Marsh Crust -Page 203, fifth paragraph.

This section implies that the marsh crust PAH contamination occurs only at 10 to 20 feet below ground surface (bgs). However, the Focused Feasibility Study for the Former Subtidal Area and Marsh Crust, at FISC and Alameda Point indicates that the Marsh Crust contamination occurs in the range of 7.5 to 20.5 feet bgs at the FISC Annex, and from 4 to 10 feet bgs at Alameda Point. In addition, sampling surveys at the Alameda Point's IR Site 25 and Parcel 181 have demonstrated that hot-spots of PAH contamination are present in surface soils within the Marsh Crust area.

Additional Analysis Required: Report the correct depths for the Marsh Crust contamination in the various project areas. Discuss the possibility that marsh crust contamination may have been brought to the surface in various and unpredictable locations throughout the Marsh Crust area, due to historical construction activities.

Incorrect Reference Page 216, second paragraph.

The section states that ?Chapter IV.B, Hazardous Materials and Waste? of the City's Reuse EIR have been incorporated into the subject EIR.

Correction Required: Please correct this reference; the Reuse EIR's chapter on hazardous materials is "Chapter 4.13." In addition, Chapter 4.13 of the Reuse EIR should be included as an appendix to the subject EIR.

Premature Conclusion -Page 217, second paragraph.

This section states that, ?No human exposure pathways for the marsh crust or groundwater are present.? In Comment #1 we noted that Marsh Crust contamination may have been brought close to the surface due to prior disturbances of soil; therefore the soil exposure pathway may be present at various, randomly located hot-spots. In addition, groundwater at portions of the FISC Annex contains volatile organic contamination which may be creating a soil gas-to-indoor air hazard. The EIR notes, in Impact HAZ-6, that the DTSC is still evaluating the adequacy of the Navy's risk assessment of the soil-gas pathway.

Additional Analysis Required: Assume that human exposure to Marsh Crust and groundwater contamination is possible. Devise appropriate mitigations.

Institutional Controls - Page 217-218.

The list of mitigation measures for Impact HAZ-1 does not include a description of DTSC oversight of institutional controls. Also missing is any description of the layering of institutional controls; the layering of institutional controls is currently recommended by the U.S. EPA.

Additional Information Required: Please include a description of DTSC's role in implementing the institutional controls for hazards identified in the project. In addition, please describe measures taken to layer any institutional controls proposed as mitigation measures.

Inadequate Sampling - Page 217, Mitigation measure HAZ-1c.

Problem: The Site Management Plan (SMP) does not include provisions for sampling and analysis of soils in certain cases where these soils were inadequately characterized. On account of some questionable Navy policies on soil sampling during the base restoration program, soil-characterization data gaps may exist at a parcel after its final conveyance. For example, deep soil sampling has not been carried out in the East Housing area, and therefore the depth to Marsh Crust contamination is currently undetermined. In the absence of this data, the City's excavation permit system will need to depend upon historical land-elevation maps to determine the depth to contamination in the area. However, this is not a reliable method since prior construction and/or regrading activities could have brought contamination closer to the surface than would be indicated by the land-elevation maps.

Another example, indicating that the proposed SMP needs to include special soil sampling provisions, is the Navy's lack of sampling around non-residential buildings affected by lead-based paint (LBP). As a matter of policy, the Navy has continued to ignore lead contamination problems in soils surrounding non-residential buildings, even though this contradicts current U.S. EPA policy (EPA considers soil lead contamination around non-residential base structures to be a CERCLA release, regardless of its source). In cases where the U.S. EPA or DTSC have carried out their own LBP inspection of non-residential buildings on bases, soil-lead concentrations have been found in excess of standard cleanup goals for lead in industrial soils. This would indicate that currently uncharacterized soil lead contamination at non-residential buildings can produce environmental impacts to future users.

Additional Information Required: Include special soil analysis provisions as part of the SMP, for all cases in which soil sampling data gaps exist; these data gaps include, but are not limited to, the Marsh Crust contamination and lead contamination surrounding non-residential buildings at the former base property.

Erroneous Reference - Page 219, third paragraph.

The section proposes the SMP for Project site construction, described in Mitigation Measure HAZ-1, as the mitigation measure for HAZ-2.

Correction Required: As noted above, this SMP should include provisions for precautionary soil sampling and analysis in cases where previous Navy (and other agency) studies have left significant data gaps.

On-going Navy responsibility -Page 224, first paragraph.

The mitigation measure for Impact HAZ-6 is inappropriate. The Navy remains responsible for any remedial measures that are necessary because of base-related contamination. Given the uncertainty regarding the potential risks of vapor transport in some of the project parcels, we also question the propriety of proposing early transfer for parcels with soil-vapor problems. This having been said, any control measures involving vapor barriers or special construction techniques should be monitored for continued efficacy over time. Thus, an inspection and sampling program should be a part of any such remedial design.

Additional Mitigation Required: An appropriate mitigation measure for Impact HAZ-6 would be to reschedule the relevant project components until all required remedial actions are in place. All remedial actions involving vapor barriers and special construction techniques must include a long-term monitoring program to insure the continued effectiveness of the remedy.

High ambient levels of chemicals -Section F.2.c

This section fails to identify, as a project impact, routine human exposure to elevated ambient levels of chemicals in the fill material. The fill material at FISC Annex and Alameda Point is known to contain levels of carcinogenic PAHs that are elevated above regional ambient concentrations. For example, surface soils at the East Housing area were found to contain Total PAHs at levels as high as 14 ppm, and carcinogenic Benzo(a)pyrene at levels as high as 1.5 ppm. A concentration of 1.5 ppm of Benzo(a)pyrene in surface soil represents a residential risk that is greater than the 1-in-one-million risk that the California DTSC uses as its point of departure for remedial decision making. This concentration also represents a risk greater than the California Prop 65 notification risk of 1-in-100,000.

Additional Analysis Required: The risk posed by elevated ambient levels to people brought to the site by the Project of contamination in the historical fill material should be analyzed as an environmental impact of the project, and appropriate mitigations should be proposed.

Radon - Section F.2.

The EIR did not address project impacts due to radon. Radon is a ubiquitous contaminant in soil gas, as well as, the residential environment, and even typical levels of indoor radon (i.e., levels lower than EPA's recommended 4 pCi/L for residential air) are associated with a cancer risk that is significantly higher than acceptable risk levels under CERCLA. However, the EPA accepts a higher public health risk for radon by virtue of the fact that radon is regulated under the less protective Toxic Substances Control Act (TSCA). Therefore, it would be more accurate to describe project-related radon impacts as significant from the perspective of relative site risks, even if radon concentrations are below EPA's current advisory level.

Additional Information Required: Please report and review the radon concentration data measured in the 1993, FISC Annex radon study. Treat radon as a significant impact and propose appropriate mitigation measures.

Regulatory Site Status (p. 206)

The statement that neither the East Housing area nor the FISC Facility is part of the NPL site is inaccurate. The boundaries of the NPL site are determined by the boundaries of the contamination, not by physical property boundaries.

As Figure IV.F-3 (Benzene Impacted Groundwater, October 1996) of the EIR shows, the boundaries of the contaminated groundwater plume at IR Site 25 at the Alameda Point NPL Site include the project's proposed multi-family residential site, portions of the project's proposed school site, and other areas proposed for industrial use.

The north side of IR Site 25 also abuts the project site. Characterizations of toxic contamination within Parcel 182 (Estuary Park) clearly indicate the boundaries of the contamination extend into the project site. In fact, Sample 182-004 was collected from the project site during EBS Phase 2A sampling in November 1994. The results of this sample led to Parcel 182 being designated as IR Site 25 .

Also, IR Site 18 at the Alameda Point NPL site includes the stormwater sewer system. The boundaries of the stormwater sewer system include the East Housing area. East Housing was included within the scope of the Site 18 CERCLA Removal Action that was conducted in 1997.

Correction Required: Revise the text to reflect that Superfund site boundaries are determined by the extent of contamination.

Description of DRMO Screening Lot (p. 207)

The DRMO Screening Lot (Site IR02) is identified as the most polluted property on the FISC Annex. The project proposes to develop this toxic waste site as multi-family housing. This toxic waste site would be located adjacent to both an existing and proposed public elementary school.

The EIR's description of contamination found at this site is incomplete. The EIR does note that IR02 is underlain with benzene contaminated groundwater. The EIR also notes, that Site IR02 will be the subject of a removal action to remove PCB contaminated soils. However, no reference to the release of radioactive material that occurred at Site IR02 is made in the EIR. This incident involved depleted uranium that the US Navy misdelivered to the site in 1994. The EIR should provide a complete description of all contamination at Site IR02.

Since the licensed professional preparing the EIR will be certifying that the benzene contaminated groundwater, the marsh crust contamination, the PCB contaminated soil and the radioactive waste spill have all been adequately addressed to allow residential housing to be built at the site, it is inappropriate for the EIR to rely solely on the US Navy's representations of risk. Instead the EIR must provide an objective and scientifically valid estimate of human health risk.

Additional Information Required: Revise description of the site to include all known discharges, and analyze all data to justify conclusion that the site will be safe for housing and a school.

Description of Marsh Crust Contamination (p. 211)

There is no evidence that the toxic wastes referred to as the Marsh Crust exist anywhere on the project site except in the immediate vicinity of the DRMO Scrap Yard, IR Site 02. Within the DRMO Scrap Yard Site and what is now Marina Village Family Housing and George Miller Elementary School, the US Navy performed open-burning of metal wastes using waste oil, solvents, and fuels. The oil, solvents and fuels that did not burn are responsible for soil and groundwater contamination referred to as the marsh crust. The EIR speculates all of this contamination resulted from pre-World War II industries and contaminated fill, but references no reliable evidence of this theory.

Due to the mischaracterization of this contamination as wide-spread and historical, it has never been properly investigated. Except within the vicinity of the DRMO scrap yard, estimates of the depth of the marsh crust contamination are entirely speculative. Without knowledge of the location of contamination an evaluation of this hazard can not be made.

Excavation of the Marsh Crust to build the Project should be recognized a significant environmental impact. The City of Alameda ordinance intended to mitigate this hazard requires mitigations to be considered on a sample by sample basis. The City's ordinance piecemeals the analysis of the environmental impacts of the marsh crust contamination. This piecemealing prevents an analysis of the cumulative and significant impacts that this hazard represents.

Additional Analysis Required: Base analysis on data.

Inhalation Risk due to VOCs (p. 212), Impact HAZ-6 mitigations

The risk due to inhalation of VOCs is misstated. According to the Environmental Baseline Survey (EBS) prepared for Alameda Point the indirect risk to human health under a residential reuse scenario for the elevated concentrations of benzene detected in the groundwater (IR Site 2 [Alameda Annex] and part of the Alameda Point Housing Area [Parcels 178, 179, 180, 181, and 184]) is 9.4 in one million.

Marina Village Family Housing was constructed on benzene contaminated groundwater the extent of which is misrepresented on Figure IV.F-3 of the EIR. Sampling inside Marina Village Housing confirmed the risks estimated in the EBS. This is despite the fact that these units were constructed on slabs with vapor barriers.

Prior to construction of Marina Village Family Housing on a former area of the Alameda Annex, the Navy requested that the Agency for Toxic Substance Disease Registry (ATSDR) provide a public health consultation. The health consultation sent to the Navy on November 20, 1990, was skeptical that a vapor barrier would be durable and remain intact for the life of a housing units. ATSDR recommended that periodic sampling of indoor air to assure that levels of remain below levels of health concern. ATSDR also recommended mitigating the source of groundwater contamination if possible.

The only subsequent sampling of indoor air occurred in 1993. Again the Navy requested an ATSDR public health consultation. ATSDR concluded that the indoor air levels of benzene in some of the housing units may represent an increased cancer risk to humans. ATSDR recommended that indoor air sampling continue in all units on an annual basis rather than the proposed air monitoring in 5 years. Due to an increased cancer risk due to exposure to benzene, ATSDR recommended that exposure to benzene in the housing units be mitigated.

The EIR has understated the significant risk represented by benzene migration from contaminated groundwater and into housing units at the project site. The long-term effectiveness of the proposed mitigations (HAZ-6) would need to be monitored throughout the life of the housing unit.

Additional Analysis Required: Provide for long term monitoring of benzene risk.

Explosion Risk due to methane gas generation (p. 215)

The proposed project is built on fill from an unknown source which may have consisted in part of municipal garbage and industrial wastes. A layer of peat, grass and other decaying marsh vegetation is expected beneath much of the project site. The EIR speculates that a layer of petroleum wastes is present throughout the project site. Anaerobic conditions exist in the subsurface and these conditions are conducive to methane gas generation. Methane can enter buildings, accumulate to explosive levels, and ignite when encountering an ignition source. No analysis or mitigations are provided in the EIR for this readily apparent environmental impact.

Additional Analysis Required: Analyze methane risk to people brought to the site by the Project and devise mitigations.

Catellus East Housing Sampling (p. 215)

Navy Environmental Baseline Sampling failed to analyze for polynuclear aromatic hydrocarbons in the East Housing area. The project proponent, Catellus, has completed sampling. Soil sample results show concentrations of individual PNAs above preliminary remediation goals. Under the Navy's tiered screening process used to perform the Environmental Baseline Surveys (EBS), a Phase 2B groundwater investigation at the East Housing area is needed.

Additional Analysis Required: Analyze sample data and devise mitigations.

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Cover Letter - Project Alternative - Analysis Failures - Deferred Mitigations
Report Organization - Land Use - Population and Housing - Traffic - Air Quality
Public Services - Noise - Drainage and Hydrology - Hazards

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