedial action is necessary to minimize exposure of human receptors, sensitive habitats, and species to impacted soil at IR Site 2. The FFA signatories developed the following remedial action objectives to address the human health and ecological risk:

• Protect sensitive human receptors, avian species, and mammal species from exposure to COCs in surface soil in the landfill and wetland portions of the site
• Protect viable wetland area in the southwest portion of the site from impacts associated with the landfill
• Protect sensitive human receptors from exposure through external radiation from surface soil in the landfill and wetland portions of the site
• Protect beneficial uses of the surface water in the San Francisco Bay from the potential for discharge of site groundwater containing COCs

2.4         DESCRIPTION OF SELECTED REMEDY

The selected remedy identified in the ROD (DON 2010) consists of the placement of a cover to isolate buried waste and soil contaminants and to prevent animal burrowing. Prior to placing the cover, the surface will undergo scanning and removal of radiological hotspot material to prevent the spread of potential contamination during site grading. Engineering controls and ICs will be implemented to protect human health and the integrity of the cover; provide for any necessary wetlands mitigation, and monitor soil cleanup and wetlands mitigation; and conduct methane gas monitoring (as necessary).

The selected remedy for groundwater is monitored natural attenuation. Site groundwater will be monitored regularly using shoreline groundwater monitoring wells. Engineering controls will be in place to protect the monitoring wells from damage and/or to protect site users from harm. ICs will be implemented across the entire site, including the wetlands, to limit human exposure to contaminants in soil and to protect the integrity of the cover.

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3.0        INSTITUTIONAL CONTROLS

ICs are legal and administrative mechanisms used to implement land use and activity restrictions to limit the exposure to hazardous substances by current and future landowner(s) and user(s) of the property and to maintain the integrity of the remedial action. ICs are required on a property where the selected remedial cleanup levels result in contamination remaining at the property above levels that allow for unlimited use and unrestricted exposure. ICs will be maintained until the concentrations of hazardous substances in soil and groundwater are at such levels to allow for unrestricted use and exposure. Implementation of ICs includes requirements for monitoring, inspections, and reporting to ensure compliance with land use or activity restrictions.

3.1         FEDERAL-TO-FEDERAL PROPERTY TRANSFER

If the IR Site 2 property is transferred to another federal agency or department, the land use restrictions and activity restrictions set forth in Section 5.0 and the Remedy Implementation Actions set forth in Section 6.0 will be incorporated into an MOU or other agreement between the DON and the federal transferee. The MOU or other agreement will also require that 1) the transferee comply with all applicable federal and state environmental, public health, and cultural and natural resource protection laws following transfer; 2) any subsequent future transfer by the federal transferee to a federal agency shall incorporate the land use and activity restrictions set forth below into a subsequent MOU or other agreement and require the same for any further conveyances between federal agencies; and 3) if the federal transferee in turn transfers the property to a nonfederal entity, it shall comply with the requirements set forth in Sections 3.2, 5.0, and 6.0. If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedial action selected for IR Site 2 from DON to another federal agency, the DON’s responsibilities under this LUC RD shall be assumed by the federal transferee and DON shall no longer be responsible for them as provided in Section 1.0.

3.2         PROPERTY TRANSFER TO A NONFEDERAL ENTITY

If the IR Site 2 property is transferred from the DON or another federal transferee to a nonfederal entity, DON will rely upon proprietary controls in the form of environmental restrictive covenants as provided in the Memorandum of Agreement (MOA) Between the United States Department of the Navy and the California Department of Toxic Substances Control and attached covenant models (DON and DTSC 2000) (hereinafter referred to as the DON/DTSC MOA). More specifically, land use and activity restrictions will be incorporated into two separate legal instruments at the time of transfer as provided in the DON/DTSC MOA:

1. Restrictive covenants included in one or more Quitclaim Deeds from the DON to the property recipient
2. Restrictive covenants included in one or more “Covenant to Restrict Use of Property” entered into by the DON and DTSC as provided in the DON/DTSC MOA and consistent with the substantive provisions of California Code of Regulations Title 22, Section 67391.1.

The “Covenant to Restrict Use of Property” will incorporate the land use and activity restrictions into environmental restrictive covenants that run with the land and are enforceable by DTSC, EPA, and any other signatory state entity (such as CDPH) against future transferees. The Quitclaim Deed(s) will include the identical land use and activity restrictions in environmental restrictive covenants that run with the land and will be enforceable by the DON against future transferees.

ICs include land use and activity restrictions and will be applied to the property in the area requiring institutional controls (ARIC) (the entire area of IR Site 2 as described in Section 4.0). These IC’s will be included in the Environmental Summary Document (for transfer to a federal agency), or a Finding of Suitability to Transfer/Finding of Suitability for Early Transfer, Covenant to Restrict Use of Property, and Quitclaim Deed(s) (for transfer to a non-federal entity).

4.0   AREA REQUIRING INSTITUTIONAL CONTROLS

The ICs, including all land use and activity restrictions selected in the ROD and described in Section 5.0, will be applied to the IR Site 2 area requiring institutional controls (ARIC). The ARIC is shown on Figure 2-1.

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5.0       INSTITUTIONAL CONTROL PERFORMANCE OBJECTIVES, LAND USE RESTRICTIONS, AND ACTIVITY RESTRICTIONS

The following sections describe the objectives to be achieved through land use and activity restrictions within the ARIC at IR Site 2. If the FFA is amended to transfer responsibility for post-RACR Operation and Maintenance and monitoring of the remedy for IR Site 2 from DON to another federal agency as provided in Section 1.0, the federal transferee shall also be responsible for compliance with the land use and activity restrictions set forth below after the IR Site 2 property is transferred to it.

5.1         LAND USE RESTRICTIONS

The IR Site 2 property shall be restricted to open space and recreational uses. In addition, the following land uses are specifically prohibited within the boundaries of the IR Site 2 ARIC:

• A residence, including any mobile home or factory-built housing, constructed or installed for use as human habitation
• A hospital for humans
• A school for persons under 21 years of age
• A daycare facility for children
  • Any permanently occupied human habitation including those used for commercial or industrial purposes

5.2         GENERAL ACTIVITY RESTRICTIONS

The following activities are restricted within the boundaries of the IR Site 2 ARIC unless prior written approval for these activities is granted by the FFA signatories, prior to conducting them:

• Land disturbing activity is prohibited unless conducted pursuant to an approved soil management plan (SMP) (Note: Additional SMP requirements for addressing radiological activity restrictions are set forth below in Section 5.3). Land disturbing activity includes, but is not limited to, 1) excavation of soil and disturbance of the multilayer soil cover; 2) construction of roads, utilities, permanently occupied buildings, facilities, structures, and appurtenances of any kind; 3) demolition or removal of paved areas; 4) actions that may impair the multilayer soil cover or other exposure prevention barriers; 5) excavation and/or disturbance of soil or riprap areas; and 6) any other activity that involves movement of soil to the surface from below the surface of the IR Site 2 property.
• Alteration, disturbance, or removal of any component of a response or cleanup action (including, but not limited to, soil cover/containment systems); groundwater extraction, injection, and monitoring wells and associated piping and equipment; or associated utilities.
• Extraction of groundwater and installation of new groundwater wells.
  • Removal of or damage to security features (e.g., locks on monitoring wells, survey monuments, signs, or monitoring equipment and associated pipelines and appurtenances).

ICs will be maintained until the concentrations of hazardous substances in the soil and groundwater are at such levels to allow for unrestricted use and exposure.

5.3         ADDITIONAL ACTIVITY RESTRICTIONS RELATED TO RADIONUCLIDES

Excavation within the IR Site 2 ARIC below a depth 1.9 feet is strictly prohibited unless approved in writing by the FFA signatories and CDPH. Any proposed excavation below this depth shall be described in a Soil Management Plan that will include but not be limited to a radiological work plan, the identification of a radiological safety specialist, soil sampling and analysis requirements, and a plan for off-site disposal of any excavated radionuclides by the transferee in accordance with federal and state law. This work plan must be submitted to and approved in writing by the FFA signatories and CDPH in accordance with procedures set forth in Section 7.0 of this LUC RD report.

The integrity of the cover must be restored upon completion of any excavation as provided in the IR Site 2 Operation and Maintenance Plan, this report, or similar document. A completion report describing the details of the implementation of the Soil Management Plan, the sampling and analysis, the off-site disposal, and the restoration of the integrity of the cover must be submitted to and approved in writing by the FFA signatories and CDPH in accordance with procedures and time frames detailed in Section 6.0 of this document.

5.4         ACCESS

The MOU or other agreement, if the property is transferred to another federal agency, or the deed(s) and CRUP(s) if the property is transferred to a nonfederal entity, shall provide that the FFA signatories and CDPH, and authorized agents, employees, contractors, and subcontractors shall have the right to enter IR Site 2 at Alameda Point to conduct investigations, tests, or surveys; inspect field activities; or construct, operate, and maintain any response or remedial action as required or necessary under the cleanup program, including monitoring wells, pumping wells, treatment facilities, and landfill cap/containment systems.

6.0        REMEDY IMPLEMENTATION ACTIONS

This section describes the responsibilities of the DON and future transferees for implementing ICs. If the DON transfers responsibility for post-RACR Operation and Maintenance and monitoring of the remedial action for IR Site 2 to another federal agency, that federal agency shall assume the DON responsibilities described in Sections 6.1 and 6.2.

6.1         RESPONSIBILITIES OF THE DON WITH RESPECT TO IC INSPECTIONS, REPORTING, AND ENFORCEMENT

The DON is responsible for implementing, maintaining, inspecting, reporting, and enforcing the land use and activity restrictions identified in Section 5.0 of this LUC RD prior to conveyance of the IR Site 2 property. The DON may later transfer these procedural responsibilities to another party (transferee) by contract, property transfer agreement, MOU, or other means. Although the DON may contractually arrange for third parties to assume responsibility for and perform any and all actions associated with ICs, the DON shall retain ultimate responsibility under CERCLA for successful implementation of ICs, including maintaining, monitoring, reporting on, and enforcing the controls as necessary to assure remedy integrity unless the FFA is amended to transfer responsibility for IR Site 2 from the DON to another federal agency at the time of transfer as described in Sections 1.0 and 6.0 above. Should any IC objectives fail, the DON, or another federal agency as appropriate, shall ensure that appropriate actions are taken to re- establish protectiveness of the remedy and may initiate legal action to either compel action by a third party(ies) and/or recover the DON’s costs for mitigating any discovered IC violation(s).

6.2         DON RESPONSIBILITIES

The DON will undertake the following IC implementation actions to ensure that the aforementioned IC objectives and land use restrictions for IR Site 2 are met and maintained:

• LUC RD Distribution:Within 30 days of receiving EPA’s, DTSC’s, Water Board’s, concurrence with this LUC RD, the DON will place the LUC RD in the Information Repository currently located at Alameda Point. A copy of the LUC RD will also be sent to EPA, DTSC, the Water Board, Alameda Reuse and Redevelopment Authority, and CDPH. Appendix A presents a list of agencies and mailing addresses.
  • Site Access: Each deed (or MOU or other agreement with another federal department or agency) will contain a reservation of access to the property for the DON, EPA, DTSC, and Water Board, and their respective officials, agents, employees, contractors, and subcontractors for the purposes consistent with the Navy IR Program or the FFA.
  • Site Inspections: Commencing upon concurrence upon this LUC RD by EPA, DTSC, and Water Board and continuing until the effective date of property transfer, the DON will undertake annual physical inspections of the site to confirm continued

compliance with all IC performance objectives and land use restrictions through the property transfer instruments described in Section 4.0. At the time of conveyance of the site, the DON and DTSC will require, via appropriate provisions to be placed in the MOU or other agreement if the property is transferred to another federal agency, or deed(s) of conveyance and CRUP if the property is transferred to a nonfederal entity, that the landowner(s) and subsequent transferees undertake continuing annual site inspections to ensure that all IC objectives and land use restrictions are complied with by all future user(s) as provided in Section 6.3 of this document.

• Compliance Reporting: Beginning upon approval of this LUC RD and continuing until the effective date of property transfer by the DON, the DON will provide to the EPA, DTSC, and Water Board, an annual IC Compliance Monitoring Report and Certificate for IR Site 2 consistent with the form located in Appendix B. The annual IC Compliance Monitoring Report will address, among other things, whether the land use and activity restrictions were communicated in the MOU or other agreement or deed(s) and CRUP whether the owners and state and local agencies were notified of the use restrictions and controls affecting the property, whether use of the property has conformed with such restrictions and controls, and will evaluate the status of the ICs. In addition, should any deficiencies be found during the annual inspection, the DON will provide the EPA, DTSC, and Water Board with a separate written explanation with the IC Compliance Certificate indicating the specific deficiencies found and what efforts or measures have or will be taken to correct those deficiencies. Copies of a completed and signed IC Compliance Monitoring Report and Certificate shall be sent to the EPA, DTSC, and Water Board by Certified Mail, Return Receipt Requested annually. Upon conveyance of fee title for the site to a nonfederal entity, the DON will require, via appropriate provisions to be placed in deed(s) of conveyance and CRUP, that the landowner(s) and subsequent transferees respond to IC violations as required by compliance reporting and provide to the FFA signatories an IC Compliance Monitoring Report and Certificate for IR Site 2 consistent with the form located in Appendix B unless and until all ICs are terminated at the site.
• If the transferee fails to provide an annual compliance monitoring report as described previously to the DON, the DON will notify EPA, DTSC and Water Board soon as practicable. If the EPA, DTSC, or Water Board do not receive the annual monitoring report from the transferee, it will notify the DON as soon as practicable. The DON shall ensure appropriate measures have been taken to verify the status of the ICs and that an annual compliance monitoring report is submitted to the EPA, DTSC, or Water Board within 90 days after the report’s due date.
• CERCLA 5-Year Reviews: The DON shall conduct 5-Year Reviews of the IR Site 2 remedy as required by CERCLA Section 121(c) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The 5-Year Reviews will evaluate, among other things, implementation and compliance with the ICs to determine whether the remedy is or will be protective of human health and the environment in the future. The annual monitoring reports prepared by the DON and transferee will be used in preparation of the 5-Year Review reports to evaluate the effectiveness of the remedy.
• Notice of Planned Property Conveyances: The DON will provide notice to the EPA, DTSC, and Water Board at least 6 months prior to any transfer or sale of IR  Site 2 by the DON so that all FFA signatories can be involved in discussions to ensure that appropriate provisions are included in the transfer terms or conveyance documents to maintain effective ICs. If it is not possible for the DON to provide notification at least 6 months prior to any transfer or sale, then the DON will notify as soon as possible but no later than 60 days prior to the transfer or the sale of any property by the DON. In addition to the land transfer notice and discussion  provisions in this LUC RD report, the DON further agrees to provide the FFA signatories with similar notice, within the same time frames, as to federal-to-federal transfer of property. The DON shall provide a copy of executed deed(s) of conveyance or CRUP or MOU or similar agreement to the EPA, DTSC, and Water Board.
• Opportunity to Review Text of Intended Deed Restrictions: Prior to conveyance of the site, the EPA, DTSC, and Water Board will be given reasonable opportunity to review and comment upon the applicable deed(s) and CRUP language related to all ICs and associated rights of entry for the FFA signatories for purposes of IC oversight and enforcement. The provisions in the deed(s) or other enforceable document(s) will be consistent with the IC objectives in Section 5.0.
• Notification should Action(s) that Interfere with IC Effectiveness be Discovered: The DON or transferee will notify the FFA signatories as soon as practicable, but no longer than 10 working days after the DON’s or transferee’s discovery of any activity that is inconsistent with the IC objectives or use restrictions or any other action that may interfere with the effectiveness of the ICs. The DON or transferee will notify the FFA signatories regarding how a breach will be addressed or has been addressed as soon as practicable, but no later than 10 working days after notification of the breach. This reporting requirement does not preclude the DON from taking immediate action pursuant to its CERCLA authorities to prevent any actual or perceived risk(s) to human health of the environment.
• IC Enforcement: The process of addressing any activity that is inconsistent with the IC objectives or use restrictions, or any other action that may interfere with the effectiveness of the ICs will be initiated by the landowner as soon as practicable, but no longer than 60 days after the landowner becomes aware of the breach. If a violation of a land use restriction is identified and/or documented by the FFA signatories, or in an owner’s annual IC Compliance Monitoring Report, the entity identifying the violation will notify the others within 10 working days of identifying the violation. The FFA signatories and CDPH will then consult to evaluate what, if any, action(s) should be taken, who shall take the action(s), and when they shall be undertaken. These actions may range from informal resolution with the owner or violator of an IC provision(s) as described in this LUC RD, to the pursuit of legal remedies or enforcement action to enforce deed or CRUP restrictions under the auspices of state property law or CERCLA if the property is transferred to a nonfederal entity. Alternatively, the DON may choose to exercise its response authorities under CERCLA and seek cost recovery from the person(s) or entity(ies) who violate a given IC objective/land use restriction set forth in the deed(s)

transferring the property. Should the DON become aware that any future owner or user of the property has violated any IC requirement over which a local agency may have independent jurisdiction, the DON will notify these agencies of such violation(s) and work cooperatively with them to reachieve owner/user compliance with the ICs.

DTSC and the DON as signatories to a CRUP (and EPA as a third-party beneficiary) will have independent authority to enforce violations of restrictions, requirements, and obligations under a CRUP. While DTSC may agree to consult with other parties before taking any enforcement action under a CRUP, it will not waive its authority to take action as necessary in the event of violations.

• Modification of Restrictions in Quitclaim Deed(s) and DTSC CRUPs:Modifications to the ICs may be required based on changes in site conditions (e.g., reduction in ARIC) during the expected duration for the ICs. When the DON or  future property owner(s) determines, with EPA, DTSC, and Water Board concurrence, that modifications to the ICs are appropriate, the IC modifications shall be documented in accordance with procedures consistent with applicable laws and regulations. The DON or future property owner(s) shall be responsible for providing pertinent information on the IC modifications to the Alameda Reuse and Redevelopment Authority and will also advise the additional interested parties listed in Appendix A. The FFA signatories, in consultation with CDPH, shall determine whether a ROD Amendment, Explanation of Significant Differences (ESD), or some other procedure consistent with the NCP is required to support the modification of the IC. The DON shall not modify or terminate LUCs, implementation actions, or modify land use without EPA, DTSC, and Water Board concurrence. The DON or transferee shall seek prior concurrence before any action anticipated by the DON or transferee that may disrupt the effectiveness of the LUCs or any action that may alter or negate the need for LUCs.
  • Termination of ICs: When the DON determines, with EPA, DTSC, and Water  Board concurrence, in consultation with CDPH, that one or more of the ICs at IR Site 2 are no longer needed for protection of human health and the environment because the property is remediated to levels of contamination that allows for unrestricted use, the DON and DTSC shall provide to the current landowner(s) of the property an appropriate release of the restriction (DON for the deed[s] and DTSC for the CRUP) in accordance with state law for recordation with the deed(s) pertaining to the site and will also timely advise the additional interested parties listed in Appendix A. Termination of restrictions contained in the ICs may be possible; however, most ICs (such as those that require protection of the soil cover) will continue in perpetuity to provide protection of human health and the environment. ICs will be maintained until the concentrations of hazardous substances in soil and groundwater are at such levels as to allow for unrestricted use and exposure.
  • Survey Plat: Prior to transfer, the DON will survey the ARICs at IR Site 2 to define the legal metes and bounds for inclusion in the property transfer documents. The DON will forward copies of the survey to the EPA, DTSC, and Water Board and will place a copy in the Administrative Record.

6.3         RESPONSIBILITIES OF THE PROPERTY OWNER(S) AND SUCCESSORS WITH RESPECT TO IC INSPECTIONS AND REPORTING

By including appropriate provisions in the MOU or other agreement if the property is transferred to another federal agency, or in deed(s) and CRUPs if the property is transferred to a nonfederal entity, the DON will cause the future property owner(s) to assume the following IC implementation responsibilities upon the DON’s conveyance of the property to ensure that the aforementioned IC objectives and land use restrictions for IR Site 2 are complied with after property transfer:

• Site Inspections: The property owner(s) will conduct annual physical inspections of the site to confirm continued compliance with all IC objectives and land use restrictions in the MOU, or deed(s) and CRUPs unless and until all ICs at the site are terminated with FFA signatories’ and CDPH approval.
• Compliance Reporting: The property owner(s) will notify the FFA signatories and CDPH within 5 working days of the property owner(s)’ discovery of any violation of an IC and include in the notification a written explanation indicating the specific IC violations found and what efforts or measures have or will be taken to correct those violations. The property owner(s) will also provide to the FFA signatories and CDPH an annual Compliance Monitoring Report and IC Compliance Certificate for IR Site 2 consistent with the form attached hereto as Appendix B unless and until all ICs are terminated at the site. In addition, should any IC violations be discovered during the annual site inspection, the property owner(s) will provide to the FFA signatories and CDPH, along with the required IC Compliance Monitoring Report Certificate, a separate written explanation indicating the specific IC violations found and what efforts or measures have or will be taken to correct those violations. The annual Compliance Monitoring Report and Certificate shall be sent to the DON, EPA, DTSC, Water Board, and CDPH by Certified Mail, Return Receipt Requested annually. The need to continue to provide such inspections and certifications on an annual basis will be re-evaluated by the FFA signatories and CDPH using the CERCLA five-year review process.
• Monitoring Well Protection: Prior to conveyance, to preclude damage to the monitoring well network at IR Site 2, the DON will provide appropriate information regarding monitoring well locations and necessary ICs to the future property owner, including, if available, any well coordinates maintained in a geographic information system (GIS) database and/or applicable maps and drawings. This will enable the future property owner and other entities responsible for planning and development of future projects within the ARIC to add the well coordinates to their GIS database and/or applicable maps and drawings.

Whenever the DON proposes to transfer real property where monitoring wells are located, the DON shall include appropriate information regarding monitoring well locations and necessary ICs in transfer documents to assure nondisturbance of the monitoring well network and prevent interference with IC effectiveness.

The future property owner(s), or other entity responsible for review and approval of any development plans prepared for projects within the ARIC, shall identify any potential for the project to impact the IC effectiveness and coordinate with the FFA signatories to prevent interference with the IC effectiveness. The DON and other FFA signatories reserve the right to deny approval of projects within the area requiring ICs ARIC deemed to interfere with IC effectiveness. This process will be evaluated during the CERCLA 5-Year Review to determine whether any changes need to be implemented.

• Notification of Proposed Changes in Land Use: Prior to seeking approval from the FFA signatories and CDPH for restricted activities within the ARIC, the recipient of the property must notify and obtain approval from the DON of any proposals for a land use change at a site inconsistent with the use restrictions and assumptions described in the final ROD.

7.0   DOCUMENT REVIEWS

Various documents may be prepared by the DON or the transferee during the implementation of ICs (e.g., Soil Management Plans). These documents are subject to review and approval by the FFA signatories (and CDPH for documents required by Section 5.3, Additional Activity Restrictions Related to Radionuclides).

Draft documents will be subject to a review period of 45 days. Reviewing parties may request extension of the review period for up to an additional 45 days from the party submitting the document. The party submitting the document will have 45 days to revise the document to address the comments received.

Draft final documents will be subject to a review period of 30 days. Reviewing parties may request extension of the review period for up to an additional 30 days from the party submitting the document. The party submitting the document will have 45 days to revise the document to address the comments received. Draft final documents will be considered to be final if no comments are received within the 30-day comment period.

All parties preparing or reviewing documents will adhere to the scheduled document preparation and review times to the maximum extent practicable.

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8.0   REFERENCES

Battelle and BBL (Blasland, Bouck, and Lee,  Inc.). 2008. Final Feasibility Study Report  IR  Site 2, West Beach Landfill and Wetlands Alameda Point, California. October.

DON (Department of the Navy). 2009. Final Proposed Plan for IR Site 2, Former NAS Alameda.

August.

—————. 2010. Final Record of Decision (ROD) for IR Site 2, Former Naval Air Station Alameda, California. August.

DON and DTSC (California Department of Toxic Substances Control). 2000. Memorandum of Agreement Between the United States Department of the Navy and the California Department of Toxic Substances Control. March 10.

E&E (Ecology and Environment, Inc.). 1983. Initial Assessment Study, Naval Air Station, Alameda, California. Prepared for the Department of the Navy, Navy Assessment and Control of Installation Pollutants Department, Naval Energy and Environmental Support Activity, Port Hueneme, CA.

Weston Solutions, Inc. 2007. Historical Radiological Assessment, Alameda Naval Air Station, Use of General Radioactive Materials 1941–2005.

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FIGURES

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APPENDIX A

LAND-USE CONTROL REMEDIAL DESIGN DISTRIBUTION LIST

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Land-Use Control Remedial Design Distribution List IR Site 2, Alameda Point, Alameda, California

1. United States Environmental Protection Agency Region IX 75 Hawthorne Street

San Francisco, CA 94105

1. Department of Toxic Substances Control 700 Heinz Avenue

Berkeley, CA 94710

1. Regional Water Quality Control Board San Francisco Bay Region

1515 Clay Street, Suite 1400

Oakland, CA 94612

1. Department of Veterans Affairs (VA) VA Sierra Pacific Network

Capital Asset Managers Office 201 Walnut Ave

Mare Island, CA 94592

1. California Department of Public Health Environmental Management Branch 1616 Capitol Avenue, MS 7405 Sacramento, CA 95899-7377

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APPENDIX B

INSTITUTIONAL CONTROLS COMPLIANCE MONITORING REPORT AND COMPLIANCE CERTIFICATE

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Attachment 12 Land Use Controls RD.doc                                                                                                                                                                     Final Land-Use Control Remedial Design

Institutional Controls Compliance Monitoring Report IR Site 2, Alameda Point, Alameda, California

EPA ID No. CA2170023236

Property Owner:                                                                                                                                                                                                                                                                                This evaluation is the final Navy certification immediately prior to site conveyance (Yes or No)

If for an annual inspection, this evaluation covers the period from                  through                 _

Certification Checklist

I, the undersigned, hereby certify that the above-described land use restrictions have been complied with for the period noted. Alternately, any known deficiencies and completed or planned actions to address such deficiencies are described in the attached Explanation of Deficiencies.

Signature                                                                                             Date

Comments:

Future property owners may provide plans to the DON, EPA, DTSC, and Water Board for review and approval if the plans do not impact land use restrictions provided in the LUC RD.

Mail completed form(s) to the DON, EPA, DTSC, Water Board, and CDPH in January of each calendar year.

IR SITE 2 SOIL ANNUAL INSTITUTIONAL CONTROLS COMPLIANCE CERTIFICATE

Installation Restoration Site 2 Alameda Point, Alameda, California EPA ID No. CA2170023236

I,                                                                                          , hereby certify that the attached IR Site 2 Soil Land Use Control Compliance Monitoring Report is complete and accurate. The requirements of LUC RD Section 5.0 have been met. I further certify that a copy of this compliance certificate and the attached IR Site 2 Soil Land Use and Groundwater Use Control Compliance Monitoring Report have been sent by Registered Mail to the following addressees:

(Name and title)

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ATTACHMENT 13

RESPONSE TO COMMENTS ON THE DRAFT REMEDIAL ACTION WORK PLAN, DATED MAY 4, 2012