Final 

Finding of Suitability to Transfer #5 

for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, 

II-R, and Building 746 

Former Marine Corps Air Station 

El Toro, California 

April 2010 
CONTENTS

i 

ACRONYMS AND ABBREVIATIONS v 

1. PURPOSE 1 

2. PROPERTY DESCRIPTION 1 

3. REGULATORY COORDINATION 2 

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 4 

4. SUMMARY OF ENVIRONMENTAL CONDITIONS AND 

NOTIFICATIONS 4 

4.1 CERCLA/RCRA 5 

4.1.1 Carve-Out I-F (Figure 3) 5 

4.1.2 Carve-Out II-E (Figure 8) 5 

4.1.3 Carve-Out II-L (Figure 9) 6 

4.1.4 Carve-Out II-M (Figure 10) 6 

4.1.5 Carve-Out II-R (Figure 11) 6 

4.2 Petroleum Products and Derivatives 7 

4.2.1 Carve-Out I-F (Figure 3) 7 

4.2.2 Carve-Out I-K (Figure 4) 7 

4.2.3 Carve-Out I-N (Figure 5) 7 

4.2.4 Carve-Out I-O (Figure 6) 7 

4.2.5 Carve-Out I-S (Figure 7) 7 

4.2.6 Carve-Out II-E (Figure 8) 7 

4.2.7 Carve-Out II-M (Figure 10) 8 

4.2.8 Carve-Out II-R (Figure 11) 8 

4.3 Asbestos-Containing Material 8 

4.4 Lead-Based Paint 8 

4.5 Polychlorinated Biphenyls 9 

4.5.1 Carve-Out I-F (Figure 3) 9 

4.5.2 Carve-Out I-S (Figure 7) 9 

4.5.3 Carve-Out II-E (Figure 8) 9 

4.5.4 Carve-Out II-R (Figure 11) 9 

4.6 School Site Considerations 10 

5. SUMMARY OF RESTRICTIONS 10 

5.1 CERCLA/RCRA 10 

5.1.1 Carve-Out I-F (Figure 3) 10 

5.2 Petroleum Products and Derivatives 12 

5.2.1 Carve-Out I-F (Figure 3) 12 

5.3 Asbestos-Containing Material 12 

5.3.1 Carve-Out I-N (Figure 5) 12 

5.3.2 Carve-Out II-E (Figure 8) 12 

5.3.3 Carve-Out Building 746 (Figure 12) 13 

5.4 Lead-Based Paint 13 

5.4.1 Carve-Out I-N (Figure 5) 13 

5.4.2 Carve-Out II-E (Figure 8) 13 
 Contents 

ii 

6. ADJACENT PROPERTIES 13 

6.1 Carve-Out II-E (Figure 8) 13 

6.2 Carve-Out II-M (Figure 10) 14 

6.3 Carve-Out Building 746 (Figure 12) 14 

7. COVENANTS 14 

8. ACCESS CLAUSE 14 

9. FINDING OF SUITABILITY TO TRANSFER 15 

10. REFERENCES 16

TABLES 

1 Buildings/Structures/Facilities 

2 Environmental Requirements and Notifications 

3 Potential Release Locations 

4 Locations of Concern 

5 Locations of Concern With Ongoing Petroleum Corrective Actions 

6 Summary of Asbestos Surveys 

7 Monitoring/Bioventing/SVE Wells 

FIGURES 

1 Vicinity Map 

2 Carve-Out Area Location Map 

3 Carve-Out I-F 

4 Carve-Out I-K 

5 Carve-Out I-N 

6 Carve-Out I-O 

7 Carve-Out I-S 

8 Carve-Out II-E 

9 Carve-Out II-L 

10 Carve-Out II-M 

11 Carve-Out II-R 

12 Carve-Out Building 746 
 Contents 

iii 

ATTACHMENTS 

1 Comments/Response to Comments 

2 Unresolved Comments 

3 RCRA Corrective Action Package 

4a Petroleum Products Notification Table 

4b Hazardous Substances Notification Table 
 Contents 

iv 

This Page Intentionally Left Blank 
ACRONYMS AND ABBREVIATIONS

 v 

ACM asbestos-containing material

APHO aerial photograph feature/anomaly 

ARIC area requiring institutional controls

AST aboveground storage tank 

bgs below ground surface

BNI Bechtel National, Inc.

BRAC Base Realignment and Closure 

CCR California Code of Regulations

CDM CDM Federal Programs Corporation 

CDPH California Department of Public Health

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CO carve-out

DERP Defense Environmental Restoration Program

DoD Department of Defense 

DON Department of the Navy

DRMO Defense Reutilization and Marketing Office 

DTSC Department of Toxic Substances Control

EBS Environmental Baseline Survey 

FAA Federal Aviation Administration

FAD friable, accessible, and damaged

FFA Federal Facility Agreement 

FOST Finding of Suitability to Transfer

HRA Historical Radiological Assessment 

HSC Health and Safety Code

IRP Installation Restoration Program 

LBP lead-based paint

LOC location of concern

LUC land use control 

MCAS Marine Corps Air Station

MSC miscellaneous 

NFA no further action

NFI no further investigation 

non-FAD non-friable, accessible, and damaged

NPL National Priorities List

OCHCA Orange County Health Care Agency 

OPS operating properly and successfully

OWS oil/water separator 

PCB polychlorinated biphenyl

ppm part per million

PRL potential release location 

RAD radiological investigation location

RCRA Resource Conservation and Recovery Act 

RFA RCRA Facility Assessment

RI Remedial Investigation 

ROD Record of Decision

RWQCB Regional Water Quality Control Board

SRU silver recovery unit 

SWMU solid waste management unit

TAA temporary accumulation area 

TSCA Toxic Substances Control Act

U.S. United States 
Acronyms and Abbreviations 

vi 

U.S.C. United States Code 

U.S. EPA United States Environmental Protection Agency

UST underground storage tank 

VOC volatile organic compound
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

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1. PURPOSE 

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

and notifications for hazardous substances, petroleum products, and other regulated material within 

Carve-Outs (COs) I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746 at former Marine 

Corps Air Station (MCAS) El Toro have been satisfied by the United States (U.S.) Department of the 

Navy (DON). Through the Base Realignment and Closure (BRAC) process, the DON transferred, by 

deed, 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 was prepared in accordance with the 

Base Redevelopment and Realignment Manual (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 consists of 10 

COs comprising approximately 119.3 acres. With the exception of CO Building 746, all COs are 

currently leased to Heritage Fields, LLC or City of Irvine. Table 1 presents a summary of the 

buildings and structures within the CO areas. Figure 2 is a base-wide map that provides the location 

of the CO areas. A brief description of the CO areas follows: 

 Carve-Out I-F (Figure 3) – consists of approximately 53.5 acres and is located in the 

northwest portion of the former base. CO I-F encompasses a Federal Aviation 

Administration (FAA) parcel of approximately 0.92 acres, which includes Building 399. 

This parcel was transferred to the FAA under a separate conveyance action. 

 Carve-Out I-K (Figure 4) – consists of approximately 2.1 acres and is located in the 

northwest portion of the former base. 

 Carve-Out I-N (Figure 5) – consists of approximately 0.8 acre and is located in the northwest 

portion of the former base. Building 1 is within this CO. 

 Carve-Out I-O (Figure 6) – consists of approximately 0.5 acre and is located in the northwest 

portion of the former base. 

 Carve-Out I-S (Figure 7) – consists of approximately 0.6 acre and is located in the northwest 

portion of the former base. 

 Carve-Out II-E (Figure 8) – consists of approximately 13.1 acres and is located in the 

northeast portion of the former base. Buildings 115, 118, 119, 139, 605, 606, 639, 640, 641, 

643, 695, 696, 697, 892, 912, 913, 914, 936, 937, 939, 940, and 972 are within this CO. 

 Carve-Out II-L (Figure 9) – consists of approximately 6.7 acres and is located in the 

northeast portion of the former base. 

 Carve-Out II-M (Figure 10) – consists of approximately 38.9 acres and is located in the 

southeast portion of the former base. 

 Carve-Out II-R (Figure 11) – consists of approximately 1.2 acres and is located in the 

southeast portion of the former base. 

 Carve-Out Building 746 (Figure 12) – consists of approximately 1.6 acres that were 

previously part of CO II-D, and is located in the northeast portion of the former base. 

Buildings 746 and 796 are within this CO. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

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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.) 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]), Santa Ana 

Regional Water Quality Control Board (RWQCB), and the DON signed a Federal Facility 

Agreement (FFA) (DON 1990). The U.S. EPA, DTSC, and Santa Ana RWQCB were notified of the 

initiation of this FOST and were issued copies for review. Regulatory agency comments to this 

FOST are provided in Attachment 1, and unresolved comments, if any, are provided in 

Attachment 2. 

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

CORRECTIVE ACTION

This FOST reviews sites that were evaluated and addressed under 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 in order 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 

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 
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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 DON (DTSC 1996a). DON continues to complete all RCRA Part B permit corrective actions for 

the SWMUs under the FFA executed in 1990. 

DTSC has not made a RCRA Corrective Action Complete Determination for the property associated 

with FOST 5. Rather, it plans to issue a letter to the transferee clarifying the corrective action 

obligations for property associated with FOST 5, as well as COs I-L and I-M, previously transferred 

under FOST 4. The RCRA Corrective Action Package can be found in 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 Resource 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 property associated with FOST 5, 

DTSC does plan to issue a letter to the transferee clarifying the corrective action obligations for 
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property associated with FOST 5, 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. Additionally, there are four sites known as potential release 

locations (PRLs) that required site inspections under CERCLA. IRP Site 16 (CO I-F) has received 

operating properly and successfully (OPS) concurrence, as noted in Section 4.1.1. CERCLA 

response actions have been completed at IRP Site 25, as noted in Section 4.1.1. Additionally, PRLs 

354, 605 and 606, and the Runway Infield Area were investigated under CERCLA and received no 

further investigation (NFI) concurrence. See Sections 4.1.4, 4.1.2, and 4.1.3, respectively. 

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 other regulated materials. Pursuant to 40 Code of Federal Regulations Part 373, the 

deed for each CO will contain a notice of hazardous substances stored, released, or disposed of, if 

any, within the CO. This notice is provided in Attachment 4b, the Hazardous Substances 

Notification Table. Notification tables for both Petroleum Products and Hazardous Substances are 

provided in Attachments 4a and 4b, respectively. 

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, polychlorinated biphenyls (PCBs), 

silver recovery units (SRUs), and radiological investigation locations (RAD) 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 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 

was warranted. PRLs 605, 606, 354, and Runway Infield Area required a more comprehensive 

investigation; therefore, a site inspection under CERCLA was conducted at these PRLs (see Section 

4.1 and Table 4). Table 3 identifies and provides the status of the non-CERCLA PRLs within the CO 

areas. Based on additional records reviews and soil sampling it was determined that no significant 

release of hazardous substances or pollutants has occurred; therefore, no further investigation is 

warranted at the following PRLs: 

 CO II-E – 118 (U.S. EPA 2005a, DTSC 2005a), and 643 (U.S. EPA 2005a, DTSC 2006a) 

 CO II-M – 442 (U.S. EPA 2005a, DTSC 2005a), and 673 (U.S. EPA 2005a, DTSC 2005a) 

 CO II-R – 457 (U.S. EPA 2008a, DTSC 2008a). 

Table 4 identifies locations of concern (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 
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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, SRUs, RAD sites, PRLs, miscellaneous (MSC) 

sites, and PCB-containing transformers and equipment. LOCs within the COs proposed for transfer 

have received regulatory agency concurrence of NFA with the exception of the on-going petroleum 

corrective action at MSC B3 within CO I-F (Table 5) and the ongoing groundwater response action 

at IRP Site 16 (Table 4). 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 received closure and NFA or OPS concurrence within the COs. 

Site closure actions are detailed in Table 4. 

4.1.1 Carve-Out I-F (Figure 3) 

TAA Sites – TAA 5A received site closure concurrence (DTSC 2003c). TAA 5B received site 

closure concurrence (RWQCB 2008g, DTSC 2009a).

APHO Sites – APHO 26 received site closure concurrence (DTSC 2000b). APHO 92 received site 

closure concurrence (RWQCB 2003a, DTSC 2004a). 

IRP Sites 

IRP Site 16. A Record of Decision (ROD) documenting the selected remedy, monitored natural 

attenuation for groundwater with institutional controls, was signed in 2003 (DON 2003). A Final 

OPS Report was completed in September 2007 (DON 2007). The Final OPS Report received 

regulatory agency concurrence (U.S. EPA 2007, DTSC 2007, RWQCB 2007). In accordance with 

CERCLA Section 120(h)(3), once an OPS determination has been granted, the Navy can transfer the 

property subject to the covenants in Section 120(h)(3) of CERCLA. 

The ROD for IRP Site 16 specifies land-use control (LUC) objectives to be achieved through landuse restrictions. The Final Remedial Design Report (CDM Federal Programs Corporation [CDM] 

2006) includes a LUC Remedial Design which provides information on implementing and 

maintaining institutional controls. The LUC Remedial Design requires that certain land-use 

restrictions be incorporated into and implemented through two separate legal instruments: 1) a 

quitclaim deed between the DON and the transferee(s) and 2) a Covenant to Restrict Use of Property 

between the DON and DTSC (herein after referred to as the DTSC Covenant). See Section 5.1.1 for 

discussion of specific restrictions associated with IRP Site 16. 

IRP Site 25. A no action ROD for IRP Site 25 was signed on 30 September 1997 (DON 1997). The 

Remedial Investigation (RI) for IRP Site 25 indicated that the site-related releases were limited to 

sediment and surface water. The human health and ecological risk assessments showed that the 

constituents present in these media do not present an unacceptable risk to human health or the 

environment (Bechtel National, Inc. [BNI] 1997). IRP Site 25 is comprised of Agua Chinon Wash, 

Bee Canyon Wash, Borrego Canyon Wash, and Marshburn Channel, with Bee Canyon Wash passing 

under CO I-F. 

4.1.2 Carve-Out II-E (Figure 8) 

RFA Sites – RFA site 14 received site closure concurrence (RWQCB 2000d). RFA site 43 received 

site closure concurrence (DTSC 2006b). RFA site 150 received site closure concurrence (DTSC 
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1996b). RFA site 152 received site closure concurrence (DTSC 1996b). RFA site 267 received site 

closure concurrence (DTSC 1996b). 

TAA Sites – TAA 115 received site closure concurrence (DTSC 2006c). TAA 605 and 606 received 

site closure concurrence (DTSC 2004c, DTSC 2004d). 

APHO Sites – APHO 37 received site closure concurrence (DTSC 1999a, U.S. EPA 1999, RWQCB 

2000g). APHO 99 received site closure concurrence (RWQCB 2003a). APHO 110 received site 

closure concurrence (RWQCB 2003a). APHO 119 received site closure concurrence (DTSC 2003e, 

RWQCB 2003a). 

PRL Sites – PRL sites 605 and 606 received site closure concurrence (U.S. EPA 2005b, DTSC 

2008b). 

4.1.3 Carve-Out II-L (Figure 9) 

IRP Site – The Bee Canyon Wash portion of IRP Site 25 passes through CO II-L. For more 

information, see Section 4.1.1. 

PRL Site – PRL Runway Infield Area received site closure concurrence (U.S. EPA 2008b, DTSC 

2008b). 

4.1.4 Carve-Out II-M (Figure 10) 

RFA Sites – RFA sites 178, 181, 182, 183, and 184 received site closure concurrence (DTSC 

1996b). RFA site 185 received site closure concurrence (DTSC 2006d). RFA site 264 received site 

closure concurrence (DTSC 1996b). 

TAA Sites – TAA 673 received site closure concurrence (DTSC 2004e). TAA 772 received site 

closure concurrence (DTSC 2003b). 

APHO Sites – APHO 20 received site closure concurrence (DTSC 2000a). APHO 27 received site 

closure concurrence (RWQCB 2000f). APHO 38 received site closure concurrence (DTSC 2005b, 

California Department of Public Health [CDPH] 2007). APHO 46 received site closure concurrence 

(U.S. EPA 2004, RWQCB 2003c, DTSC 2004b, CDPH 2006, RWQCB 2006). APHO 51 received 

site closure concurrence (DTSC 2000d, RWQCB 2000h). 

RAD Sites – The RAD Nuclear, Biological, and Chemical site received site closure concurrence 

(CDPH 2007). The RAD Defense Reutilization and Marketing Office (DRMO) site received site 

closure concurrence (DTSC 1996b). During the year 2000, a station-wide historical radiological 

assessment (HRA) was conducted. The HRA recommended further radiological investigation for the 

DRMO Yard 3 prior to final disposition. A radiological survey was completed in 2001 and the 

results were presented in a radiological release report. CDPH concurred with the recommendation 

for unrestricted release (CDPH 2007). 

MSC Sites – MSC D1 received site closure concurrence (RWQCB 2000b). MSC 673T3 received 

site closure concurrence (DTSC 1996a). 

PRL Site – PRL 354 received site closure concurrence (U.S. EPA 2008b, DTSC 2009b). 

4.1.5 Carve-Out II-R (Figure 11) 

APHO Site – APHO 42 received site closure concurrence (DTSC 2000c, RWQCB 2000h). 

RFA Site – RFA site 244 received site closure concurrence (DTSC 1998). 
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SRUs – SRU 3C was evaluated under PRL 457, and received site closure concurrence (U.S. EPA 

2008a, DTSC 2008a). 

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 I-F (Figure 3) 

USTs – UST 6B received site closure concurrence (OCHCA 1997b). UST 101 received site closure 

concurrence (RWQCB 2003b, DTSC 2003d). USTs 850A and 850B received site closure 

concurrence (RWQCB 2008b). 

OWS – OWS 850E received site closure concurrence (RWQCB 2008b). 

MSC Sites – MSC B1 received site closure concurrence (RWQCB 2001b). MSC B2 received site 

closure concurrence (RWQCB 2000a). MSC B3 is undergoing corrective action for a petroleum 

release (see Section 5.2.1 for restrictions). 

4.2.2 Carve-Out I-K (Figure 4) 

USTs – UST 68 received site closure concurrence (RWQCB 1997a). UST 70 received site closure 

concurrence (RWQCB 2008d). UST 72 received site closure concurrence (RWQCB 2008c). UST 

718 received site closure concurrence (OCHCA 1996c). 

4.2.3 Carve-Out I-N (Figure 5) 

AST – AST 1 received site closure concurrence (RWQCB 2001a). 

USTs – USTs 1A and 1B received site closure concurrence (RWQCB 1996a and RWQCB 2008e). 

4.2.4 Carve-Out I-O (Figure 6) 

UST – UST 98A received site closure concurrence (RWQCB 2008a). 

4.2.5 Carve-Out I-S (Figure 7) 

USTs – UST 147 received site closure concurrence (RWQCB 2003d). UST 273 received site closure 

concurrence (RWQCB 1996c). UST 273B received site closure concurrence (RWQCB 2008f). 

4.2.6 Carve-Out II-E (Figure 8) 

USTs – UST 115A received site closure concurrence (RWQCB 1996b). UST 115B received site 

closure concurrence (RWQCB 1998a). UST 116 received site closure concurrence (RWQCB 2000e). 

UST 117 received site closure concurrence (RWQCB 1998b). UST 605A received site closure 

concurrence (RWQCB 1997b). UST 605B received site closure concurrence (OCHCA 1999). UST 

606A received site closure concurrence (RWQCB 1997b). UST 643A received site closure 

concurrence (OCHCA 1997a). 

OWSs – OWS 605C received site closure concurrence (OCHCA 1999). OWS 643B received site 

closure concurrence (OCHCA 1997a). OWS 892 received site closure concurrence (RWQCB 

2000c). 
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4.2.7 Carve-Out II-M (Figure 10) 

UST – UST 442 received site closure concurrence (OCHCA 1996a). 

OWSs – OWS 673A received site closure concurrence (RWQCB 2001c). OWS 832 received site 

closure concurrence (RWQCB 2004 and DTSC 2005c). 

4.2.8 Carve-Out II-R (Figure 11) 

UST – UST 457 received site closure concurrence (OCHCA 1996b). 

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 (non-FAD) ACM was detected in a survey that was conducted prior to but not since 1997 

(i.e., not within the last 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 twenty-five non-residential buildings within three of the COs proposed for 

transfer, fourteen of which have been surveyed for ACM. Information on the existence, extent, and 

condition of ACM at these buildings is provided in Table 6. 

4.4 LEAD-BASED PAINT

Notifications of potential LBP at buildings within the COs proposed for transfer are based on the age 

of construction (i.e., constructed before the Consumer Product Safety Commission’s 1978 ban on 

LBP for residential use). The COs proposed for transfer contain buildings that were constructed prior 

to 1978 and may contain LBP. The age of many of the buildings on the property suitable for transfer 

suggests the likelihood that LBP may be present on some of these buildings. 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. The construction dates for each of the buildings within 

the COs are summarized in Table 1. None of the buildings listed in Table 1 have been used for 

residential purposes. 

Demolition of non-residential buildings 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 non-residential buildings 

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 for soil-lead hazards, and to 

abate any such hazards that may be present, after demolition of such non-residential buildings and 

prior to occupancy of any newly constructed residential buildings. 
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4.5 POLYCHLORINATED BIPHENYLS

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

components. A comprehensive survey of the 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 ballasts 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 that may be 

disposed as municipal solid waste. No action is required at buildings, structures, and 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 be 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 disposal of PCBs is regulated under the federal Toxic Substances Control Act (TSCA) (15 

U.S.C. Section 2601, et seq., as implemented by 40 Code of Federal Regulations Part 761), which 

banned the manufacture and distribution of PCBs, with the exception of PCBs used in enclosed 

systems. By federal definition, PCB equipment contains 500 parts per million (ppm) PCBs or more, 

whereas PCB-contaminated equipment contains PCB concentrations equal to or greater than 50 ppm, 

but less than 500 ppm. The TSCA regulates and the U.S. EPA enforces the removal and disposal of 

all sources of PCBs containing 50 ppm or more. Items containing PCBs below 50 ppm are classified 

by TSCA as non-PCB items and are not required to be removed from service. 

4.5.1 Carve-Out I-F (Figure 3) 

Transformer PCB T1 was within CO I-F. This transformer was replaced with a non-PCB transformer 

and no evidence of a release has been identified at this transformer location (DTSC 2003a and U.S. 

EPA 2003). 

4.5.2 Carve-Out I-S (Figure 7) 

Transformers PCB T36, T37, and T38 were within CO I-S. These transformers were replaced with 

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

(DTSC 2003a and U.S. EPA 2003). 

4.5.3 Carve-Out II-E (Figure 8) 

Transformers PCB T15, T16, T81, and T82 were within CO II-E. These transformers were replaced 

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

locations (DTSC 2003a and U.S. EPA 2003). 

Non-transformer PCB items with less than 5 ppm PCB concentrations were associated with 

Buildings 643 and 892 (PCB 643 and PCB 892). NFA was received at these non-transformer PCB 

locations (DTSC 2003a and U.S. EPA 2003). 

4.5.4 Carve-Out II-R (Figure 11) 

There is one pad-mounted transformer (PCB T74) at Building 457. A response action was required 

for releases of transformer oil containing PCBs at Building 457 (RFA 244). Shallow soil samples 

that were collected in the area affected by the PCB release identified PCBs in one of the seven 

samples collected. The transformer was replaced and impacted soil was removed. The response 
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action was completed and closed in December 1998. No evidence of a release for PCB T74 or RFA 

244 was observed during the visual site inspections conducted for the 2003 EBS. All required 

responses have been completed, and NFA was received (DTSC 2003a and U.S. EPA 2003). 

Building 457 has subsequently been demolished to its foundation. 

4.6 SCHOOL SITE CONSIDERATIONS

If, subsequent to transfer, any portions of the property found suitable to transfer by this FOST are 

considered for the proposed acquisition and/or construction of school properties using 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 LBP 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. 

5. SUMMARY OF RESTRICTIONS 

This section summarizes the restrictions, if any, associated with each of the CO areas proposed for 

transfer related to CERCLA/RCRA sites, petroleum products and derivatives, ACM, and LBP. These 

restrictions on certain activities ensure that post-transfer use of the CO areas is consistent with 

protection of human health and the environment. 

5.1 CERCLA/RCRA 

5.1.1 Carve-Out I-F (Figure 3) 

IRP Site 16. – Land-use controls implementing LUC objectives for IRP Site 16 restrict future 

landowner(s) and/or user(s) use of the property in order to limit potential exposure to hazardous 

substances until the remedial action objectives are met. The area subject to these restrictions is 

identified on Figure 3 as the area requiring institutional controls (ARIC). This rectilinear area is 

different than the curvilinear ARIC that was depicted in the ROD and the Final Remedial Design 

Report (CDM 2006). The ARIC was slightly expanded in lieu of area encompassing the VOCimpacted groundwater plume and its associated buffer zone. The revised ARIC was reviewed by and 

received concurrence from the FFA signatories. In addition to the LUC objectives to restrict the use 

of the property, the wells listed in Table 7 and identified on Figure 3, will be protected. The 

following list of LUCs are consistent with the Final Remedial Design Report (CDM 2006) and will 

be similarly incorporated into the quitclaim deed and the DTSC Covenant: 

 The transferee shall not install new groundwater wells of any type within the ARIC without 

prior review and written approval from the FFA signatories; 

 The transferee shall not allow the use of volatile organic compound (VOC)-impacted 

groundwater within the ARIC without prior review and written approval from the FFA 

signatories; 
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 The transferee shall not alter, disturb, or remove existing or future wells and associated 

equipment within the ARIC without prior review and written approval from the FFA 

signatories; and 

 The transferee shall not conduct any subsurface excavation, drilling, or other disturbance of 

the ground surface of the main pit area within the ARIC without prior review and written 

approval from the FFA signatories. 

The Navy will also include the following specific additional requirements in the quitclaim deed and 

will work with DTSC to incorporate similar language into the DTSC Covenant: 

- The transferee and future transferee(s) must comply with all terms and conditions relating to 

land-use restrictions set forth in the IRP Site 16 ROD and IRP Site 16 Remedial Design. 

- The transferee(s) and future transferee(s) shall allow the DON, FFA signatories, and their 

authorized agents, employees, contractors and subcontractors to enter the site to conduct 

investigations, sampling, surveys, and inspect field activities associated with the remedy for 

IRP Site 16. 

- The transferee(s) and future transferee(s) shall continue to perform annual site inspections to 

ensure that all LUC performance objectives are being complied with by all future user(s), 

continue to report results from those inspections, and enforce the land-use restrictions 

identified in the Remedial Design. However, the DON shall retain the ultimate responsibility 

for the integrity of the remedy. 

- The transferee and future transferee(s) shall provide to the DON and to the FFA signatories 

an annual LUC Compliance Certificate for IRP Site 16. In addition, should any deficiencies 

be found during any annual inspection, the future property owner(s) will provide to the FFA 

signatories a separate written explanation with the LUC Compliance Certificate indicating 

the specific deficiencies found and what efforts or measures have or will be taken to correct 

those deficiencies. Copies of a completed and signed LUC Compliance Certificate shall be 

sent to the FFA signatories by certified mail, return receipt requested in January of each 

calendar year. The need to continue to provide such inspections and certifications on an 

annual basis will be re-evaluated every 5 years by the FFA signatories. 

- At least 60 days prior to conveyance of the IRP Site 16 property to any other agency, person, 

or entity, the DON or property owner shall provide notice to the FFA signatories of such 

intended conveyance. The notice shall describe the mechanism by which LUCs will continue 

to be implemented, maintained, inspected, reported, and enforced. Reference to the IRP Site 

16 LUC Remedial Design shall be sufficient description of the mechanism. 

- The DON shall require, via appropriate provisions to be placed in the DTSC Covenant and 

quitclaim deed, that the future landowner(s) shall notify the FFA signatories within 3 

business days of the discovery of any activity on the property inconsistent with the land-use 

restrictions. The landowner(s) shall then work with the FFA signatories to correct the 

problem(s) discovered. Should the DON discover any activity on the property inconsistent 

with the land-use restrictions, the DON shall notify the FFA signatories within 3 business 

days of such discovery. The DON shall then work with the FFA signatories to correct the 

problem(s) discovered. This reporting requirement does not preclude the DON from taking 

immediate action pursuant to its CERCLA authorities to prevent any actual or perceived 

risk(s) to human health or the environment. 
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5.2 PETROLEUM PRODUCTS AND DERIVATIVES

5.2.1 Carve-Out I-F (Figure 3) 

MSC B3 – MSC B3 is part of an on-going petroleum corrective action related to soil. Therefore, 

land use restrictions for the petroleum-impacted soil will be incorporated into the quitclaim deed and 

implemented in order to limit the exposure to petroleum and its derivatives and to maintain the 

integrity of corrective actions until corrective action is complete and federal and state cleanup levels 

have been met. 

In order to protect present and future human health, safety, and the environment, the transferee shall 

refrain from the following acts within the area designated on Figure 3 as the no dig area for ongoing 

petroleum corrective action, without prior review and approval from the DON and RWQCB until 

cleanup objectives have been achieved: 

 "Land disturbing activity" includes, but is not limited to: 

o Excavation of soil; and 

o Any activity that involves movement of soil to the surface of the land from below the 

surface of the land. 

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

 Removal of or damage to locks on monitoring wells, survey monuments, fencing, or signs. 

These restrictions may be released when the RWQCB has concurred that the cleanup objectives have 

been achieved and a release document is recorded with the County Clerk. However the DTSC 

Covenant, as discussed in Section 5.1, will remain in effect. 

5.3 ASBESTOS-CONTAINING MATERIAL

The transferee will be required to comply with the specific restrictions listed below for the status of 

ACM that has been identified within the respective COs. Information on the existence, extent, and 

condition of ACM at buildings within COs I-N, II-E, and Building 746 is provided in Table 6. 

5.3.1 Carve-Out I-N (Figure 5) 

Building 1 – This building had an ACM survey conducted in 1999 that detected non-FAD ACM. The 

transferee shall be responsible for the removal and/or management of ACM prior to or during 

renovation or demolition in accordance with applicable regulatory requirements.

5.3.2 Carve-Out II-E (Figure 8) 

Buildings 605 and 606 – These building are classified as containing FAD ACM based on previous 

surveys conducted in 1991 and 1999. Except for short-term and emergency maintenance, access, use, 

or occupancy is prohibited pending either (1) completion of ACM surveys and completion of any 

necessary ACM abatement, 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. 

Buildings 115, 118, 119, 139, 695, 696, and 697 – These buildings require an ACM survey because 

the previous survey detected non-FAD ACM. Except for short-term and emergency maintenance, 

access, use, or occupancy is prohibited pending either (1) completion of ACM surveys and 

completion of any necessary ACM abatement, or (2) demolition by the transferee, in accordance 

with all applicable local, state, and federal laws and other requirements relating to asbestos or ACM. 
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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. 

5.3.3 Carve-Out Building 746 (Figure 12) 

Building 746 – This building had ACM surveys conducted in 1991 and 1999 that detected non-FAD 

ACM. The transferee shall be responsible for the removal and/or management of ACM prior to or 

during renovation or demolition in accordance with applicable regulatory requirements. 

5.4 LEAD-BASED PAINT

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

structures, and facilities, and identification and/or evaluation of any LBP hazards, the transferee shall 

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

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

5.4.1 Carve-Out I-N (Figure 5) 

Building 1 (1943) – This nonresidential building was constructed prior to 1978 and may not be used 

for residential use or as child-occupied building unless the transferee performs any necessary 

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

requirements. 

5.4.2 Carve-Out II-E (Figure 8) 

Buildings 115 (constructed in 1966), 118 (1943), 119 (1943), 139 (1943), 605 (1962), 606 (1965), 

639 (1969), 640 (1969), 641 (1969), 643 (<1973), 695 (1975), 696 (1975), 697 (1975) – these 

nonresidential buildings were constructed prior to 1978 and may not be used for residential use or as 

child-occupied buildings unless the transferee performs any necessary evaluation(s) and abatement in 

accordance with all local, state, and federal laws and other applicable requirements. 

6. ADJACENT PROPERTIES 

Six of the ten COs in the FOST are surrounded by property that was transferred in the initial MCAS 

El Toro FOST of July 2004 (DON 2004) and subsequent FOSTs. As the land areas of the earlier 

FOST were found suitable for transfer, they pose no negative effects on the COs proposed for 

transfer in this FOST. The three COs in this FOST that are adjacent to COs requiring additional 

remediation are described below. 

6.1 CARVE-OUT II-E (FIGURE 8) 

CO II-E adjoins CO II-Q; however, releases that occurred within the CO do not pose an 

environmental threat to CO II-E. CO II-Q contains a ferrocene spill area (IRP Site 4) that occurred in 

August 1983 when the contents of a 500-gallon tank (wash water and residual jet fuel) reportedly 

overflowed. The RI for the site indicated that the site-related contamination was limited to the 

shallow soil interval and the human health and ecological risk assessments showed that the 

constituents present in the soil do not present an unacceptable risk to human health or the 

environment (BNI 1997). Therefore, no remedial action was required. The NFA ROD addressing 

IRP Site 4 was signed on 30 September 1997. CO II-Q also encompasses two petroleum plumes 

caused by leaking USTs at Tank Farm 5 and Building 398. The plume associated with Tank Farm 5 

is approximately 400 feet southeast of CO II-E. The plume associated with Building 398 is 

approximately 400 feet southwest of CO II-E. Based on the monitoring data collected to date it is 

projected that both of these plumes will not encroach on CO II-E. 
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6.2 CARVE-OUT II-M (FIGURE 10) 

This CO adjoins CO II-H which contains a former landfill site (IRP Site 5) that was active from 

approximately 1955 until the late 1960s. Due to the potential for the landfill to contain radioactive 

material at depths of several feet below ground surface (bgs), on-site radiological survey and 

laboratory analyses of soil samples were conducted for IRP Site 5 from June through November 

2001 and during March 2004. Detailed descriptions of the survey activities, results, analyses, and 

recommendations are presented in the Radiological Release Report (Weston 2006). Based on the 

survey results, and risk and dose calculations, it was concluded that Radium-226 concentrations in 

surface soil (up to 18 inches bgs) do not pose unacceptable risk. However, since there is potential 

for the landfill to contain radioactive material, IRP Site 5 was recommended for restricted 

radiological release. 

A ROD addressing IRP Site 5 was signed in 2008 (DON 2008c) and remedial design activities have 

been initiated. Due to the extent of the landfill buffer zone and the fact that the landfill was not 

operated for an extended period of time and that the waste is overlain by 2 to 4 feet of soil cover, 

there is no danger of landfill contamination spreading to CO II-M. APHO 46 is present within both 

COs II-M and II-H. APHO 46 has received regulatory concurrence on NFA for both radiological and 

non-radiological issues (U.S. EPA 2004, RWQCB 2003c, DTSC 2004b, CDPH 2006, RWQCB 

2006); therefore, there is no concern regarding previous contamination concerns of this APHO 

between the two COs. 

6.3 CARVE-OUT BUILDING 746 (FIGURE 12) 

This CO borders COs II-D and II-Q. CO II-D contains a former landfill site (IRP Site 3) that was 

active from 1943 until 1955. A ROD addressing IRP Site 3 was signed in 2008 (DON 2008c) and 

remedial design activities have been initiated. Due to the extent of the landfill buffer zone and the 

fact that the landfill was closed for an extended period of time, there is no danger of landfill 

contamination spreading to CO Building 746. Section 6.1, above, details CO II-Q. Similar to CO IIE, neither of the petroleum plumes associated with Tank Farm 5 or Building 398 will encroach into 

CO Building 746. 

7. COVENANTS 

The deed for transfer of any property 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 identified pursuant to section 

120(h)(3)(A)(i)(I) of the Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 remaining on the property has been taken before the date of this deed” 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. CO 

I-K, I-N, I-O, and I-S were only impacted by petroleum or its derivatives; therefore, these COs shall 

be conveyed “as is” without a CERCLA covenant. 

8. ACCESS CLAUSE 

The deed will reserve and the transferee shall grant to the U.S. (DON and U.S. EPA) access to COs 

I-F, II-E, II-L, II-M, II-R, and Building 746 pursuant to CERCLA Section 120(h) (3) (A) (iii). 

DTSC, RWQCB, U.S. EPA and their successors and assigns shall also be granted access to the 

property to enter the COs in any case in which remedial action or corrective action is found to be 

necessary on COs after the date of transfer. In addition, the deed will provide for a right of access for 

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10. REFERENCES 

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

Marine Corps Air Station El Toro, California. June 1997. 

______. 2000. Draft Phase II Feasibility Study Report, Operable Unit 3 – Site 16, Crash Crew 

Training Pit No. 2 Marine Corps Air Station, El Toro, California. February. 

______. 2002. Final Phase II Focused Feasibility Study Report, OU-3 Site 16, Crash Crew Training 

Pit No. 2, Former Marine Corps Air Station El Toro, California. August. 

Brown and Caldwell. 2006. Closure Report for Former Temporary Accumulation Area Site 115, 

Former Marine Corps Air Station El Toro, Irvine, California. July 20. 

California Department of Public Health (CDPH). 2006. Concurrence Letter for Unrestricted Release 

of Anomaly Area 3 (AA3) and Aerial Photograph Anomaly 46 (APHO 46) at former Marine 

Corps Air Station, El Toro, California. May 19. 

______. 2007. Concurrence Letter for Unrestricted Release of Defense Reutilization and Marketing 

Office (DRMO) Yard 3, Former Nuclear, Biological and Chemical Complex (NBC), including 

Aerial Photograph Anomaly (APHO) 38, and Paved Area Located South of Building 295, 

Marine Corps Air Station El Toro, California. August 20. 

California Regional Water Quality Control Board (RWQCB). 1996a. No Further Action 

Concurrence Letter for Underground Storage Tank (UST) 1A. October 2. 

______. 1996b. No Further Action Concurrence Letter for Underground Storage Tank (UST) 115A.

December 16. 

______. 1996c. No Further Action Concurrence Letter for Underground Storage Tank (UST) 273. 

October 3. 

______. 1997a. No Further Action Concurrence Letter for Underground Storage Tank (UST) 68.

October 3. 

______. 1997b. No Further Action Concurrence Letter for Underground Storage Tank (UST) 605A 

and 606A. April 11. 

______. 1998a. No Further Action Concurrence Letter for Underground Storage Tank (UST) 115B.

January 7. 

______. 1998b. No Further Action Concurrence Letter for Underground Storage Tank (UST) 117.

January 7. 

______. 2000a. No Further Action Concurrence Letter for Firefighter Burn Pit MSC B2. October 10. 

______. 2000b. No Further Action Concurrence Letter for Desert Storm Material Staging Area MSC 

D1. September 28. 

______. 2000c. No Further Action Concurrence Letter for Oil Water Separator (OWS) 892. July 7. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

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______. 2000d. No Further Action Concurrence Letter for RCRA Facility Assessment (RFA) Site 14.

March 31. 

______. 2000e. No Further Action Concurrence Letter for Underground Storage Tank (UST) 116.

August 31. 

______. 2000f. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) Site 

27. October 18. 

______. 2000g. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 

Sites 2, 3, 8, 10, 16, 18, 25, 30, 34, 36, 37, and 41. October 31. 

______. 2000h. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 

Sites 1, 5, 7, 12, 15, 22, 23, 24, 27, 29, 39, 42, 49, 51, 52, 53, 54, 55, 56, 57, and 58. October 

18. 

______. 2001a. No Further Action Concurrence Letter for Aboveground Storage Tank (AST) 1. 

January 17. 

______. 2001b. No Further Action Concurrence Letter for Firefighter Burn Pit MSC B1. October 11. 

______. 2001c. No Further Action Concurrence Letter for Oil Water Separator (OWS) 673A.

January 17. 

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

Sites 92, 99, 110, and 119. August 14. 

______. 2003b. No Further Action Concurrence Letter for Underground Storage Tank (UST) 101.

October 20. 

______. 2003c. No Comment Letter for APHO 46 and MSC R2. May 1. 

______. 2003d. No Further Action Concurrence Letter for Underground Storage Tank (UST) 147. 

November 24. 

______. 2004. No Further Action Concurrence Letter for Oil Water Separator (OWS) 832. February 

23. 

______. 2006. Concurrence Letter regarding Draft Final Radiological Release Report, IRP Sites 3 

and 5, Aerial Photograph Anomaly Site 46, Anomaly Area 3, and Building 244, Former 

Marine Corps Air Station, El Toro. October 23. 

______. 2007. Concurrence Letter regarding Demonstration that Remedial Action is Operating 

Properly and Successfully (OPS), Operable Unit (OU) 3, Installation Restoration Program 

(IRP) Site 16, Crash Crew Training Pit No. 2. 

______. 2008a. No Further Action Concurrence Letter for Underground Storage Tank (UST) 98A.

October 6. 

______. 2008b. No Further Action Concurrence Letter for Underground Storage Tank (UST) 850A, 

850B, and Oil/Water Separator 850E. August 28. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

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______. 2008c. No Further Action Concurrence Letter for Underground Storage Tank (UST) 72.

July 15. 

______. 2008d. No Further Action Concurrence Letter for Underground Storage Tank (UST) 70.

July 15. 

______. 2008e. No Further Action Concurrence Letter for Underground Storage Tank (UST) 1B.

October 10. 

______. 2008f. No Further Action Concurrence Letter for Underground Storage Tank (UST) 273B. 

December 12. 

______. 2008g. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) Site 

5B. November 24. 

California Department of Toxic Substances Control (DTSC). 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. 

______. 1998. No Further Action Concurrence Letter for RCRA Facility Assessment (RFA) Site 244. 

December 17. 

______. 1999a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 37. 

September 9. 

______. 2000a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 20. 

March 3. 

______. 2000b. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 26. 

January 4. 

______. 2000c. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 42. 

March 27. 

______. 2000d. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 51. 

June 14. 

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

______. 2003b. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 

772. November 7. 

______. 2003c. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 5A. 

March 4. 

______. 2003d. No Further Comments Letter for Underground Storage Tank (UST) 101. September 

17. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

19 

______. 2003e. 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. 

______. 2004a. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 92. 

April 20. 

______. 2004b. No Further Investigation Concurrence Letter for APHO 46 and MSC R2. May 17. 

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

605. September 13. 

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

606. September 16. 

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

673. September 24. 

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

Locations (PRLs). July 13. 

______. 2005b. No Further Action Concurrence Letter for Aerial Photograph Anomaly (APHO) 38. 

April 6. 

______. 2005c. No Further Action Concurrence Letter for Oil Water Separator (OWS) 832. April 

20. 

______. 2006a. No Further Investigation Concurrence Letter for Group III Potential Release 

Locations (PRLs). February 3. 

______. 2006b. No Further Action Concurrence Letter for RCRA Facility Assessment (RFA) Site 43. 

June 5. 

______. 2006c. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 

115. December 28. 

______. 2006d. No Further Action Concurrence Letter for RCRA Facility Assessment (RFA) Site 

185. July 31. 

______. 2007. Concurrence on Final Operating Properly and Successfully (OPS) Report, Operable 

Unit 3, Installation Restoration Program (IRP) Site 16, Former marine Corps Air Station 

(MCAS) El Toro, Irvine, California. October 18. 

______. 2008a. No Further Investigation Concurrence with Final Summary Report for Group IV 

Potential Release Locations (PRLs). August 21. 

______. 2008b. No Further Investigation Concurrence with Final Summary Report for Group VI 

Potential Release Locations (PRLs). November 26. 

______. 2009a. No Further Action Concurrence Letter for Temporary Accumulation Area (TAA) 5B. 

April 8. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

20 

______. 2009b. No Further Investigation Concurrence with Final Summary Report for Group VI 

Potential Release Locations (PRLs), including PRL 354. September 25. 

CDM Federal Programs Corporation (CDM). 2003. Final Summary Report, Former Underground 

Storage Tank Site 101, Former Marine Corps Air Station El Toro, El Toro, California. August 

21. 

______. 2006. Final Remedial Design for Monitored Natural Attenuation with Institutional Controls, 

Operable Unit 3, IRP Site 16, Crash Crew Training Pit No. 2, Former Marine Corps Air 

Station El Toro, California. March. 

County of Orange Health Care Agency (OCHCA). 1996a. Completion of Tank Removal Project and 

No Further Action Requite Letter for Underground Storage Tank (UST) 442. December 9. 

______. 1996b. Completion of Tank Removal Project and No Further Action Require Letter for 

Underground Storage Tank (UST) 457. December 9. 

______. 1996c. Completion of Tank Removal Project and No Further Action Require Letter for 

Underground Storage Tank (UST) 718. December 9. 

______. 1997a. Completion of Tank Removal Project and No Further Action Require Letter for 

Underground Storage Tank (UST) 643A and Oil/Water Separator (OWS) 643B. July 11. 

______. 1997b. Completion of Tank Removal Project and No Further Action Require Letter for 

Underground Storage Tank (UST) 6B. March 27. 

______. 1999. Completion of Tank Removal Project and No Further Action Require Letter for 

Underground Storage Tank (UST) 605B and Oil/Water Separator (OWS) 605C. December 9. 

Department of Defense (DoD). See United States Department of Defense. 

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

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 III Potential Release Locations, Environmental Baseline 

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

———. 2008a. Draft Summary Report for Group VI Potential Release Locations, Site Inspection, 

Former Marine Corps Air Station, El Toro, California. October. 

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

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

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

March. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

21 

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. 

Radian. 1996. Final AB 2588 Air Toxics “Hot Spots” 1995 Inventory Report for Marine Corps Air 

Station El Toro, California, SCAQMD ID No. 6281. May. 

Shaw Environmental, Inc. (Shaw). 2003a. Closure Report, Former Temporary Accumulation Area 

673, Former Marine Corps Air Station El Toro, California. May 21. 

_______. 2003b. Summary Report, Aerial Photograph Anomaly (APHO) 38, Marine Corps Air 

Station, El Toro, California. December 19. 

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. From Principle Assistant Deputy 

Under Secretary of Defense (Environmental Security). October. 

______. 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. 

______. 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. 

______. 2003. Final Record of Decision, Operable Unit 3 Site 16 Crash Crew Training Pit No. 2, 

Former Marine Corps Air Station El Toro, California. August. 

______. 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. 
Final Finding of Suitability to Transfer #5 Finding of Suitability 

April 2010 Former MCAS El Toro, California to Transfer 

22 

______. 2007. Final Operating Properly and Successfully (OPS) Report, Operable Unit 3, 

Installation Restoration Program (IRP) Site 16, Former marine Corps Air Station (MCAS) El 

Toro, Irvine, California. September. 

______. 2008a. Summary Report, Former Underground Storage Tank Site 273B, Former Marine 

Corps Air Station, El Toro, California. October. 

______. 2008b. Closure Report, Temporary Accumulation Area (TAA) Site 5B, Former Marine 

Corps Air Station, El Toro, California. November. 

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

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

______. 2009. Final Finding of Suitability to Transfer #4 for Carve-outs I-B, I-F, I-G, I-H, I-L, I-J, 

I-L, I-M, I-P, II-G, II-I, II-P, and III-D, Former Marine Corps Air Station, El Toro, 

California. January. 

United States Environmental Protection Agency (U.S. EPA) Region IX. 1999. Concurrence Letter 

for Aerial Photograph Anomaly (APHO) Sites 8, 9, 10, 28, 30, 35, 37, and 41. November 4. 

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

September 25. 

______. 2004. Concurrence Letter for APHO 46 and MSC R2. March 8 

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

______. 2005b. Concurrence Letter for Group III Potential Release Locations (PRLs). November 3. 

______. 2007. Concurrence Letter regarding Demonstration that Remedial Action is Operating 

Properly and Successfully (OPS), Operable Unit (OU) 3, Installation Restoration Program 

(IRP) Site 16, Crash Crew Training Pit No. 2. April 10. 

______. 2008a. Concurrence Letter for Group IV Potential Release Locations (PRLs). April 17. 

______. 2008b Concurrence Letter for Group VI Potential Release Locations (PRLs). November 20. 

Weston Solutions, Inc. (Weston). 2006. Final Radiological Release Report, Installation Restoration 

Program Sites 3 and 5, Aerial Photograph Anomaly Site 46, Anomaly Area 3, and Building 

244. December. 

______. 2007. Radiological Release Report, Former Explosive Ordnance Disposal (EOD) Range - 

IRP Site 1, Former Defense Reutilization and Marketing Office (DRMO) Yard 3, Former 

Nuclear, Biological & Chemical (NBC) Complex, including Aerial Photograph Anomaly 

(APHO) 38, and Paved Area Located South of Building 295. April 12. 
Tables 
This Page Intentionally Left Blank 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California Table 1

Page 1 of 1 

Table 1: Buildings/Structures/Facilities

Carve-out 

Building/Structure/Facility 

Number Building/Structure/Facility Name/Description 

Year of 

Construction Square Feet 

Carve-Out I-N 

I-N 1 Squadron Headquarters Telephone Exchange 1943 15,768 

Carve-Out II-E 

II-E 115 Aircraft Maintenance Hanger 1966 25,414 

II-E 118 Aircraft Maintenance Hanger 1943 6,240 

II-E 119 Aircraft Maintenance Hanger 1943 6,240 

II-E 139 3rd Marine Air Wing Embarkation area 1943 6,240 

II-E 605 Maintenance Hanger 1962 23,598 

II-E 606 Maintenance Hanger 1965 23,598 

II-E 639 Electric Power Plant Building 1969 144 

II-E 640 Electric Power Plant Building 1969 144 

II-E 641 Electric Power Plant Building 1969 144 

II-E 643 Fixed Aircraft Start System <1973 14,915 

II-E 695 Line Maintenance Shelter 1975 900 

II-E 696 Line Maintenance Shelter 1975 900 

II-E 697 Line Maintenance Shelter 1975 900 

II-E 892 Aircraft Washrack Pavement 1991 672 

II-E 912 Hazardous and Flammable Materials Storehouse 1993 150 

II-E 913 Hazardous and Flammable Materials Storehouse 1993 150 

II-E 914 

Vacant Hazardous and Flammable Materials 

Storehouse 1993 150 

II-E 936 Hazardous Waste Storehouse 1994 272 

II-E 937 Hazardous Waste Storehouse 1994 272 

II-E 939 Hazardous Waste Storehouse 1994 255 

II-E 940 Hazardous Waste Storage 1994 272 

II-E 972 Liquid Oxygen Shelter 1994 320 

Carve-Out Building 746 

Building 746 746 Flight Simulator 1984 22,516 

Building 746 796 Substation Chiller Building 1984 1,518 

Source: Earth Tech 2003. 

Notes: 

< = before 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 1 

Table 2: Environmental Requirements and Notifications 

Applicable to Property 

Carve Out 

Environmental Factors Considered I-F I-K I-N I-O I-S II-E II-L IPresence of Hazardous Substances (Notification) Y N N N N Y Y CERCLA/RCRA (Response/Corrective Action) Y N N N N Y Y Presence of Petroleum Products and Derivatives (Notification) Y Y Y Y Y Y N UST/AST Storage Tanks (Closure/Removal) Y Y Y Y Y Y N Munitions and Explosives of Concern – Response Actions N N N N N N N Asbestos-Containing Material (Abatement, Notification) N N Y N N Y N Lead-Based Paint (Non-Residential Buildings Notification) N N Y N N Y N Polychlorinated Biphenyls (Notification) Y N N N Y Y N School Site Considerations Y Y Y Y Y Y Y Notes  AST = aboveground storage tank  CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act  N = No  RCRA = Resource Conservation and Recovery Act  UST = underground storage tank  Y = Yes 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 2 

Table 3: Potential Release Locations

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFI Letter 

Agency/Date Notes 

Carve-Out II-E 

PRL 118 118 Maintenance Hangar Summary Report 

for Group I PRLs 

Site Insepction 

(SI) by Earth 

Tech, March 

2005 (Earth 

Tech 2005a) 

U.S. EPA 

04/07/2005 

DTSC 07/13/2005 

Records review, VSIs, and soil sampli118 from 2002 to 2004, to evaluate whhazardous substances or pollutants inoccurred. Based on the results of thesinvestigation (NFI) was recommended Report for Group I PRLs and regulato

PRL 643 643 Fixed Aircraft Start System Summary Report 

for Group III 

PRLs SI by Earth 

Tech, October 

2005 (Earth 

Tech 2005b) 

U.S. EPA 

11/03/2005 

DTSC 02/03/2006 

Records review and VSIs were conduwhether the release of hazardous subenvironment has occurred. Based on investigations, NFI was recommended Report for Group III PRLs and regulato

Carve-Out II-M 

PRL 442 442 Aviation Armament/Missile 

Maintenance Equipment 

Shop 

Summary Report 

for Group I PRLs 

SI by Earth 

Tech, March 

2005 (Earth 

Tech 2005a) 

U.S. EPA 

04/07/2005 

DTSC 07/13/2005 

Records review, VSIs, and soil sampli442 from 2002 to 2004, to evaluate whsubstances or pollutants into the environ the results of these investigations, this PRL in the Summary Report for Gconcurrence was obtained. 

PRL 673 673 Aircraft Ground Support 

Equipment Shop 

Summary Report 

for Group I PRLs 

SI by Earth 

Tech, March 

2005 (Earth 

Tech 2005a) 

U.S. EPA 

04/07/2005 

DTSC 07/13/2005 

Records review, VSIs, and soil sampli673 from 2002 to 2004, to evaluate whsubstances or pollutants into the environ the results of these investigations, this PRL in the Summary Report for Gconcurrence was obtained. 

Carve-Out II-R 

PRL 457 457 Dental Clinic Summary Report 

for Group IV 

PRLs SI by Earth 

Tech, March 

2008 (Earth 

Tech 2008b) 

DTSC 08/21/2008 

U.S. EPA 

04/17/2008 

Site identified as a former SRU at a phdental clinic (SRU 3C). Records reviewwere conducted for PRL 457 from 200whether a release of hazardous substenvironment has occurred. Based on investigations, NFI was recommended Report for Group IV PRLs and regulatobtained. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 2 of 2 

Table 3: Potential Release Locations

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFI Letter 

Agency/Date Notes 

Source: Earth Tech 2003. 

DTSC = Department of Toxic Substances Control ID = Identification LOC = Location of Concern NFI = No Further Investigation PRL = Potential Release Location SI = Site Inspection SRU = Silver Recovery Unit U.S. EPA = Environmental Protection Agency VSI = Visual Site Inspection 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

Carve-Out I-F 

APHO 26 Crash Crew Pit 

No. 2 

Disturbed Ground 

and Excavation 

Summary Report, 

APHO 26 

10/30/1999 

by 

NAVFAC SW 

DTSC 01/04/2000 APHO 26, also known as SAIC anoma

aerial photograph dated 08/28/1968. Sexcavation (EX) with possible liquid (LQof the taxiways, about 1,200 feet north feet west of Runway 34L. The purpose unknown. Investigation of site's history facility records were reviewed, visual inand the findings were documented in th10/30/1999. No further action is require

APHO 92 Compass Rose 

No. 1 

Stain Information 

Package, APHOs 

83, 91, and 92 

04/17/2003 

by 

NAVFAC SW 

RWQCB 08/14/2003 

DTSC 04/20/2004 

APHO 92, also known as SAIC anomaaerial photograph dated 06/28/1960 ph"There is a possible stain (ST) around No. 1, near K Street and N 1st Place. A

recommended." Historical facility recorinspections were conducted, and the fi“Information Package, APHO 83 (SAIC and APHO 92 (SAIC 117), Former MarToro, California” dated 04/17/2003. DTaction on 04/20/2004. RWQCB concur08/14/2003. No further action is require

TAA 5A 5 < 90-Day 

Accumulation Point 

Summary Report, 

TAA 5A 07/17/2002 

by 

IT 

DTSC 03/04/2003 TAA 5A, also known as SWMU/AOC 2

1991 visual site inspection. Light stains concrete surrounding the TAA. Howeveinspections from 1993 through 2000, nwere observed. No visible signs of a re2002 VSI conducted in support of the Eand DTSC concurred with NFA. No furt

TAA 5B 5 < 90-Day 

Accumulation Point 

Closure Report, 

TAA 5B 11/24/2008 

by 

BRAC PMO West 

RWQCB 11/24/2008 

DTSC 04/08/2009 

TAA 5B, also known as SWMU/AOC 2soil during a site visit conducted in supsoil sampling identified TPH in the soils PRGs. The removal of contaminated so2008. A closure report was distributed recommending NFA. RWQCB concurr11/24/2008, and DTSC concurred with 04/08/2009. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 2 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

UST 6B 6 500-Gallon Fuel Oil 

Tank 

UST Removal 

Report, UST 6B 

01/30/1997 

by 

Geofon 

OCHCA 03/27/1997 UST 6B and approximately 45 feet of a

removed on 11/07/1996 under OCHCA closed by OCHCA in a letter dated 03/2required. 

UST 101 6 168-Gallon Diesel 

Tank 

Final Summary 

Report, Former UST 

Site 101 

08/21/2003 

by 

CDM Federal 

Programs Corp. 

RWQCB 10/20/2003 

DTSC 09/17/2003 

Former UST Site 101 is located at the f101, a former standby power building fo168-gallon tank, was used to store diesgenerator. Building 101 was demolishelocation of the former tank site was esthistorical facility plans. Exploratory trenformer tank site in November 2002 and was observed. It is possible that UST 1demolition of Building 101. Soil sampleborings located at the former tank locatresults were presented in a Summary Rthe RWQCB and DTSC. Both RWQCB NFA. No further action is required. 

UST 850A 850 5,000-Gallon JP-5 

Tank 

Tank Removal & 

Site Closure Report, 

UST 850A, UST 

850B, and OWS 

850E 

05/30/2008 

by 

BRAC PMO West 

RWQCB 08/28/2008 UST 850A (SWMU 288), UST 850B (S

approximately 400 feet of associated pFebruary 2000. Approximately 912 tons excavated and removed from the forme850B, and OWS 850E during January a2003 and 2004, soil samples were colleassessment report was submitted in 20in a letter dated 08/28/2008. No further 

UST 850B 850 5,000-Gallon JP-5 

Tank 

Tank Removal & 

Site Closure Report, 

UST 850A, UST 

850B, and OWS 

850E 

05/30/2008 

by 

BRAC PMO West 

RWQCB 08/28/2008 UST 850A (SWMU 288), UST 850B (S

approximately 400 feet of associated pFebruary 2000. Approximately 912 tons excavated and removed from the forme850B, and OWS 850E during January a2003 and 2004, soil samples were colleassessment report was submitted in 20in a letter dated 08/28/2008. No further 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 3 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

OWS 850E 850 1,500-Gallon JP-5/ 

water storage tank 

Tank Removal & 

Site Closure Report, 

UST 850A, UST 

850B, and OWS 

850E 

05/30/2008 

by 

BRAC PMO West 

RWQCB 08/28/2008 OWS 850E, UST 850A, and UST 850B 

2000. Approximately 912 tons of fuel-imand removed during January and Febr2004, soil samples were collected from assessment report was submitted in 20in a letter dated 08/28/2008. No further 

MSC B1 850 Inactive Burn Pit Site Assessment 

Report, Firefighter 

Training Burn Pit 

MSC B1 02/11/2000 

by OHM and 

Addendum to Site 

Assessment Report, MSC B1 02/15/2001 

by OHM 

RWQCB 10/11/2001 MSC B1, an inactive circular concrete b

near IRP Site 16. Initial field sampling w1999, and additional sampling was conof RWQCB comments dated 10/20/200a Site Assessment Report and an AddeAssessment Report. The concrete struOctober and November 2000. Site closdated 10/11/2000. No further action is 

MSC B2 850 Inactive Burn Pit Summary Report, 

Former Firefighter 

Training Burn Pit 

MSC B2 12/29/1999 

by OHM 

RWQCB 10/10/2000 MSC B2 was a rectangular-shaped con

near MSC B1 that was reportedly used was conducted in 1999; the results werReport dated 1999, and the RWQCB caction on 10/10/2000. The concrete strduring October and November 2000. Sletter dated 10/10/2000. No further acti

PCB T1 6 Pad mounted 

transformer 

Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Replaced with a non-PCB transformer. original transformer replaced with a noevidence of release. No PCB releases search or VSIs conducted for the 2003 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 4 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

IRP Site 16 NA Crash Crew Pit No. 

2 (OU-3) Associated groundwater plume and buffer zone 

N/A DTSC 10/18/2007 

U.S. EPA 

04/10/2007 

RWQCB 2007 

Site was operational from 1972 to 198fluid, crankcase oil, white phosphorusnapalm were burned in unlined pits foFinal RI (BNI 1997), FS (BNI 2000 and (DON 2003) completed. Pilot study coMonitored natural attenuation has beefor ground water. A final Operating Pro(OPS) Report was completed in Septeconcurrence with the conclusions of thobtained. 

IRP Site 25 NA Major Drainages 

(OU-2A) 

Draft Final Record 

of Decision, OU 2A 

& 3A, No Action 

Sites 

09/30/1997 

by 

NAVFAC SW 

U.S. EPA, DTSC, 

RWQCB 

09/30/1997 

IRP Site 25 consisted of four drainage 

or adjacent to the Station and receive the Station. Concentrations of metals, products below levels requiring responthe site. ROD that selected no action aSeptember 1997. 

Carve-Out I-K 

UST 68 68 500-Gallon Diesel 

Tank 

Summary Report, 

Former 

Underground 

Storage Tank Site 

68 09/04/1997 

by 

NAVFAC SW 

RWQCB 10/03/1997 Removal completed on 02/06/1992. Sit

letter dated 10/03/97. No further action 

UST 70 70 500-Gallon Diesel 

Tank 

Closure Report, 

USTs 70 and 72 

04/16/2008 

by 

ECS 

RWQCB 07/15/2008 Tank removed during construction of B

submitted to RWQCB in 2001. Site closdated 07/15/2008. No further action req
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 5 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

UST 72 72 500-Gallon Diesel 

Tank 

Closure Report, 

USTs 70 and 72 

04/16/2008 

by 

ECS 

RWQCB 07/15/2008 Tank removed during construction of B

submitted to RWQCB in 2001. Site closdated 07/15/2008. No further action req

UST 718 718 4,000-Gallon Fuel 

Oil Tank 

Tank Removal Field 

Activities, Tank 718 

08/05/1993 

OCHCA 12/09/1996 Tank removed in 1993. Site closed by O

12/09/1996. No further action required. 

Carve-Out I-N 

AST 1 1 55-Gallon Diesel 

Tank 

Tank Closure 

Report, 

Aboveground 

Storage Tank (AST) 

1 12/18/2000 

by IT 

RWQCB 01/17/2001 Tank operated from mid-1940s to 1999

tank for an emergency generator. Tank releases identified. Site closed by RWQ

01/17/2001. No further action required. 

UST 1A 1 500-Gallon Diesel 

Tank 

Site Assessment 

Report, Former 

Underground 

Storage Tank, Site 

1A 09/11/1996 

by OHM 

RWQCB 10/02/1996 Removal completed on 02/06/1992. Sit

letter dated 10/02/1996. No further acti

UST 1B 1 500-Gallon Diesel 

Tank 

 Summary Report, 

Underground 

Storage Tank (UST) 

1B 08/05/2008 

by NAVFAC SW 

RWQCB 10/10/2008 UST 1B and associated fill pipe were re

Remedial actions were completed in JuRWQCB in a letter dated 10/10/2008. N

Carve-Out I-O 

UST 98A 98 1,500-Gallon Fuel 

Oil Tank 

Summary Report, 

Underground 

Storage Tank Site 

98A 

RWQCB 10/06/2008 The UST was demolished in-place on 1

RWQCB in a letter dated 10/06/2008. N

Carve-Out I-S 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 6 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

UST 147 147 280 Gallon Diesel 

Tank 

Information 

Package, Former 

UST Site 147 

08/18/2003 

by 

NAVFAC EFD 

Southwest 

RWQCB 11/24/2003 Fuel tank for former booster pump for w

was located inside Building 147. Explo2002 identified a former tank excavatiopea gravel. RWQCB concurred with NF11/24/2003. No further action required. 

UST 273 273 300 Gallon Fuel Oil 

Tank 

Site Assessment 

Report, Former 

Underground 

Storage Tank Site 

273 09/09/1996 

by 

OHM 

RWQCB 10/3/1996 Removal completed on 02/28/1994. Sit

letter dated 10/13/1996. No further acti

UST 273B 273 1,400 Gallon Fuel 

OilTank 

Summary Report, 

Former 

Underground 

Storage Tank Site 

273B 10/22/2008 

by 

BRAC PMO West 

RWQCB 12/12/2008 Cylindrical concrete storage tank used 

Removal completed on 08/26/2004. Vconducted in 2004 and 2005. Contami08/12/2008-08/13/2008. Closure repor10/22/2008. Site closed by RWQCB in 

PCB T36 147 Pad mounted 

transformer 

Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Replaced with a non-PCB transformer. transformer has been replaced; new tragood condition, with no indication of PCobserved. No PCB releases identified tVSIs conducted for the 2003 EBS. 

PCB T37 147 Pad mounted 

transformer 

Final EBS 

(09/12/2003) 

by Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Replaced with a non-PCB transformer. transformer has been replaced; new tragood condition, with no indication of PCobserved. No PCB releases identified tVSIs conducted for the 2003 EBS. 

PCB T38 147 Pad mounted 

transformer 

Final EBS 

(09/12/2003) 

by Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Replaced with a non-PCB transformer. transformer has been replaced; new tragood condition, with no indication of PCobserved. No PCB releases identified tVSIs conducted for the 2003 EBS. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 7 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

Carve-Out II-E 

RFA 14 606 Drop Tank Fuel 

Storage Area 

Summary Report, 

Site Verification at 

Former Aircraft Drop 

Tank Fuel Storage Area near Building 

606, SWMU 

Number 14 

11/09/1999 

by 

NAVFAC SW 

RWQCB 03/31/2000 RWQCB concurred with NFA in a letter 

action required. 

RFA 43 139 Drum Storage Area Closure Report, 

Solid Waste 

Management Unit 

43 05/09/2006 

by 

CDM Federal 

Programs Corp. 

DTSC 06/05/2006 Site also identified as SWMU 43. RFA 

Building 139, and received site closure 2006. 

RFA 150 605 (on tarmac) Aircraft Wash Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 Aircraft wash area situated on tarmac. 

associated with this wash rack. NFA stReport (JEG 1993) and DTSC concurrein a letter dated 07/23/1996. No further 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 8 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

RFA 152 606 (on tarmac) Aircraft Wash Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report 5/1996 

by Bechtel National 

DTSC 07/23/1996 Aircraft wash area on the tarmac outsid

(Maintenance Hangar). Site is inactive. RFA Report (JEG 1993) and DTSC conrecommendation in a letter dated 07/23required. 

RFA 267 605 Drop Tank Fuel 

Storage Area 

Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 NFA status identified in Final RFA Rep

concurrence obtained. No further actio

TAA 115 115/914 < 90-Day 

Accumulation Point 

Closure Report, 

Former Temporary 

Accumulation Area 

Site 115 07/20/2006 

By 

Brown and Caldwell 

DTSC 12/28/2006 Site also identified as SWMU/AOC 39. 

residential PRGs. No visible signs of reconducted in support of the EBS. NFA sampling results and the 2002 VSI. DTfurther action required. 

TAA 605 605/912 < 90-Day 

Accumulation Point 

Closure Report, 

TAA 605 

by 

Shaw 

Environmental Inc. 

DTSC 09/13/2004 SWMU/AOC 149. Sampling results bel

was recommended and DTSC concurreaction required. 

TAA 606 606/913 < 90-Day 

Accumulation Point 

Closure Report, 

TAA 605 

by 

Shaw 

Environmental Inc. 

DTSC 09/16/2004 Site also identified as SWMU/AOC 255

residential PRGs. NFA was recommenwith NFA. No further action required. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 9 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

APHO 37 115 Stains and Wet Soil Summary Report, 

APHO 37, Possible 

Stain 08/20/1999 

by 

NAVFAC SW 

DTSC 09/09/1999 

U.S. EPA 

11/04/1999 

RWQCB 03/31/2000 

Records reviews, site visits, and compa

of the site identified no evidence of relestaining or a release identified during 2of the EBS. Regulatory agency concurrrecommendation has been obtained. N

APHO 99 139 Soil Stains Information 

Package, APHO 87, 

90, 98, 99, 100, and 

109 05/2003 

by 

NAVFAC SW 

RWQCB 08/14/2003 Identified on a 1967 photograph. The a

three parallel lines on the westerly side was a public works shop located east oarea of the anomaly is within the formefuel tanks were removed and the site wthe location and the fact that all sites wclosed, no further action was recommea VSI conducted in June 2003, RWQCaction in a letter dated 08/14/2003. 

APHO 110 121 Liquid Information 

Package, APHO 

110 04/28/2003 

by 

NAVFAC SW 

RWQCB 08/14/2003 Identified on a 1974 photograph. The fa

APHO is a fire station and the liquid floprobably water used in routine operatioon a VSI conducted in June 2003, RWQfurther action in a letter dated 08/14/20

APHO 119 Edge of Aircraft 

Apron between 

605 and 606 

Stains Information 

Package, APHO 

119 04/22/2003 by 

NAVFAC SW 

and 

NFA Determination 

for APHOs (site visit 

by DTSC on 

06/13/2003) 

DTSC 06/25/2003 

RWQCB 08/14/2003 

Identified on a 1983 photograph. The Ainspected in April 2003. No evidence ofor the storm drain was noted in that loc[SWMU 149] and TAA 606 [SWMU 255and 606. NFA has been obtained for thBased on a Visual Site Inspection condand RWQCB concurred with recomme119. No further action required. 

UST 115A 115 650-Gallon Fuel Oil 

Tank 

Site Assessment 

Report, Former UST 

Site 115A 

11/13/1996 

by 

OHM 

RWQCB 12/16/1996 Removal completed on 02/28/94. Site c

dated 12/16/1996. No further action req
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 10 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

UST 115B 115 560-Gallon Fuel Oil 

Tank 

Site Assessment 

Report, UST Site 

115B 12/10/1997 

by 

OHM 

RWQCB 01/07/1998 Removal completed on 06/17/1993. Sit

letter dated 01/07/1998. No further acti

UST 116 116 500-Gallon Diesel 

Tank 

Site Assessment 

Report, Former UST 

Site 116 01/12/1999 

by 

OHM 

RWQCB 08/31/2000 Tank has been removed. Site closed b

08/31/2000. No further action required. 

UST 117 117 500-Gallon Diesel 

Tank 

Site Assessment 

Report, UST Site 

117 

12/10/1997 

RWQCB 01/07/1998 Tank has been removed. Site closed b

01/07/1998. No further action required. 

UST 605A 605 1,700-Gallon Diesel 

Tank 

Technical 

Memorandum, 

Former 

Underground 

Storage Tank Sites 

114A, 295, 296, 

435, 455, 605A, and 

606A 03/21/1997 

by 

NAVFAC SW 

RWQCB 04/11/1997 Removal completed 10/08/1991. Site c

dated 04/11/1997. No further action req

UST 605B 605 500-Gallon Diesel 

Tank 

Tank Removal Field 

Activities, Tank 

605B & OWS 605C 

09/09/1999 

OCHCA 12/09/1999 Removal completed on 09/09/1999. No 

identified. Site closed by OCHCA in a lfurther action required. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 11 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

UST 606A 606 1,700-Gallon Diesel 

Tank 

Technical 

Memorandum, 

Former 

Underground 

Storage Tank Sites 

114A, 295, 296, 

435, 455, 605A, and 

606A 03/21/1997 

by 

NAVFAC SW 

RWQCB 04/11/1997 Tank has been removed. Site closed b

04/11/1997. No further action required. 

UST 643A 643 185-Gallon Waste 

Oil Tank 

Tank Removal and 

Site Closure Report, 

UST 643A and 

OWS 643B 06/12/1997 

by 

OHM 

OCHCA 07/11/1997 Site also identified as SWMU/AOC 162

03/06/1997. Site closed by OCHCA in a further action required. 

OWS 605C 605 500-Gallon 

Oil/Water 

Separator 

Tank Removal Field 

Activities, Tank 

605B & OWS 605C 

09/09/1999 

OCHCA 12/09/1999 Site also identified as SWMU/AOC 151

OWS was removed in 1997. OWS assowas investigated; the RFA recommendOWS. No significant soil contamination closed by OCHCA in a letter dated 12/0required. 

OWS 643B 643 100-Gallon 

Oil/Water 

Separator 

Tank Removal and 

Site Closure Report, 

UST 643A and 

OWS 643B 06/12/1997 

by 

OHM 

OCHCA 07/11/1997 Site also identified as SWMU/AOC 163

OWS was removed in 1997. OWS was Site was investigated, and no significanidentified at this site based on the resuclosed by OCHCA in a letter dated 07/1required. 

OWS 892 892 1,375-Gallon 

Oil/Water 

Separator 

Site Assessment 

Report, OWS Site 

892 07/09/1999 

by 

OHM 

RWQCB 07/07/2000 OWS installation date unknown. OWS 

not associated with a UST. Site was invRWQCB in a letter dated 07/07/2000. N
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 12 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

PRL 605 605 Maintenance 

Hangar 

Summary Report for 

Group III PRLs SI 

by Earth Tech, 

October 2005 (Earth 

Tech 2005b) 

Summary Report for 

Group VI PRLs SI 

by Earth Tech, 

October 2008 (Earth 

Tech 2008a) 

U.S. EPA 

11/03/2005 

DTSC 11/26/2008 

Records review, VSIs, and soil samplin605 from 2002 to 2008, to evaluate whhazardous substances or pollutants int

occurred. Based on the results of thesrecommended for this PRL in the Summ(Earth Tech 2005) and Group VI PRLs concurred with NFI recommendation in DTSC concurrence on NFI was receive

PRL 606 606 Maintenance 

Hangar 

Summary Report for 

Group III PRLs SI 

by Earth Tech, 

October 2005 (Earth 

Tech 2005b) 

Summary Report for 

Group VI PRLs SI 

by Earth Tech, 

October 2008 (Earth 

Tech 2008a) 

U.S. EPA 

11/03/2005 

DTSC 11/26/2008 

Records review, VSIs, and soil samplin606 from 2002 to 2008, to evaluate whhazardous substances or pollutants int

occurred. Based on the results of thesrecommended for this PRL in Summary Tech 2005) and Group VI PRLs (Earth concurred with NFI recommendation in DTSC concurrence on NFI was receive

PCB T15 115 Pad-Mounted 

Transformer 

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. No PCB releasrecords search or VSIs conducted for t

PCB T16 118 Pole-Mounted 

Transformer 

Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Replaced with a non-PCB transformer. original transformer replaced with a noevidence of release. No PCB releases search or VSIs conducted for the 2003 

PCB T81 605 Pad-Mounted 

Transformer 

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. No PCB releasrecords search or VSIs conducted for t

PCB T82 606 Pad-Mounted 

Transformer 

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. No PCB releasrecords search or VSIs conducted for t
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 13 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

PCB 643 643 3 oil-filled cutouts Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

3 oil-filled cutouts with less than 1 ppm portion of the building. 

PCB 892 892 3 oil-filled cutouts Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

3 oil-filled cutouts with less than 0.005 leaking during 2003 inspection. 

Carve-Out II-L 

IRP Site 25 NA Major Drainages 

(OU-2A) 

Draft Final Record 

of Decision, OU 2A 

& 3A, No Action 

Sites 

09/30/1997 

U.S. EPA, DTSC, 

RWQCB 

09/30/1997 

IRP Site 25 consisted of Four Drainage 

or adjacent to the Station and receive sthe Station. Concentrations of metals, pproducts below levels requiring responthe site. ROD was signed in Septembe

PRL 

Runway 

Infield Area 

Northwest 

Quadrant 

Station’s Runways Summary Report for 

Group VI PRLs SI 

by Earth Tech, 

October 2008 (Earth 

Tech 2008a) 

U.S. EPA 

11/20/2008 

DTSC 11/26/2008 

This PRL was identified because waste have been applied as dust control agenshoulders of the installations runways aSoil sampling conducted in 2003 and 2PAHs exceeding residential PRGs in salength of the runway. Surface soil exteof the runway was removed during runwoperations performed by the developerEnvironmental Review Form (PERF) co(11/01/2006). Therefore, soil sampling at this PRL to characterize the current grading operations. Based on the resuwas recommended for this PRL in the SPRLs, and regulatory concurrence was 

Carve-Out II-M 

RFA 178 673 Vehicle Wash Rack Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 Inactive vehicle wash rack. OWS 673A 

rack. NFA status identified in Final RFA DTSC concurred in a letter dated 07/23required. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 14 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

RFA 181 673 Land/Farming Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 NFA status identified in Final RFA Rep

concurrence obtained. No further actio

RFA 182 673 Drum Storage Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 Not located during RFA; no releases id

storage areas were taken during a site Health Services (DHS) on 10/29/1980. RFA Report (JEG 1993) and regulatory further action required. 

RFA 183 673 Drum Storage Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 Not located during RFA; no releases id

storage areas were taken during a site 10/29/1980. NFA status identified in Fand regulatory concurrence obtained. N
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 15 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

RFA 184 673 Drum Storage Area Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 Not located during RFA; no releases id

storage areas were taken during a site 10/29/1980. NFA status identified in Fand regulatory concurrence obtained. N

RFA 185 673 Drum Storage Area Information 

Package, Solid 

Waste Management 

Unit 185 12/07/2005 

by 

Navy BRAC PMO 

West 

DTSC 07/31/2006 RFA site 185 was associated with Build

closure concurrence in 2006. 

RFA 264 DRMO Yard No. 3 DRMO Yard No. 3 Final RCRA Facility 

Assessment (RFA) 

Report July 1993 by 

Jacobs Engineering 

Group 

and 

Final Addendum to 

RFA Report May 

1996 by Bechtel 

National 

DTSC 07/23/1996 NFA status identified in Final RFA Rep

concurrence obtained. No further actio

TAA 673 673 < 90-Day 

Accumulation Point 

Closure Report, 

Former Temporary 

Accumulation Area 

673 05/21/2003 

by 

Shaw 

Environmental 

DTSC 09/24/2004 Site also identified as SWMU/AOC 186

in a letter dated 09/24/2004. No further 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 16 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

TAA 772 772 < 90-Day 

Accumulation Point 

Closure Report, 

TAA 772 

06/26/2003 

by 

OHM 

DTSC 11/07/2003 Site also identified as SWMU/AOC 225

contaminants between residential and results of risk screening, soil managemconcurred with NFA in a letter dated 11required. 

APHO 20 DRMO Yard No. 3 Disturbed Ground 

and Excavation 

Summary Report, 

APHO 20 & APHO 

21 11/30/1999 

by 

NAVFAC SW 

DTSC 03/03/2000 Regulatory agency concurrence of NFA 

obtained. No further action required. 

APHO 27 DRMO Yard No. 3 Stains and Wet Soil Summary Report, 

APHOs 23, 27, 58 

(Area 2) 03/07/2000 

by 

NAVFAC SW 

RWQCB 10/18/2000 No evidence of staining or a release ide

conducted in support of the EBS. SampPRGs. Regulatory agency concurrence 

been obtained. No further action requir

APHO 38 1789 Disturbed Ground 

and Excavation 

Summary Report, 

APHO 38 

12/19/2003 by Shaw 

Environmental 

and 

Radiological 

Release Report, 

IRP Site 1, DRMO 

Yard 3, NBC, APHO 

38, Paved Area 

south of Building 

295 04/12/2007 by 

Weston Solutions 

DTSC 04/06/2005 

CDPH 08/20/2007 

APHO 38 was associated with Building closure concurrence from DTSC in 200non-radiological constituents. Radiological investigations were condupresented in a radiological release repothe results of these investigations, CDPrecommendation for unrestricted releasdated 08/20/2007. No further action req
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 17 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

APHO 46 Golf Course – 

Hole No. 5; 

overlaps IRP Site 

5 

Disturbed Ground 

and Excavation 

Summary Report, 

APHO 46 January 

2005 by Earth Tech 

and 

Radiological 

Release Report, 

IRP Sites 3 and 5 

(including APHO 

46), AA 3, and 

Building 244 

December 2006 

by Weston Solutions 

DTSC 05/17/2004 

U.S. EPA 

03/08/2004 

RWQCB 05/01/2003 

CDPH 05/19/2006 

The extent of the anomaly has been invgeophysical survey, which identified onsurficial debris. Surface debris was also conducted in support of the EBS. Charand associated areas was conducted ainvestigation for IRP Site 5. Based on tinvestigations, NFA was recommended DTSC concurred with no further investiradiological constituents in a letter dateRadiological investigations at APHO 46 conjunction with IRP Site 5 and results release report (Weston 2006). Based oinvestigations, CDPH concurred with thunrestricted release of APHO 46 in a lefurther action required. 

APHO 51 673 Stains and Wet Soil Summary Report, 

APHO 51 

02/24/2000 

by 

NAVFAC SW 

DTSC 06/14/2000 

RWQCB 10/18/2000 

No evidence of staining or a release ideconducted in support of the EBS. ReguNFA recommendation has been obtainrequired. 

UST 442 442 110-Gallon Fuel Oil 

Tank 

Tank Removal Field 

Activities 

05/27/1993 

OCHCA 12/09/1996 Tank removed in 1993. Site closed by O

12/09/1996. No further action required. 

OWS 673A 673 895-Gallon 

Oil/Water 

Separator 

Site Assessment 

Report, OWS 673A 

04/12/1999 

by 

NAVFAC SW 

RWQCB 01/17/2001 Site also identified as SWMU/AOC 179

OWS closed in place. OWS was assocwas investigated and NFA was recommthe results of soil sampling. Site closed 01/17/2001. No further action required. 

OWS 832 832 500-Gallon 

Oil/Water 

Separator 

Summary Report, 

APHO 38 

12/19/2003 

by 

Shaw 

Environmental 

DTSC 04/20/2005 OWS identified during geophysical surv

03/24/2003. OWS was removed and sa2003. Site closure was received in 200
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 18 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

RAD 

DRMO 

DRMO Yard 3 

(RFA 264) 

Outside storage area used by DRMO to store scrap and excess materials and equipment awaiting disposition. Area had been in operation since the 1950s. 

Radiological 

Release Report, 

IRP Site 1, DRMO 

Yard 3, NBC, APHO 

38, Paved Area 

south of Building 

295 04/12/2007 

by 

Weston Solutions 

DTSC 07/23/1996 

CDPH 08/20/2007 

The yard was restricted from receiving components containing radioactive marecords or direct knowledge of radiologby the El Toro DRMO. However, during was stated that, “Marines could have sradium painted parts and gauges at the regional storage yard.” No releases wehas been determined to require no furtthe no further action determination was letter dated 07/23/1996. During the yeaHistorical Radiological Assessment (HRrecommended further radiological inves3 prior to final disposition. A radiologica2001 and the results were presented in (Weston 2007). CDPH concurred with unrestricted release in a letter dated 08

RAD NBC NBC Area 

(Buildings 787, 

1789, and 1803 

and surface 

impoundments 

[APHO-38]) 

Buildings and surface impoundments are situated north of the intersection of East Marine Way and El Toro Boulevard. Buildings supported training of personnel for readiness for nuclear, biological, and/or chemical weapons attack. 

Radiological 

Release Report, 

IRP Site 1, DRMO 

Yard No. 3, NBC, 

APHO 38, Paved 

Area south of 

Building 295 

04/12/2007 

by 

Weston Solutions 

CDPH 08/20/2007 Building 1789 contained a 4 foot by 6 fo

for storing non-licensed, radioactive sohoused NBC training facilities. These boffices, training/instruction areas, and tIt is not known whether impoundments with NBC training operations. During thHRA was conducted. The HRA recomminvestigation for the NBC Area prior to radiological survey was completed in 2recommendation for unrestricted releas08/20/2007. 

MSC D1 DRMO Yard No. 3 Desert Storm 

Supply Storage 

Area 

Site Assessment 

Report, Desert Storm Material 

Staging Area, MSC 

D1 03/01/2000 

by 

OHM 

RWQCB 09/28/2000 Desert Storm supply storage area near 

inactive. NFA concurrence obtained fro09/28/2000. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 19 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

MSC 673T3 673 RCRA Storage 

Facility 

Final Closure 

Certification Report, 

Hazardous Waste 

Container Storage 

Area Nov 1995 

by 

OHM 

DTSC 03/08/1996 Former RCRA-permitted facility. Site is 

obtained from DTSC in a letter dated 0required. 

PRL 354 354 Former Skeet 

Range 

Summary Report for 

Group VI PRLs SI 

by Earth Tech, 

October 2008 (Earth 

Tech 2008a) 

U.S. EPA 

11/20/2008 

DTSC 2009b 

Site is a former skeet range, utilized bewas situated in the current location of treview, VSIs, and soil sampling were c2002 to 2008, to evaluate whether a resubstances or pollutants into the enviroon the results of these investigations, NPRL in the Summary Report for Group concurrence on NFI was received on 1concurrence was received on 09/25/20

Carve-Out II-R 

RFA 244 457 PCB Spill Area 

Near Building 457 

Closure Report, 

Solid Waste 

Management Unit 

244 10/28/1998 

by 

OHM 

DTSC 12/17/1998 Site was also identified as SWMU/AOC 

soils was completed in 1997. All requirebeen completed. DTSC concurred with 12/17/1998. No further action required. 

APHO 42 457 Stains and Wet Soil Summary Report, 

APHO 42 

12/15/1999 

by 

NAVFAC SW 

DTSC 03/27/2000 

RWQCB 10/18/2000 

Records reviews, site visits, and compa

of the site identified no evidence of relestaining or a release identified during 2of the EBS. Regulatory agency concurrrecommendation has been obtained. N

UST 457 457 2,000-Gallon Diesel 

Tank 

Tank Removal Field 

Activities 

05/27/1993 

OCHCA 12/09/1996 Tank removed in 1993. Site closed by O

12/09/1996. No further action required. 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 20 of 20 

Table 4: Locations of Concern 

LOC ID 

Building 

Number/ 

Location Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

SRU 3C 457 Dental Clinic Summary Report for 

Group IV PRLs by 

Earth Tech (March 

2008) 

DTSC 08/21/2008 

U.S. EPA 

04/17/2008 

Site identified as a former SRU at a phdental clinic (SRU 3C). Site was recomfor potential discharges of contaminantsystem. SRU 3C was investigated as pThe investigations included records revBased on the results of these investigawas recommended in Summary Reporregulatory concurrence was obtained. 

PCB T74 457 Pad-Mounted 

Transformer 

Final EBS 

(09/12/2003) 

By Earth Tech 

DTSC 09/25/2003 

U.S. EPA 

09/25/2003 

Site was also identified as SWMU/AOC PCB transformer. A response action watransformer oil containing PCBs at BuilShallow soil samples that were collectePCB release identified PCBs in one of The transformer was replaced and impresponse action was completed and thDecember 1998. No evidence of a releVSIs conducted for the 2003 EBS. All been completed. No further action requ

AOC = Area of Concern APHO = Aerial Photograph Anomaly AST = aboveground storage tank AVGAS = aviation gasoline BNI = Bechtel International, Inc. CDPH = California Department of Public Health DHS = Department of Health Services DON = Department of the Navy DRMO = Defense Reutilization and Marketing Office DTSC = Department of Toxic Substances Control EBS = Environmental Baseline Survey FS = Feasibility Study HRA = Historical Radiological Assessment ID = Identification IRP = Installation Restoration Program JEG = Jacobs Engineering Group JP-5 = Jet Propulsion Fuel, Grade 5 < = less than 

LOC = Location of Concern MCAS = Marine Corps Air Station MSC = miscellaneous NA = not applicable N/A = not available NAVFAC SW = Naval Facilities Engineering Command,  Southwest NBC = Nuclear, Biological, Chemical NFA = No Further Action OCHCA = Orange County Health Care Agency OHM = OHM Remediation Services Inc. OPS = Operating Properly and Successfully OU = Operable Unit OWS = oil/water separator 

PCB = polychlorinated biphenyl PP = Proposed Plan ppm = part per million 

PRG = preliminRAD = radiologRCRA = ResourRI = RemedRFA = RCRA ROD = Record RWQCB = RegionSAIC = Science  CorporaSRU = Silver RSWMU = Solid WTAA = TempoUST = undergU.S. EPA = United  ProtectVSI = visual s
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 1 

Table 5: Locations of Concern With Ongoing Petroleum Corrective Actions

LOC ID Description 

Closure Report 

Title/Date 

NFA Letter 

Agency/Date Notes 

Carve-Out I-F MSC B3 Inactive Burn Pit Pending Pending MSC B3 was the main fire fighting crash 

approximately 67 feet in diameter, and twDuring training exercises, this pit was fillewith mixtures of JP-5, AVGAS, crank casfluids. MSC B3 is addressed as a petrole

AVGAS = aviation gasoline ID = Identification JP-5 = jet propulsion fuel, grade 5 MSC = Miscellaneous NFA = No further action 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 2 

Table 6: Summary of Asbestos Surveys

Building 

Number Description 

Square 

Feet Year Built 

Historical Asbestos Survey 

Information 

Carve-Out I-N 

1 Squadron Headquarters Telephone 

Exchange 

15,768 1943 CABACO/Tait (06/15/1999): Stucco Non-FAD AC

Carve-Out II-E 

115 Aircraft Maintenance Hangar 25,414 1966 IT Corp (1989): Floor tile, transite, pipe 

insulation. CABACO/Tait (06/15/1999): Stucco, pipe elbows, floor tile & mastic, window putty, boiler flue, exterior mastic, wall panels, drywall joint compound 

Non-FAD AC

118 Aircraft Maintenance Hangar 6,240 1943 IT Corp (1989): No ACM Found 

CABACO/Tait (07/22/1999): Stucco 

Non-FAD ACobserved. 

119 Aircraft Maintenance Hangar 6,240 1943 IT Corp (1989): No ACM Found 

CABACO/Tait (06/15/1999): Stucco 

Non-FAD ACobserved. 

139 3rd Marine Air Wing Embarkation area 6,240 1943 IT Corp (1989): No ACM Found 

CABACO/Tait (10/15/1999): Stucco 

Non-FAD ACobserved. 

605 Maintenance Hangar 23,598 1965 e&e (1991): Floor tile, roofing, pipe fitting 

insulation, damper gaskets, carpet. CABACO/Tait (06/15/1999): Floor tile & mastic, window putty, pipe elbows 

FAD ACM fo

606 Maintenance Hangar 23,598 1965 e&e (1991): Floor tile, roofing, pipe fitting 

insulation, damper gaskets, carpet. CABACO/Tait (06/15/1999): Floor tile & mastic, window putty, pipe elbows 

FAD ACM fo

639 Electric Power Plant Building 144 1969 e&e (1991): No ACM Found No ACM foun640 Electric Power Plant Building 144 1969 e&e (1991): No ACM Found No ACM foun641 Electric Power Plant Building 144 1969 e&e (1991): No ACM Found No ACM foun695 Line Maintenance Shelter 900 1975 e&e (1991): Floor tile, roofing Non-FAD AC

since 1997. 

696 Line Maintenance Shelter 900 1975 e&e (1991): Floor tile, roofing Non-FAD AC

since 1997. 

697 Line Maintenance Shelter 900 1975 e&e (1991): Roofing Non-FAD AC

observed; no
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 2 of 2 

Table 6: Summary of Asbestos Surveys

Building 

Number Description 

Square 

Feet Year Built 

Historical Asbestos Survey 

Information 

Carve-Out Building 746 

746 Flight Simulator 22,516 1984 e&e (1991): Floor tile, drywall, carpet. 

CABACO/Tait (06/15/1999): Floor tile mastic 

Non-FAD AC

Source: USMC/SWDIV 2003. Note: The information presented in this table was obtained from the listed source. ACM = Asbestos-containing material CABACO = CABACO, Inc. e&e = Ecology & Environment, Inc. FAD = Friable, Accessible, and Damaged 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California Table 7 

Page 1 of 1 

Table 7: Monitoring/Bioventing/SVE Wells 

Carve Out Well ID Purpose 

Carve-Out I-F

I-F 16 DBMW52 Groundwater Monitoring 

I-F 16 DGMW81 Groundwater Monitoring 

I-F 16 GE1 Groundwater Extraction 

I-F 16 MPE1 Groundwater Extraction 

I-F 16 MW1 Groundwater Monitoring 

I-F 16 MW2 Groundwater Monitoring 

I-F 16 MW3 Groundwater Monitoring 

I-F 16 MW4 Groundwater Monitoring 

I-F 16 MW5 Groundwater Monitoring 

I-F 16 MW6 Groundwater Monitoring 

I-F 16 MW7 Groundwater Monitoring 

I-F 16 MW08 Groundwater Monitoring 

I-F 16 MW09 Groundwater Monitoring 

I-F 16 MW10 Groundwater Monitoring 

I-F 16 MW11 Groundwater Monitoring 

I-F 16 MW12 Groundwater Monitoring 

I-F 16 MW13 Groundwater Monitoring 

I-F 16 MW14 Groundwater Monitoring 

I-F 16 MW15 Groundwater Monitoring 

I-F 16 MW16 Groundwater Monitoring 

I-F 16 MW17 Groundwater Monitoring 

I-F 16 VEMP1 Soil Vapor Extraction 

I-F 16 VEMP2 Soil Vapor Extraction 

I-F 16 VEW1 Soil Vapor Extraction 

I-F 16 VEW2 Soil Vapor Extraction 

I-F 16 VM1 Soil Vapor Monitoring 

ID = Identification 
Figures 
This Page Intentionally Left Blank 
5

15

215

405

Former MCAS

Pacific Ocean El Toro

10

210

San Bernardino County

Riverside County

San Diego County

Los Angeles County

Orange County

Irvine

Costa Mesa

Santa Ana

Anaheim

Fullerton

Orange

Tustin

El Toro

Norwalk

1

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VICINITY MAP

FINDING OF SUITABILITY TO TRANSFER

(FOST #5)

FORMER MCAS EL TORO

CALIFORNIA

April 2009

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TAA 605

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UST 115A

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PCB 892

PCB T81

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PCB 643

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RFA 181

RFA 178

RFA 264

RFA 182

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Attachment 1 

Comments/Response to Comments 
This Page Intentionally Left Blank 



April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and 

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

SPECIFIC COMMENTS 1. Page ii Table of Contents. Section 9 (Finding of Suitability to Transfer) is 

missing. Please add Section 

The TOC has been updated to in

2. Page iii Table of Contents. The title for Attachment 3 should be changed to 

“RCRA Corrective Action Package”. The package would include the FOST Concurrence Letter, Letter to Heritage Fields, LLC, and any Navy FOST Public Notices. There would be no Resource Conservation and Recovery Act (RCRA) Facility Boundary Map included since the RCRA facility boundary will not be revised 

The recommended title change hthe updated text. The package wPublic Notice. 

3. Page 1, 

Section 2 first bullet. 

Please change the second sentence to read, “...approximately 0.92 acres, which includes Building 399.” The recommended change has b

updated text. 

4 Page 1, 

Section 2, COs II-E and II-L. 

According to Figure 2, these COs appear to be located in the northwest portion of the base, not northeast. 

These COs are closer to the nort

they are to the northwestern bounchange is required. 

5. Page 2, 

Section 3.1 

Please insert the following language at the end of Section 3.1: “DTSC has not made a RCRA Corrective Action Complete Determination for the property associated with FOST 5. Rather, it plans to issue a letter to the transferee (Heritage Fields, LLC) clarifying the corrective action obligations for property associated with FOST 5, as well as COs I-L and I-M, previously transferred under FOST 4. The RCRA Corrective Action Package can be found in Attachment 3 

The recommended change has bupdated text except for “(Heritage 

6. Page 3, 

Section 3.2, Paragraph 3. 

Please verify that No-Further-Action (NFA) letters issued by the Regional Water Quality Control Board (RWQCB) and Orange County Health Care Agency (OCHCA) for sites covered in this FOST actually state that NFA determinations were based upon Section 2721(e), Title 23 California Code of Regulations (CCR). (FOST 4 only referred to the RWQCB). 

The text will be clarified that both have delegated authority from the Board and their NFA determinatio2721(e), Title 23 California Code follows: "NFA letters issued by the RWQCaccordance with Section 2721(e) above which provides "Upon comcorrective action, the regulatory aresponsible party in writing that nat that time, based on available in
April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Bu

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

7. Page 3, 

Section 3.2, Paragraph 5 

Please delete the last sentence, as DTSC has not made a 

determination that investigations and cleanups conducted under the oversight of the RWQCB and OCHCA on property identified in this FOST have satisfied the corrective action requirements under 

RCRA and the Hazardous Waste Control Law. (FOST 4 did not include the sentence either) 

The sentence has been revised as fo

“While DTSC has not made Action Complete Determinaassociated with FOST 5, Da letter to the transferee claaction obligations for propeFOST 5, including property and cleaned up under the oRWQCB and the OCHCA (

8 Page 4, 

Section 3.3, Line 4 

Please change “Section 4.1.3” to “Section 4.1.1”. (The reference to IRP Site 25) 

The recommended change has been updated text. 

9. Page 4, 

Section 4, Last Paragraph, Sentence 3. 

IRP Site 16 should be included as a Location of Concern (LOC) that has not received regulatory agency concurrence of NFA. It does have regulatory agency concurrence of Operating Properly 

and Successfully (OPS) but not NFA 

IRP Site 16 is included as an LOC in been modified to include mention of action at IRP Site 16. 

10 Page 8, 

Section 4.3, Paragraph 2 

a. This language was not included in FOST 4. It is not clear 

whose requirements they are. Please explain. 

b. Also, the acronym in line 2 should have been (non-FAD) 

since it seems to be referring to non-friable, accessible, and damaged asbestos-containing materials 

a. This text clarifies the situations 

surveys need to be conducted of FAD, non-FAD and ACM. 

b. The recommended change has 

the updated text. 

11 Page 9, 

Section 4.5.4 

a. According to Table 1 and Figure 11, Building 457 appears 

to have been demolished. If true, please note this fact in the text of this paragraph. 

b. The text refers to SWMU 244, but there is also reference 

to RFA 244 in the FOST. Please use a consistent designation if these two designations refer to the same site. 

a. Building 457 has been dem

foundation. The recommenincorporated into the updat

b. The text has been updated 

The following text has been portion of Table 4: “Site was also identified as 

12 Page 10, 

Section 5.1.1 

a. The second sentence in the first paragraph refers to the 

area requiring institutional control (ARIC). Please expand the text to (i) indicate that this ARIC is different (and how) from the one in the Record of Decision and Remedial 

a. The second sentence in the firs

5.1.1 has been revised as followto these restrictions is identified area requiring institutional contr
April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and 

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

Design for Site 16, (ii) provide an explanation for the change, and (iii) indicate that the change received concurrence from FFA signatories. 

b. Since the land use controls (LUCs) will not be 

incorporated into the quitclaim deed and DTSC Covenant exactly as written, please change the last sentence in the same paragraph as follows: “The following list of LUCs are consistent with the Final Remedial Design Report (CDM 2006) and will be similarly incorporated into the quitclaim deed and the DTSC Covenant 

c. In the second bullet, please insert “within the area 

requiring institutional controls” after the word “groundwater 

d. Please change the text in the third bullet to read, “The 

transferee shall not alter, disturb, or remove existing or future wells and associated equipment within the area requiring institutional controls without prior review and written approval from the FFA signatories; and 

e. In the fourth bullet, please insert “within the area requiring 

institutional controls” after the word “area 

f. Please change the non-bulleted sentence near the bottom 

of the page to read, “The Navy will also include the following specific additional requirements in the quitclaim deed and will work with DTSC to incorporate similar language into the DTSC Covenant:” 

rectilinear area is different ththat was depicted in the ROD 

Design Report (CDM 2006). expanded in lieu of area encimpacted groundwater plume zone. The revised ARIC was received concurrence from th

b. The recommended change h

the updated text. 

c. The recommended change h

the updated text. 

d. The recommended change h

the updated text. 

e. The recommended change h

the updated text. 

f. The recommended change h

the updated text. 

13. Page 11, 

Section 5.2.1. 

Please change the second paragraph to read, “In order to protect present and future human health, safety, and the environment, the transferee shall refrain from the following acts within the area designated on Figure 3 as the no dig area for ongoing petroleum corrective action, without prior review and approval from the DON and RWQCB until cleanup objectives have been achieved 

The recommended change has bupdated text. 

14. Page 12, 

Section 5.3.2 

Please add the 1999 survey to the first sentence. (See Table 6) The recommended change has b

updated text. 

15 Page 12, 

Section 5.3.3, 

Building 746. Please add the 1991 survey to the first sentence. 

(See Table 6) 

The recommended change has bupdated text. 
April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Bu

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

16. Page 13. 

Section 5.4.2 

The date of construction for Building 605 is listed as 1962. Table 1 

lists it as constructed in 1965. Please reconcile. 

Table 1 has been corrected to state 

17. Page 13, 

Section 6.1 

Please expand the text at the end of the paragraph to explain why neither of the petroleum plumes in CO II-Q is projected to encroach onto CO II-E, e.g., plumes are well characterized, remedy is 

monitored natural attenuation, plume size is decreasing, contaminant concentrations are decreasing, etc 

The text has been modified to read “monitoring data collected to date it is these petroleum plumes will not enc

18. Page 14, 

Section 6.3 

The last sentence states “Similar to CO II-E, the petroleum plumes associated with Tank Farm 5 did not encroach onto CO Building 

746.” Please either use the singular form of plume or change the 

text to read “... associated with Tank Farm 5 and Tank 398 did not ...”. (See Comment #24 also) 

The sentence will read as follows: “ neither of the petroleum plumes ass5 or Building 398 will encroach into C

19 Table 1 Buildings/Structures/Facilities. Since Building 399 is shown on 

Figure 3, it is recommended that it be included in Table 1 with a footnote explaining that it was previously transferred, similar to what is stated on Page 1, first bullet. Also, please see Comment #17 above regarding the construction date for Building 605 

As the FAA Parcel transfer is not suBuilding 399 will not be added to the date for Building 605 has been inser

20 Table 6 Summary of Asbestos Surveys. Please change the definition of the 

FAD acronym in the Footnote to read, “Friable, Accessible, and Damaged 

The recommended change has been updated text 

21. Figure 8 Carve-Out II-E. PRL 119 is listed on this figure. It was not 

included in the draft FOST and it is also not listed on Tables 3 or 4 of this draft final FOST. Please explain. 

PRL 119 has been removed from the does not exist. 

22. Figure 10 Carve-Out II-M. 

a. The upper left corner of the buffer zone for IRP Site 5 

spills over onto property that was previously transferred (CO II-G [FOST 4]). The Navy is working with regulatory agencies to modify the boundary of the buffer zone in this area to follow CO II-G boundary. Since regulatory agency concurrence with the boundary modification is expected to 

happen prior to finalization of the FOST, Figure 10 needs updating once concurrence is received. 

b. The Figure shows a TAA 673. Table 3 lists a PRL 673. 

Please confirm whether they are the same. If they are 

a. Comment noted; regulatory 

received, and the figure has 

b. PRL/TAA 673 are collocate

modified to reflect both LOC
April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and 

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

not, please include PRL 673 in the figure. 

23 Carve-Out 

Building 746 

The figure refers to the plume as JP5 Truck Fueling Area Plume both in the figure and the legend. Sections 6.1 & 6.3 refer to the plume as Tank Farm 5 Plume. Please use a consistent plume designation. (see Comment #18 also) 

The figure has been changed to rPlume. 

24. Attachment 4b 

Page 7 of 8, Footnote (c) 

It is DTSC’s position that the Navy must address any levels of 

pesticides or herbicides that create a risk to human health or the environment. Therefore, please: Delete statements that are based on the Navy's belief that pesticides were not applied "inconsistent with labeling and in 

accordance with FIFRA..." and "[t]the Grantor knows no use...". Delete the last sentence that begins, "The grantor shall have no obligation 

The Navy asserts that legally appin accordance with FIFRA), do nodefined in CERCLA, that would wHealth and Safety Code Section 2term “Release” does not include aThe normal application of fertilizeand pesticides.” The recommendhave not been made. However, thwas modified to: 

“The Property may contapesticides that have beemanagement of the Propof no use of any registerinconsistent with its labeapplications were made Federal Insecticide, FunAct (FIFRA - 7 U.S.C. Simplementing regulationlabeling provided with suGrantor’s position that it under the covenants pro120(h)(3)(A)(ii) of the CoEnvironmental ResponsLiability Act of 1980, 42 9620(h)(3)(A)(ii), for the applied pesticides.” 

EDITORIAL COMMENTS 1. Page 5 Section 

4.1.1, 

APHO Sites. Please delete the word “and”. The recommended change has b

updated text 
April 2010 Response to Comments 

Document Titles: Draft Final Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Bu

Marine Corps Air Station El Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

18 February 2010 

Comment No. 

Section/ Page No. Comment Response 

2. Page 13, 

Section 6.2, Paragraph 1. 

On line 3, the acronym “bgs” should be inserted after “below ground surface” since it is used down on line 8 

The recommended change has been updated text 

3. Figure 2, 

Carve-Out Area Location Map 

Please use a darker shade of yellow for Building/Facility. The current shade does not show up very well against the white, 

“transferred areas”. 

The recommended change has been updated Figure 2 

4. Figure 3, 

Carve-Out I-F 

a. Please ensure that all of the lines extending out from a 

well actually point to a well location. In order to easily view the well details, it is suggested that either the figure be placed on an 11x17 sheet of paper or the right half of the CO be presented as an additional figure (Figure 3a perhaps). 

b. The legend says “Groundwater Monitoring Well”, but not 

all the wells are groundwater monitoring wells. Please modify the legend. 

a. An 11x17 Figure has been 

arrows will point to cited we

b. The legend has been revise

“Groundwater/Vapor Well” 

5 Figure 10, 

Carve-Out IIM. 

The figure shows no groundwater monitoring wells so please delete 

the reference in the legend. 

The recommended change has been updated Figure 10 

6. Figure 11, 

Carve-Out II-R 

Please change the color of the APHO, UST and PCB sites (figure and legend) to match the colors used in the other figures. 

The recommended change has been updated Figure 11. 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

GENERAL COMMENTS 1. Please confirm that the current lessees (Heritage Fields, 

City of Irvine) are the proposed transferees for the property covered in this FOST. 

Confirmed. 

2. Building 746 is not a Carve-Out (CO) previously identified 

in the 2004 Finding of Suitability to Lease (FOSL) dated 

July 2004. The COs and their boundaries were designated in the FOSL, which is a formal finding by the Navy. The FOSL said it was prepared in accordance with Department of Defense (DoD) guidance documents and that the findings were based on the Environmental Baseline Survey (EBS). Typically, the Navy proposes to transfer COs in their entirety once they are deemed by the Navy to be 

suitable for transfer. This is the first time the Navy is proposing to transfer a portion of a CO. In this case, the new CO Building 746 is a portion of the existing CO II-D. 

Changing the CO boundaries would be a change to the FOSL. Please inform DTSC whether (a) there is a procedure for changes to the FOSL, e.g., notification to regulatory agencies and the public, and (b) the DoD guidance documents address changes to the FOSL. CO Building 746 is located in CO II-D. It is referred to as “property associated with Building 746” in Section 1, but then throughout the rest of the FOST it is referred to as 

“CO Building 746”. Is the Environmental Condition of the Property the same for CO II-D and CO Building 746? Would the new CO be subject to the same conditions, notifications and restrictions as CO II-D? Please explain. 

The purpose of a Finding Of Suitability To of Suitability to Lease (FOSL) is to documenvironmentally suitable for transfer or lereference to “Carve-Outs” in Department guidance. Therefore, if there are no envi

land area (in this case CO Building 746) t“procedure change” notice. Building 746 and its associated land were II-D in the 2004 FOSL. The FOSL conclusuitable for lease, subject to the conditionrestrictions set forth in that document. Threstrictions apply to the entire CO, includencompasses Building 746. Thus, no chnecessary. Building 746 and its associatconsidered for transfer, separate from CO description for CO II-D includes the bounThere is no requirement, other than prepadocument that this property is now suitabThe reference to “property associated witdeleted from Section 1. CO Building 746 is separate from CO II-Dits own notifications and restrictions as noAdditional text has been added to Section Building 746 now reads as follows: “...co1.6 acres that were previously part of CO 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

3. PRL 354, which is located in CO II-M, has not received a 

site closure concurrence from DTSC. Section 4.1.4, Table 

4, and Page 18 of Section 10 (References) need to be 

changed to reflect this fact. DTSC and the Navy are in discussion on the issue of polycyclic aromatic hydrocarbons (PAHs) detection in shallow soil and on whether DTSC can concur with the no further investigation 

recommendation by the Navy. 

DTSC has concurred on the NFI recommendReport that includes the site and has agreed Section 4.1.4, Section 10 (References), and have been revised to indicate NFI concurren09/25/2009. 

4. DTSC presently cannot make a RCRA Corrective Action 

Complete Determination (RCACD) for IRP Site 16. The site, which has the remedy of monitored natural attenuation (MNA) with institutional controls (IC), has yet to meet cleanup goals identified in the 2003 Final Record of Decision (ROD). In addition, there is still ongoing petroleum corrective action at MSC B3 at Site 16. A RCACD cannot be made at a site with ongoing corrective action, including ongoing petroleum corrective action. (See Specific Comment No. 3f) 

With concurrence on the Operating Properly Report for IRP Site 16 by all Federal Facility signatories, the Navy considers CO I-F envirtransfer as documented in this FOST. Based on recent agreement between DTSC the FFA, the Navy will continue to be responcleanup in a manner that integrates the requRCRA and other applicable state or federal lwill not make a RCACD for the properties su

5. There is a “Monitoring/Bioventing/SVE Wells” notification 

and restriction in the FOSL for COs I-F, I-N, and II-M. Please ensure that the notification and restriction are carried over to this FOST, if applicable. 

The following language has been inserted in Section 5.1.1 for CO I-F: 

“In addition to the LUC objectives to property, the wells listed on Table 7 Figure 3 will be protected.” 

The wells in COs I-N and II-M are no longer decommissioned in accordance with applica

6. Radon was listed as a notification in the 2004 FOSL and 

should be carried over as a notification in this FOST. This was done in FOST 4. 

Although inserted as part of FOST 4, the notbeen further refined for consistency with DoD Radon is not listed as a notification requirem
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

SPECIFIC COMMENTS 1. Section 3.1 

(RCRA Permit and Subtitle C Corrective Action) 

a. Paragraph 2 describes a determination that all 

necessary RCRA Subtitle C corrective action has been completed. Note that this determination is made by DTSC. 

b. Paragraph 6 has a placeholder for CACD/CEQA 

actions, to be added in the Draft Final FOST. 

a. Text has been revised based on rece

DTSC and DON. 

b. Text has been revised based on rec

DTSC and DON. 

2. Section 3.3 

(CERCLA) 

This section describes response actions that were initiated 

on the COs proposed to be transferred. The status of the response action, e.g., completed or ongoing, should be 

included. References to where additional information can be found should also be provided, as was done in FOST 4. 

The following text has been added to Se(CO I-F) has received operating properly concurrence, as noted in Section 4.1.1. actions have been completed at IRP Site 4.1.3. Additionally, PRLs 354, 605 and 6Infield Area were investigated under CESee Sections 4.1.4, 4.1.2, and 4.1.3, res

3. Section 4 

(Summary of Environmental Conditions and Notifications) 

a. Paragraph 1 should cite 40 CFR part 373, Reporting 

Hazardous Substances Activity When Selling or Transferring Federal Real Property, which contains applicable notification requirements and criteria. 

b. Paragraph 3 should make reference to Table 4 for 

PRLs 354, 605, 606, and Runway Infield Area. 

c. PRL 643 is missing in the first bullet. d. The reference in the third bullet should be “DTSC 

2008a”. 

e. Paragraph 4 should have a discussion on PRLs 

because they are listed in Table 4, unless a reference to Table 4 is added to the discussion on the PRLs in Paragraph 3. 

f. Paragraph 4 describes ongoing petroleum corrective 

action at MSC B3. Please note that a corrective action complete determination cannot be made at a site with 

a. The following text has been added to 

4a and 4b – “Pursuant to 40 Code of 373, the deed for each CO will contasubstances stored, released, or dispCO. This notice is provided in AttachSubstances Notification Table. AttacProducts Notification Table, lists the petroleum products only.” 

b. The text has been revised as follows

“PRLs 605, 606, 354, and Runway Inmore comprehensive investigation; tunder CERCLA was conducted at th4.1 and Table 4).” 

c. PRL 643 has been added to the first d. The reference has been revised to “De. PRLs have been added to the parag
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

ongoing corrective action, including ongoing petroleum corrective action. (See General Comment No. 4) 

types. 

f. Comment noted. 

4. Section 4.1.1 

(Carve-Out 1-F) 

a. TAA Sites: TAA 5B received site closure concurrence 

from DTSC on April 8, 2009. Please revise the section and Table 4 to reflect this fact. 

b. IRP Sites section: The section describes a covenant 

between the Navy and DTSC for Site 16 (DTSC Covenant). The cited restrictions (Section 5.1.1) should be consistent with the remedy in the Site 16 ROD and any restrictions in the Operating Properly and Successfully (OPS) determination and Remedial Design Report and should be included in the DTSC Covenant itself. Note that Section 5.1.1 states the restrictions will apply to the entire CO I-F. 

a. The DTSC site closure concurrence dat

been added to the RWQCB site closure 11/24/2008 in Section 4.1.1 and Table 4

b. The cited restrictions in Section 5.1.1 ar

IRP Site 16 ROD and Land Use Control are included in the DTSC Covenant. Thas been changed to clarify the area reqcontrols within CO I-F. 

5. Section 4.1.4 

(Carve-Out IIM) 

According to the FOSL, a portion of IRP Site 5 has radiological (RAD) issues. Please include a discussion on Site 5 under RAD Sites in this section. 

CO II-M is the subject of Section 4.1.4. IRP Photographic Anomaly (APHO) 46 are within included in FOST #5. However, the followinradiological issues has been added to SectioCO II-H in relation to its proximity to CO II-M

“Due to the potential for the landfill material at depths of several feet beon-site radiological survey and labosamples were conducted for IRP SNovember 2001 and during March descriptions of the survey activitiesrecommendations are presented in Release Report (Weston 2006). Baresults, and risk and dose calculatiothat Radium-226 concentrations in inches bgs) do not pose unacceptasince there is potential for the landf
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

radioactive material, IRP Site 5 wrestricted radiological release.” The last paragraph has been rev

“APHO 46 has received regulatofor both radiological and non-rad2004, RWQCB 2003c, DTSC 20RWQCB 2006); therefore, there previous contamination concerns the two COs.” 

6. Section 4.1.5 

(Carve-Out IIR) 

The reference for the SRUs should read “(U.S. EPA 2008a, DTSC 2008a)”. 

References have been revised as follows2008a. 

7. Section 4.2 

(Petroleum Products and Derivatives) 

Additional language about the DTSC’s RCACD is to be added to this section in the Final FOST. 

Based on recent agreement between DTSinsertion of this language is no longer req

8. Section 4.2.1 

(Carve-Out I-F) 

Please address the status of UST 399 in CO 1-F. (see FOSL) 

UST 399 was located adjacent to Building Parcel 2, which is not included in FOST #been added to Page 1, Section 2, Proper

“CO 1-F encompasses a Federa(FAA) parcel of approximately 0was transferred to the FAA undeaction.” 

9. Section 4.2.5 

(Carve-Out IS) 

a. The FOSL does not contain CO I-S. The sheet in the 

front cover pocket of the FOSL binder (labeled FOSL Cross Reference Table of Carve-out Identifiers) shows that CO I-S became CO I-Q. The FOSL Errata Sheet #1, Item #3, states that CO I-S is a new CO of about 1 acre in size and includes UST 273B and Buildings 273 

a. Buildings 273 and 147 were included 

Subsequently, a previously unknown to Building 273 (the concrete UST idFOST Errata Sheet #1 and FOSL Erresult, new CO I-S was designated to 273 and 147. The newly-identified U
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

and 147. This Errata Sheet does not indicate that there is a UST 147 or UST 273 in this CO. However, the USTs are both included in this FOST for CO I-S. Please clarify the confusion about USTs 147 and 273. 

b. This section makes reference to UST 147 closure as 

(RWQCB 2005d). Page 16 of the References shows a (RWQCB 2003d). Please reconcile. 

273B and received site closure concurreletter dated 12/12/2008. 

b. The reference has been revised to 2003

10. Section 4.3 

(AsbestosContaining Material) 

a. This section should describe the number of asbestos 

surveys that are still to be done for the COs proposed for transfer. 

b. A reference should be made in the first paragraph to 

the DoD1994 Asbestos, Lead Paint, and Radon Policies at BRAC Properties, as done in FOST 4. 

a. There is no regulatory requirement for th

additional asbestos surveys on COs pro

b. The reference has been added to Sectio

11. Section 4.4 

(Lead-Based Paint) 

Please add a statement about the number of residential buildings, if any, present on the COs proposed for transfer. 

The following text has been added to the end in Section 4.4: 

“None of the buildings listed in Tabresidential purposes.’ 

12. Section 4.5.2 

(Carve-Out IS) 

Please explain why transformers PCB T36, T37, and T38 were not listed in the FOSL, yet they are included in this FOST for CO I-S. 

The three transformers were included in FOSfinalization of the 2004 FOST and FOSL doccarve-outs areas were slightly modified to berelevant LOCs. At that time it was determinethree transformers were associated with Buithey were physically located within Building signatories were notified of these changes in 2005. The letter included Errata Sheets idenand updated maps. 

13. Section 5.1.1 

(Carve-Out I-F) 

This section describes the restrictions that will apply to the entire CO through a quitclaim and a land use covenant between DTSC and the Navy (DTSC Covenant). Since the activities associated with the Site 16 remedy of MNA are estimated to continue for 19 years, the land use restrictions are essential for ensuring remedial action effectiveness. 

Consistent with the March 10, 2000 MOA beDTSC, the transfer deed and the DTSC coveappropriate environmental restrictions and thbe processed and recorded at the time of tra
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

To ensure that the land use restrictions are in place, transfer of the property to a nonfederal entity should not occur until after the DTSC Covenant has been fully executed by the Navy and DTSC. 

14. Section 5.2.1 

(Petroleum, Carve-Out I-F) 

a. MSC B3 – Please refer to General Comment No. 4 

and Specific Comment No. 3f. 

b. The third paragraph states that certain restrictions on 

CO I-F may be released when the RWQCB has concurred that cleanup objectives have been achieved and a release document recorded with the County Clerk. Please note that any release by the RWQCB would not affect land use restrictions in the DTSC Covenant for CO I-F. Any release by the RWQCB would not affect DTSC’s authority with respect to making a RCACD for CO I-F. 

a. Comment noted. Please see respon

No. 4. 

b. Comment noted. The following text will be added at the en

“However the DTSC Covenant, 5.1, will remain in effect.” 

15. Section 5.4 

(Lead-Based Paint) 

Please add the following sentence to this section. “In its use and occupancy of the property, including but not limited to demolition of buildings, structures, and facilities, and 

identification and/or evaluation of any LBP hazards, the transferee shall be responsible for managing LBP and LBP hazards in accordance with applicable local, state, and 

federal laws, and other requirements relating to LBP and LBP hazards.” This is consistent with FOST 4. 

Text has been added as suggested. 

16. Section 6.3 

(Carve-Out Building 746) 

The EBS (page A.14) indicates that there was a 20-gallon hydraulic fluid tank in the building but the FOST does not. Please explain. 

The tank referenced in EBS Table A-1 waroll-up door system. No visible staining wof the visual site inspection. As such, the as an LOC and thus it was not included in FOST. 

17. Section 7 

(Covenants) 

This section states that the deed for transfer of property on which hazardous substances were stored, 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). Note 

Comment noted. Current text is consistent with Departmen(DoDi) 4165.72, for insertion of covenant 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

that the CERCLA section does not limit storage, release or disposal to that resulting only from former activities conducted by the U.S. Note that the first quotation from CERCLA section 120(h) regarding the covenant should read: The covenant will warrant 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 before the date of such transfer . . . .” 

18. Table 7 

(Monitoring/Bioventing/SVE Wells): 

a. This table lists several wells on COs I-F, I-N, and II-M 

that cannot be easily identified as monitoring wells. The FOST should describe what these wells are being used for and how their presence and use affects the COs proposed for transfer. 

b. What is the status of 1BSVE-01 located in CO I-N and 

why are there no notifications or restrictions associated 

with the well? 

c. What is the status of 18 BGMW02A, C, D, and E 

located in CO II-M and why are there no notifications or restrictions associated with the wells? 

d. It appears that there is no reference to Table 7 in the 

FOST text. Please verify. 

a. Table 7 has been updated to accurately 

As stated in response to Comment #5, aand II-M have been decommissioned. A has been added to the table to identify twell. 

b. CO I-N no longer contains any wells. T

updated accordingly. 

c. CO II-M no longer contains any wells. T

updated accordingly. 

d. Reference to Table 7 has been added to 

19. Section 8, 

Access Clause: 

CERCLA Section 120(h) (3) (A) (iii) would not apply to COs I-K, I-N, I-O, and I-S because they are proposed for conveyance “as is” without a CERCLA Covenant, therefore, please change the first sentence to read, “The deed will 

reserve and the transferee shall grant to the U.S. (DON 

and U.S. EPA) access to COs I-F, II-E, II-L, II-M, II-R, and Building 746 pursuant to CERCLA Section 120(h) (3) (A) (iii)”. 

Text has been revised as follows: 

"The deed will reserve and the tranthe U.S. (DON and U.S. EPA) acceL, II-M, II-R, and Building 746 pursuSection 120(h) (3) (A) (iii)." 

20. Table 1: 

Buildings/Struc

a. The 2004 FOSL shows Building 939 as demolished. a. Building 939 exists as depicted on Figur
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response tures/Facilities Please reconcile. 

b. The year of construction for Buildings 936 and 939 is 

listed as “unknown” and the year of construction for Buildings 937 and 940 is listed as “<1997”. Please ensure the appropriate LBP restrictions are in place for these buildings. 

b. Structures 936, 939, 937, and 940 w

so LBP restrictions are not necessarupdated to reflect these changes. 

21. Table 2 Environmental Requirements and Notifications: Please 

mark “Y” for “School Site Considerations” for COs I-S and Building 746. 

Text has been revised as suggested. 

22. Table 4 

(Locations of Concern), Page 6 of 20, UST 273B 

The table lists the removal completion date as 8/27/2004 but the 2004 FOST Errata Sheet #1 lists a different date. 

Please reconcile. 

Table 4 has been revised to state that the 08/26/2004. 

23. Table 6: 

Summary of Asbestos Surveys 

Some of the descriptions don’t match the descriptions in Table 1. Please reconcile. COs I-N and Building 746 need to be included in Section 5.3 because both COs include a building where a previous survey detected non-FAD ACM. Restrictions apply. 

Descriptions behave been made consiste6. CO I-N is now included in Section 5.3, SuAsbestos-Containing Material, as Section CO II-E is now included in Section 5.3, SAsbestos-Containing Material, as Section CO Bldg 746 is now included in Section 5Restrictions, Asbestos-Containing Materi

24. Figure 3 

(Carve-Out I-F) 

a. Building 399 is shown in dark green and the legend 

explains that it is not part of the CO I-F transfer. Please explain. 

b. The source should be listed as “Earth Tech 2003”. c. The figure shows an “Institutional Control Boundary”, a 

“Carve-Out. Area Subject to IRP Site 16 Restrictions” 

a. See response to Comment #8. Addi

to clarify. 

b. The reference has been revised as sc. Text and figure have been clarified to 

restricted areas. The ARIC boundarentire CO, this is now more clearly re
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

and a “No Dig Area for Ongoing Petroleum Corrective Action”. Sections 5.1.1 and 5.2.1 also discuss three different boundaries for restrictions. It is difficult to understand exactly what property is going to be restricted, what the restrictions will be, and the mechanisms that will be in place to implement the restrictions. This confusion/ambiguity should be clarified so it will not pose a problem when preparing the quitclaim deed and DTSC Covenant. 

footprint associated with the petroleum overlaps with the area subject to the IRP restrictions. However, this distinction is accurately describe what area will be thcovenant and the restrictions associated going petroleum corrective action. 

25. Figure 8 

(Carve-Out IIE) 

If applicable, please show the petroleum plumes associated with CO II-Q. 

The petroleum plumes associated do not faldescribing the plumes has been added to Seplumes will not be added to Figure 8. 

26. Figure 10 

(Carve-Out IIM) 

Figure 10 (Carve-Out II-M): Please show the buffer zone for IRP Site 5 on the figure. 

The IRP Site 5 buffer zone has been added 

27. Figure 12 

(Carve-Out Building 746) 

Please show the buffer zone for IRP Site 3 on the figure. If applicable, please show the Tank Farm 5 plume in CO IIQ that encroached on CO II-D. 

The buffer zone and the plume have been a

28. Attachment 4a 

(Petroleum Products Notification Table, CO I-S, UST 273B) 

The Attachment shows the date of operation as “unknown”. 

The 2004 FOSL, Errata Sheet #1 shows “1944-1994”. Please reconcile. 

Attachment 4a has been revised to show da

1944-1994. 

29. Attachment 4b 

(Hazardous Substances Notification Table) 

PCB T74 is listed, but not the other PCB transformers. 

Please explain. 

PCB T74 was the only site at which a responfor releases of transformer oil containing PCII-E had PCB-containing transformers at one of a release was noted at those sites, thus nrequired. 

EDITORIAL COMMENTS 1. Page i In the column of page numbers on the right side, please Alignment of the page number has been cor
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restor

16 April 2009 

Comment No. 

Section/ Page No. Comment Response (Contents) realign page number 3. 

2. Page i 

(Contents) 

A new Section 3.4 will need to be added to the Final FOST. DTSC will provide language for this Section. 

Based on an agreement with DTSC, the ano longer necessary. 

3. Page 1 Please revise the descriptions of location of some COs to 

be more precise, e.g., the first 5 COs, CO II-E, and CO II-M are in the northwestern, central, and southern portion of the former Base, respectively. 

Text has been revised to be more precise

4. Section 4.1, 

first sentence 

The word “parcels” should be deleted. Text has been revised, “parcels” has bee

5. Section 4.1.1, 

IRP Sites 

Paragraph 2 refers to the Covenant to Restrict Use of Property as the “DTSC Covenant”. Please ensure this reference is used appropriately throughout the FOST, e.g., Section 5.1.1. 

References to the DTSC Covenant have they are capitalized in Section 5.1.1 and S

6. Page 17, 

References 

Reference RWQCB 2008f on Page 17 of the References shows “27bB” instead of “273B” for the UST. Please correct. 

Text has been revised to “273B”. 

7. Table 3 Potential Release Locations: Please include “SI” in the list 

of acronyms at the end of the table. 

SI has been added to the acronym list. 

8. Table 4: 

Locations of Concern 

a. Page 7 of 20 – RFA 14: Please correct the two 

typographical errors in the “Closure Report Title/Date” column. 

b. Page 9 of 20 – APHOs 99 and 110: Please correct the 

grammatical error in the last sentence under the “Notes” column. 

c. Page 12 of 20 – PRL 605: In the “Notes” column, 

please insert a space between “the” and “Summary” in line 5. 

d. Page 13 of 20: Please delete the second row (PCB 

643). It’s a repeat of the one above. 

a. Spelling of the words, “Aircraft” and “

corrected. 

b. The extraneous “s” has been removec. A space has been added as suggest

d. The second instance of PCB 643 ha

suggested. 

e. The term “MSC” has been inserted bf. Acronyms have been revised as sug
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoratio

16 April 2009 

Comment No. 

Section/ Page No. Comment Response 

e. Page 19 of 20: In row #1, column #1, please insert 

“MSC” before “673T3”. 

f. Page 20 of 20: Please add the following acronyms to 

the list: DON, DRMO, PERF, and OPS. Also, please correct the typographical error with “SRU”. “Sliver” should be changed to “Silver”. 

9. Figure 3 

(Carve-Out I-F) 

There are two different colors of green used in the legend. The colors are difficult to distinguish. Please change one of the shades of green to a different color. 

The shading surrounding Building 399 has bcolor. 

10. Attachment 4b 

(Hazardous Substances Notification Table) 

a. Please delete “Non-Trans” from the list of acronyms at 

the bottom of the table, and add “SRU”. 

b. Please include Radian 1996 in Section 10, 

References. 

Text has been revised as suggested. 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: John Broderick, California Regional Water Quality Control Board, Santa Ana Region, Email dated 22 April 2009 Comment No. 

Section/ Page No. Comment Response 

GENERAL COMMENTS 1. A 22 April 2009 e-mail from RWQCB stated that the agency 

had no comments on the Draft FOST. 

Comment noted. 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Ma

Toro, California Reviewer: Rich Muza, Remedial Project Manager, United States Environmental Protection Agency Region 9, Federal Facilities and dated 3 April 2009 

Comment No. 

Section/ Page No. Comment Response 

GENERAL COMMENTS 1. EPA previously provided the following comment to the 

Navy with regard to the proposed plans for the on-going Petroleum Corrective Action Program closure efforts at MSC-3: 

“While the EPA strives to support the Navy’s goals for cleaning up the former MCAS El Toro under both the Federal Superfund and State Corrective Action programs, in this instance the corrective action to be performed will have a temporary impact on a Superfund remedy in place and defined by EPA to be operating properly and successfully at IRP Site 16. Of particular concern to EPA is the destruction and post-corrective action replacement of three ground-water monitoring wells located in the source area of the IRP Site 16 TCE plume. Since the Superfund remedy for IRP Site 16 is monitored natural attenuation, EPA deems these monitoring wells to be a significant component of that remedy. As such, EPA will not concur with the Finding of Suitability to Transfer for this parcel until we have been provided with a report that includes 1) well logs and construction details for all replacement monitoring wells and the comparison of the results of a round of ground-water quality sampling from the replacement monitoring wells to the TCE trend from the destroyed monitoring wells and 2) details on the post-corrective action site re-grading efforts to assure proper drainage in the TCE plume source area as mandated by the Record of Decision for IRP Site 16.” 

Due to the Navy’s intent to finalize FOST #5 in FY09 and the unknown timing of the on-going Petroleum Corrective Action Program closure efforts at MSC-3, it may be in the 

Navy’s best interest to remove Carve-Out I-F from this 

The Petroleum Corrective Action Program at Miscellaneous Site of Concern (MSC) implemented until after property conveyathe Federal Facility Agreement (FFA) sigincludes a recommendation to re-evaluatnetwork in the main pit area, additional timsubstantive technical comments and coo

As such, Installation Restoration Program received concurrence on an operating pro(OPS) determination. As you know, an Oapproved by U.S. Environmental Protectirequired to document that all remedial achuman health and the environment has bcovenant required by Section 120(h)(3)(AComprehensive Environmental Response Liability Act (CERCLA). U.S. EPA providletter dated February 2, 2009. At the time all appropriate IRP Site 16 remedy compotherefore, IRP Site 16 can be transferred CERCLA. The Navy will continue to work closely witensure that the objectives of both the PCCERCLA (e.g. IRP Site 16) programs are 
January 2010 Response to Comments 

Document Titles: Draft Finding of Suitability to Transfer (FOST) #5 for Carve-Outs I-F, I-K, I-N, I-O, I-S, II-E, II-L, II-M, II-R, and Building 746, Former Marin

Toro, California Reviewer: Rich Muza, Remedial Project Manager, United States Environmental Protection Agency Region 9, Federal Facilities and Site dated 3 April 2009 

Comment No. 

Section/ Page No. Comment Response 

FOST. At the current rate of progress on this effort, CarveOut I-F should be included in FOST #6. 

2. It is not clear from the Draft FOST what reuse is anticipated 

for the various parcels. Of particular concern is whether or not the buildings will be reused or demolished. For example, if the reuse of a parcel is residential and the 

building(s) will be used, then a deed restriction – not just a notice -- is needed that will prohibit residential reuse of structures until 1) both asbestos and lead-based paint sampling programs have been performed and 2) any necessary remediation has been completed. It is recommended that the Draft Final FOST address future reuse to address this concern and add corresponding deed restriction language, if necessary. 

Navy FOST policy (March 2006 BRRM) doerequirement to address “potential reuses." T

appropriate notifications and restrictions relawhich is incorporated into the deed which is document on how buildings are reused. Speis often fluid and dependent on a myriad of fcontrol. Accordingly, it is not appropriate for discuss planned reuse. 
Attachment 2 

Unresolved Comments 
This Page Intentionally Left Blank 
(There are no unresolved comments for FOST #5) 
This Page Intentionally Left Blank 
Attachment 3 

RCRA Corrective Action Package 
This Page Intentionally Left Blank 





Attachment 4a 

Petroleum Products Notification Table 
This Page Intentionally Left Blank 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California Attachment 4a 

Page 1 of 1

Attachment 4a: Petroleum Products Notification Table 

Carve-out 

ID Area Type ID Petroleum Products*

Dates of 

Operation 

Activities 

Conducted At Site 

Carve-Out I-F 

I-F UST 6B Fuel Oil 1943-1996 S 

I-F UST 101 Diesel Unknown S 

I-F UST 399 Diesel 1955-1999 S 

I-F UST 850A JP-5 1988-2000 S 

I-F UST 850B JP-5 1988-2000 S 

Carve-Out I-K 

I-K UST 68 Diesel 1943-1992 S 

I-K UST 70 Diesel 1973-1999 S 

I-K UST 72 Diesel 1948-1999 S 

I-K UST 718 Fuel Oil 1978-1993 S 

Carve-Out I-N 

I-N AST 1 Diesel 1943-1999 S 

I-N UST 1A Diesel 1943-1992 S 

I-N UST 1B Diesel 1943-1992 S 

Carve-Out I-O 

I-O UST 98A Fuel Oil 1943-1997 S 

Carve-Out I-S 

I-S UST 147 Diesel 1943-1999 S 

I-S UST 273 Fuel Oil 1944-1994 S 

I-S UST 273B Fuel Oil 1944-1994 S 

Carve-Out II-E 

II-E RFA 267 Gasoline Unknown-1999 S 

II-E UST 115A Fuel Oil 1943-1994 S 

II-E UST 115B Fuel Oil 1966-1993 S 

II-E UST 116 Diesel 1943-1999 S 

II-E UST 117 Diesel 1943-1997 S 

II-E UST 605A Diesel 1965-1991 S 

II-E UST 605B Diesel 1965-1999 S 

II-E UST 606A Diesel 1965-1997 S 

II-E UST 643A Waste Oil 1982-1997 S 

Carve-Out II-M 

II-M UST 442 Fuel Oil 1959-1993 S 

Carve-Out II-R 

II-R UST 457 Diesel 1960-1993 S 

Notes: 

* Includes only petroleum products which fall within the scope of the 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 of 1980 

ID = Identification 

JP-5 = Jet Propulsion Fuel, Grade 5 

RFA = RCRA Facility Assessment 

S = Storage of Hazardous Material or Waste 

UST = underground storage tank
Attachment 4b 

Hazardous Substances Notification Table 
This Page Intentionally Left Blank 
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 1 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

Carve-Out I-F I-F 5 TAA 5A Substances associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

I-F 850 MSC B1 JP-5, Solvents, Waste Oil NA NA NA Unk

1

I-F 850 MSC B2 JP-5, Solvents, Waste Oil NA NA NA 1I-F 850 MSC B3 JP-5, Solvents, Waste Oil NA NA NA Unk

1

I-F 850 OWS 850E Oil/Fuel/ Water NA NA NA Unk

1

I-F NA IRP 16 JP-5, AVGAS, hydraulic 

fluid, crankcase oil, white 

phosphorus, magnesium 

phosphate, and napalm 

NA NA NA 197

I-F NA IRP 25 Substances associated 

with storm water 

discharges and drainage 

channels 

NA NA NA Unk

1

I-F NA APHO 26 Unknown NA NA NA Unk

1

I-F NA APHO 92 Unknown NA NA NA Unk

1
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 2 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

Carve-Out II-E II-E NA APHO 119 Unknown NA NA NA Unk

1

II-E 115 TAA 115 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-E 115 APHO 37 Unknown NA NA NA Unk

1

II-E 118 PRL 118 Solvents, Waste Oils NA NA NA Unk

1

II-E 121 APHO 110 Unknown NA NA NA Unk

1

II-E 126 N/A Ethylbenzene 

P-Xylene 

M-Xylene 

Toluene 

Perchloroethylene 

1,1,1-Trichloroethane 

O-Xylene 

17.41 lbs 

8.70 lbs 

17.41 lbs 17.41 lbs 17.41 lbs 17.41 lbs 

8.70 lbs 

100-41-4 106-42-3 108-38-3 108-88-3 127-18-4 

71-55-6 95-47-6 

N.E. N.E. N.E. 

U220 U210 U226 

N.E. 

Unk

1

II-E 126 N/A 1,4-Dichlorobenzene 

Perchloroethylene 

Dichloromethane 

Napthalene 

0.81 lbs 1.01 lbs 0.60 lbs 

12.09 lbs 

25321-22-6 

127-18-4 

75-09-2 91-20-3 

N.E. 

U210 

N.E. 

U165 

Unk

1

II-E 139 RFA 43 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-E 139 APHO 99 Unknown NA NA NA Unk

1

II-E 605 PRL 605 Fuels, Paints NA NA NA Unk

1
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 3 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

II-E 605 RFA 14 Unknown NA NA NA Unk

1

II-E 605 RFA 150 Solvents NA NA NA Unk

1

II-E 605 TAA 605 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-E 605 OWS 605C Oil/Water NA NA NA Unk

1

II-E 605 PRL 605 Pesticides NA NA NA Unk

1

II-E 606 PRL 606 Paint NA NA NA Unk

1

II-E 606 RFA 152 JP-5, Solvents, 

Lubricating Oils 

NA NA NA Unk

1

II-E 606 TAA 606 Substances Associated 

with Materials Storage 

NA NA NA Unk

1

II-E 606 NA Pesticides NA NA NA Unk

1

II-E 643 PRL 643 Fuels NA NA NA Unk

1

II-E 643 UST 643A Waste Oil NA NA NA 198II-E 643 OWS 643B Oil/Water NA NA NA 198II-E 892 OWS 892 Oily water NA NA NA Unk

1

Carve-Out II-L II-L NA PRL Runway 

Infield Area 

Waste Oil NA NA NA 194
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 4 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

II-L NA IRP 25 Substances associated 

with storm water 

discharges and drainage 

channels 

NA NA NA Unk

1

Carve-Out II-M II-M 1789 APHO 38 Disturbed Ground and 

Excavation 

NA NA NA Unk

1

II-M 354 PRL 354 Lead and Other Metals NA NA NA Unk

1

II-M 442 PRL 442 Hazardous Wastes NA NA NA Unk

1

II-M 673 PRL 673 Hazardous Wastes, 

Battery Acid, Solvents 

NA NA NA Unk

1

II-M 673 RFA 178 Washwater from vehicles NA NA NA Unk

1

II-M 673 RFA 181 Substances Associated 

with Land-farming Areas

NA NA NA Unk

1

II-M 673 RFA 182 Substances Associated 

with drum storage areas

NA NA NA Unk

1

II-M 673 RFA 183 Substances Associated 

with drum storage areas

NA NA NA Unk

1

II-M 673 RFA 184 Substances Associated 

with drum storage areas

NA NA NA Unk

1

II-M 673 RFA 185 Substances Associated 

with drum storage areas

NA NA NA Unk

1

II-M 673 TAA 673 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-M 673 APHO 51 Unknown NA NA NA Unk

1

II-M 673 OWS 673A Oil/Oily Water NA NA NA 198
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 5 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

II-M 673 MSC 673 T3 Solvents, Waste Oil, Fuel, 

Asbestos, Lead paint, 

PCBs, and other 

substances associated 

with aircraft maintenance, 

repair, cleaning, grease 

and painting 

NA NA NA Unk

1

II-M 673 N/A Ethylbenzene 

P-Xylene 

M-Xylene 

Toulene 

Perchloroethylene 

1,1,1-Trichloroethane 

O-Xylene 

2.90 1.45 2.90 2.90 2.90 2.90 1.45 

100-41-4 106-42-3 108-38-3 108-88-3 127-18-4 

71-55-6 95-47-6 

N.E. N.E. N.E. 

U220 U210 U226 

N.E. 

Unk

1

II-M 673 N/A P-Xylene 

M-Xylene 

Toulene 

Acetone 

O-Xylene 

39.67 79.34 

105.14 198.02 

39.67 

106-42-3 108-38-3 108-88-3 

67-64-1 95-47-6 

N.E. N.E. 

U220 U002 

N.E. 

Unk

1

II-M 673 N/A P-Xylene 

M-Xylene 

Toulene 

Ethylene Glycol 

Monobutyl Ether 

Acetone 

O-Xylene 

16.13 32.25 

193.50 

2.58 

322.50 

16.13 

106-42-3 108-38-3 108-88-3 111-76-2 

67-64-1 95-47-6 

N.E. N.E. 

U220 

N.E. 

U002 

N.E. 

Unk

1

II-M 772 TAA 772 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-M 832 OWS 832 Oil/Oily Water NA NA NA Unk

1
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 6 of 7 

Attachment 4b: Hazardous Substances Notification Table 

Carve-out 

ID 

Building 

Number Area Type ID 

Hazardous 

Substances(a)(b)

Reportable 

Quantity 

(lb/year)(c) CAS Number

RCRA Waste 

Code 

Da

Ope

II-M DRMO Lot No. 

3 

RFA 264 Substances Associated 

with DRMO Storage Yard 

operations 

NA NA NA Unk

1

II-M DRMO Yard RAD DRMO Potential Radiological 

Materials 

NA NA NA Unk

1

II-M DRMO Yard 3 APHO 20 Disturbed Ground and 

Excavation 

NA NA NA Unk

1

II-M DRMO Yard 3 APHO 27 Unknown NA NA NA Unk

1

II-M DRMO Yard 3 MSC D1 Substances Associated 

with less than 90-day 

accumulation of wastes 

NA NA NA Unk

1

II-M Golf Course APHO 46 Unknown NA NA NA Unk

1

II-M RAD Area RAD NBC Potential Radiological 

Materials 

NA NA NA Unk

1

Carve-Out II-R II-R 457 PCB T74 PCBs NA NA NA Unk

1

II-R 457 RFA 244 PCBs NA NA NA Unk

1

II-R 457 PRL 457 Photographic 

Development Chemicals

NA NA NA Unk

1

II-R 457 APHO 42 Unknown NA NA NA Unk

1

II-R 457 SRU 3C Photographic Chemicals NA NA NA Unk

1
Final Finding of Suitability to Transfer #5 

April 2010 Former MCAS El Toro, California 

Page 7 of 7 

Notes: 

(a) This table was prepared in accordance with 40 CFR 373 and 40 CFR 302.4. The substances which do not have c

down (and associated annual reportable quantity) are not listed in 40 CFR 302.4, and therefore have no correspon

Abstracts Services (CAS) number, no regulatory synonyms, no Resource, Conservation, and Recovery Act (RCRAno reportable quantities. 

(b) The Property may contain pesticide residue from pesticides that have been applied in the management of the Prop

knows of no use of any registered pesticide in a manner inconsistent with its labeling and believes that all applicatiaccordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA - 7 U.S.C. Sec. 136, et seq.), its imregulations, and according to the labeling provided with such substances. It is the Grantor’s position that it shall ha

the covenants provided pursuant to Section 120(h)(3)(A)(ii) of the Comprehensive Environmental Response, Comp

Act of 1980, 42 U.S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides. (c) Reportable Quantity 

For Buildings with chemical-specific break down and associated reportable quantity, the information was obtained 

Source Survey, Final Submittal, MCAS El Toro. The reportable quantity was assumed to be the estimate of the air was calculated based on a quantity used during the year. For non-VOCs, the specific chemicals are listed and the 

Sources: Earth Tech 2003, Radian 1996. 

APHO = Aerial Photograph Feature/Anomaly AVGAS = aviation gasoline CAS = Chemical Abstracts Services D = Disposal of wastes DRMO = Defense Reutilization and Marketing Office ID = Identification IRP = Installation Restoration Program JP-5 = Jet Propulsion Fuel, Grade 5 lb = pound MSC = miscellaneous NA = not applicable NBC = Nuclear, Biological, Chemical N.E. = Not Established ND = Operations at site are Not Determined OWS = Oil Water Separator PCB = polychlorinated biphenyls PRL = Potential Release Location RAD = Radiological RCRA = Resources Conservation and Recovery Act RFA = RCRA Facility Assessment S = Storage of Hazardous Material or Waste SRU = Silver Recovery Unit TAA = Temporary Accumulation Area UST = underground storage tank