FINAL

Finding of Suitability to Transfer #7 

for Carve-Outs II-F-1, II-Q, and II-V-1

Former Marine Corps Air Station

El Toro, California

July 2012

Base Realignment and Closure

Program Management Office West

1455 Frazee Road, Suite 900

San Diego, California 92108

Prepared under:

Naval Facilities Engineering Command 

Contract Number N62473-11-C-5001

DCN: ECS-5001-0000-0102
TABLE OF CONTENTS

i

ACRONYMS AND ABBREVIATIONS iii

1. PURPOSE 1

2. PROPERTY DESCRIPTION 1

3. REGULATORY COORDINATION 1

3.1 Resource Conservation and Recovery Act Part B Permit 

and Subtitle C Corrective Action 2

3.2 Resource Conservation and Recovery Act Subtitle I 

Corrective Action 3

3.3 Comprehensive Environmental Response, 

Compensation, and Liability Act 3

4. SUMMARY OF ENVIRONMENTAL CONDITIONS AND 

NOTIFICATIONS 4

4.1 CERCLA/RCRA 4

4.1.1 Carve-Out II-F-1 (Figure 3) 5

4.1.2 Carve-Out II-Q (Figure 4) 5

4.1.3 Carve-Out II-V-1 (Figure 5) 6

4.2 Petroleum Products and Derivatives 6

4.2.1 Carve-Out II-F-1 (Figure 3) 6

4.2.2 Carve-Out II-Q (Figure 4) 6

4.2.3 Carve-Out II-V-1 (Figure 5) 7

4.3 Asbestos-Containing Material 7

4.4 Lead-Based Paint 7

4.5 Polychlorinated Biphenyls 8

4.5.1 Carve-Out II-Q (Figure 4) 8

4.6 Pesticides 8

5. SUMMARY OF RESTRICTIONS 9

5.1 Petroleum Products and Derivatives 9

5.1.1 Carve-Out II-Q (Figure 6) 9

5.2 Asbestos-Containing Material 9

5.3 Lead-Based Paint 9

6. ADJACENT PROPERTIES 10

7. COVENANTS 10

8. ACCESS CLAUSE 11

9. FINDING OF SUITABILITY TO TRANSFER 11

10. REFERENCES 12
Contents

ii

TABLES

1 Buildings/Structures 

2 Environmental Requirements and Notifications

3 Potential Release Locations 

4 Locations of Concern 

5 Summary of Asbestos Surveys

6 Monitoring Wells

FIGURES

1 Vicinity Map

2 Carve-Out Areas Location Map

3 Carve-Out II-F-1

4 Carve-Out II-Q

5 Carve-Out II-V-1

6 Carve-Out II-Q Existing Buildings/Structures and Wells

ATTACHMENTS

1 Comments/Response to Comments

2 Unresolved Comments

3 Agency Correspondence

4a Hazardous Substances Notification Table

4b Petroleum Products Notification Table
ACRONYMS AND ABBREVIATIONS

iii

ACM asbestos-containing material

APHO aerial photograph feature/anomaly

ARPR area requiring petroleum restrictions

AST aboveground storage tank

BNI Bechtel National, Inc.

BRAC Base Realignment and Closure

CABACO/Tait CABACO/Tait Environmental Management, Inc.

CCR California Code of Regulations

CERP Covenant and Environmental Restriction on Property 

CFR Code of Federal Regulations

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CO carve-out

DERP Defense Environmental Restoration Program

DoD United States Department of Defense

DON United States Department of the Navy

DTSC California EPA/Department of Toxic Substances Control

e&e Ecology and Environment

EBS Environmental Baseline Survey

FAD friable, accessible, and damaged

FFA Federal Facility Agreement

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FOST Finding of Suitability to Transfer

HSC Health and Safety Code

IRP Installation Restoration Program

IT Corp. International Technology Corporation

JP5 jet propulsion fuel, grade 5

LBP lead-based paint

LLC Limited Liability Corporation

LOC location of concern

MCAS Marine Corps Air Station

MNA monitored natural attenuation

MSC Miscellaneous

NFA no further action

NFI no further investigation

NPL National Priorities List

OCHCA Orange County Health Care Agency
ACRONYMS AND ABBREVIATIONS

iv

OU Operable Unit 

OWS oil/water separator

PCB polychlorinated biphenyl

ppm parts per million

PRG Preliminary Remediation Goal

PRL potential release location

RACR Remedial Action Completion Report

RCRA Resource Conservation and Recovery Act

RFA RCRA Facility Assessment

RI Remedial Investigation

ROD Record of Decision

RWQCB California Regional Water Quality Control Board, Santa Ana Region

SVOC

SWMU

semi-volatile organic compounds

solid waste management unit

TAA temporary accumulation area

TFA truck fueling area

U.S. United States

U.S.C. United States Code

U.S. EPA United States Environmental Protection Agency

UST underground storage tank

VOC volatile organic compound
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1. PURPOSE

The purpose of this Finding of Suitability to Transfer (FOST) #7 is to summarize how the 

requirements and notifications for hazardous substances, petroleum products, and other regulated 

material within Carve-Outs (COs) II-F-1, II-Q, and II-V-1 at former Marine Corps Air Station 

(MCAS) El Toro have been satisfied by the United States Department of the Navy (DON). Through 

the Base Realignment and Closure (BRAC) process, the DON transferred, by deed(s), certain former 

MCAS El Toro real property in 2004. Other real property known as COs was retained by the DON, 

pending further investigation and cleanup to support determinations that the property is 

environmentally suitable for transfer. This FOST #7 was prepared in accordance with the 

Department of the Navy Base Realignment and Closure Program Management Office Policy for 

Processing Findings of Suitability to Transfer or Lease (BRAC 2008), Base Redevelopment and 

Realignment Manual (United States Department of Defense [DoD] 2006), and is consistent with the 

DoD Base Redevelopment and Implementation Manual (DoD 1997).

2. PROPERTY DESCRIPTION

Former MCAS El Toro is located in central Orange County, California (Figure 1) and was 

operationally closed in July 1999. The property proposed for transfer under this FOST #7 consists of 

3 COs comprising approximately 150.281 acres. Table 1 presents a summary of the existing 

remaining buildings and structures within the COs. Figure 2 is a base-wide map that provides the 

locations of the COs. A brief description of the COs follows:

 CO II-F-1 (Figure 3) – consists of approximately 26.459 acres located in the east-central 

portion of the former Station and contains no buildings or structures. The DON leased this 

CO to Heritage Fields, Limited Liability Corporation (LLC), who has subsequently assigned 

the lease for the majority of this CO to the City of Irvine.

 CO II-Q (Figures 4 & 6) – consists of approximately 83.702 acres located in the central 

portion of the former Station and contains Buildings 114, 124, 125, 126, 127, 230, 231, 363, 

372, 642, 658, 677, 698, 716, 747, 752, 763, 779, 903, 923, 938, 952, and 1804. CO II-Q 

also contains structures 396, 558, 559, 560, 561, 659, 904, 905, 906, 907, 908, 909, 910, and 

911. The DON leased this CO to Heritage Fields, LLC, who has subsequently assigned the 

lease for the majority of this CO to the City of Irvine.

 CO II-V-1 (Figure 5) – consists of approximately 40.120 acres located along the eastern 

edge of the former Station and contains no buildings or structures. The DON leased this CO 

to Heritage Fields, LLC, who has subsequently assigned the lease to the City of Irvine.

3. REGULATORY COORDINATION

Former MCAS El Toro was listed on the U.S. Environmental Protection Agency (U.S. EPA) 

National Priorities List (NPL) under the Comprehensive Environmental Response, Compensation, 

and Liability Act (CERCLA) in February 1990. The Defense Environmental Restoration Program 

(DERP), codified as 10 United States Code (U.S.C.) Sections 2701–2709, gave the DoD 

Environmental Restoration Program a statutory basis. The DON implements the DERP subject to, 

and in a manner consistent with, CERCLA and its regulations.

In October 1990, U.S. EPA Region 9, State of California Department of Health Services (now 

referred to as California EPA/Department of Toxic Substances Control [DTSC]), California 

Regional Water Quality Control Board, Santa Ana Region (RWQCB) and the DON signed a Federal 

Facility Agreement (FFA) (DON 1990). The U.S. EPA, DTSC, and RWQCB were notified of the 
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initiation of this FOST #7 and were issued copies for review. Regulatory agency comments to this

FOST #7 are provided in Attachment 1, and unresolved comments are provided in Attachment 2.

3.1 RESOURCE CONSERVATION AND RECOVERY ACT PART B PERMIT AND SUBTITLE C

CORRECTIVE ACTION

This FOST #7 reviews sites that were evaluated and addressed under the DON’s CERCLA and 

DERP authority as well as sites addressed under the corrective action requirements of the Resource 

Conservation and Recovery Act (RCRA) Subtitle C (for solid waste management units [SWMUs]),

RCRA Subtitle I (for underground storage tanks [USTs]) and associated state laws and regulations 

administered by the U.S. EPA, the State of California, and the County of Orange. These corrective 

action authorities are similar to CERCLA in that they require response/corrective action (cleanup) 

where necessary to ensure adequate protection of human health and the environment - see Section 

121(d) of CERCLA, Health and Safety Code (HSC) Section 25296.10(b), Title 23 California Code 

of Regulations (CCR) Sections 2720 (definition of “corrective action”) and 2725(c), and Title 22 

CCR Section 66264.101(a).

A decision that no action is required in order to protect human health and the environment, made by 

the DON or an environmental regulator under the laws and regulations listed above, also supports a 

DON determination under Section 120(h) of CERCLA that all remedial action necessary to protect 

human health and the environment with respect to any such substance remaining on the property has 

been taken.

Former MCAS El Toro was subject to a RCRA Part B permit that was issued in June 1993 and 

expired on 18 August 2003. The permit addressed one regulated unit (Building 673-T3) as well as 

RCRA corrective action requirements for SWMUs. The RCRA permit incorporated the FFA

(referred to as the “Agreement”) for MCAS El Toro by reference and provided, in relevant part: 

“The activities required by the Agreement are intended to satisfy the corrective action requirements 

of RCRA Section 3004(u) and (v), and 42 U.S.C. Section 6924(u) and (v). The Agreement and any 

schedules contained therein are hereby incorporated by reference as the schedule for completing 

corrective action at the facility...” (Subsection V.A.1 of the permit). The FFA itself specifically 

requires that RCRA corrective action requirements be addressed in the FFA process - see subsections 

1.1(b), 1.2(e), 3.1, 17.1, 17.2, 17.3, and 19 of the FFA (DON 1990).

The rationale for integrating CERCLA and RCRA corrective action requirements in this fashion is 

straightforward. The cleanup standard for CERCLA is set forth in Section 121 of CERCLA (Cleanup 

Standards), which states in the relevant part of Subsection 121(b)(1): “...The President shall select a 

remedial action that is protective of human health and the environment...” (42 U.S.C. Section 

9621(b)(1)). The cleanup standard for RCRA Subtitle C corrective action in the State of California,

as set forth in Title 22 CCR Section 66264.101(a), provides: “The owner or operator of a facility 

seeking a permit for the transfer, treatment, storage, or disposal of hazardous waste shall institute 

corrective action as necessary to protect human health and the environment for all releases of 

hazardous waste or constituents from any solid or hazardous waste management unit at the facility, 

regardless of the time at which waste was placed in such unit.” Also see HSC Sections 25187 and 

25200.10(b).

In a letter dated 8 March 1996, DTSC concurred with no further action (NFA) for Building 673-T3 

and stated that the permit was terminated based on the Closure Certification Report that was 

submitted by the DON (DTSC 1996a). The DON continues to complete all RCRA Part B permit 

corrective actions for the SWMUs under the FFA executed in 1990.
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DTSC has not made a RCRA Corrective Action Complete Determination for the property associated 

with this FOST #7. However, DTSC has reviewed the Navy's FOST #7 and concurs that the subject 

property is suitable for transfer in a manner that is protective of human health and the environment. 

See attached letters from DTSC to transferee(s) dated 30 July 2012 and 2 August 2012 (Attachment 

3).

3.2 RESOURCE CONSERVATION AND RECOVERY ACT SUBTITLE I CORRECTIVE ACTION

The Orange County Health Care Agency (OCHCA) and the RWQCB administer the UST corrective

action program at former MCAS El Toro pursuant to RCRA Subtitle I and Section 25280-25299.8 of 

the California HSC. The authority of OCHCA and the RWQCB to require corrective action at UST 

sites is set forth at Title 23 CCR, division 3, chapter 16.

These regulations specifically define “corrective action” as “...any activity necessary to investigate 

and analyze the effects of an unauthorized release; propose a cost-effective plan to adequately 

protect human health, safety, and the environment and to restore or protect current and potential 

beneficial uses of water; and implement and evaluate the effectiveness of the activity(ies)...” (Title 

23 CCR Section 2720). Furthermore, Section 2725(c) of the regulations sets forth requirements for 

corrective action plans prepared by responsible parties and states that: “The regulatory agency shall 

concur with the corrective action plan after determining that implementation of the plan will 

adequately protect human health, safety, and the environment and will restore and protect current or 

potential beneficial uses of water.”

NFA letters issued by the RWQCB and OCHCA are in accordance with Section 2721(e) of the 

regulations listed above which provides: “Upon completion of required corrective action, the 

regulatory agency shall inform the responsible party in writing that no further work is required at that 

time, based on available information.”

HSC Section 25296.10(a) provides that the State Water Resources Control Board “...shall develop 

corrective action requirements for health hazards and protection of the environment based on the 

severity of the health hazards and the other factors listed in subdivision (b)...” HSC Section 

25296.10(b) provides: “Any corrective action conducted pursuant to this chapter shall ensure 

protection of human health, safety, and the environment.”

The corrective action cleanup standard for USTs implemented by the RWQCB and OCHCA are 

codified in HSC Section 25296.10(b), Title 23 CCR 2720 (definition of "corrective action") and Title 

23 CCR 2725(c) (soil and water investigation phase, corrective action plan). While DTSC has not 

made a RCRA Corrective Action Complete Determination for the property associated with FOST #7, 

DTSC has reviewed this FOST #7 and concurs that the property is suitable for transfer in a manner 

that is protective of human health and the environment. DTSC has issued a letter to the transferee(s) 

clarifying the corrective action obligations for property associated with this FOST #7, including 

property that was investigated and cleaned up under the oversight of the RWQCB and the OCHCA 

(Attachment 3).

3.3 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT

CERCLA response actions are initiated at environmental sites where CERCLA hazardous substances 

have been or may have been released. There are two such areas known as Installation Restoration 

Program (IRP) sites in this FOST #7. CERCLA response actions have been completed at two IRP 

Sites: 4 and 25, as noted in Section 4.1. 
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4. SUMMARY OF ENVIRONMENTAL CONDITIONS AND NOTIFICATIONS

This section summarizes the environmental conditions and notifications as they relate to CERCLA 

and RCRA, petroleum products and derivatives, asbestos-containing materials (ACM), lead-based 

paint (LBP), and/or other regulated materials. Pursuant to 40 Code of Federal Regulations (CFR) 

Part 373, the deed(s) for the CERCLA-impacted COs will contain a notice of hazardous substances 

stored, released, or disposed of, if any, within the CO. This notice is provided in Attachment 4a, the 

Hazardous Substances Notification Table. Attachment 4b, the Petroleum Products Notification 

Table, lists the locations of concern (LOCs) associated with the storage of petroleum products only.

Table 2 identifies the environmental requirements and notifications applicable to the COs. Based on 

an evaluation of the MCAS El Toro Environmental Baseline Survey (EBS) of September 2003 

(Earth Tech 2003), hazardous substances, petroleum products, CERCLA, and RCRA response 

actions, storage tanks, oil/water separators (OWSs), ACM, LBP, and polychlorinated biphenyls 

(PCBs) were present or have occurred within the COs.

The EBS identified several facilities/features as being associated with a potential release of 

contaminants into the environment. These locations were first identified during the preparation of the 

2003 EBS, and are labeled potential release locations (PRLs). Subsequently, the FFA signatories 

agreed that the DON would prepare investigation plans, perform field evaluations, and provide 

conclusions as to whether a PRL needed to be included in a specific regulatory clean-up program, or 

whether no further investigation (NFI) was warranted. Table 3 and Table 4 identify and provide the 

status of the PRLs within the COs as indicated on Figure 4. Based on additional records reviews and 

soil sampling, it was determined that no significant release of hazardous substances or pollutants has 

occurred; therefore, NFI is warranted at the following PRLs:

 CO II-Q – PRL 114 (DTSC 2005a, U.S. EPA 2005a), PRL 235 (DTSC 2009a), PRL 372 

(DTSC 2009a), PRL 658 (DTSC 2005a, U.S. EPA 2005a), PRL 716 (DTSC 2009a), PRL 

747 (DTSC 2009a), and PRL 923 (DTSC 2005b, U.S. EPA 2005b). 

A petroleum release was identified at PRL 127, and PRL 127 is discussed in Section 4.2.2. Table 4 

identifies LOCs within the COs. LOCs are areas where a release is suspected to have occurred, a 

documented release has occurred, or based on the types of activities that occurred in the area, there 

was a potential for a release. The types of LOCs present within the COs include: hazardous 

substance sites, RCRA Facility Assessment (RFA) sites, temporary accumulation areas (TAAs), 

aerial photograph feature/anomaly (APHO) sites, IRP sites, aboveground storage tanks (ASTs), 

USTs, OWSs, miscellaneous (MSC) sites, PRL sites, and PCB-containing transformers and 

equipment. The LOCs within the COs proposed for transfer have received regulatory agency

concurrence for NFA with the exception of ongoing petroleum corrective actions for groundwater at:

1) UST 398 within CO II-Q, and: 2) MSC jet propulsion fuel, grade 5 (JP5) pipelines and associated 

truck fueling areas (TFAs) within CO II-Q. These sites with ongoing petroleum corrective actions for 

groundwater have received vadose zone soil NFA closure from the RWQCB, but will transfer with 

restrictions as noted in Section 5.1. NFA designations are based on the findings of evaluations or 

cleanup actions that these LOCs are suitable for transfer as long as the applicable notifications and 

restrictions outlined in Sections 4 and 5 respectively are adhered to. This includes LOCs that meet 

the federal and state definitions of SWMUs and received NFA designations either because no 

corrective action was required to provide adequate protection of human health and the environment, 

or the required corrective action has been completed.

4.1 CERCLA/RCRA

The following CERCLA/RCRA sites within the COs received closure and NFA. Site closure actions 

are detailed in Table 4.
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4.1.1 Carve-Out II-F-1 (Figure 3)

There are no CERCLA/RCRA LOCs within CO II-F-1.

4.1.2 Carve-Out II-Q (Figure 4)

APHO Sites – APHO 25 received site closure concurrence (DTSC 1999a, U.S. EPA 1999, RWQCB 

2000a). APHO 50 received site closure concurrence (DTSC 1999b, RWQCB 2000a). APHO 98

received site closure concurrence (DTSC 2004a, RWQCB 2003a). APHO 100 received site closure 

concurrence (DTSC 2003a, RWQCB 2003a).

IRP Sites

IRP Site 4: IRP Site 4 is located immediately southeast of Building 658, a former jet-engine testing 

facility. The Site is bounded by 9th Street to the south, Building 658 to the north and west, and Tank 

Farm No. 5 to the east. IRP Site 4 consists of two units: Unit 1 is an oil-stained area southeast of 

Building 658 which overlaps a concrete transformer pad, and Unit 2 is a drainage ditch which 

received runoff from a ferrocene spill.

The staining at Unit 1 was the result of oily discharges from Building 658, which were observed over 

an approximate 2-year period. The contamination at Unit 2 originated from an August 1983 spill, 

when the contents of a 500-gallon tank (wash water and residual jet fuel) reportedly overflowed 

during washing and spilled onto the ground, draining into a ditch adjacent to 9th Street. The spilled 

liquid reportedly contained approximately 5 gallons of ferrocene and a hydrocarbon carrier solution. 

Investigations conducted at IRP Site 4 include a Phase I Remedial Investigation (RI) and aerial 

photograph surveys in 1993. Volatile organic compounds (VOCs) and semi-volatile organic 

compounds (SVOCs) were below residential Preliminary Remediation Goals (PRGs) in both Units.

The human health and ecological risk assessments showed that the contaminants present in the soil 

do not present an unacceptable risk to human health or the environment. Therefore, no remedial 

action was required. The NFA Record of Decision (ROD) was signed on 30 September 1997 (DON 

1997).

During the RI for IRP Site 4, groundwater monitoring wells were installed near Building 658 and a 

release of petroleum to groundwater was detected. This release was attributed to jet fuel released 

from the nearby JP5 pipelines at the former JP5 TFA; the petroleum-impacted groundwater is known 

as the JP5 TFA Plume. The RWQCB has approved closure of the vadose zone soil for the MSC JP5 

pipeline segments and TFA features overlying the plume. An evaluation of natural attenuation of 

groundwater was completed in 2007, and the RWQCB concurred with monitored natural attenuation 

(MNA) with long-term monitoring as the groundwater remedy on 31 August 2007. The DON is 

conducting groundwater monitoring of the JP5 TFA Plume in accordance with the MNA remedy as 

required by the Monitored Natural Attenuation Evaluation and Long-Term Monitoring Plan, Former 

JP-5 Truck Fueling Area, Former Marine Corps Air Station, El Toro, California (Wiedemeier & 

Associates 2007). Figure 6 shows the location of the JP5 TFA Plume, and Section 5.1 summarizes 

restrictions related to petroleum products and its derivatives.

IRP Site 25. IRP Site 25 comprises Agua Chinon Wash, Bee Canyon Wash, Borrego Canyon Wash, 

and Marshburn Channel that flow through former MCAS El Toro. Three of these drainages (Agua 

Chinon Wash, Bee Canyon Wash, and Borrego Canyon Wash) are continuations of natural washes 

that originate in the Santa Ana Mountains. Surface drainage from the hills and upgradient irrigated 

farmland combines with runoff generated from extensive paved surfaces at former MCAS El Toro. 

The on-Station storm water system discharges to the drainage channels, which in turn flow into San 

Diego Creek. San Diego Creek discharges into upper Newport Bay, about 7 miles downstream from 
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its intersection with Marshburn Channel. The portion of IRP Site 25 addressed in this FOST #7 is 

Agua Chinon Wash which traverses CO II-Q.

IRP Site 25 includes drainages that had the potential to contaminate regional groundwater. The Site

was formed before the source of the regional VOC groundwater contamination had been identified at 

IRP Site 24. The Site was identified for a Phase II RI, but the drainages were investigated as part of 

the Phase I RI for Sites 18 and 24 to evaluate the source of the off-site VOC groundwater plume. 

Potential contamination within the major drainages and San Diego Creek was assessed by analyzing 

surface water, sediment, soil, and soil gas samples. Except for the Borrego Canyon Wash, metals and 

pesticides were detected above former MCAS El Toro background concentrations in all drainages. 

The human health and ecological risk assessments showed that the contaminants present in these 

media do not present an unacceptable risk to human health or the environment. Therefore, no 

remedial action was required. The Draft Final RI Report was completed in 1997 (Bechtel National, 

Inc. [BNI] 1997), and the IRP Site 25 Final ROD for NFA was signed on 30 September 1997 (DON 

1997).

RFA Sites – RFA 13 received site closure concurrence (DTSC 1996b). RFA 15 received site closure 

concurrence (DTSC 1996b). RFA 16 received site closure concurrence (DTSC 1996b). RFA 40 

received site closure concurrence (DTSC 1996b). RFA 41 received site closure concurrence (DTSC 

1996b). RFA 210 received site closure concurrence (DTSC 1996b). RFA 257 received site closure 

concurrence (DTSC 1996b). RFA 258 received site closure concurrence (DTSC 1996b).

TAA Sites – TAA 658 received site closure concurrence (DTSC 2004b). TAA 698 received site 

closure concurrence (DTSC 2004c). TAA 779 received site closure concurrence (DTSC 2004d).

4.1.3 Carve-Out II-V-1 (Figure 5)

There are no CERCLA/RCRA LOCs within CO II-V-1.

4.2 PETROLEUM PRODUCTS AND DERIVATIVES

The corrective action cleanup standards for petroleum USTs implemented by the RWQCB and 

OCHCA are codified in HSC Section 25296.10(b), Title 23 CCR 2720 (definition of "corrective 

action") and Title 23 CCR 2725(c) (soil and water investigation phase, corrective action plan). Site 

closure actions are detailed in Table 4.

4.2.1 Carve-Out II-F-1 (Figure 3)

There are no petroleum related LOCs within CO II-F-1. 

4.2.2 Carve-Out II-Q (Figure 4)

ASTs – AST 126 received site closure concurrence (RWQCB 2011a). AST 372 received site closure 

concurrence (RWQCB 2000b). AST 658 received site closure concurrence (DTSC 2003b).

USTs - UST 114A received site closure concurrence (RWQCB 1997a). UST 114B received site 

closure concurrence (RWQCB 1999a). UST 114C received site closure concurrence (OCHCA 2004). 

UST 126 received site closure concurrence (RWQCB 1996). UST 204 received site closure 

concurrence (RWQCB 2003b). UST 205 and UST 207 received site closure concurrence (OCHCA 

1998a). UST 206 received site closure concurrence (RWQCB 2008). UST 208, UST 209, UST 211,

UST 213, and UST 215 received site closure concurrence (OCHCA 1997a). UST 210, UST 212, and 

UST 214 received site closure concurrence (OCHCA 1996). UST 372A received site closure 

concurrence (OCHCA 2000a). UST 372B received site closure concurrence (RWQCB 1995). UST 

398 received NFA concurrence for vadose zone soil (RWQCB 2011b); however, the petroleum 

groundwater plume associated with UST 398 is part of an ongoing petroleum corrective action. The 
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area requiring petroleum restrictions (ARPR) for UST 398 is shown on Figure 6 and the restrictions 

are listed in Section 5.1. UST 658A and UST 658B recevied site closure concurrence (OCHCA 

1998b). UST 716A received site closure concurrence (OCHCA 1998c and RWQCB 1999b). UST 

763B received site closure concurrence (OCHCA 2000b). UST 902A, UST 902B, and UST 902C 

received site closure concurrence (OCHCA 2000c). UST T-6 received site closure concurrence 

(OCHCA 1997a). UST T-7 and UST T-8 received site closure concurrence (OCHCA 2000d). UST 

T-9 received site closure concurrence (OCHCA 1997b).

OWSs – OWS 658C and OWS 658D received site closure concurrence (RWQCB 2003c). OWS 

658E received site closure concurrence (RWQCB 2003d). OWS 716B received site closure 

concurrence (OCHCA 1998c and RWQCB 1999b). OWS 763A received site closure concurrence 

(OCHCA 2000b).

PRL Site – A petroleum release was identified and evaluated at PRL 127, and the RWQCB 

concurred with no further action (RWQCB 2009). 

MSC Sites – The portions of MSC JP5 pipelines with associated TFA within CO II-Q received 

vadose zone soil closure concurrence (RWQCB 2011c), however, the petroleum groundwater plume 

associated with the MSC JP5 pipelines and associated TFA is part of an ongoing petroleum 

corrective action. The ARPR is shown on Figure 6 and the restrictions are listed in Section 5.1. 

4.2.3 Carve-Out II-V-1 (Figure 5)

There are no petroleum related LOCs within CO II-V-1. 

4.3 ASBESTOS-CONTAINING MATERIAL

It is DoD policy to manage ACM in a manner protective of human health and the environment, and 

to comply with all applicable federal, state, and local laws and regulations governing ACM hazards 

(DoD 1994). Therefore, unless it is determined by a competent authority that ACM on the property 

poses a threat to human health at the time of transfer, all property containing ACM will be conveyed, 

leased, or otherwise disposed “as is” through the BRAC process. If ACM in a building does pose a 

threat to human health or the environment, occupation of the building will be prohibited until the 

ACM is abated or the building is demolished by a transferee. Remediation of ACM is not required in 

buildings that are scheduled for demolition by the transferee.

Buildings require a survey if they have never been surveyed for ACM; non friable, accessible, and 

damaged (FAD) ACM was detected in a survey that was conducted prior to but not since 1997 (i.e., 

not within the last three (3) years of Station operation) or they were surveyed for FAD ACM only 

and therefore, the presence of non-FAD ACM is unknown.

There are a total of 23 non-residential buildings and 14 structures within CO II-Q. A total of 17 nonresidential buildings within CO II-Q have been surveyed and the coating on a segment of the MSC 

JP5 pipeline within CO II-Q has been sampled for ACM. Information on the existence, extent, and 

condition of ACM at these buildings and structures is provided in Table 5. 

4.4 LEAD-BASED PAINT

Notification of potential LBP at buildings and structures is based on the age of construction (i.e., 

constructed before the Consumer Product Safety Commission’s 1978 ban on LBP for residential 

use). CO II-Q contains buildings and structures that were constructed prior to 1978 and, therefore, 

suggests the likelihood that LBP may be present. This in turn creates the possibility that, through the 

action of normal weathering and maintenance, there may be lead from LBP in the soil surrounding 
Final Finding of Suitability to Transfer #7 Finding of Suitability

July 2012 Former MCAS El Toro, California to Transfer

8

these buildings and structures. Construction dates for each of the buildings and structures in CO II-Q 

are summarized in Table 1. There are no buildings or structures located in CO II-F-1 or CO II-V-1. 

Demolition of non-residential buildings and structures constructed prior to 1978 creates the 

possibility of lead being found in the soil as a result of such activities. With respect to any such nonresidential buildings and structures which the transferee intends to demolish and redevelop for 

residential use after transfer, the transferee may, under applicable law or regulation, be required by 

DTSC or other regulatory agencies to evaluate the soil adjacent to such non-residential buildings and 

structures for soil-lead hazards, and to abate any such hazards that may be present after demolition of 

such non-residential buildings and structures, and prior to occupancy of any newly constructed 

residential buildings.

There are no residential buildings or structures associated with FOST #7. No LBP surveys were 

conducted for buildings and structures associated with FOST #7. See Section 5.3 for restrictions.

4.5 POLYCHLORINATED BIPHENYLS

The DON has investigated potential releases of PCBs into the environment pursuant to its CERCLA 

authority and did not identify any such releases that required CERCLA remedial action. Therefore, 

all necessary remedial action to address PCB releases has been taken.

Ballasts in fluorescent light fixtures made prior to 1979 may contain sealed PCB-containing 

components. A comprehensive survey at the former Station for PCB-containing light ballasts has not 

been conducted; however, it is assumed that buildings, structures, and facilities constructed prior to 

1979 have PCBs in the ballast of older light fixtures. It should be noted that many buildings that 

were constructed prior to 1979 have had interior renovations and new light fixtures installed that do 

not contain PCBs.

Fluorescent light ballasts manufactured before 1979 often contain PCB capacitors. No action is 

required at buildings, structures, and/or facilities unless large quantities of PCB-containing 

fluorescent light ballasts are removed. According to DON guidance on the disposal of fluorescent

light ballasts containing PCBs (DON 1989), when a large quantity of PCB capacitors needs to 

disposed, they should be handled as regulated PCB equipment. Fluorescent light ballasts that contain 

PCBs have approximately 1.0 to 1.5 ounces of PCB fluid in each capacitor. There are approximately 

3.1 to 4.7 pounds of PCB fluid for every 50 PCB small capacitors in fluorescent light ballasts. The 

transferee may, under applicable laws and regulations, be required by DTSC or other regulatory 

agencies to address disposal of light fixtures if they remove them following transfer of the property.

4.5.1 Carve-Out II-Q (Figure 4)

Transformers PCB T14, T20, T21, T58, T60, T89, and T94 within CO II-Q were replaced with a 

non-PCB transformer and no evidence of a release has been identified at these transformer locations 

(DTSC 2003c and U.S. EPA 2003). Transformer PCB T109 was removed during UST excavation 

activities related to former Tank Farm 6 (DTSC 2003c and U.S. EPA 2003), and no evidence of a 

release has been identified at this transformer location. Non-transformer PCB items with less than 10

parts per million (ppm) PCB concentrations were associated with Buildings 208 and 372. NFA was 

received at these non-transformer PCB locations (DTSC 2003c and U.S. EPA 2003).

4.6 PESTICIDES

The transferee is hereby notified that the property may contain pesticide residue from pesticides that 

have been applied in the management of the property. The DON knows of no use of any registered 

pesticide in a manner inconsistent with its labeling and believes that all applications were made in 

accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. Section 
Final Finding of Suitability to Transfer #7 Finding of Suitability

July 2012 Former MCAS El Toro, California to Transfer

9

136, et seq.), its implementing regulations, and according to the labeling provided with such 

substances. It is the DON position that it shall have no obligation under the covenants provided 

pursuant to Section 120(h)(3)(A)(ii) of CERCLA, 42 U.S.C. Section 9620(h)(3)(A)(ii), for the 

remediation of legally applied pesticides.

5. SUMMARY OF RESTRICTIONS

This section summarizes restrictions, if any, related to petroleum products and derivatives, ACM, 

and/or LBP. These restrictions ensure that post-transfer use of the CO areas is consistent with 

protection of human health and the environment.

5.1 PETROLEUM PRODUCTS AND DERIVATIVES

5.1.1 Carve-Out II-Q (Figure 6)

Former UST 398 and MSC JP5 pipelines with associated TFA – Former UST 398 and MSC JP5 

pipelines with associated TFA are part of an ongoing petroleum corrective action related to 

groundwater. Therefore, land use restrictions for these petroleum plume areas will be incorporated 

into and implemented through two separate legal instruments: (1) a quitclaim deed between the DON 

and the transferee and (2) a Covenant and Environmental Restriction on Property (CERP) 

(hereinafter referred to as the RWQCB Covenant) between the DON and the RWQCB.

In order to limit the exposure to petroleum and its derivatives and to maintain the integrity of the 

corrective action until the corrective action is complete, the RWQCB Covenant will restrict the 

following activities within the ARPR as shown on Figure 6 without prior review and approval from 

the DON and RWQCB:

 Any activity that causes or facilitates the movement of known contaminated groundwater;

 Alteration, disturbance, or removal of any component of a corrective action, including but 

not limited to, groundwater monitoring wells (Table 6) and associated equipment, or 

associated utilities;

 Extraction of groundwater and installation of new groundwater wells; and

 Removal of or damage to security features (for example, locks on monitoring wells, survey 

monuments, fencing, signs, or monitoring equipment and associated appurtenances).

5.2 ASBESTOS-CONTAINING MATERIAL

The transferee will be required to comply with the specific restrictions listed below for ACM that has 

been identified within CO-II-Q. Information on the existence, extent, and condition of ACM at 

buildings, structures, and MSC JP5 Pipelines within CO II-Q is provided in Table 5.

Except for short-term tours and emergency maintenance, access, use, or occupancy is prohibited 

pending either (1) completion of ACM surveys and completion of any necessary ACM abatement by 

the transferee or (2) demolition by the transferee, in accordance with all applicable local, state, and 

federal laws and other requirements relating to asbestos or ACM. Pending completion of abatement 

or demolition, the transferee shall manage the ACM in accordance with all such applicable local, 

state, and federal laws and requirements. This restriction is applicable to all buildings, structures, and 

MSC JP5 Pipelines located within CO II-Q.

5.3 LEAD-BASED PAINT

In its use and occupancy of the property, including, but not limited to: demolition of buildings, 

structures, and identification and/or evaluation of any LBP hazards, the transferee shall be 
Final Finding of Suitability to Transfer #7 Finding of Suitability

July 2012 Former MCAS El Toro, California to Transfer

10

responsible for managing LBP and LBP hazards in accordance with applicable federal, state, and 

local laws, and other requirements relating to LBP and LBP hazards.

Non-residential buildings and structures constructed prior to 1978 (Table 1) may not be used for 

residential use or child-occupied buildings and structures unless the transferee performs any 

necessary evaluation(s) and abatement in accordance with all federal, state, and local laws and other 

applicable requirements. This restriction applies to all buildings and structures located within CO 

II-Q (Table 1).

6. ADJACENT PROPERTIES

The COs in this FOST #7 are primarily adjoined by property previously transferred under the MCAS 

El Toro FOST of July 2004 (DON 2004), or subsequent FOSTs. A review of all the available 

information, including review of records from the RWQCB Geotracker website, as well as DTSC 

EnviroStor website, indicate no known sources of contamination on the adjoining properties.

However, the COs are also adjacent to COs remaining under DON that require additional 

remediation as described below.

CO II-Q is adjoined to the northeast by CO II-D (Figure 2). CO II-D includes IRP Site 3, Original 

Landfill. The Final ROD (DON 2008) documents the final selected remedy for soil and NFA for 

groundwater. The final selected remedy for soil includes a landfill cap, landfill gas monitoring and 

control system, groundwater monitoring, and institutional controls. Construction activities are 

complete and the landfill remedy is in place. The landfill remedy has achieved the Remedial Action 

Objectives specified in the Final ROD. As such, a Draft Remedial Action Completion Report 

(RACR) has been issued which also documents that the Site is protective of human health and the 

environment.

CO II-F-1 adjoins DON-retained CO II-F-2 and CO II-F-3. The CO II-F-3 is associated with former 

Tank Farm 555 area petroleum corrective action related to groundwater undergoing MNA (Figure 2). 

The CO II-V-1 adjoins DON retained CO II-V-2 which is associated with IRP Site 1 and IRP Site 2 

groundwater plumes undergoing remediation (Figure 2). Buffer zones within the retained COs are 

sufficient for containing the plumes and protect COs II-F-1 and II-V-1.

7. COVENANTS

The deed for transfer of CO II-V-1 on which there has been no release or disposal of hazardous 

substances or petroleum products or petroleum derivatives, and for which required regulatory 

concurrence as to such status has been obtained, will include a covenant made pursuant to CERCLA 

Section 120(h)(4)(D)(i). Such covenant will warrant that any response action or corrective action 

found to be necessary after the date of transfer shall be conducted by the U.S. This covenant shall not 

apply to any response action or corrective action required on the CO that is a result of an act or 

omission of the transferee.

The deed for transfer of CO II-Q and CO II-F-1 on which “any hazardous substance was stored for 

one year or more, [or] known to have been released, or disposed...” as a result of former activities 

conducted by the U.S., will include a covenant made pursuant to CERCLA Section 120(h)(3)(A)(ii) 

and (B). The covenant will warrant that all remedial action necessary to protect human health and the 

environment with respect to any hazardous substance remaining on the property has been taken 

before the date of transfer and that “any additional remedial action found to be necessary after the 

date of such transfer shall be conducted by the United States.” This covenant will not apply to any 

remedial action required on COs that is the result of an act or omission of the transferee that causes a 

new release of hazardous substances. 

(THIS PAGE LEFT INTENTIONALLY BLANK)
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10. REFERENCES

Base Realignment and Closure Program Management Office. 2008. Policy for Processing 

Findings of Suitability to Transfer or Lease. December.

Bechtel National, Inc. (BNI). 1997. Draft Final Phase II Remedial Investigation Report OU-3A

Sites. Marine Corps Air Station El Toro, California. March.

CABACO/Tait Environmental Management, Inc. (CABACO/Tait). 1999a. Asbestos and Lead 

Survey Report, MCAS, El Toro, California. October 15. 

______. 1999b. Asbestos and Lead Survey Report, MCAS, El Toro, California. June 15.

______. 1999c. Asbestos and Lead Survey Report, MCAS, El Toro, California. July 22.

California Department of Toxic Substances Control (DTSC). 1995. Concurrence Letter for 

Environmental Baseline Survey, Marine Corps Air Station, California. April 1995.

______. 1996a. Letter. Acceptance of Closure Certification: Hazardous Waste Storage Area 

(Building 673-T3) Marine Corps Air Station El Toro, Santa Ana, California (EPA ID No. CA 

6170023208). March.

______. 1996b. Final RCRA Facility Assessment (RFA) Approval: Marine Corps Air Station 

(MCAS) El Toro. July 23.

______. 1999a. No Further Action Concurrence for APHO 25. August 31.

______. 1999b. No Further Action Concurrence for APHO 50. November 30.

______. 2003a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 

Sites 83, 85, 87, 89, 90, 91, 95, 100, 102, 104, 108, 109, 112, 114, 116, 117, 119, 123, and 

124. June 25.

______. 2003b. No Further Action Concurrence Letter for Above Ground Storage Tank (AST) 658. 

March 10.

______. 2003c. Concurrence with the Final Environmental Baseline Survey dated September 25.

______. 2004a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 98. 

July 9.

______. 2004b. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA)

658. September 1.

______. 2004c. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 

698. September 28.

______. 2004d. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 

779. September 7.

______. 2005a. No Further Investigation Concurrence Letter for Group I Potential Release 

Locations (PRLs). July 13.
Final Finding of Suitability to Transfer #7 Finding of Suitability

July 2012 Former MCAS El Toro, California to Transfer

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______. 2005b. No Further Investigation Concurrence Letter for Group II Potential Release 

Locations (PRLs). November 2.

______. 2009a. No Further Investigation Concurrence with Final Summary Report for Group V 

Potential Release Locations (PRLs). February 4.

California Regional Water Quality Control Board (RWQCB), Santa Ana Region. 1995. No Further 

Action Concurrence Letter for Former UST 372B. December 11.

______ 1996. No Further Action Concurrence Letter for Former UST 126. March 12.

______ 1997a. No Further Action Concurrence Letter for Former UST Sites 114A, 295, 296, 435, 

455, 605A, and 606A. April 11.

______. 1999a. No Further Action Concurrence Letter for UST 114B. April 12.

______. 1999b. No Further Action Concurrence Letter for UST 716A and OWS 716B. April 14.

______. 2000a. No Further Action Concurrence Letter for APHOs 25 and 50. March 31.

______. 2000b. No Further Action Concurrence Letter for AST 372. August 28.

______. 2003a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 

Sites 87, 90, 98, 99, 100, and 109. August 14.

______. 2003b. No Further Action Concurrence Letter for UST 204. November 6.

______. 2003c. No Further Action Concurrence Letter for OWS 658C and 658D. January 8.

______. 2003d. No Further Action Concurrence Letter for OWS 658E. March 7.

______. 2008. No Further Action Concurrence Letter for UST 206. September 10.

______. 2009. No Further Action Concurrence Letter for PRL 127. July 23.

______. 2011a. No Further Action Concurrence for AST 126, Former Marine Corps Air Station, El 

Toro, Irvine, California. June 3.

______. 2011b. Closure For Petroleum Release – Vadose Zone Soils, Former Tank 398 Site, Former 

Marine Corps Air Station, El Toro, Irvine, California. March 11.

______. 2011c. Comments on the Information Package, Location of Concern MSC JP5 (JP5 

Pipelines) Former Marine Corps Air Station, El Toro, (Geotracker No. T0605964530). June 

17.

Department of Defense (DoD). See U.S. Department of Defense.

Department of the Navy (DON). See U.S. Department of the Navy.

Ecology and Environment (e&e) 1991. Asbestos Survey and Assessment , Camp Pendleton, El Toro 

and Tustin, Marine Corps Air Stations, California, Volume 1 Report. December.
Final Finding of Suitability to Transfer #6 Finding of Suitability

July 2012 Former MCAS El Toro, California to Transfer

14

Earth Tech. 2003. Final Environmental Baseline Survey, Former Marine Corps Air Station, El Toro, 

California. September.

______. 2005a. Summary Report for Group I Potential Release Locations, Environmental Baseline 

Survey, Former Marine Corps Air Station, El Toro, California. February.

______. 2005b. Summary Report for Group II Potential Release Locations, Environmental Baseline 

Survey, Former Marine Corps Air Station, El Toro, California. March.

———. 2008. Final Summary Report for Group V Potential Release Locations, Environmental 

Baseline Survey, Former Marine Corps Air Station, El Toro, California. December.

International Technology (IT) Corporation, 1989. Asbestos Survey and Assessment, MCAS, El Toro. 

March.

Jacobs Engineering Group (JEG). 1993. Marine Corps Air Station El Toro, El Toro, California, 

Installation Restoration Program, Resource Conservation and Recovery Act (RCRA) Facility 

Assessment Report. July.

______. 1995. Marine Corps Air Station El Toro, El Toro, California, Installation Restoration 

Program, Final Environmental Baseline Survey Report. April.

Orange County Health Care Agency (OCHCA). 1996. No Further Action Concurrence Letter for 

USTs 210, 212, and 214. September 20.

______. 1997a. No Further Action Concurrence Letter for USTs 208, 209, 211, 213, 215, and T-6. 

March 27.

______. 1997b. No Further Action Concurrence Letter for UST T-9. July 11.

______. 1998a. No Further Action Concurrence Letter for UST 205 and UST 207. April 24.

______. 1998b. No Further Action Concurrence Letter for UST 658A and UST 658B. April 24.

______. 1998c. No Further Action Concurrence Letter for UST 716A and OWS 716B. July 28.

______. 2000a. No Further Action Concurrence Letter for UST 372A. July 26.

______. 2000b. No Further Action Concurrence Letter for UST 763B and OWS 763A. July 26.

______. 2000c. No Further Action Concurrence Letter for USTs 902A, 902B, and 902C. August 4.

______. 2000d. No Further Action Concurrence Letter for UST T-7, UST T-8, and UST 726. July 26.

______. 2004. No Further Action Concurrence Letter for UST 114C. May 25.

U.S. Department of Defense (DoD). 1994. Asbestos, Lead Paint, and Radon Policies at BRAC 

Properties. Memorandum for Assistant Secretary of the Army (Installations, Logistics, and 

Environment); Assistant Secretary of the Air Force (Manpower, Reserve Affairs, Installations, 

and Environment); and Director, Defense Logistics Agency. Principle Assistant Deputy Under 

Secretary of Defense (Environmental Security). October.
Final Finding of Suitability to Transfer #7 Finding of Suitability

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______. 1997. Base Redevelopment and Implementation Manual. Office of the Deputy Under 

Secretary of Defense (Industrial Affairs and Installations). December.

______. 2006. Base Redevelopment and Realignment Manual. Office of the Deputy Under Secretary 

of Defense (Installations and Environment). March.

U.S. Department of the Navy (DON). 1989. Memorandum for T.J. Zagrobelny, Commander, Naval 

Facilities Engineering Command, referencing U.S. EPA memorandum on disposal 

requirements for PCB small capacitors. Subject: Disposal of Fluorescent Light Ballasts 

Containing PCBs.

______. 1990. Southwest Division, Naval Facilities Engineering Command (SWDIV). Federal 

Facility Agreement between the U.S. Marine Corps, U.S. EPA Region IX, California 

Department of Health Services, and State Water Resources Control Board.

______. 1997. Final Record of Decision, Operable Units 2A and 3A, No Action Sites, Marine Corps 

Air Station El Toro, California. Southwest Division, Naval Facilities Engineering Command, 

San Diego, California. September 30.

______. 2002a. Final Environmental Impact Statement for the Disposal and Reuse of Marine Corps 

Air Station, El Toro, California. March.

______. 2002b. Record of Decision, Disposal and Reuse of Marine Corps Air Station El Toro, 

California. April.

______. 2004. Final Finding of Suitability to Transfer (Parcel IV and Portions of Parcels I, II, and 

III), Former Marine Corps Air Station El Toro, California. July.

______. 2008. Final Record of Decision, Operable Unit 2C, Installation Restoration Program Sites 

3 and 5, Former Marine Corps Air Station, El Toro, California. March.

______. 2009. Base Realignment and Closure Program Management Office. Summary Report, JP5 

Building 363 Dry Well, Former Marine Corps Air Station, El Toro, California. May 27.

____. 2011. Base Realignment and Closure Program Management Office. Information Package, 

Location of Concern MSC JP5 (JP5 Pipelines), Former Marine Corps Air Station, El Toro, 

California. April 29.

United States Environmental Protection Agency (U.S. EPA) Region IX. 1999. No Further Action 

Concurrence for APHO 25. October 6.

______. 2003. Concurrence Letter for Final Environmental Baseline Survey (EBS) dated April 2003.

September 25.

______. 2005a. Concurrence Letter for Group I Potential Release Locations (PRLs). March 16.

______. 2005b. Concurrence Letter for Group II Potential Release Locations (PRLs). April 7.

Wiedemeier & Associates (Wiedemeier). 2007. Monitored Natural Attenuation Evaluation and 

Long-Term Monitoring Plan, Former JP-5 Truck Fueling Area, Former MCAS El Toro, 

California. June.
TABLES
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 1

Page 1 of 2

Table 1: Buildings/Structures 

CarveOutBuilding/Structure

Number Building/Structure/Description

Year of 

Construction Square Feet

Carve-Out II-Q

II-Q 114 Maintenance Hangar 1966 32,921

II-Q 124 Maintenance Hangar 1943 6,240

II-Q 125 Maintenance Hangar 1943 4,224

II-Q 126 Maintenance Hangar 1943 4,224

II-Q 127 Tire Storage Plant 1943 4,026

II-Q 230 Paint Locker 1943 78

II-Q 231 Paint Locker 1943 78

II-Q 363 Petroleum, oil, and lubricants (POL) Pipeline 

Shelter 1952 200

II-Q 372 Airfield Operations /Control Tower 1954 26,375

II-Q S396 Aircraft Truck Fueling <1958 140

II-Q S558 Aircraft Truck Fueling Facility <1973 160

II-Q S559 Aircraft Truck Fueling Facility <1973 160

II-Q S560 Aircraft Truck Fueling Facility <1973 160

II-Q S561 Aircraft Truck Fueling Facility <1973 160

II-Q 642 Electric Power Plant 1969 144

II-Q 658 Jet Engine Testing Facility 1972 2,894

II-Q S659 Storage Tank non potable water <1973

25,000 

Gallons

II-Q 677 Meteorological Building <1973 8

II-Q 698 Line Maintenance Shelter 1975 900

II-Q 716 Engine Test Cell / Hush House 1978 8,880

II-Q 747 Contract Refueler Facility 1983 1,200

II-Q 752 Fuel Farm No. 5 Office 1983 348

II-Q 763 Aircraft Washrack Utility Building 1984 684

II-Q 779 Hazardous Waste Collection Facility 1983 204

II-Q 903 Shelter <1997 315

II-Q S904 Aircraft Fueling Station <1997 800

II-Q S905 Aircraft Fueling Station <1997 800

II-Q S906 Aircraft Fueling Station <1997 800

II-Q S907 Aircraft Fueling Station <1997 800

II-Q S908 Aircraft Fueling Station <1997 800

II-Q S909 Aircraft Fueling Station <1997 800

II-Q S910 Aircraft Fueling Station <1997 800

II-Q S911 Aircraft Fueling Station <1997 800

II-Q 923 Drop Tank Rinse Facility 1993 576

II-Q 938 Vacant Hazardous Waste Storehouse <1997 272

II-Q 952 Hazardous Waste Storehouse <1997 272

II-Q 1804 Vacant Maintenance Hangar 1966 480

Source: Earth Tech 2003 and Enviro Compliance Solutions, Inc. (ECS) field visit and review of station records in April

2011
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 1

Page 2 of 2

Notes: Buildings/structures that have been demolished or removed are not shown.

Acronyms and Abbreviations:

ECS = Enviro Compliance Solutions, Inc.

MCAS = Marine Corps Air Station

POL = petroleum, oil, and lubricants

S = structure

< = before specified year
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 2

Page 1 of 1

Table 2: Environmental Requirements and Notifications

Applicable to Property

Carve-Out

Environmental Factors Considered II-F-1 II-Q II-V-1

Presence of Hazardous Substances (Notification) N Y N

CERCLA/RCRA (Response/Corrective Action) N Y N

Presence of Petroleum Products and Derivatives N Y N

UST/AST Storage Tanks (Closure/Removal) N Y N

Munitions and Explosives of Concern – Response Actions N N N

Asbestos-Containing Material N Y N

Lead-Based Paint N Y N

Polychlorinated Biphenyls N Y N

Pesticides (Agricultural) Y Y Y

Acronyms and Abbreviations:

 AST = Aboveground Storage Tank

 CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act

 MCAS = Marine Corps Air Station

 N = No

 RCRA = Resource Conservation and Recovery Act

 UST = underground storage tank

 Y = Yes
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 3

Page 1 of 2

Table 3: Potential Release Locations

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA and NFI Letter 

Agency/Date Notes

Carve-Out II-Q

PRL 114 114 Maintenance Hangar Summary Report 

for Group I PRLs

February 2005

by

Earth Tech

Department of Toxic 

Substances Control 

(DTSC)

07/13/2005

U.S. Environmental 

Protection Agency 

(U.S. EPA)

03/16/2005

Potential Release Location (PRL) 114 is associated with 

Maintenance Hangar 114. No siginificant staining or other evidence 

of release was observed at Building 114 and its vicinity during the

visual site inspection (VSI) in 2004. NFI was recommeded for PRL 

114 in the February 2005 Summary Report for Group I PRLs and 

regulatory concurrence was obtained. 

PRL 235 235 Former Bore Sighting 

Range/Pistol Range

Summary Report 

for Group V 

PRLs

December 2008

by

Earth Tech

DTSC

02/04/2009

This facility is a former bore sighting range/pistol range. Facility has 

been removed. All available records were reviewed and evaluated 

and NFI was recommeded for PRL 235 in the December 2008 

Summary Report for Group V PRLs. Regulatory concurrence on NFI

was obtained

PRL 372 372 Airfield Operations/Control 

Tower

Summary Report 

for Group V 

PRLs

December 2008

by

Earth Tech

DTSC

02/04/2009

PRL 372 is associated with Building 372. Pad mounted transformers 

were identified with stickers indicating less than 50 parts per million 

polychlorinated biphenyls. No leaks or stains were observed near the 

transformers. NFI was recommeded for PRL 372 in the December 

2008 Summary Report for Group V PRLs and regulatory concurrence 

was obtained.

PRL 658 658 Jet Engine Testing Facility Summary Report 

for Group I PRLs

February 2005

by

Earth Tech

DTSC

07/13/2005

U.S. EPA

03/16/2005

PRL 658 is associated with Building 658. No investigation activities 

were proposed for PRL 658 based on the review of previously 

completed investigations and closure. NFI was recommeded for PRL 

658 in the February 2005 Summary Report for Group I PRLs and 

regulatory concurrence was obtained.

PRL 716 716 Engine Test Cell / Hush 

House

Summary Report 

for Group V 

PRLs

December 2008

by

Earth Tech

DTSC

02/04/2009

PRL 716 is associated with Building 716. A possible release of a 

waste. Staining on concrete pad and nearby soil and stressed 

vegetation was observed during the 2004 VSI. A catch basin for 

stormwater is situated outside the building. Sumps and trench drains 

are situated in the facility. A floor drain was identified in a former 

engine test cell. A hydraulic pit is situated in the facility. Soil sampling 

was conducted in June 2005 and based on the review of the soil 

sampling data, NFI was recommeded for PRL 716 in the December 

2008 Summary Report for Group V PRLs and regulatory concurrence 

was obtained. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 3

Page 2 of 2

Table 3: Potential Release Locations

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA and NFI Letter 

Agency/Date Notes

PRL 747 747 Contract Refueler Facility Summary Report 

for Group V 

PRLs

December 2008

by

Earth Tech

DTSC

02/04/2009

PRL 747 is associated with Building 747. Stained areas were noted 

within concrete berm and at certain locations surrounding concrete 

bermed area during 2002 VSI. Possible releases of fuel may have 

occurred due to fuel sampling activities conducted in the past. Soil 

sampling was conducted in June 2005 and based on the review of 

the soil sampling data, NFI was recommeded for PRL 747 in the 

December 2008 Summary Report for Group V PRLs and regulatory 

concurrence was obtained. 

PRL 923 923 Drop Tank Rinse area 

runoff

Summary Report 

for Group II PRLs

March 2005

by

Earth Tech

DTSC

11/02/2005

U.S. EPA

04/07/2005

PRL 923 is associated with Building 923.This building was utilized as 

a drop tank rinse facility. A sump was observed in the northwestern 

portion of Building 923. Soil sampling was completed in January 

2005. NFI was recommeded for PRL 923 in the March 2005 

Summary Report for Group II PRLs and regulatory concurrence was 

obtained. 

Source: Earth Tech 2003 and Review of Records by Enviro Compliance Solutions, Inc., in April 2011.

Acronyms and Abbreviations

DTSC = Department of Toxic Substances Control

EBS = environmental baseline survey

ID = Identification

LOC = location of concern

MCAS = Marine Corps Air Station

NFA = no further action

NFI = no further investigation

PRL = potential release location

U.S. EPA = U.S. Environmental Protection Agency

VSI = visual site inspection
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 1 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

Carve-Out II-F-1

There are no CERCLA or Petroleum locations of concern (LOCs) within Carve-Out (CO) II-F-1

Carve-Out II-Q

APHO 25 Agua Chinon 

Wash

Disturbed Ground and 

Excavation

Summary Report, 

APHO 25, Mounded 

Material 

08/10/1999 

by 

Naval Facilities 

Engineering 

Command (NAVFAC) 

Engineering Field 

Division (EFD) 

Southwest (SW)

California 

Department of 

Toxic Substances 

Control (DTSC) 

08/31/1999 

U.S. EPA 

10/06/1999 

Regional Water 

Quality Control 

Board Santa Ana 

Region (RWQCB)

03/31/2000

APHO 25 is located near Agua Chinon Wash. Historical facility 

records were reviewed and a Summary Report recommending 

NFA was submitted in 1999. Regulatory concurrence on NFA 

has been obtained. 

APHO 50 Tank Farm No. 

5

Disturbed Ground and 

Excavation

Summary Report, 

APHO 50, Former 

Trench or other 

Linear Feature 

09/29/1999 

by 

NAVFAC EFD SW

DTSC 

11/30/1999 

RWQCB 

03/31/2000

APHO 50 was located near former Tank Farm 5 and Agua 

Chinon Wash. Historical facility records were reviewed and a 

Summary Report recommending NFA was submitted in 1999. 

Regulatory agency concurrence of NFA recommendation has 

been obtained.

APHO 98 372 Wet Soil Information Package, 

APHO 87, 90, 98, 99, 

100, and 109 

May 2003 

by 

NAVFAC EFD SW

RWQCB 

08/14/2003

DTSC 

07/09/2004

Identified on a 1967 photograph. Wet soil was noted near 

Facility 1793 and Facility 372, and near the edge of an aircraft 

parking apron. There were three former fuel storage tanks 

located adjacent to Facility 372 (Underground Storage Tanks 

[USTs] 902A, 902B, and 902C). The tanks were removed and 

the site was closed in 2000. NFA was recommended at Aerial 

Photograph Feature/Anomaly (APHO) 98, due to the proximity 

of this anomaly to a former fuel storage area. RWQCB and 

DTSC concurred with recommendation of NFA. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 2 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

APHO 100 114 Liquid Flowing Information Package, 

APHOs 87, 90, 98, 

99, 100, and 109 

May 2003 

by 

NAVFAC EFD SW

DTSC 

06/25/2003 

RWQCB 

08/14/2003

Identified on a 1967 photograph. Liquid was reported to be 

flowing from Facility 114. Facility 114 is adjacent to a former 

wash rack. The wash rack was evaluated and granted an NFA 

status in 1996. The tank (UST 763B) and Oil/Water Separator 

(OWS) 763A associated with the wash rack have been 

removed and closed. NFA was recommended for APHO 100 

based upon results of sampling for the wash rack and the 

removal of the associated tank and OWS. Based on a VSI 

conducted in June 2003, DTSC and RWQCB concurred with 

recommendation of NFA. 

IRP Site 4 658 Ferrocene Spill Area 

(Operable Unit [OU]-3)

Final Record of 

Decision (ROD), OU 

2A & 3A, No Action 

Sites

09/30/1997

by

NAVFAC SW

U.S.EPA, DTSC, 

RWQCB

09/30/1997

Installation Restoration Program (IRP) Site 4 consists of two 

units: Unit 1 is an oil-stained area southeast of Building 658 

which overlaps a concrete transformer pad, and Unit 2 is a 

drainage ditch which received runoff from a ferrocene spill.

The staining at Unit 1 was the result of oily discharges from 

Building 658, which were observed over an approximate 

2-year period. The contamination at Unit 2 originated from an 

August 1983 spill, when the contents of a 500-gallon tank 

(wash water and residual jet fuel) reportedly overflowed during 

washing and spilled onto the ground, draining into a ditch 

adjacent to 9th Street. The spilled liquid reportedly contained 

approximately 5 gallons of ferrocene and a hydrocarbon carrier 

solution

Investigations conducted at IRP Site 4 include a Phase I 

Remedial Investigation (RI) and aerial photograph surveys in 

1993. Volatile organic compounds (VOCs) and semi-volatile 

organic compounds (SVOCs) were below residential 

Preliminary Remediation Goals (PRGs) in both units. The 

human health and ecological risk assessments showed that 

the contaminants present in the soil do not present an 

unacceptable risk to human health or the environment. 

Therefore, no remedial action was required. The ROD was 

signed on 30 September 1997.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 3 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

During the RI of IRP Site 4, groundwater monitoring wells were 

installed near Building 658 and a release of petroleum to 

groundwater was detected. This release was attributed to jet 

fuel released from the nearby jet propulsion fuel, grade 5 (JP5)

pipelines at the former JP5 Truck Fueling Area (TFA); the 

petroleum-impacted groundwater is known as the JP5 TFA 

Plume. The RWQCB has approved closure of the vadose zone 

soil for the Miscellaneous (MSC) JP5 pipeline segments and 

TFA features overlying the plume. An evaluation of natural 

attenuation of groundwater was completed in 2007, and the 

RWQCB concurred with monitored natural attenuation (MNA) 

with long-term monitoring as the groundwater remedy on 31 

August 2007. The Department of the Navy (DON) is 

conducting groundwater monitoring of the JP5 TFA Plume in 

accordance with the MNA remedy as required by the 

Monitored Natural Attenuation Evaluation and Long-Term 

Monitoring Plan, Former JP-5 Truck Fueling Area, Former 

Marine Corps Air Station, El Toro, California. (Wiedemeier & 

Associates 2007).

IRP Site 25 N/A Major Drainages (OU2A)Final ROD, OU 2A & 

3A, No Action Sites

09/30/1997

by

NAVFAC SW

U.S. 

Environmental 

Protection Agency 

(U.S. EPA), 

DTSC, RWQCB

09/30/1997

IRP Site 25 consisted of four drainage channels that flow 

through or adjacent to the Station and receive storm water 

discharges from the Station. Concentrations of metals, 

pesticides, and petroleum products below levels requiring 

response actions were detected at the site. The NFA ROD was 

signed on 09/30/1997 

RFA 13 114 and 115 Drop Tank Storage 

Area

Final RFA report July 

1993 by Jacobs 

Engineering Group 

(JEG) and 

Final Addendum to 

RFA report May 1996 

by Bechtal National, 

Inc. (BNI)

DTSC 

07/23/1996

NFA status was identified in the final Resource Conservation 

and Recovery Act (RCRA) Facility Assessment (RFA) report 

(JEG 1993) and regulatory concurrence obtained.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 4 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

RFA 15 N/A Wash water Runoff Site 

associated with Aircraft 

Fueling Station

Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC 

07/23/1996

Wash water runoff site situated adjacent to former JP5 

Fueling Station 576. Site is inactive. NFA status identified in 

the final RFA report (JEG 1993) and DTSC concurred with 

NFA recommendation in a letter dated 07/23/96.

RFA 16 N/A Wash water Runoff Site 

associated with Aircraft 

Fueling Station

Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC

07/23/1996

Wash water runoff sites situated adjacent to former Fueling 

Station 574. Site is inactive. NFA status identified in the final 

RFA report (JEG 1993) and DTSC concurred with NFA 

recommendation in a letter dated 07/23/96.

RFA 40 127 Drum Storage Area Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC 

07/23/1996

RFA 40, a former drum storage area in the vicinity of Building 

127 and RFA 41, was not located during the RFA. The site 

was described in a letter dated June 23, 1989. NFA was 

recommended in the RFA report (JEG 1993) and regulatory 

concurrence was obtained in a letter dated 7/23/1996.

RFA 41 127 Vehicle Wash Rack Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC 

07/23/1996

RFA 41, a former vehicle wash rack, was located near Building 

127. Soil samples were collected during the RFA Sampling 

Visit. NFA was recommended in the RFA report (JEG 1993), 

and DTSC concurred with NFA recommendation in a letter 

dated 07/23/96. 

RFA 210 763 Vehicle Wash Rack Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC

07/23/1996

Inactive vehicle wash rack. NFA status was identified in final 

RFA report (JEG 1993) and DTSC concurred with NFA 

recommendation in a letter dated 07/23/96.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 5 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

RFA 257 N/A Wash water Runoff Site 

associated with Aircraft 

Fueling Station

Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC 

07/23/1996

Wash water runoff sites near former Aircraft Direct Fueling 

Station 575. Site is inactive. NFA status identified in the final 

RFA report (JEG 1993) and DTSC concurred with NFA 

recommendation in a letter dated 07/23/96.

RFA 258 N/A Wash water Runoff Site 

associated with Aircraft 

Fueling Station

Final RFA report July 

1993 by JEG 

and 

Final addendum to 

RFA report May 1996 

by BNI

DTSC 

07/23/1996

Wash water runoff sites near former Aircraft Direct Fueling 

Station 577. Site is inactive. NFA status identified in the final 

RFA report (JEG 1993) and DTSC concurred with NFA 

recommendation in a letter dated 07/23/96.

TAA 658 658 < 90-day Accumulation 

Point

Addendum to Closure 

Report for Temporary 

Accumulation Area 

658

05/27/2003

By

Shaw

DTSC

09/01/2004

Temporary Accumulation Area (TAA) 658 also known as Solid 

Waste Management Unit (SWMU)/Area of Concern (AOC) 

171. Site assessment and soil sampling was completed in 

March 2003. An addendum to closure report was submitted on 

05/27/2003 to DTSC and DTSC concurred with the NFA 

recommendation in a letter dated 09/01/2004.

TAA 698 698 < 90-day Accumulation 

Point

Closure Report

TAA 698

06/06/2003

By

Shaw

DTSC

09/28/2004

TAA 698 also known as SWMU/AOC 252. Soil sampling was 

completed in February 2003. A closure report was submitted 

on 06/06/2003 to DTSC and DTSC concurred with the NFA 

recommendation in a letter dated 09/28/2004. 

TAA 779 779 < 90-day Accumulation 

Point

Addendum to Closure 

Report

TAA 779

02/05/2003

By

IT Corp.

DTSC

09/07/2004

TAA 779 also known as SWMU/AOC 227. Soil sampling was 

completed in December 2002. An addendum to closure report 

was submitted on 02/05/2003 to DTSC and DTSC concurred 

with the NFA recommendation in a letter dated 09/07/2004. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 6 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

AST 126 126 300 Gallon Oil Tank Information Package, 

Aboveground 

Storage Tank (AST) 

126.

11/06/2001 

by 

NAVFAC EFD SW

RWQCB

06/03/2011

Tank has been removed. No releases identified. The RWQCB 

concurred with the NFA in a letter dated 06/03/2011. 

AST 372 372 275 Gallon Diesel Tank Summary Report, 

Former AST 372 

07/24/2000 

by 

NAVFAC EFD SW

RWQCB 

08/28/2000

Tank has been removed. NFA decision by RWQCB as of 

08/28/2000. 

AST 658 658 200 Gallon Ferrocene 

Tank

Information Package, 

AST 658 04/04/2002 

by 

NAVFAC EFD SW

DTSC 

03/10/2003

Formerly situated at Building 658 near IRP Site 4. Tank has 

been removed and NFA was received as of 03/10/2003. 

UST 114A 114 1,500 Gallon Fuel Oil 

Tank

Technical 

Memorandum, 

Former UST Sites 

114A, 295, 296, 435, 

455, 605A, and 606A 

03/21/1997 

by 

NAVFAC EFD SW

RWQCB 

04/11/1997

UST removal completed on 10/11/91. Site closed by RWQCB 

in an NFA letter dated 04/11/97. 

UST 114B 114 560 Gallon Diesel Tank Site Assessment 

Report, Former UST 

Site 114B 06/15/1998 

By OHM Remediation 

Services, Inc. (OHM)

RWQCB 

04/12/1999

Removal completed on 10/11/91. Site closed by RWQCB in an 

NFA letter dated 04/12/99.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 7 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST 114C 114 600 Gallon Fuel Oil 

Tank

Closure Report 

UST 114C

04/08/2004

by

Geofon, Inc. (Geofon) 

Orange County 

Health Care 

Agency (OCHCA)

05/25/2004

UST 114C was closed in place with OCHCA oversight on 

March 10, 2004. Tank contents were removed, tank closed in 

place, and soil samples were collected on March 10, 2004. 

Site closed by OCHCA in a letter dated 05/25/2004. 

UST 126 126 500 Gallon Diesel Tank Site Assessment 

Report, UST 126 

November 1995 

by 

BNI

RWQCB 

03/12/1996

UST 126 was removed on November 27, 1991 under the 

OCHCA oversight. Additional site assessment activities were 

completed in 1995. A site assessment report was submitted to 

RWQCB in November 1995. Site closed by RWQCB in an NFA 

letter dated 03/12/96.

UST 204 204 50,000 Gallon Diesel 

Tank

UST Removal 

Report, UST 204 

10/29/1999 

by 

Geofon and 

Addendum Site 

Assessment Report, 

UST 204 09/09/2003 

by 

Shaw

RWQCB 

11/6/2003

SWMU/AOC 60. Tank was formerly within Tank Farm No. 6. 

Tank has been removed. All required response actions have 

been completed. RWQCB concurred with NFA in a letter dated 

11/6/2003.

UST 205 205 25,000 Gallon 

Recovered JP5 Tank

Tank Closure Report, 

USTs 205 and 207 

03/18/1998 

by 

OHM

OCHCA 

04/24/1998

SWMU/AOC 61. Tank was formerly within Tank Farm No. 6. 

Removal completed on 12/29/97. Site closed by OCHCA in an

NFA letter dated 04/24/98. 

UST 206 206 50,000 Gallon 

Unleaded Fuel Tank

Summary Report

UST 206

July 2008

by

Enviro Compliance 

Solutions, Inc. 

RWQCB

09/10/2008

SWMU/AOC 62. Tank was formerly within Tank Farm No. 6. 

UST 206 was removed on 08/31/1999. From 2000 to 2008 

additional site assessment and excavation activities were 

completed. A Summary report was submitted to the RWQCB in 

July 2008 and RWQCB concurred with NFA in a letter dated 

09/10/2008. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 8 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST 207 207 50,000 Gallon 

Unleaded Fuel Tank

Tank Closure Report, 

USTs 205 and 207 

03/18/1998 

by 

OHM

OCHCA 

04/24/1998

SWMU/AOC 63. Tank was formerly within Tank Farm No. 6. 

Removal completed on 01/8/98. Site closed by OCHCA in an 

NFA letter dated 04/24/98. 

UST 208 208 50,000 Gallon Aviation 

Gas Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 to 

12/17/1996

by

American Processing

OCHCA 

03/27/1997

Tank was formerly within Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA 

letter dated 03/27/97. 

UST 209 209 25,000 Gallon Aviation 

Gas Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 to

12/17/1996

by

American Processing

OCHCA 

03/27/1997

Tank was formerly within Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA 

letter dated 03/27/97.

UST 210 210 25,000 Gallon Aviation 

Gas, JP5 Tank

Tank Removal 

Closure Report for 

USTs at Tank Farm 

No. 5 

08/01/1996

by

Toxguard

OCHCA

09/20/1996

Tank was formerly within Tank Farm No. 5. Removal 

completed on 06/14/96. Site closed by OCHCA in an NFA 

letter dated 09/20/96.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 9 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST 211 211 50,000 Gallon Aviation 

Gas Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 to 

12/17/1996

by

American Processing

OCHCA 

03/27/1997

Tank was formerly within Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA 

letter dated 03/27/97.

UST 212 212 50,000 Gallon Aviation 

Gas, JP5 Tank

Tank Removal 

Closure Report for 

USTs at Tank Farm 

No. 5 

08/01/1996

by

Toxguard

OCHCA

09/20/1996

Tank was formerly within Tank Farm No. 5. Removal 

completed on 6/14/96. Site closed by OCHCA in an NFA letter 

dated 09/20/96. 

UST 213 213 25,000 Gallon Aviation 

Gas Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 to 

12/17/1996

by

American Processing

OCHCA

03/27/1997

Tank was formerly within Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA 

letter dated 03/27/97.

UST 214 214 25,000 Gallon Aviation 

Gas, JP5 Tank

Tank Removal 

Closure Report for 

USTs at Tank Farm 

No. 5 

08/01/1996

by

Toxguard

OCHCA

09/20/1996

Tank was formerly within Tank Farm No. 5. Removal 

completed on 06/14/96. Site closed by OCHCA in an NFA 

letter dated 09/20/96.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 10 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST 215 215 50,000 Gallon Aviation 

Gas Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 to 

12/17/1996

by

American Processing

OCHCA

03/27/1997

Tank was formerly within Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA

letter dated 03/27/97.

UST 372A 372 2,000 Gallon Diesel 

Tank

UST removal report, 

UST 372A 6/12/2000 

by 

Geofon

OCHCA 

07/26/2000

Removal completed on 02/28/00. No evidence of a release 

was identified. Site closed by OCHCA in an NFA letter dated 

07/26/00.

UST 372B 372 2,500 Gallon Diesel 

Tank

Site assessment 

report, UST 372 

8/1995 

by 

BNI

RWQCB 

12/11/1995

Removal completed on 02/28/94. Site closed by RWQCB in an 

NFA letter dated 12/11/95. 

UST 398 398 108,000 Gallon JP5 

Tank

Information Package

Former Tank 398 Site

01/27/2011

by 

DON Base 

Realignment and 

Closure (BRAC) 

Program 

Management Office 

(PMO) West

RWQCB

03/11/2011

UST 398 was removed in 1993. A Remedial Action Plan for 

MNA of groundwater and free product removal was approved 

by RWQCB in December 2006. A five year MNA 

demonstration with free product removal is on going since 

2007. 

A Summary Information Package with NFA for vadose zone 

soil at former UST 398 Site was submitted on January 27, 

2011 to the RWQCB. The RWQCB in a letter dated March 11, 

2011 closed the vadose zone soil at former UST 398 Site. 

The area requiring petroleum restrictions (ARPR) for former 

UST 398 Site addressed in this Finding of Suitability to 

Transfer (FOST) affects the CO II-Q.

UST 658A 658 10,000 Gallon JP5 

Tank

Tank closure report, 

USTs 658A and 658B 

03/27/1998 

by 

OHM

OCHCA 

04/24/1998

Removal completed on 01/26/98. Site closed by OCHCA in an 

NFA letter dated 04/24/98.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 11 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST 658B 658 10,000 Gallon JP5 

Tank

Tank closure report, 

USTs 658A and 658B 

03/27/1998 

by 

OHM

OCHCA 

04/24/1998

Removal completed on 1/26/98. Site closed by OCHCA in an 

NFA letter dated 04/24/98. 

UST 716A 716 3,000 Gallon Waste Oil 

Tank

Tank closure report, 

UST 716A and OWS 

716B 

05/13/1998 

by 

OHM

OCHCA

07/28/1998 

RWQCB 

04/14/1999

SWMU/AOC 192. Tank closed in place. Site closed by OCHCA 

in a letter dated 07/28/98 and by RWQCB in an NFA letter 

dated 04/14/99.

UST 763B 763 500 Gallon Waste Oil 

Tank

UST & OWS removal 

report, UST 763B & 

OWS 763A 

6/12/2000 

by 

Geofon

OCHCA 

07/26/2000

SWMU/AOC 212. Removal completed on 02/28/00. Site 

closed by OCHCA in an NFA letter dated 07/26/00. 

UST 902A 902 50,000 Gallon JP5 

Tank

UST removal report, 

UST 902A 7/11/2000 

by 

Geofon

OCHCA 

08/04/2000

Tank has been removed. Site closed by OCHCA in an NFA 

letter dated 08/04/00. 

UST 902B 902 50,000 Gallon JP5 

Tank

UST removal report, 

UST 902C 7/11/2000 

by 

Geofon

OCHCA 

08/04/2000

Tank has been removed. Site closed by OCHCA in an NFA 

letter dated 08/04/00. 

UST 902C 902 2,500 Gallon JP5 Tank UST removal report, 

UST 902C 7/11/2000 

by 

Geofon

OCHCA 

08/04/2000

Tank has been removed. Site closed by OCHCA in an NFA 

letter dated 08/04/00. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 12 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

UST T-6 T-6 2,000 Gallon Waste 

JP5 Tank

Tank Removal Field 

Activities, Tank 208, 

209, 211, 213, 215, 

and T-6 

12/16/1996 & 

12/17/1996

by

American Processing

OCHCA 

03/27/1997

SWMU/AOC 21. Associated with Tank Farm No. 5. Removal 

completed on 12/16/96. Site closed by OCHCA in an NFA 

letter dated 03/27/97. 

UST T-7 T-7 2,000 Gallon Waste 

JP5 Tank

UST Removal 

Report, UST T-7 

06/12/2000 

by 

Geofon

OCHCA 

07/26/2000

SWMU/AOC 24. Associated with Tank Farm No. 6. Removal 

completed on 02/28/00. No evidence of a release was 

identified. Site closed by OCHCA in an NFA letter dated 

07/26/00.

UST T-8 T-8 2,000 Gallon Waste 

JP5 Tank

UST Removal 

Report, UST T-8 

06/12/2000 

by 

Geofon

OCHCA

07/26/2000

SWMU/AOC 22. Associated with Tank Farm No.5. Removal 

completed on 02/28/00. Site closed by OCHCA in an NFA 

letter dated 07/26/00.

UST T-9 T-9 2,000 Gallon JP5 Tank Tank Removal and 

Site Closure Report, 

UST T-9 

06/16/1997 

by 

OHM

OCHCA

07/11/1997

SWMU/AOC 228. Associated with Tank Farm No.6. Removal 

completed on 03/27/97. Site closed by OCHCA in an NFA 

letter dated 07/11/97.

OWS 658C 658 400 Gallon OWS Site Assessment 

Report, OWS 658C 

and 658D 12/31/1998 

by 

NAVFAC EFD SW

RWQCB

01/08/2003

OWS installed in 1972; OWS closed in place. OWS was an 

underground unit and was not associated with a UST. Site 

closed by RWQCB in an NFA letter dated 01/08/2003. 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 13 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

OWS 658D 658 1,750 Gallon OWS Site Assessment 

Report, OWS 658C 

and 658D 12/31/1998 

by 

NAVFAC EFD SW

RWQCB 

01/08/2003

OWS installed in 1995. OWS closed in place. OWS was an 

aboveground unit and was not associated with a UST. Site 

closed by RWQCB in an NFA letter dated 01/08/2003. 

OWS 658E 658 10 Gallon OWS Memorandum, OWS 

658E 

01/23/2003 

by 

NAVFAC EFD SW

RWQCB

03/07/2003

OWS was removed and backfilled in November 2002. Soil 

samples were taken during this removal action. Site closed by 

RWQCB in an NFA letter dated 03/07/2003. 

OWS 716B 716 100 Gallon OWS Tank Closure Report, 

UST 716A and OWS 

716B 

05/13/1998 

by 

OHM

OCHCA 

07/28/1998 

RWQCB

04/14/1999

Site also identified as SWMU/AOC 193. OWS was installed in 

1976. OWS has been removed. OWS was associated with 

UST 716A. Site was investigated and recommended for NFA 

by the RFA based on the results of soil sampling. Site closed 

by OCHCA in a letter dated 07/28/98 and by RWQCB in an 

NFA letter dated 04/14/99.

OWS 763A 763 100 Gallon OWS UST & OWS 

Removal Report, 

UST 763B & OWS 

763A 

06/12/2000 

by 

Geofon

OCHCA

07/26/2000

Site also identified as SWMU/AOC 211. OWS installed in 

1982. OWS has been removed. OWS was associated with 

UST 763B. Site was investigated and NFA was recommended 

in the RFA based on soil sample results. No significant soil 

contamination was identified at this site. Site closed by 

OCHCA in an NFA letter dated 07/26/00.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 14 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

MSC JP5 CO-II-Q Fuel Pipelines and 

Associated Truck 

Fueling Areas

Closure Report

MSC JP5 Units 1 and 

3

06/26/2001

by OHM

Information Package 

MSC JP5 Pipelines

04/29/2011

by

DON BRAC PMO 

West

RWQCB

06/17/2011

The JP5 pipelines and all associated TFA features within CO 

II-Q are inactive. Pipelines have been abandoned in place. 

Pipeline segments and associated features were separately 

investigated and closed by the RWQCB. NFA concurrence 

was obtained for all the segments of MSC JP5 pipelines and 

associated TFA features from the RWQCB.

The groundwater plume underlying the MSC JP5 pipelines 

segments and associated TFA encompasses the area beneath 

former Tank Farm No. 5, former Tank Farm No. 6, the former 

TFA, and IRP Site 4. The RWQCB has closed the vadose 

zone soil for the MSC JP5 pipeline segments and TFA features 

overlying the plume. An evaluation of natural attenuation of 

groundwater was completed in 2007, and the RWQCB 

concurred with monitored natural attenuation as the 

groundwater remedy on 31 August 2007.

The ARPR for MSC JP5 pipeline and associated TFA plume 

addressed in this FOST affects the CO II-Q.

PRL 127 127 Tire Storage Plant Summary Report for 

PRL 127

05/15/2009

By 

DON, BRAC PMO 

WEST

RWQCB

07/23/2009

Building 127 was a former propeller shop with floor drains and 

trench drains in the facility. A wash rack, RFA 41 was 

associated with the operations. During the 2005 EBS update 

VSI visit, petroleum impacted soils were identified in a small 

area southwest of Building 127. In 2009, exploratory 

excavation and soil sampling was completed. A Summary 

Report was submitted to RWQCB on 05/15/2009 and Potential 

Release Location (PRL) 127 was closed by RWQCB in a letter 

dated 07/23/2009. 

PCB T14 114 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-polychlorinated biphenyl (PCB) 

transformer. A 1994 field survey indicates no evidence of 

release. No PCB releases identified through the records 

search or VSIs conducted for the 2003 EBS.

PCB T20 125 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. A 1994 field survey 

indicates no evidence of release. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 15 of 16

Table 4: Locations of Concern

LOC ID

Building 

Number/ 

Location Description

Closure Report 

Title/Date

NFA Letter 

Agency/Date Notes

PCB T21 125 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. A 1994 field survey 

indicates no evidence of release. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.

PCB T58 372 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. A 1994 field survey 

indicates no evidence of release. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.

PCB T60 378 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. A 1994 field survey 

indicates no evidence of release. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.

PCB T89 658 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. A 1994 field survey 

indicates no evidence of release. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.

PCB T94 716 Transformer Pad Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Replaced with a non-PCB transformer. No evidence of release 

observed during 1994 field survey. No PCB releases identified 

through the records search or VSIs conducted for the 2003 

EBS.

PCB T109 Tank Farm No. 

6

Transformer Pole Final EBS 

09/12/2003

by

Earth Tech

DTSC 

09/25/2003

U.S. EPA 

09/25/2003

Building demolished; no evidence of release observed during 

1994 field survey. No PCB releases identified through the 

records search or VSIs conducted for the 2003 EBS.

Carve-Out II-V-1

There are no CERCLA or Petroleum LOCs within CO II-V-1

Acronyms and Abbreviations

AOC = area of concern

APHO = aerial photograph feature/anomaly

ARPR = area requiring petroleum restrictions

AST = aboveground storage tank 

BNI = Bechtel National, Inc.

IT Corp. = IT Corporation

JEG = Jacobs Engineering Group

JP5 = jet propulsion fuel, grade 5

< = less than

LOC = location of concern 

MCAS = Marine Corps Air Station

RCRA = Resource Conservation and Recovery Act

RI = remedial investigation

RFA = RCRA facility assessment

ROD = Record of Decision

RWQCB = Regional Water Quality Control Board

= Santa Ana Region
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 4

Page 16 of 16

BRAC = Base Realignment and Closure

CERCLA = Comprehensive Environmental Response,

= Compensation, and Liability Act

CO = Carve-Out

DON = Department of the Navy

DTSC = California Department of Toxic Substances

= Control

EBS = environmental baseline survey

EFD = Engineering Field Division 

FOST = finding of suitability to transfer

Geofon = Geofon, Inc.

ID = identification

IRP = installation restoration program

MNA = monitored natural attenuation

MSC = miscellaneous

N/A = not applicable

NAVFAC = Naval Facilities Engineering Command 

NFA = no further action

OCHCA = Orange County Health Care Agency

OHM = OHM Remediation Services, Inc.

OU = operable unit

OWS = oil/water separator

PCB = polychlorinated biphenyl

PMO = Project Management Office

PRG = preliminary remediation goal

PRL = potential release location

SVOC = semi-volatile organic compounds

SW = southwest

SWMU = solid waste management unit

TAA = temporary accumulation area

TFA = truck fueling area

UST = underground storage tank

U.S. EPA = United States Environmental 

Protection Agency

VSI = visual site inspection

VOC = volatile organic compound
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 5

Page 1 of 2

Table 5: Summary of Asbestos Surveys

Building 

Number Description Square Feet Year Built

Historical Asbestos Survey 

Information Comments

Carve-Out II-Q

114 Maintenance Hangar 32,921 1966 IT Corporation (IT Corp.) [1989]: Floor 

tile, transite, pipe 

insulation.CABACO/Tait Environmental 

Management, Inc. (CABACO/Tait);

(6/15/99): Stucco, pipe elbows, floor tile 

& mastic, window putty, boiler flue, 

exterior mastic, wall panels, drywall joint 

compound

Non-friable, acessible, and damaged 

(FAD) asbestos-containing material 

(ACM) found.

124 Maintenance Hangar 6,240 1943 CABACO/Tait (10/15/99): Stucco Non-FAD ACM found; no interior ACM 

observed.

125 Maintenance Hangar 4,224 1943 IT Corp. (1989): Floor tile. CABACO/Tait 

(7/22/99): Stucco, cement ceiling 

(assumed)

Non-FAD ACM found.

126 Maintenance Hangar 4,224 1943 IT Corp. (1989): No ACM Found No ACM found.

127 Tire Storage Plant 4,026 1943 IT Corp. (1989): No ACM Found No ACM found.

230 Paint Locker 78 1943 IT Corp. (1989): No ACM Found No ACM found.

231 Paint Locker 78 1943 IT Corp. (1989): No ACM Found No ACM found.

363 Petroleum, Oil, and Lubricants (POL)

Pipeline Shelter

200 1952 Ecology & Environment, Inc. (e&e)

[1991]: No ACM Found

No ACM found.

372 Airfield Operations /Control Tower 26,375 1954 IT Corp. (1989): Transite, vibration 

dampener, pipe insulation, floor tile. 

CABACO/Tait (6/15/99): Ceiling panels, 

drywall joint compound, floor tile & 

mastic, pipe insulation, duct connectors 

(assumed), cement panels (assumed).

Non-FAD ACM found.

642 Electric Power Plant 144 1969 e&e (1991): No ACM Found No ACM found.

658 Jet Engine Testing Facility 2,894 1972 e&e (1991): Floor tile, noise and 

fireproofing panels

Non-FAD ACM found. 

677 Meteorological Building 8 <1973 e&e (1991): No ACM Found No ACM found.

698 Line Maintenance Shelter 900 1975 e&e (1991): Floor tile, roofing Non-FAD ACM found. 

716 Engine Test Cell / Hush House 8,880 1978 e&e (1991): Floor tile, fireproofing 

panels. CABACO/Tait (10/15/99): Floor 

tile mastic

Non-FAD ACM found.
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 5

Page 2 of 2

Table 5: Summary of Asbestos Surveys

Building 

Number Description Square Feet Year Built

Historical Asbestos Survey 

Information Comments

747 Contract Refueler Facility 1,200 1983 IT Corp. (1989): No ACM Found No ACM found.

752 Fuel Farm No. 5 Office 348 1983 e&e (1991): Roofing Non-FAD ACM found; no interior ACM 

observed. 

1804 Vacant Maintenance Hangar 480 1966 e&e (1991): Floor tile Non-FAD ACM found. 

MSC JP5 Portions of the Miscellaneous (MSC)

Jet Propulsion Fuel, Grade 5 (JP5)

pipeline 

Unknown Many 

segments 

<1960.

Some 

segments 

Unknown.

Department of the Navy (DON) [2009]: 

pipeline outer tar coating 

A sample of the black tarry coating on 

a segment of the JP5 pipeline near the 

JP5 Building 363 Dry Well was 

analyzed for asbestos in order to 

characterize the coated pipeline for 

disposal. The sampling activity is not 

considered similar to an asbestos 

survey for buildings or structures. The 

sampling activity is included in Table 5 

in order to disclose the presence of 

asbestos in the coating. Non-FAD ACM 

found.

Source: Earth Tech 2003 and Review of Records by Enviro Compliance Solutions, Inc., in 2011.

Notes: The information presented in this table was obtained from the listed source.

Acronyms and Abbreviations

ACM = asbestos-containing material 

CABACO/Tait = CABACO/Tait Environmental Management, Inc.

DON = Department of the Navy

e&e = Ecology & Environment, Inc.

FAD = friable, accessible, and damaged 

IT Corp. = IT Corporation

JP5 = jet propulsion fuel, grade 5

MCAS = Marine Corps Air Station

MSC = Miscellaneous

POL = petroleum, oil, and lubricants

< = before specified year 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Table 6

Page 1 of 1

Table 6: Monitoring Wells

Carve Out Well ID Purpose

Carve-Out II-Q (Figure 6)

II-Q 03LYS1 Leachate Monitoring

II-Q 04UGMW63 Groundwater Monitoring

II-Q 04 DGMW66A Groundwater Monitoring

II-Q ASMW398-01 Groundwater Monitoring

II-Q ASMW398-02 Groundwater Monitoring

II-Q MW398-01R Groundwater Monitoring

II-Q MW398-4 Groundwater Monitoring

II-Q MW398-6 Groundwater Monitoring

II-Q MW398-12 Groundwater Monitoring

II-Q MW398-13 Groundwater Monitoring

II-Q MW398-17 Groundwater Monitoring

II-Q MW398-19D Groundwater Monitoring

II-Q MW398-21R Groundwater Monitoring

II-Q MW398-26 Groundwater Monitoring

II-Q MW398-28 Groundwater Monitoring

II-Q MW398-29 Groundwater Monitoring

II-Q MW398-30 Groundwater Monitoring

II-Q MW398-31 Groundwater Monitoring

II-Q RW398-01 Groundwater Monitoring

II-Q RW398-02 Groundwater Monitoring

II-Q TF6MW-01 Groundwater Monitoring

II-Q TF6MW-02 Groundwater Monitoring

II-Q TFAMW-01 Groundwater Monitoring

II-Q TFAMW-02 Groundwater Monitoring

II-Q TFAMW-03 Groundwater Monitoring

Source:

Earth Tech 2003 

Enviro Compliance Solutions, Inc. Field Visit and Records Review in April 2011.

 Accronyms and Abbreviations:

ASMW = Air Sparge Monitoring Well

DGMW = Downgradient Monitoring Well

ID = Identification

LYS = Lysimeter

MCAS = Marine Corps Air Station

MW = Monitoring Well

RW = Recovery Well

UGMW = Upgradient Monitoring Well

TF = Tank Farm

TFA = Truck Fueling Area 
FIGURES
Figure 1

Vicinity Map

Finding of Suitability 

to Transfer (FOST #7)

Former MCAS El Toro, California

Source:

Final Environmental Baseline Survey,

Former Marine Corps Air Station

El Toro, California. Earth Tech 2003 3

Former MCAS El Toro

Project Location

P A C I F I C O C E A N

0 10 20 5

Miles
III-B-3

III-B-3 II-H

II-F-1

II-V-1

II-Q II-D

II-C

Site 1

II-V-2

II-F-2

II-F-3
 II-F-1

II-F-2

II-F-3

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!

A!
[_

[_

[_

[_

!= !=

!=

"/

"/

"/ #0

#0

#0

#0

#0

#0

#0

$1

$1

$1

$1

$1

$1 $1

$1

")

#*

#*

#*

#*

#*

APHO 98

APHO 100

APHO 50

PRL 747

PRL 716

PRL 658

[_

[_

[_

#0

PCB T21

MSC JP5

IRP S

MSC JP5

MSC JP5

642

372

677

779

903

S904

S906

231

124

114

1804

952

698

S558 363

S560

752

125

S561

763

S907

S905

S910 S911

S908 S909

230

S559

747

S396

938

923

S659

658

126

127

716

PRL 127[_

#0

UST 398

UST 20

UST 208 UST 

UST 210

U

UST 212 

US

UST T

UST T-8

UST 204

UST T-7

UST 207

UST 205

UST 206

UST T-9

UST 126

UST 114C

UST 902C

UST 902B

UST 902A

UST 372B

UST 372A

UST 658B UST 658A

UST 763B

UST 114B

UST 716A

UST 114A

RFA 258

RFA 15 RFA 210

RFA 40

RFA 41

RFA 13

RFA 257

RFA 16

AST 126

AST 372

AST 658

PRL 372

PRL 923

PRL 114

PRL 23

PCB T60

PCB T58

PCB T94

PCB T14

PCB T109

PCB T20

PCB T89

TAA 658

TAA 698 TAA 779

OWS 658E

OW

OWS 763A

OWS 716B

")

")

")

")

")

")

") ") ") ") ") ")

")

")

")

")

") ")

")

")")

")

") ")

")

")

II-Q
 II-V-1

 II-F-1

 II-V-2

II-F-2
A!

A! 

0

TFAMW-01

TFAMW-03

MW398-01R

MW398-28

A!TFAMW-02

A!

RW398-02

A!

MW398-30

A!

A! A! MW398-31

A! MW398-4

RW398-01

A!

ASMW398- 02

TF6MW-01

TF6MW-02

S561

FORMER UST 398 GROUNDWATER PLUME AREA WITH BUFFER ZONE

MSC JP5 PIPELINES AND ASSOCIATED 

TFA GROUNDWATER PLUME AREA WITH 

BUFFER ZONE

230

S559

779

126

127

716

S904

S905

S910 S911

S908 S909

S906

S907

II-Q 938

MW398-6

MW398-21R

MW398-17

MW398-13

04DGMW66A

MW398-26

MW398-12

ASMW398-01

MW398-29

03L

MW398-19D

A!

A!

A!

A! A!A! A!

A!

A!

A!

A!

A!

A!

372

658

698

763

747

363

952 S560

S558

S396

752

923

S659

114

125

124

677

1804 642

903

231
ATTACHMENT 1

COMMENTS/RESPONSE TO COMMENTS
July 25, 2012 Responses to Comments Page 1 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1a. Table 5 MSC JP5 Pipeline

Table 5 – Summary of Asbestos Surveys: A new entry 

for MSC JP5 was added at the bottom of the Table. The 

entry is rather confusing. The description in Column 2 

indicates it is for portions of the MSC JP5 pipeline. This 

pipeline runs throughout Carve-Out (CO) II-Q. However, 

the 2009 reference listed in Column 5 is specifically for a 

“Summary Report, JP5 Building 363 Dry Well, ...” 

Please explain the relationship between the JP5 Building 

363 Dry Well and the MSC JP5 pipeline. 

A segment of the JP5 pipeline discharged fuel from fuel 

filter units and truck fueling stations into a dry well, 

known as the JP5 Building 363 Dry Well. During the 

excavation of petroleum-impacted soils from the JP5 

Building 363 Dry Well, a segment of the JP5 pipeline 

was exposed and removed. The pipeline was coated 

with a black tarry or bituminous coating. A sample of 

the coating was analyzed for asbestos in order to 

characterize the coating for disposal of the pipeline 

segment. The test results were presented in the 

“Summary Report, JP5 Building 363 Dry Well...”.

The Comments column of Table 5 will be revised to add 

a comment stating: “A sample of the black tarry coating 

on a segment of the JP5 pipeline near the JP5 Building 

363 Dry Well was analyzed for asbestos in order to 

characterize the coated pipeline for disposal. The 

sampling activity is not considered similar to an 

asbestos survey for buildings or structures. The 

sampling activity is included in Table 5 in order to 

disclose the presence of asbestos in the coating.”

1b. Table 5 Table 5 also lists Building 363 (Petroleum, Oil, and 

Lubricants (POL) Pipeline Shelter) as having been 

surveyed in 1991 and no ACM was found. Please explain 

the relationship between the Building 363 (POL Pipeline 

Shelter) entry and the MSC JP5 entry that references the 

JP5 Building 363 Dry Well.

The JP5 Building 363 Dry Well was a feature or 

component of the Location of Concern (LOC) known as 

MSC JP5, identified in Table 4. The JP5 Building 363 

Dry Well was located approximately 40 feet north of 

Building 363, and the dry well was a subsurface 

rectangular wood-framed feature, approximately 4 feet 

square and 3.5 feet deep. The dry well was filled with 

gravel and cobbles to a depth of 3.5 feet below ground 

surface. JP5 pipelines from the fuel filtering system and 

the original JP5 Truck Fueling Area Stations 363A 

through 363D discharged into the dry well.
July 25, 2012 Responses to Comments Page 2 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1c. Table 5 Building 363 (POL Pipeline Shelter) is shown on Table 

1 but the JP5 Building 363 Dry Well is not. Please 

explain.

The JP5 Building 363 Dry Well is not included in Table 

1 because it is neither a building nor a structure. The 

JP5 Building 363 Dry Well is a feature or component of

the LOC known as MSC JP5, identified in Table 4. 
July 25, 2012 Responses to Comments Page 3 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1d. Table 5 What is the condition of the outer tar coating on the 

MSC JP5 pipeline? Was there a release of asbestos 

containing material (ACM) into the environment? Were 

soil samples taken from around the MSC JP5 pipeline 

and tested for asbestos?

The non-friable black tarry coating on the MSC JP5 

pipeline was observed to be in good condition in several 

exploratory trenches and excavations. Soil samples for 

asbestos analysis were not collected from the soil 

surrounding the MSC JP5 pipeline.

During May 2006, Lennar Communities (Heritage Fields 

LLC) received Department of the Navy (DON) and 

regulatory agency approval on Project Environmental 

Review Form (PERF) No. ET002 Rev 1 to remove 

approximately 2,250 linear feet of the Norwalk - El Toro 

JP5 pipeline located northeast of Irvine Boulevard. The

pipeline was coated with a non-friable black tarry 

substance containing chrysotile asbestos. The pipeline 

was removed by Lennar, and following the removal of 

the pipeline, thirteen (13) soil samples were collected 

from the bottom of the pipe trench at 300-foot intervals 

and analyzed for asbestos content using United States 

Environmental Protection Agency (EPA) Method 600/R93/116. No asbestos fibers were detected in the soil 

samples (Final Supplemental Environmental Baseline 

Survey Report for On-Station Portion of the Defense 

Fuel Supply Point Norwalk El Toro Pipeline, Former 

Marine Corps Air Station El Toro, California, Enviro 

Compliance Solutions, Inc. (ECS) June 2008). The 

black coating on the pipeline that was removed 

according to PERF ET002 Rev 1 appears similar to the 

coating on segments of the MSC JP5 pipeline within CO 

II-Q. Based upon the results of sampling associated 

with PERF ET002, it is unlikely that a release of 

asbestos to the environment has occurred along the 

MSC JP5 pipelines within CO II-Q.
July 25, 2012 Responses to Comments Page 4 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1e. Table 5 It is noted in Table 4, Locations of Concern, that the JP5 

pipelines are inactive and have been abandoned in 

place. Why were the pipelines not removed?

The JP5 pipelines were abandoned in place with the 

concurrence of the California Regional Water Quality 

Control Board (RWQCB), Santa Ana Region. The 

pipelines were not removed due to the proximity of 

nearby utility conduits and various structures.

1f. Table 5 The fact that MSC JP5 is now listed in Table 5 indicates 

that an asbestos survey was performed. Please explain 

exactly what was surveyed for asbestos (i.e., MSC JP5 

pipeline, Building 363 POL Pipeline Shelter, and/or JP5 

Building 363 Dry Well)

Table 5 includes MSC JP5 because the black tarry 

coating on a segment of the MSC JP5 pipeline near the 

MSC JP5 Building 363 Dry Well was tested and was 

found to contain asbestos. 

1g. Table 5 Please add MSC JP5 to Table 1, as it can be classified 

as a “structure”, similar to the storage tank (S659) that is 

listed in Table 1. Please also make any other necessary 

changes to the FOST as a result of adding MSC JP5 to 

Table 1.

The MSC JP5 pipelines are not listed as structures in 

Table 1 because the MSC JP5 pipelines are part of the 

LOC known as MSC JP5, identified in Table 4.

2. Section 2 Property Description: CO II-Q currently refers to Figure 4; 

however, Figure 6 should be referenced since it is the 

figure titled “Carve-Out II-Q Existing Buildings/Structures 

and Wells”.

Section 2, Carve-Out (CO) II-Q will be revised to refer to 

both Figure 4 and Figure 6.

3. Section 4 Page 4, PRL 127: Paragraph 3 says “Table 3 identifies 

and provides the status of the PRLs within the COs as 

indicated on Figure 4.” This statement is not correct 

because PRL 127 has been removed from Table 3 even 

though PRL 127 is shown on Figure 4. Please correct the 

statement.

The text on Section 4, Page 4, will be revised as

follows: ”Table 3 and Table 4 identify and provide the 

status of the PRLs within the COs as indicated on 

Figure 4.” 

4. Section 4.1.2 IRP Site 4: Since the new paragraph discusses the JP5 

TFA plume, please make a reference to Figure 6 and the 

restrictions in Section 5.1 (similar to the reference made 

for MSC Sites in Section 4.2.2).

The following sentence will be added at the end of

Section 4.1.2: “Figure 6 shows the location of the JP5 

TFA Plume, and Section 5.1 summarizes restrictions 

related to petroleum products and its derivatives.”
July 25, 2012 Responses to Comments Page 5 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

5. Section 4.3 Asbestos-Containing Material: Please update the last 

paragraph to reflect the addition of the MSC JP5 

Pipelines.

The last paragraph of Section 4.3 will be revised to 

state that “A total of 17 non-residential buildings within 

CO II-Q have been surveyed and the coating on a 

segment of the MSC JP5 pipeline within CO II-Q has 

been sampled for ACM”. 

6. Section 4.4 Lead-Based Paint: Please add “and structures” after 

each “building” encountered in this section except where 

it has already been done.

The words “and structures” will be added to appropriate 

sentences within Section 4.4.

7. Section 4.6 Pesticides: This notification applies to all the property 

proposed for transfer under this FOST, as does footnote 

(c) in Attachment 4a. However, Table 2 only shows the 

pesticide notification for COs II-F-1 and II-Q, and not CO 

II-V-1. Please provide consistency between Section 4.6, 

Attachment 4a, and Table 2.

Table 2 will be revised to include the pesticide 

notification for CO II-V-1. 
July 25, 2012 Responses to Comments Page 6 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

8. Section 5.1.1 Carve-Out II-Q (Figure 6): Beginning with the second 

sentence, DTSC proposes the following re-write to this 

section (Since DTSC has not seen the “RWQCB 

Covenant”, please ensure DTSC’s proposed language is 

consistent with the RWQCB Covenant): “Therefore, 

land use restrictions for these petroleum plume areas will 

be incorporated into and implemented through two 

separate legal instruments: (1) a quitclaim deed between 

the DON and the transferee and (2) a Covenant and 

Environmental Restriction on Property (CERP) 

(hereinafter referred to as the RWQCB Covenant) 

between the DON and the RWQCB.

In order to limit the exposure to petroleum and its 

derivatives and to maintain the integrity of the corrective 

action until corrective action is complete, the RWQCB 

Covenant will restrict the following activities within the 

ARPR as shown on Figure 6 without prior review and 

approval from the DON and RQWCB:”

The four bulleted items would stay the same and the last 

(single sentence) paragraph in this section should be 

deleted. Also, please add “CERP” to the list of acronyms. 

Section 5.1 will be revised as follows (beginning with 

the second sentence):

“Therefore, land use restrictions for these petroleum 

plume areas will be incorporated into and implemented 

through two separate legal instruments: (1) a quitclaim 

deed between the DON and the transferee and (2) a 

Covenant and Environmental Restriction on Property 

(CERP) (hereinafter referred to as the RWQCB 

Covenant) between the DON and the RWQCB.

In order to limit the exposure to petroleum and its 

derivatives and to maintain the integrity of the corrective 

action until it is complete, the RWQCB Covenant will 

restrict the following activities within the area requiring 

petroleum restrictions (ARPR) as shown on Figure 6 

without prior review and approval from the DON and 

RWQCB:”

The last sentence after the four bullets will be deleted.

CERP will be added to the list of acronyms and 

abbreviations.

9a. Section 5.2 Asbestos-Containing Material:

Please update the first paragraph to reflect the MSC JP5 

Pipelines.

The text of Section 5.2 will be revised to include the 

MSC JP5 Pipelines within CO II-Q.
July 25, 2012 Responses to Comments Page 7 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

9b. Section 5.2 Please include a new restriction for the MSC JP5 

Pipelines.

Notification pertaining to asbestos-containing material

(ACM) on the MSC JP5 Pipelines has been provided in 

Table 5. The text of Section 5.2 will be revised to 

include MSC JP5 Pipelines.

9c. Section 5.2 The last sentence in this section says the restriction 

applies to all buildings and structures located within CO 

II-Q. However, the first paragraph in this section says the 

restriction only applies to ACM that has been identified 

with the respective COs. The two sentences are not 

consistent with each other. Please explain.

The first sentence of Section 5.2 will be revised to be 

consistent with the last sentence. The first sentence will 

be changed to: “The transferee will be required to 

comply with the specific restrictions listed below for 

ACM that has been identified within CO-II-Q”.

10. Section 6 Adjacent Properties, 3rd Paragraph: In the first sentence, 

CO II-F-1 should be singular. In the second sentence, 

“adjoin” should be “adjoins” and CO II-V-1 does not 

adjoin CO II-F-2. In other words, the second sentence 

should read “The CO II-V-1 adjoins DON retained CO IIV-2 which is associated with ..... remediation (Figure 2)”.

The two sentences will be revised as follows:

“CO II-F-1 adjoins DON retained CO II-F-2 and CO IIF-3.” And “ The CO II-V-1 adjoins DON retained CO IIV-2 which is associated with IRP Site 1 and IRP Site 2 

groundwater plumes undergoing remediation (Figure 

2).”

11a. Section 7 Covenants:

2nd Paragraph: The second quotation is not a direct 

quote from CERCLA. DTSC suggests that the quotation 

marks are removed and some text removed such that the 

sentence would read as “The covenant will warrant that 

all remedial action necessary to protect human health 

and the environment with respect to any hazardous 

substance remaining on the property has been taken 

before the date of transfer and that ... “

The second quotation in the 2nd paragraph of Section 7 

will be revised as follows:

“The covenant will warrant that all remedial action 

necessary to protect human health and the environment 

with respect to any hazardous substances remaining on 

the property has been taken before the date of transfer 

and that ... “
July 25, 2012 Responses to Comments Page 8 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

11b. Section 7 This section is specifically for the CERCLA warranties. 

Please remove the last two paragraphs which were 

recently added.

The last two paragraphs of Section 7 will be removed as 

requested.

12. Table 1 Buildings/Structures: Storage tank S659 is listed as 

(containing) non potable (liquid). Was this liquid water or 

something else? If it was something else, please explain 

and ensure its inclusion in the appropriate table(s). Does 

it have a coating that contains asbestos?

According to historical facility records, Storage Tank 

S659 was constructed prior to 1973, was used for 

storage of non-potable water, and was associated with 

the fire protection system. The tank has a painted 

exterior surface that is not suspected of containing 

asbestos. 

13. Table 4/Page 4 

of 18

Carve-Out II-Q, APHO 25: It appears that “Agua Chinon 

Wash” was changed to “Agua ChinonWash”. Please 

confirm and explain the change

Table 4 will be corrected to use Agua Chinon Wash.

14. Figures All Figures are dated April 2012. Please update the 

figures in the Final FOST document.

The figures will be updated to the appropriate month 

and year when FOST #7 is finalized.

15. Figure 3 Please ensure that the boundary between II-F-1 and II-F3 is drawn such as the MSC JP5 is entirely excluded 

from II-F-1.

The CO II-F-1 boundary shown on Figure 3 was verified 

to be correct and does exclude the LOC known as MSC 

JP5.

16a. Figure 4 Please provide the figure in the 11”x17” format in the 

Final FOST document.

The Final FOST #7 will include an 11” x 17” copy of 

Figure 4.

16b. Figure 4 The blue triangle representing OWS 763A can barely be 

seen. Please correct.

The blue triangle representing OWS 763A will be 

modified to improve its visibility, as requested.

17a. Figure 6 In the legend, please include “(ARPR)”. The acronym ARPR will be added in the legend and 

throughout the Final FOST #7.

17b. Figure 6 If applicable, please include “WITH BUFFER ZONE” in 

each of the plume titles.

The words “WITH BUFFER ZONE” will be included with 

each of the plume titles.
July 25, 2012 Responses to Comments Page 9 of 9

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Comments in E-mail Dated: June 12, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

18. Attachment 2 Unresolved Comments: Please also include DTSC’s 

original comment on Schools Notification (August 19, 

2011) and the DON’s response in the attachment.

The DTSC’s original comment dated August 19, 2011 

and the DON’s response will be included in Attachment 

2.

19a. Attachment 4a IRP 4 is associated with a petroleum release and the 4th 

column only lists Ferrocene. Please confirm that there 

were no other petroleum contaminants detected. Also the 

last column should have an “R” instead of a “D”.

The 4th column will be revised to include “Ferrocene 

and oily discharges from Building 658”. The last column 

will be corrected to “R”.

19b. Attachment 4a UST 716A lists “D” in the last column but Attachment 4b 

lists “S”. Please explain the discrepancy.

The reference to UST 716A in the last column of 

Attachment 4a will be corrected to “S”.

19c. Attachment 4a Why is MSC JP5 not listed in this attachment? RFA 15 is 

included in this attachment and the hazardous substance 

listed is JP5. There are many examples of this type of 

occurrence. Please check the attachment for accuracy.

MSC JP5 is not listed in Attachment 4a because it 

stored JP5. MSC JP5 is listed in Attachment 4b. 

Attachments 4a and 4b will be checked for accuracy.
July 17, 2012 Responses to Comments Page 1 of 1

Document Title: 

Pre-Final Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (May 17, 2012) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), Supplemental Comments in E-mail Dated: June 21, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1a. Section 7, 

Covenants

Please change the first sentence of the 2nd paragraph to 

read “The deed for transfer of CO II-Q on which ... ” 

The comment will be incorporated.

1b. Section 7, 

Covenants

Please change the last sentence of the 1st paragraph to 

read “This covenant shall not apply to ... required on the 

COs that is ... ”

The comment will be incorporated.

1c. Section 7, 

Covenants

Please change “COs” in the last sentence of the 2nd

paragraph to “the CO”.

The comment will be incorporated and the word “CO” 

will be used in place of “COs”.

2. Section 5.1.1 Section 5.1.1: Please change “the former UST 398 and 

the former TFA site”, encountered in a couple of places 

in the bottom half of the first paragraph, to “the former 

UST 398 and MSC JP5 pipelines with associated TFA 

sites”.

The comment will be incorporated and the names of the 

sites will be revised in response to the comment.

3. Section 5.1.1 In DTSC’s Comment #9 on the Pre-Final FOST #7 dated 

6/12/12, the last acronym of the RWQCB (in DTSCsuggested text for Section 5.1.1) was misspelled as 

“RQWCB”. Please use the correct spelling of the 

acronym in the final version of the FOST. 

The comment will be incorporated and the correct 

spelling of the acronym RWQCB will be used in the text 

of Section 5.1.1.
November 22, 2011 Response to Review Comments Page 1 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

1. General Were lead-based paint surveys conducted for any of the 

buildings or structures associated with this FOST #7? If 

so, what were the findings?

No lead-based paint (LBP) surveys were conducted for 

buildings, structures, or facilities associated with Finding 

of Suitability to Transfer (FOST) #7.

Section 4.4 will be revised in response to the comment. 

The following paragraphs will replace the existing 

paragraphs in Section 4.4:

“Notification of potential lead-based paint (LBP) at 

buildings is based on the age of construction (i.e., 

constructed before the Consumer Product Safety 

Commission’s 1978 ban on LBP for residential use). 

Carve-out (CO) II-Q contains buildings, structures, or 

facilities that were constructed prior to 1978 and, 

therefore, suggests the likelihood that LBP may be 

present. This in turn creates the possibility that, through 

the action of normal weathering and maintenance, there 

may be lead from LBP in the soil surrounding these 

buildings. Construction dates for each of the buildings 

in CO II-Q are summarized in Table 1. There are no 

buildings, structures, or facilities located in CO II-F-1 or 

CO II-V-1. 

In order to address the risk of adverse health effects to 

children from LBP exposure, legislation and national 

policy regarding LBP has focused on residential areas 

and child-occupied buildings/structures/facilities where 

children may be present. Non-residential 

buildings/structures/facilities (e.g., warehouses and 

office buildings) are typically occupied by adults, with 

minimal exposure to children.
November 22, 2011 Response to Review Comments Page 2 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

Non-residential buildings/ structures/ facilities 

constructed prior to 1978 may not be used for 

residential use or child-occupied buildings/ structures/

facilities unless the transferee performs any necessary 

evaluation(s) and abatement in accordance with all 

federal, state, and local laws and other applicable 

requirements. This restriction applies to all buildings, 

structures, or facilities located within CO II-Q.

There are no residential buildings, structures, or 

facilities associated with FOST #7, and no LBP surveys 

were conducted for buildings, structures, or facilities 

associated with FOST #7. The Department of the Navy 

(DON) will not conduct LBP evaluations at nonresidential buildings, structures, or facilities prior to 

transfer. See Section 5.3 for restrictions.”

The text of Section 5.3 will be revised in response to the 

comment to provide the following restriction:

“Non-residential buildings/ structures/ facilities 

constructed prior to 1978 may not be used for 

residential use or child-occupied buildings/ structures/

facilities unless the transferee performs any necessary 

evaluation(s) and abatement in accordance with all 

federal, state, and local laws and other applicable 

requirements. This restriction applies to all buildings, 

structures, or facilities located within CO II-Q.”
November 22, 2011 Response to Review Comments Page 3 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

2. General The MCAS El Toro Finding of Suitability to Lease (FOSL) 

(July 2004) contains a pesticide notification (Section 

4.1.9). The following paragraph is only the first 

notification of five notifications from that FOSL:

“Agricultural areas are present on the FOSL areas. The 

land that former MCAS El Toro occupies was used for 

agricultural purposes prior to its development for military 

purposes in the early 1940s. There are 32.4 acres of 

agricultural property within two carve-outs (28.7 acres 

within Carve-out II-F and 3.7 acres within Carve-out II-Q). 

The following discussion provides notifications that are 

required based on previous use of pesticides and 

herbicides at these areas.” 

FOST #7 does not include a similar notification. Please 

include a pesticide notification in Section 4, Table 2, and 

Attachment 4a. 

Former agricultural areas are present within COs II-F-1 

and II-Q. Table 2 and Attachment 4a have been 

updated to include pesticides, and Section 4 has been 

revised to include a new subsection 4.6 for pesticides 

with the following text:

4.6 Pesticides

The Transferee is hereby notified that the property may 

contain pesticide residue from pesticides that have 

been applied in the management of the property. The 

Navy knows of no use of any registered pesticide in a 

manner inconsistent with its labeling and believes that 

all applications were made in accordance with Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 

U.S.C. Section 136, et seq.), its implementing 

regulations, and according to the labeling provided with 

such substances. It is the Navy's position that it shall 

have no obligation under the covenants provided 

pursuant to Section 120(h)(3)(A)(ii) of the 

Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA), 42 U.S.C. 

Section 9620(h)(3)(A)(ii), for the remediation of legally 

applied pesticides.
November 22, 2011 Response to Review Comments Page 4 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

3. General Section 5.13 of the FOSL (July 2004) included 

restrictions for buildings and structures that required an 

asbestos containing material (ACM) survey. FOST #7 

indicates that there are many buildings/structures in 

FOST #7 that require an ACM survey because: they 

have never been surveyed for ACM; non friable, 

accessible, and damage (FAD) ACM was detected in a 

survey that was conducted prior to but not since 1997 

(i.e., not within the last three (3) years of station 

operation); or they were surveyed for FAD ACM only and 

therefore, the presence of non-FAD ACM is unknown. 

There is also one building classified as containing FAD 

ACM. FOST #7 does not include similar restrictions for 

those buildings/structures. Please explain why the 

restrictions for these buildings/structures are not 

consistent with those restrictions outlined in Section 5.13 

of the FOSL (July 2004).

In response to this comment, FOST #7 Section 5.2, 

CO II-Q will be revised to remove the existing 

paragraphs and to include the following restrictions for 

asbestos-containing material in buildings/ structures/

facilities:

“Except for short-term tours and emergency 

maintenance, access, use, or occupancy is prohibited 

pending either (1) completion of asbestos-containing 

material (ACM) surveys and completion of any 

necessary ACM abatement by the transferee or (2) 

demolition by the transferee, in accordance with all 

applicable local, state, and federal laws and other 

requirements relating to asbestos or ACM. Pending 

completion of abatement or demolition, the transferee 

shall manage the ACM in accordance with all such 

applicable local, state, and federal laws and 

requirements. This restriction is applicable to all 

buildings/structures/facilities located within CO II-Q.”
November 22, 2011 Response to Review Comments Page 5 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

4. General Please provide the following “Schools Notification” in 

Section 4.0 and also include the notification in Table 2:

SCHOOL SITE CONSIDERATIONS

If, subsequent to transfer, any portions of the property 

found suitable to transfer by this FOST is considered for 

the proposed acquisition and/or construction of school 

properties utilizing state funding, a separate 

environmental review process in compliance with the 

California Education Code section 17210 et seq. will 

need to be conducted by the transferee and approved by 

DTSC (Brownfields and Environmental Restoration 

Program). The California Education Code requires that a 

comprehensive evaluation of natural and manmade 

hazardous materials be conducted for school properties. 

This comprehensive evaluation requires additional 

investigation of hazardous materials outside the scope of 

CERCLA hazardous substances. This additional 

evaluation includes: legally applied pesticides and 

herbicides, imported fill materials, naturally occurring 

hazardous substances such as heavy metals (e.g., 

chromium, mercury, nickel), metalloids (e.g., arsenic, 

selenium), gases (e.g., methane, hydrogen sulfide), 

radioactive elements (e.g., radon gas) and naturally 

occurring petroleum deposits. The evaluation also 

includes ACM and lead based paint at concentrations 

that fall outside the scope of CERCLA. Any 

requirements associated with the evaluation of any 

property for compliance with the California Education 

Code are the sole responsibility of the transferee.

As was the case for FOST #6, FOST #7 was prepared 

in accordance with the most current Department of 

Navy (DON) Base Realignment and Closure (BRAC)

Program Management Office (PMO) guidance for 

processing Findings of Suitability to Transfer or Lease

(2008); this guidance does not require “School Site 

Considerations” to be included. No changes were made

to the text in response to this comment.

Section 10.0 – References was revised to include the 

document “Policy for Processing Findings of Suitability 

to Transfer or Lease” (DON BRAC PMO 2008).
November 22, 2011 Response to Review Comments Page 6 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

Specific 

Comments

1. Page 5,

Section 4.1.2, 

Installation 

Restoration 

Program 

(IRP) Site 4.

Based on the information provided in this section it 

sounds as though the No-Further-Action (NFA) Record of 

Decision (ROD) was for soil only. Is this the case? If so, 

what is the status of the other media (e.g., groundwater) 

at this site?

Groundwater beneath Installation Restoration Program 

(IRP) Site 4 is impacted by the petroleum release from 

miscellaneous (MSC) JP5 pipelines associated with the 

former JP5 Truck Fueling Area (TFA).

The text of Section 4.1.2 will be revised to include the 

following information:

“During the remedial investigation of IRP Site 4, 

groundwater monitoring wells were installed near 

Building 658 and former Tank Farm 5, and a release of 

petroleum to groundwater was detected. This release 

was attributed to jet fuel released from the nearby JP5 

pipelines at the former JP5 Truck Fueling Area (TFA);

the petroleum-impacted groundwater is known as the 

JP5 TFA Plume. The Regional Water Quality Control 

Board, Santa Ana Region (RWQCB) has approved 

closure of the vadose zone soil for the MSC JP5 

pipeline segments and TFA features overlying the 

plume. An evaluation of natural attenuation of 

groundwater was completed in 2007, and the RWQCB 

concurred with monitored natural attenuation (MNA)

with long-term monitoring as the groundwater remedy 

on 31 August 2007. The Navy is conducting 

groundwater monitoring of the JP5 TFA Plume in 

accordance with the MNA remedy as required by the

Monitored Natural Attenuation Evaluation and LongTerm Monitoring Plan, Former JP-5 Truck Fueling Area, 

Former Marine Corps Air Station, El Toro, California 

(Wiedemeier & Associates 2007).”
November 22, 2011 Response to Review Comments Page 7 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

2. Page 5, 

Section 4.1.2, 

IRP Site 25.

Is there any underlying groundwater contamination at 

IRP Site 25 within the portion proposed for transfer? No underlying groundwater contamination at IRP Site 

25 is within the portion proposed for transfer.

3. Page 8, 

Section 4.5,

last 

paragraph.

The text indicates that “Fluorescent light ballasts 

manufactured before 1979 often contain PCB capacitors 

that may be disposed of as municipal solid waste.” 

DTSC PCB advisories indicate that non-leaking PCB 

ballasts must be managed as a hazardous waste. DTSC 

recommends revising the sentence to delete “that may 

be disposed of as municipal solid waste.”

The text of the first sentence of the last paragraph of 

Section 4.5 has been revised as follows in response to

the comment: “Fluorescent light ballasts manufactured 

before 1979 often contain polychlorinated biphenyl

(PCB) capacitors.” 

4. Page 8, 

Section 4.5.2, 

2nd Sentence.

Please state that there was no evidence of a release, 

consistent with the information provided in Table 4.

The text of the second sentence of Section 4.5.2 has 

been revised as follows in response to the comment:

“Transformer PCB T109 was removed during UST 

excavation activities related to former Tank Farm 6 

(DTSC 2003c and U.S. EPA 2003), and no evidence of 

a release has been identified at this transformer 

location.”
November 22, 2011 Response to Review Comments Page 8 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

5. Pages 8 and 

9, Section 

5.1.

Section 67391.1 of title 22 of the California Code of 

Regulations prohibits DTSC from considering property to 

be suitable for transfer to nonfederal entities pursuant to 

42 United States Code section 9620(h) 3-4 where 

hazardous materials, hazardous wastes or constituents, 

or hazardous substances remain at the property at levels 

which are not suitable for unrestricted use of land, unless 

an appropriate land use covenant is executed and 

recorded. Section 5.1 indicates that hazardous 

materials, hazardous wastes or constituents (petroleum 

and/or its derivatives) remain and ongoing petroleum 

corrective action is occurring. In order to adequately 

provide for the protection of human health and the 

environment, and in accordance with DTSC’s land use 

covenant regulations, title 22, section 67391.1, DTSC 

recommends that a land use covenant be put in place for 

all of the areas identified in this FOST #7 as areas 

requiring petroleum restrictions (ARPRs). DTSC will 

withhold further comment on this section until this 

comment has been addressed.

The former Tank Farm 555 area within CO II-F-1 is part 

of an on-going MNA petroleum corrective action for 

groundwater being overseen by the RWQCB. The 

RWQCB approved closure of the petroleum release to 

vadose zone soils on 26 January 2011. The Navy is 

coordinating with Orange County Health Care Agency 

(OCHCA) to close the tank structures in place. The 

boundary of CO II-F-1 was revised to exclude the 

former Tank Farm 555 area from FOST #7 as shown on 

the revised Figures 2, 3, and 6. The text, tables and 

attachments have also been revised to exclude the 

former Tank Farm 555 from FOST #7. The former Tank 

Farm 555 will be addressed as CO II-F-3 in a future 

FOST.

The RWQCB has concurred with MNA as the 

groundwater petroleum corrective action for the 

petroleum-impacted groundwater at the former UST 

398 and the MSC JP5 pipelines associated with the 

former Truck Fueling Area (TFA) in CO II-Q. The 

RWQCB approved closure of the petroleum releases to 

the vadose zone soils at former UST 398 and the TFA 

on 11 March 2011 and 17 June 2011, respectively. 

These sites are petroleum-only sites and there are no 

CERCLA hazardous substances present in the vadose 

zone or groundwater. The Navy is conducting long-term 

groundwater monitoring of the petroleum plumes at the 

former UST 398 and the former TFA in accordance with 

the MNA Long-Term Monitoring Plans, and the 

restrictions described in Section 5.1 will enable the 

Navy to complete the MNA petroleum corrective action. 

No changes to Section 5.1, CO II-Q will be made in 

response to this comment.
November 22, 2011 Response to Review Comments Page 9 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

6. Page 10, 

Underground 

Storage 

Tanks (USTs) 

547 to 551.

What is the condition of the outer black tar coating on 

each of the USTs? Was there a release of asbestos 

containing material to the environment? Were soil 

samples taken from around the USTs and tested for 

asbestos? Why were the USTs not removed?

The CO boundary of Parcel II-F-1 has been revised to 

exclude the former Tank Farm 555 area from FOST #7. 

The text, tables, figures, and attachments of FOST #7 

will be revised accordingly. 

7. Page 10, 

Section 5.2.2, 

Building 124.

The reference listed here shows (CABACO/Tait 1999b). 

Page 13 lists the date of this document as October 15, 

1999. Table 5, Column 5 lists the date of this document 

as 7/22/99. Please reconcile.

The reference date of October 15, 1999 is correct and 

Table 5, Column 5 has been revised in response to the 

comment as “10/15/99.”

8. Page 10, 

Section 5.2.2, 

Buildings 114, 

125 and 372.

Similarly, the 1999 reference listed here and on page 13 

does not match the reference listed in Table 5 for 

Building 125. Please reconcile.

Table 5 reference date for Building 125 has been 

revised in response to the comment as “7/15/99.”

9. Page 10, 

Section 5.3.2.

There are several buildings and structures that were 

constructed prior to 1997 according to Table 1. Unless it 

is known that they were constructed after the Consumer 

Product Safety Commission’s 1978 ban on lead based 

paint for residential use, they should be listed in Section 

5.3.2. There is also one structure constructed prior to 

1958 and several other structures built prior to 1973 

according to Table 1. Why are those structures not listed 

in Section 5.3.2?

The restrictions in Section 5.3 have been revised in 

response to this comment.

See response to general comment 1. 
November 22, 2011 Response to Review Comments Page 10 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

10. Page 11, 

Section 7.

The last sentence is not consistent with Sections 4.1.3 

and 4.2.3, which state that there are no CERCLA/RCRA 

or petroleum related locations of concern (LOCs) in CO 

II-V-1. Why is CO II-V-1 not identified as CERCLA 120 

(h)(4) property with the appropriate covenant [CERCLA 

120 (h)(4)(D)(i)]? 

The text in Section 7 will be revised for CO II-F-1 and 

CO II-V-1 in response to the comment as follows:

“The deed for transfer of CO II-F-1 and CO II-V-1 on 

which there has been no release or disposal of 

hazardous substances or petroleum products or 

petroleum derivatives, and for which required regulatory 

concurrence as to such status has been obtained, will 

include a covenant made pursuant to CERCLA Section 

120(h)(4)(D)(i). Such covenant will warrant that any 

response action or corrective action found to be 

necessary after the date of transfer shall be conducted 

by the U.S. This covenant shall not apply to any 

response action or corrective action required on the 

property that is a result of an act or omission of the 

transferee.”

11. Page 11, 

Section 8. 

If CO II-V-1 is identified as CERCLA 120 (h)(4) property, 

the CERCLA 120 (h)(4)(D)(ii) access clause should be 

added to this section.

The CERCLA 120 (h)(4)(D)(i) covenant will apply to CO 

II-F-1 and CO II-V-1. Please see response above for 

comment 10.

12. Page 16, 

Section 10, 

11th

reference.

Why is a draft final listed rather than a final document? The draft final document became the final document in 

accordance with Section 7.9 of the Federal Facility 

Agreement for MCAS El Toro.

13. Table 4, Page 

4 of 17, IRP 

Site 4 and 

IRP Site 25, 

Column 4. 

Why is a draft final listed rather than a final document? Please see response above for comment 12.
November 22, 2011 Response to Review Comments Page 11 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

14. Table 4, Page 

4 of 17, IRP 

Site 4, 

Column 6, 2nd

Paragraph. 

Based on the information provided in this paragraph it 

sounds as though the NFA ROD was for soil only. Is this 

the case? If so, what is the status of the other media 

(e.g., groundwater) at this site?

Please see response to specific comment number 1.

15. Table 4, Page 

7 of 17, AST 

126, Columns 

5 and 6. 

Reference to the DTSC site closure concurrence is 

missing. This is not consistent with what is listed on 

page 6 in Section 4.2.2 for AST 126. Please reconcile.

The text on page 6 of Section 4.2.2 for AST 126 has 

been revised in response to the comment and for 

consistency with the information presented in Table 4 

as follows:

“AST 126 received site closure concurrence (RWQCB 

2011c).”

16. Table 4, Page 

14 of 17, 

Oil/Water 

Separators 

(OWSs) 658C 

and 658D, 

Columns 5 

and 6.

The NFA letter dates (01/08/2003) are not consistent with 

the date listed in the references section on page 14 

(January 18, 2003). Please reconcile.

The reference on page 14 has been revised as follows 

in response to the comment;

“2003d. No Further Action Concurrence Letter for OWS 

658C and 658D. January 8.”

17. Table 4, Page 

17 of 17, 

Acronyms 

and 

Abbreviations.

Please add “DON” to the list Table 4 has been revised to incorporate the comment.

18. Table 5, 

Building 125, 

Column 5. 

The CABACO/Tait (7/22/99) reference is missing from 

Section 10, page 13. Please correct.

Section 10 has been revised to incorporate the 

reference.
November 22, 2011 Response to Review Comments Page 12 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

19. Figures 3 and 

6, Legend.

In the Note, please change “will remain in place” to “were 

abandoned in place” for consistency with page 1.

The Note refers to USTs 547 to 551 within the former 

Tank Farm 555. The boundary of CO II-F-1 was 

revised to exclude the former Tank Farm 555 from 

FOST #7. Figures 3 and 6 have been revised to delete 

the Note and to revise the boundary of CO II-F-1 to 

exclude the former Tank Farm 555 area from FOST #7.

20. Figures 6 and 

7. 

Why are USTs shown on Figure 6, but no USTs/ASTs 

are shown on Figure 7? Figures 3 and 6 have been revised to exclude the

former Tank Farm 555 area from CO II-F-1. There are 

no remaining buildings, structures, or facilities within the 

revised CO II-F-1. Figure 7 also presents all the 

existing structures that are still in place within CO II-Q 

and there are no USTs/ASTs remaining within CO II-Q. 

For that reason, no USTs/ ASTs are shown on Figure 

7.

21. Attachment 

4a, Column 9.

Please explain where this information came from and 

how it was determined that activities conducted at the 

various locations were either “not determined”, “storage”, 

“disposal”, or “release”. It is possible that more than one 

activity (“storage”, “disposal”, and/or “release”) was 

conducted at a location. Where applicable, please 

indicate if more than one activity was determined to be 

conducted. Please ensure that each of the “activity(s)” 

listed is accurate. 

The information in Attachment 4a, column 9 came from 

the agency concurred Final Finding of Suitability to 

Lease, for Carve-Outs within Parcel I, II, and III, Former 

Marine Corps Air Station, El Toro, California (DON July

2004). The information was reviewed for accuracy, and 

the following revisions will be made to the activity (s) 

listed in column 9 of Attachment 4a:

“TAA 658, AST 658, TAA 698, and TAA 779 activities in 

column 9 have been revised to ‘S’ - Storage."

22. Attachment 

4a, Page 1 of 

4, PRL 127. 

Column 8 shows “Unknown-1999”, but Attachment 4b 

shows “Unknown”. Please correct the inconsistency.

Attachment 4b for PRL 127 has been revised as 

“Unknown – 1999” in response to the comment.
November 22, 2011 Response to Review Comments Page 13 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

23 Attachment 

4a, Page 2 of 

4, PRL 372.

Column 4 shows “fuel oil”, but Table 3 discusses “PCBs”. 

Also, Column 8 shows “Unknown-1999”, but Attachment 

4b shows “1954-1999. “ Please correct the 

inconsistencies.

Attachment 4a and Attachment 4b have been revised in 

response to the comment. Attachment 4a, page 2 of 4, 

column 4 for PRL 372 has been revised for consistency 

with Table 3 information for PRL 372 to show PCBs 

rather than fuel oil. Attachment 4b has been revised to 

delete PRL 372 since PRL 372 is not a petroleum site.

24. Attachment 

4a, Page 2 of 

4, AST 658. 

Column 8 shows “Unknown-1999”, but Attachment 4b 

shows ”Unknown -2002”. Please correct.

Attachment 4b for AST 658 has been revised to show 

“Unknown-1999” in response to the comment.

25. Attachment 

4b, Column 5.

Please explain where this information came from and

how it was determined that activities conducted at the 

various sites were either “not determined” or “storage”. 

Please also explain why none of the activities listed in 

Attachment 4b were identified as “release” and/or 

“disposal.” For example, FOST #7, Table 4, indicates 

that a release and/or disposal occurred at USTs 547 to 

551 but Attachment 4b does not. Please ensure that 

each “activity(s)” listed for the various sites is accurate.

The information in Attachment 4b, column 5 came from 

the Final Finding of Suitability to Lease, for Carve-Outs 

within Parcel I, II, and III, Former Marine Corps Air 

Station, El Toro, California dated 2004.

The information presented in Table 4 and Attachment 

4b was verified in response to the comment.

The purpose of Attachment 4b is to provide notification 

related to types of petroleum products that were stored 

within each CO. Table 4 provides relevant information 

related to the history and closure status of each 

Location of Concern. 

The CO boundary of Parcel II-F-1 has been revised to 

exclude the former Tank Farm 555 area FOST #7. 

Therefore, the text, tables, figures, and attachments will 

be revised accordingly. 

26. Attachment 

4b.

USTs 549 and 553 are missing from the list. Please 

correct.

The CO boundary of Parcel II-F-1 has been revised to 

exclude the former Tank Farm 555 area from FOST #7. 

Therefore, the text, tables, figures, and attachments will 

be revised accordingly. 
November 22, 2011 Response to Review Comments Page 14 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

27. Attachment 

4a

Please ensure the notification language in 40 Code of 

Federal Regulations part 373.3 is prominently displayed 

on Attachment 4a. 

In response to the comment, the following notification 

language from the 40 Code of Federal Regulations part 

373.3 will be included in Attachment 4a under Notes:

“The information contained in this Notice is required 

under the authority of regulations promulgated under 

Section 120(h) of the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA 

or “Superfund”) 42 U.S.C. Section 9620(h).”

Editorial 

Comments

1. Table 3, Page 

1 of 3, PRL 

372, Column 

6. 

Please delete the extra punctuation at the end of the 

paragraph.

Table 3, page 1 of 3, PRL 372, column 6 has been 

revised in response to the comment.

2. Table 4, Page 

5 of 17, RFA 

15, Column 6, 

Line 1.

Please make “site” plural. The word “site” has been changed to “sites” in Table 4, 

page 5 of 17, RFA 15, column 6, line 1 has been 

revised in response to the comment.

3. Table 4, Page 

5 of 17, RFA 

16, Column 6.

In line 1 please make “site” plural. In line 2, please insert 

the correct punctuation after “574”.

The word “site” has been changed to “sites” in and the 

correct punctuation mark has been added after “574” in 

Table 4, page 5 of 17, RFA 16, column 6, line 1 in 

response to the comment.

4. Table 4, Page 

6 of 17, RFA 

257, Column 

6, Line 1. 

Please make “site” plural. The word “site” has been changed to “sites” in Table 4, 

page 6 of 17, RFA 257, column 6, line 1 in response to 

the comment.

5. Table 4, Page 

6 of 17, RFA 

258, Column 

6, Line 1. 

Please make “site” plural. The word “site” has been changed to “sites” in Table 4, 

page 6 of 17, RFA 258, column 6, line 1 in response to 

the comment.
November 22, 2011 Response to Review Comments Page 15 of 15

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ Page 

No. Comment Response

6. Table 4, Page 

8 of 17, UST 

126, Column 

6, Line 1. 

Please correct the spelling error. The word “removed” has been correctly spelled in Table 

4, page 8 of 17, UST 126, column 6, line 1 in response 

to the comment.
April 19, 2012 Response to Review Comments Page 1 of 4

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, 

California (Navy November 22, 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E-mail Message With Comments Dated: January 20, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1. General

Comment (GC) 

#1

DTSC's comment was simply to ask if lead-based paint 

surveys were conducted and if so what the results of 

the surveys were. While the Navy provided a response 

to DTSC's comment, DTSC did not expect the 

language used in the draft FOST #7 to change from 

language agreed to in previous FOSTs. DTSC 

requests that the Navy keep the language used in the 

draft FOST unchanged with the exception of adding 

information about the lead-based paint surveys.

The comment will be incorporated, and the text of 

Section 4.4 and Section 5.3 will be revised as follows:

1st paragraph of Section 4.4: “Notification of potential 

LBP at buildings is based on the age of construction 

(i.e., constructed before the Consumer Product Safety 

Commission’s 1978 ban on LBP for residential use). CO 

II-Q contains buildings and structures that were 

constructed prior to 1978 and, therefore, suggests the 

likelihood that LBP may be present. This in turn creates 

the possibility that, through the action of normal 

weathering and maintenance, there may be lead from 

LBP in the soil surrounding these buildings. 

Construction dates for each of the buildings in CO II-Q 

are summarized in Table 1. There are no buildings or 

structures located in CO II-F-1 or CO II-V-1.” 

3rd paragraph of Section 4.4: “There are no residential 

buildings or structures associated with FOST #7. No 

LBP surveys were conducted for buildings and 

structures associated with FOST #7. See Section 5.3 

for restrictions.”
April 19, 2012 Response to Review Comments Page 2 of 4

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, 

California (Navy November 22, 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E-mail Message With Comments Dated: January 20, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

1 Response to Comment 1 (continued).

Paragraphs 5.3.1 and 5.3.2 will be replaced with the 

following paragraph:

“Non-residential buildings and structures constructed 

prior to 1978 (Table 1) may not be used for residential 

use or child-occupied buildings and structures unless 

the transferee performs any necessary evaluation(s) 

and abatement in accordance with all federal, state, and 

local laws and other applicable requirements. This 

restriction applies to all buildings and structures located 

within CO II-Q (Table 1).”
April 19, 2012 Response to Review Comments Page 3 of 4

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, 

California (Navy November 22, 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E-mail Message With Comments Dated: January 20, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

2. GC #3 Similarly, DTSC is fine with the format in previous 

FOSTs concerning asbestos and prefers that the Navy 

use the previous format.

The comment will be incorporated, and the text of 

Section 5.2 will be revised as follows:

2nd paragraph of Section 5.2. Paragraphs 5.2.1 and 

5.2.2 will be replaced with the following text:

“Except for short-term tours and emergency 

maintenance, access, use, or occupancy is prohibited 

pending either (1) completion of ACM surveys and 

completion of any necessary ACM abatement by the 

transferee or (2) demolition by the transferee, in 

accordance with all applicable local, state, and federal 

laws and other requirements relating to asbestos or 

ACM. Pending completion of abatement or demolition, 

the transferee shall manage the ACM in accordance 

with all such applicable local, state, and federal laws 

and requirements. This restriction is applicable to all 

buildings and structures located within CO II-Q.”

3. GC #4 DTSC requests that this comment regarding school 

site considerations on any FOST #7 properties be 

placed in the "Unresolved Comments" section.

The comment will be incorporated. The school site 

considerations comment will be placed in the 

“Unresolved Comments” section in Attachment 2 of 

FOST #7.

4. Specific 

Comments

(SC) #5

DTSC is engaged in a dialogue with the RWQCB 

regarding the potential need for a land use covenant at 

the sites with ongoing petroleum corrective action such 

as former UST 398 and the MSC JP5 pipelines 

(associated with the former Truck Fueling Area), when 

these sites are transferred to a non-federal entity. 

DTSC will soon provide a comment on this issue.

The comment was evaluated, and Section 5.1 of FOST 

#7 will be revised to include a description of the DONRWQCB covenant and environmental restriction. 
April 19, 2012 Response to Review Comments Page 4 of 4

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, 

California (Navy November 22, 2011) 

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E-mail Message With Comments Dated: January 20, 2012.

Comment 

No.

Section/ Page 

No. Comment Response

5. SCs #8 and 

#18

References to Building 125 in Section 5.2.2, on Page 

13, and in Table 5 need to be correct and consistent.

The restrictions from Section 5.2.2 are now presented in 

Section 5.2. 

6. SC #9 SC #9: DTSC's comment still stands, i.e., there are 

several buildings listed in Table 1 for Carve-Out (CO) 

II-Q which should be listed in Section 5.3.2, the Navy's 

response to our SC # 9 not withstanding. Please also 

refer to GC #1 above.

Section 5.3.2 has been revised to include reference to 

Table 1 which lists all the buildings for CO II-Q. Please 

see the response to Comment No. 1 (pertaining to GC 

#1).

7. SC #11 According to the Navy's response to DTSC's SC # 10, 

COs II-V-1 and II-F-1 are indeed identified as CERCLA 

120(h)(4) property with the appropriate covenants 

pursuant to CERCLA 120(h)(4)(D)(i). As a result, 

Section 8 should include the access clause for COs IIV-1 and II-F-1 pursuant to CERCLA 120(h)(4)(D)(ii).

The comment will be incorporated. Section 8 will be 

revised to include the access clause for COs II-V-1 and 

II-F-1 pursuant to CERCLA 120(h)(4)(D)(ii).

8. SC #14 The Navy's response to DTSC's SC #1 confirms that 

groundwater is contaminated and there is ongoing 

petroleum action for groundwater beneath IRP Site 4. 

It is not clear in the Navy's response to this comment if 

any information is going to be added to Table 4. DTSC 

requests that information about the ongoing petroleum 

corrective action for groundwater beneath Site 4 be 

added to the table.

The comment will be incorporated. Information from the

revised text of Section 4.1.2 (from the response to 

DTSC’s SC #1) will be added to Table 4 for IRP Site 4. 

9. SC #25 DTSC requests that the last sentence on Page 3 be 

revised to read "Attachment 4b, the Petroleum 

Products Notification Table, lists the locations of 

concern (LOCs) associated with the storage of 

petroleum products only".

The comment will be incorporated. The last sentence of 

1st paragraph of Section 4 will be revised to read 

"Attachment 4b, the Petroleum Products Notification 

Table, lists the locations of concern (LOCs) 

associated with the storage of petroleum products 

only".
November 22, 2011 Response to Review Comments Page 1 of 1

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: Thelma Estrada, U.S. EPA Region 9, E-mail comment dated: August 22, 2011

Comment 

No.

Section/ Page 

No. Comment Response

1. Section 7 / 

Page 11

Covenants, the last sentence states: CO II-V-I was not 

impacted by petroleum or its derivatives, therefore, this 

CO shall be conveyed "as is" without a CERCLA 

covenant." The CERCLA covenants under 120(h) are 

for hazardous substances, not petroleum, so I am not 

sure what the DON means to say here. 

The text in Section 7 will be revised in order to 

incorporate the comment. Section 7 addresses both CO

II-V-1 and CO II-F-1 due to recent changes to the CO IIF-1 boundary. Please see the Navy responses to DTSC 

specific comments 5 and 6 for additional information 

pertaining to changes to the CO II-F-1 boundary. The 

revised text follows: 

“The deed for transfer of CO II-V-1 and CO II-F-1 on 

which there has been no release or disposal of 

hazardous substances or petroleum products or 

petroleum derivatives, and for which required regulatory 

concurrence as to such status has been obtained, will 

include a covenant made pursuant to CERCLA Section 

120(h)(4)(D)(i). Such covenant will warrant that any 

response action or corrective action found to be 

necessary after the date of transfer shall be conducted 

by the U.S. This covenant shall not apply to any 

response action or corrective action required on the 

property that is a result of an act or omission of the 

transferee.”
November 22, 2011 Response to Review Comments Page 1 of 1

Document Title: 

Draft Finding of Suitability to Transfer #7 for Carve-Outs II-F-1, II-Q, and II-V-1, Former MCAS El Toro, California (June 2011) 

Reviewer: John Broderick, California Regional Water Quality Control Board, Santa Ana Region. Dated August 10, 2011

Comment 

No.

Section/ Page 

No. Comment Response

1. General We have reviewed the above-referenced document, dated 

June 2011, which we received on July 5, 2011. This 

document summarizes how the requirements and 

notifications for hazardous substances, petroleum 

products, and other regulated material within the above 

identified carve-outs have been satisfied.

We have no comments on this finding of suitability to 

transfer.

Thank you for your review of this document.
ATTACHMENT 2

UNRESOLVED COMMENTS
July 2012 Unresolved Comments Page 1 of 1

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1. Former MCAS El Toro, 

California (Navy, June 2011)

Reviewer: Quang Than, Department of Toxic Substances Control, Dated: August 19, 2011

Comment 

No.

Section/ 

Page No. Comment Response

1. General

Comment 

#4

Please provide the following “Schools Notification” in 

Section 4.0 and also include the notification in Table 2:

SCHOOL SITE CONSIDERATIONS

If, subsequent to transfer, any portions of the property 

found suitable to transfer by this FOST is considered for 

the proposed acquisition and/or construction of school 

properties utilizing state funding, a separate environmental 

review process in compliance with the California Education 

Code section 17210 et seq. will need to be conducted by 

the transferee and approved by DTSC (Brownfields and 

Environmental Restoration Program). The California 

Education Code requires that a comprehensive evaluation 

of natural and manmade hazardous materials be 

conducted for school properties. This comprehensive 

evaluation requires additional investigation of hazardous 

materials outside the scope of CERCLA hazardous 

substances. This additional evaluation includes: legally 

applied pesticides and herbicides, imported fill materials, 

naturally occurring hazardous substances such as heavy 

metals (e.g., chromium, mercury, nickel), metalloids (e.g., 

arsenic, selenium), gases (e.g., methane, hydrogen 

sulfide), radioactive elements (e.g., radon gas) and 

naturally occurring petroleum deposits. The evaluation 

also includes ACM and lead based paint at concentrations 

that fall outside the scope of CERCLA. Any requirements 

associated with the evaluation of any property for 

compliance with the California Education Code are the 

sole responsibility of the transferee.

As was the case for FOST #6, FOST #7 was prepared in 

accordance with the most current Department of Navy 

(DON) Base Realignment and Closure (BRAC) Program 

Management Office (PMO) guidance for processing 

Findings of Suitability to Transfer or Lease (2008); this 

guidance does not require “School Site Considerations” 

to be included. No changes were made to the text in 

response to this comment.
July 2012 Unresolved Comments Page 1 of 1

Document Title: 

Response to Comments Package on the Draft Finding of Suitability to Transfer (FOST) #7 for Carve-Outs II-F-1, II-Q, and II-V-1. Former MCAS El Toro, 

California (Navy, November 22, 2011)

Reviewer: Quang Than, Department of Toxic Substances Control (DTSC), E-mail Message With Comments Dated: January 20, 2012.

Comment 

No.

Section/ 

Page No. Comment Response

1. General

Comment 

#4

DTSC requests that this comment regarding school site 

considerations on any FOST #7 properties be placed in the 

“Unresolved Comments” section.

As was the case for FOST #6, FOST #7 was prepared in 

accordance with the most current Department of Navy 

(DON) Base Realignment and Closure (BRAC) Program 

Management Office (PMO) guidance for processing 

Findings of Suitability to Transfer or Lease (2008); this 

guidance does not require “School Site Considerations” 

to be included. No changes were made to the text in 

response to this comment.
ATTACHMENT 3

AGENCY CORRESPONDENCE








Department of Toxic Substances Control 

Matthew Rodriquez 

Secretary for 

Environmental Protection 

July27,2012 

Mr. James Callian 

Deborah O. Raphael, Director 

5796 Corporate Avenue 

Cypress, California 90630 

BRAC Environmental Coordinator 

Environmental Division/MCAS EI Toro 

Navy BRAC Program Management Office West 

1455 Frazee Road, Suite 900 

San Diego, California 92108-4310 

Edmund G. Brown Jr. 

Governor 

CONCURRENCE WITH FINAL FINDING OF SUITABILITY TO TRANSFER #7 FOR 

CARVE-OUTS II-F-1, 11-0, AND II-V-1, FORMER MARINE CORPS AIR STATION 

(MCAS) EL TORO, IRVINE, CALIFORNIA (SITE CODE: 400055) 

Dear Mr. Callian: 

The California Department of Toxic Substances Control (DTSC) has reviewed the Final 

Finding of Suitability to Transfer #7 for Carve-Outs /I-F-1, /I-Q, and /I-V-1, Former 

Marine Corps Air Station EI Taro, California (FOST #7), which was dated July 2012 and 

received in electronic format on July 26, 2012. FOST #7 provides environmental 

findings that establish Carve-Outs (COs) II-F-1, 11-0, and II-V-1 as being suitable for 

transfer. These three COs comprise approximately 150 acres at the former MCAS EI 

Toro. DTSC concurs that the property associated with FOST #7 can be transferred with 

the specified notifications, restrictions, and covenants, and in a manner that is protective 

of human health and the environment. 

DTSC commented on the Draft and Pre-Final versions of FOST #7 and the Navy has 

satisfactorily responded to the comments. Based on our review of the electronic final 

version, DTSC determines that the response to our comments has been adequately 

incorporated into the report. As a result, DTSC concurs with the FOST #7 report and 

accepts it as written. 

® Printed on H.ecycled Paper 
~. 

Mr. Callian 

July 27, 2012 

Page 2 of 3 

Thank you for providing DTSC with the opportunity to review and comment on the 

FOST #7 report. If you have any questions about this concurrence, please contact me at 

(714) 484-5352 or gthan@dtsc.ca.gov. 

Sincerely, 

Quang an 

Remedial Project Manager 

Brownfields and Environmental Restoration Program 

rs/qt 

cc: Content Arnold 

BRAC PMO West 

1455 Frazee Road,Suite 900 

San Diego, California 92108 

Lynn Hornecker 

BRAG PMO West 

1455 Frazee Road, Suite 900 

San Diego, California 92108 

Robert Woodings 

Restoration Advisory Board Co-Chair 

11 Teal 

Irvine, California 92604 

Marcia Rudolph 

Restoration Advisory Board Co-Chair 

24922 Muirland, #139 

Lake Forest, California 92108 

Daniel Jung 

City of Irvine 

P.O. Box 19575 

Irvine, California 92623-9575 

James Strozier 

Orange County Environmental Health Division 

1241 East Dyer Road, Suite 120 

Santa Ana, California 92705 
Mr. Callian 

July 27,2012 

Page 3 of 3 

Polin Modanlou 

Orange County Planning & Development Services Department 

300 North Flower Street, 3rd Floor 

Santa Ana, California 92703 

Mary Aycock 

U.S. Environmental Protection Agency, Region IX 

75 Hawthorne Street, Mail Code SFD-8-1 

San Francisco, California 94105-3901 

John Broderick 

Regional Water Quality Control Board, Santa Ana Region 

3737 Main Street, Suite 500 

Riverside, California 92501-3348 

Robert Elliott 

Department of Toxic Substances Control 

1001 "I" Street 23rd , Floor 

Sacramento, California 95182 

Erika Giorgi 

Department of Toxic Substances Control 

1001 "I" Street 23rd , Floor 

Sacramento, California 95182 

Jennifer Rich 

Department of Toxic Substances Control 

5697 Corporate Avenue 

Cypress, California 90630 




ATTACHMENT 4

4a–HAZARDOUS SUBSTANCES NOTIFICATION TABLE

4b–PETROLEUM PRODUCTS NOTIFICATION TABLE 
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Attachment 4a

Page 1 of 4

Attachment 4a: Hazardous Substances Notification Table

Carve-Out 

ID

Building/Structure

Number Area Type ID

Hazardous 

Substances(a)(c)

Reportable 

Quantity 

(Lb/year)(b) CAS Number

RCRA Waste 

Code

Dates of 

Operation

Activities 

Conducted at 

Site

Carve-Out II-Q

II-Q 114 PRL 114 Solvents N/A N/A N/A Unknown1999ND

II-Q 114 APHO 100 Unknown N/A N/A N/A Unknown ND

II-Q 114 PCB T14 PCBs N/A N/A N/A Unknown1999S

II-Q 114 RFA 13 Unknown N/A N/A N/A Unknown1999S

II-Q 125 PCB T20 PCBs N/A N/A N/A Unknown1999S

II-Q 125 PCB T21 PCBs N/A N/A N/A Unknown1999S

II-Q 127 PRL 127 Petroleum products 

and hazardous 

substances

N/A N/A N/A Unknown1999ND

II-Q 127 RFA 40 Substances 

associated with drum 

storage areas

N/A N/A N/A Unknown1999S

II-Q 127 RFA 41 Washwater from 

vehicles

N/A N/A N/A Unknown1999D

II-Q 208 Non-Trans 208 PCBs N/A N/A N/A Unknown1999S

II-Q 235 PRL 235 Lead and other 

metals

N/A N/A N/A Unknown1999ND

II-Q 372 PCB T58 PCBs N/A N/A N/A 1954-1994 S

II-Q 372 APHO 98 Unknown N/A N/A N/A Unknown ND

II-Q 372 Non-Trans 372 PCBs N/A N/A N/A Unknown1999S

II-Q 372 PRL 372 PCBs N/A N/A N/A Unknown1999S

II-Q 378 PCB T60 PCBs N/A N/A N/A 1954-1994 S
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Attachment 4a

Page 2 of 4

Attachment 4a: Hazardous Substances Notification Table

Carve-Out 

ID

Building/Structure

Number Area Type ID

Hazardous 

Substances(a)(c)

Reportable 

Quantity 

(Lb/year)(b) CAS Number

RCRA Waste 

Code

Dates of 

Operation

Activities 

Conducted at 

Site

II-Q Former JP5 Fueling 

Station 574

RFA 16 Washwater from 

vehicles

N/A N/A N/A Unknown1999D

II-Q Former JP5 Fueling 

Station 575

RFA 257 Washwater from 

vehicles

N/A N/A N/A Unknown1999D

II-Q Former JP5 Fueling 

Station 576

RFA 15 Washwater from 

vehicles

N/A N/A N/A Unknown1999D

II-Q Former JP5 Fueling 

Station 577

RFA 258 Washwater from 

vehicles

N/A N/A N/A Unknown1999D

II-Q 658 TAA 658 Substances 

associated with less 

than 90-day 

accumulation of 

wastes

N/A N/A N/A Unknown1999S

II-Q 658 AST 658 Ferrocene N/A N/A N/A Unknown1999S

II-Q 658 OWS 658C Oil/water N/A N/A N/A 1972-1999 S

II-Q 658 OWS 658D Oil/water N/A N/A N/A 1995-1999 S

II-Q 658 OWS 658E Oil/water N/A N/A N/A Unknown1999S

II-Q 658 PRL 658 Waste JP5 N/A N/A N/A Unknown1999S

II-Q 658 PCB T89 PCBs N/A N/A N/A Unknown1999S

II-Q 698 TAA 698 Substances 

associated with 

materials storage

N/A N/A N/A Unknown1999S

II-Q 716 UST 716A Waste oil N/A N/A N/A 1976-1998 S

II-Q 716 PRL 716 Waste JP5 N/A N/A N/A Unknown1999ND

II-Q 716 OWS 716B Oil/oily water N/A N/A N/A 1976-1988 S

II-Q 716 PCB T94 PCBs N/A N/A N/A Unknown1999S
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Attachment 4a

Page 3 of 4

Attachment 4a: Hazardous Substances Notification Table

Carve-Out 

ID

Building/Structure

Number Area Type ID

Hazardous 

Substances(a)(c)

Reportable 

Quantity 

(Lb/year)(b) CAS Number

RCRA Waste 

Code

Dates of 

Operation

Activities 

Conducted at 

Site

II-Q 747 PRL 747 Waste fuels N/A N/A N/A Unknown1999ND

II-Q 763 RFA 210 Solvents, waste oil N/A N/A N/A Unknown1999D

II-Q 763 UST 763B Waste Oil N/A N/A N/A 1982-1999 S

II-Q 763 OWS 763A Oily water N/A N/A N/A 1982-1999 S

II-Q 779 TAA 779 Substances 

associated with less 

than 90-day 

accumulation of 

wastes

N/A N/A N/A Unknown1999S

II-Q 923 PRL 923 Drop tank rinse area N/A N/A N/A Unknown1999S

II-Q N/A IRP 4 Ferrocene and oily 

discharges from 

Building 658

N/A N/A N/A 1983 R

II-Q T-6 UST T-6 Waste JP5 N/A N/A N/A 1988-1996 S

II-Q T-7 UST T-7 Waste JP5 N/A N/A N/A 1988-1999 S

II-Q T-8 UST T-8 Waste JP5 N/A N/A N/A 1988-1999 S

II-Q T-9 UST T-9 Waste JP5 N/A N/A N/A 1988-1999 S

II-Q N/A IRP 25 Substances 

associated with storm 

water discharges and 

drainage channels

N/A N/A N/A Unknown1999R

II-Q Agua Chinon Wash APHO 25 Unknown N/A N/A N/A Unknown ND

II-Q Tank Farm No. 5 APHO 50 Unknown N/A N/A N/A Unknown ND

II-Q Tank Farm No. 6 PCB T109 PCBs N/A N/A N/A Unknown1999S
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Attachment 4a

Page 4 of 4

Notes:

(a) This table was prepared in accordance with 40 Code of Federal Regulations (CFR) 373.3 and 40 CFR 302.4. The information contained in this Notice is required under the 

authority of regulations promulgated under Section 120(h) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or “Superfund”) 42 

U.S.C. Section 9620(h). The substances which do not have chemicals-specific break down (and associated annual reportable quantity) are not listed in 40 CFR 302.4, and 

therefore have no corresponding Chemical Abstracts Services (CAS) number, no regulatory synonyms, no Resource, Conservation, and Recovery Act (RCRA) waste 

numbers, and no reportable quantities. (b) Reportable Quantity

For Buildings with chemical-specific break down and associated reportable quantity, the information was obtained from the Air Emissions Source Survey, Final Submittal, 

MCAS El Toro. The reportable quantity was assumed to be the estimate of the air emissions value that was calculated based on a quantity used during the year. For nonvolatile organic compounds (VOCs), the specific chemicals are listed and the quantity is unknown. (c) The Property may contain pesticide residue from pesticides that have been applied in the management of the Property. The Grantor knows of no use of any registered 

pesticide in a manner inconsistent with its labeling and believes that all applications were made in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act 

(FIFRA – 7 U.S.C. Sec 136, et seq.), its implementing regulations, and according to the labeling provided with such substances. It is the Grantor’s position that it shall have 

no obligation under the covenants provided pursuant to Section 120(h)(3)(A)(ii) of the CERCLA of 1980, 42 U.S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally 

applied pesticides.

Sources: Earth Tech 2003, Radian 1996.

Acronyms and Abbreviations:

APHO = aerial photograph feature/anomaly

AST = aboveground storage tank

CAS = Chemical Abstracts Services

CERCLA = Comprehensive Environmental Response, Compensation and Liability Act

CFR = Code of Federal Regulations

D = disposal of wastes

ID = Identification

FIFRA = Federal Insecticide, Fungicide, and Rodenticide Act

IRP = Installation Restoration Program

JP5 = Jet propulsion fuel, grade 5

Lb = pound

MCAS = Marine Corps Air Station

N/A = not applicable

ND = operations at site are not determined

No. = number

Non-Trans= non transformer PCB containing equipment/items

OWS = oil/ water separator

PCB = polychlorinated biphenyls

PRL = potential release location

R = release

RCRA = Resources Conservation and Recovery Act

RFA = RCRA facility assessment

S = storage of hazardous material or waste

TAA = temporary accumulation area

U.S.C = United States Code

UST = underground storage tank

VOCs = volatile organic compounds
Final Finding of Suitability to Transfer #7

July 2012 Former MCAS El Toro, California Attachment 4b

Page 1 of 1

Attachment 4b: Petroleum Products Notification Table

Carve-Out 

ID Area Type ID Petroleum Products*

Dates of 

Operation

Activities 

Conducted At Site

Carve-Out II-Q

II-Q MSC JP5 JP5 Unknown-1999 S

II-Q UST 114A Fuel oil 1966-1991 S

II-Q UST 114B Diesel 1966-1991 S

II-Q UST 114C Fuel oil 1966-1991 S

II-Q AST 126 Oil Unknown - 1999 S

II-Q UST 126 Diesel Unknown - 1996 S

II-Q UST 204 Diesel 1943-1999 S

II-Q UST 205 Recovered JP5 1943-1997 S

II-Q UST 206 Unleaded gasoline 1945-1999 S

II-Q UST 207 Unleaded fuel 1943-1998 S

II-Q UST 208 Aviation gas 1943-1996 S

II-Q UST 209 Aviation gas 1943-1996 S

II-Q UST 210 Aviation gas, JP5 1943-1996 S

II-Q UST 211 Aviation gas 1943-1996 S

II-Q UST 212 Aviation gas, JP5 1943-1996 S

II-Q UST 213 Aviation gas 1943-1996 S

II-Q UST 214 Aviation gas, JP5 1943-1996 S

II-Q UST 215 Aviation gas 1943-1996 S

II-Q AST 372 Diesel 1954-1999 S

II-Q UST 372A Diesel 1954-2000 S

II-Q UST 372B Diesel 1954-1994 S

II-Q UST 398 JP5 1956-1993 S

II-Q AST 658 Ferrocene Unknown - 1999 S

II-Q UST 658A JP5 1972-1998 S

II-Q UST 658B JP5 1972-1998 S

II-Q UST 902A JP5 1993-2000 S

II-Q UST 902B JP5 1993-2000 S

II-Q UST 902C JP5 1993-2000 S

Notes:

* Includes only petroleum products which fall within the scope of the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) Petroleum exclusion set forth in CERCLA Section 101(14).

Source: Earth Tech 2003.

AST = aboveground storage tank

CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act

ID = identification

JP5 = jet propulsion fuel, grade 5

MCAS = Marine Corps Air Station

MSC = miscellaneous

S = storage of hazardous material or waste

UST = underground storage tank