# 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 R ecovery 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

b gs b elow ground surface

BNI Bechtel National, Inc.

BRAC Base Realignment and Closure

CCR California Code of Regulations

CDM CDM Federal Pr ograms Corporation

CDPH California Department of Public Health

CERCLA Comprehensive Environmental Res ponse, Compensation, and Liability Act

CO carve-ou t

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 Transfe r

HRA Historical Radiological Assessment

HSC Health and Safety Code

IRP Installation Restoration Program

LBP lead- b ased pain t

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 Assessmen t

RI Remedial Investigation

ROD Record of Decision

RWQCB Regional Water Quality Control Board

SRU silver recovery unit

SWMU solid waste management uni t

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

1 

# 1. PURPOSE

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

and notifications for hazardous substances, petroleu m 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 satisfi ed by the United States (U.S.) Department of the

Navy (DON). Through the Base Realignment and Cl osure (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 investigati on 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 (D epartment of Defense [DoD] 2006), and is

consistent with the DoD Base Redevelopm ent 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 pr oposed 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. Figur e 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 appr oximately 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 approxima tely 0.8 acre and is located in the northwest

portion of the former base. Bu ilding 1 is within this CO.

 

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

portion of the former base.

 

# Carve-Out I-S (Figure 7) – consists of approxima tely 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 a pproximately 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 a pproximately 1.2 acres and is located in the

southeast portion of the former base.

 

# Carve-Out Building 746 (Figure 12) – consis ts 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

2 

# 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 Comprehe nsive 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 im plements 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 (RWQ CB), 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 fo r review. Regulatory agency comments to this

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

Attachment 2.

3.1 R ESOURCE 

# C ONSERVATION AND 

# R ECOVERY 

# A CT 

# P ART 

# B P ERMIT AND 

# S UBTITLE 

# C

C ORRECTIVE 

# A CTION



# 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 Calif ornia, 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 pr otection of human health and the environment - see

Section 121(d) of CERCLA, Health and Safety C ode (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 Pa rt 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 SWMU s. 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 inte nded 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 incorporat ed 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 corr ective 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 h ealth and the environment...” (42 U.S.C. Section

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

April 2010 Former MCAS El Toro, California to Transfer

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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 plac ed 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 R ESOURCE 

# C ONSERVATION AND 

# R ECOVERY 

# A CT 

# S UBTITLE 

# I C ORRECTIVE 

# A CTION



# 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 releas e; 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 eval uate 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 par ties and states that, “The regulatory agency shall

concur with the corrective action plan after de termining that implementation of the plan will

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

potential beneficial uses of water.”

NFA letters issued by the RWQCB and OCHCA ar e 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 fa ctors listed in subdivision (b),...” HSC Section

25296.10(b) provides, “Any corrective action conduc ted 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 Determ ination for property associated with FOST 5,

DTSC does plan to issue a letter to the transfer ee clarifying the corrective action obligations for

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

April 2010 Former MCAS El Toro, California to Transfer

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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 C OMPREHENSIVE 

# E NVIRONMENTAL 

# R ESPONSE



# , C OMPENSATION



# , AND 

# L IABILITY 

# A CT



# CERCLA response actions are initiated at environm ental sites where CERCLA hazardous substances

have been or may have been re leased. There are two such area s 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 we re investigated under CERCLA and received no

further investigation (NFI) concurrence. See Sec tions 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, as bestos-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 provide d in Attachment 4b, the Hazardous Substances

Notification Table. Notification tables for bot h 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, pe troleum 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 signato ries agreed that the DON would

prepare investigation plans, perform field evalua tions, and provide conclusions as to whether a PRL

needed to be included in a specific regulatory cl ean-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 th e status of the non-CERCLA PRLs within the CO

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

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

warranted at the following PRLs:

 CO II-E – 118 (U.S. EPA 2005a, DTSC 200 5a), and 643 (U.S. EPA 2005a, DTSC 2006a)

 CO II-M – 442 (U.S. EPA 2005a, DTSC 200 5a), 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) with in the COs. LOCs are areas where a release is

suspected to have occurred, a documented release h as 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

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

April 2010 Former MCAS El Toro, California to Transfer

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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 (Tab le 5) and the ongoing groundwater response action

at IRP Site 16 (Table 4). NFA designations ar e 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 respectiv ely are adhered to. This includes LOCs that meet

the federal and state definitions of SWMUs a nd 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 concu rrence (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 cont rol (LUC) objectives to be achieved through landuse restrictions. The Final Remedial Design Re port (CDM Federal Programs Corporation [CDM]

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

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

restrictions be incorporated into and implemen ted 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 indicat ed that the site-related releases were limited to

sediment and surface water. The human health an d 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). IR P Site 25 is comprised of Agua Chinon Wash,

Bee Canyon Wash, Borrego Canyon Wash, and Marshbur n 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 c oncurrence (RWQCB 2000d). RFA site 43 received

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

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

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# 1996b). RFA site 152 received site closure conc urrence (DTSC 1996b). RFA site 267 received site

closure concurrence (DTSC 1996b).

TAA Sites

– TAA 115 received site closure concurren ce (DTSC 2006c). TAA 605 and 606 received

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

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

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

closure concurrence (RWQCB 2003a). APHO 119 recei ved 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 concurren ce (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 r eceived 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 Ma rketing Office (DRMO) site received site

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

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

DRMO Yard 3 prior to final disposition. A ra diological 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 conc urrence (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).

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

April 2010 Former MCAS El Toro, California to Transfer

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# SRUs – SRU 3C was evaluated under PRL 457, and r eceived site closure concurrence (U.S. EPA

2008a, DTSC 2008a).

4.2 P ETROLEUM 

# P RODUCTS AND 

# D ERIVATIVES



# The corrective action cleanup standards for pe troleum 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 in vestigation 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 concurre nce (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 concurren ce (RWQCB 1997a). UST 70 received site closure

concurrence (RWQCB 2008d). UST 72 received si te 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 clos ure concurrence (RWQCB 2001a).

USTs – USTs 1A and 1B received site closur e 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 concurre nce (RWQCB 1996b). UST 115B received site

closure concurrence (RWQCB 1998a). UST 116 recei ved 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 (R WQCB 1997b). UST 643A received site closure

concurrence (OCHCA 1997a).

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

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

2000c).

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April 2010 Former MCAS El Toro, California to Transfer

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

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

OWSs – OWS 673A received site closure concu rrence (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 clos ure concurrence (OCHCA 1996b).

4.3 A SBESTOS 

# -C ONTAINING 

# M ATERIAL



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

to comply with all applicable federal, state, a nd 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 tran sfer, all property containing ACM will be conveyed,

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

threat to human health or the environment, o ccupation 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 detect ed in a survey that was conducted prior to but not since 1997

(i.e., not within the last 3 years of station operati on); 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 L EAD 

# -B ASED 

# P AINT



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

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

LBP for residential use). The COs proposed for transf er 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 so me of these buildings. This in turn creates the

possibility that, through the action of normal weat hering 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 re develop for residential use after transfer, the

transferee may, under applicable law or regula tion, be required by DTSC or other regulatory

agencies to evaluate the soil adjacen t to such non-residential buildi ngs for soil-lead hazards, and to

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

prior to occupancy of any newly constructed residential buildings.

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April 2010 Former MCAS El Toro, California to Transfer

9 

# 4.5 P OLYCHLORINATED 

# B IPHENYLS



# 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, st ructures, 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 ha d 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 re quired 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 fe deral 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, w ith the exception of PCBs used in enclosed

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

whereas PCB-contaminated equipment contains PCB c oncentrations 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 tr ansformer 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 pp m PCB concentrations were associated with

Buildings 643 and 892 (PCB 643 and PCB 892). NF A 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 iden tified PCBs in one of the seven

samples collected. The transforme r 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 inspectio ns 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 S CHOOL 

# S ITE 

# C ONSIDERATIONS



# If, subsequent to transfer, any portions of the prope rty found suitable to transfer by this FOST are

considered for the proposed acquisition and/or c onstruction of school properties using state funding,

a separate environmental review process in comp liance 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 Californi a Education Code requires that a comprehensive

evaluation of natural and manmade hazardous mate rials be conducted for school properties. This

comprehensive evaluation requires additional inves tigation 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., ra don gas), and naturally-occurring petroleum deposits.

The evaluation also includes ACM and LBP at c oncentrations that fall outside the scope of

CERCLA. Any requirements associated with the eval uation of any property fo r 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 th e CO areas proposed for

transfer related to CERCLA/RCRA sites, petroleum products and de rivatives, 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 me t. 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 depi cted 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 buffe r 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 a nd 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 qu itclaim 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 prio r review and written approval from the FFA

signatories; and

 The transferee shall not conduct any subsurface ex cavation, 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 a dditional requirements in the quitclaim deed and

will work with DTSC to incorporate si milar language into the DTSC Covenant:

- The transferee and future transferee(s) must co mply with all terms a nd conditions relating to

land-use restrictions set forth in the IRP S ite 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 annua l site inspections to

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

continue to report results from those inspec tions, 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 futu re 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, re turn 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 pr ovide 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, repor ted, 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 require ment 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.

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

April 2010 Former MCAS El Toro, California to Transfer

12 

# 5.2 P ETROLEUM 

# P RODUCTS AND 

# D ERIVATIVES



# 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 pe troleum 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 de signated on Figure 3 as the no dig area for ongoing

petroleum corrective action, without prior revi ew 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 so il 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 RWQC B 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 A SBESTOS 

# -C ONTAINING 

# M ATERIAL



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

ACM that has been identified with in the respective COs. Informati on 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 classi fied as containing FAD ACM based on previous

surveys conducted in 1991 and 1999. Except for shor t-term and emergency main tenance, access, use,

or occupancy is prohibited pending either (1) co mpletion 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 requi rements relating to asbestos or ACM. Pending

completion of abatement or demolition, the transferee shall manage the AC M in accordance with all

such applicable local, state, and federal laws and requirements.

Buildings 115, 118, 119, 139, 69 5, 696, and 697 – These buildings require an ACM survey because

the previous survey detected non-FAD ACM. Excep t for short-term and em ergency maintenance,

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

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

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

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

April 2010 Former MCAS El Toro, California to Transfer

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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 c onducted 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 w ith applicable regulatory requirements.

5.4 L EAD 

# -B ASED 

# P AINT



# In its use and occupancy of the property, incl uding 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 applic able 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 build ing unless the transferee performs any necessary

evaluation(s) and abatement in accordance with all lo cal, 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 constr ucted prior to 1978 and may not be used for residential use or as

child-occupied buildings unless the transferee perfo rms 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 pr operty 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 C ARVE 

# -O UT 

# II-E (F IGURE 

# 8)

CO II-E adjoins CO II-Q; however, releases th at 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 th e site-related contamina tion was limited to the

shallow soil interval and the human health a nd 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 Build ing 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. Base d on the monitoring data collected to date it is

projected that both of these plumes will not encroach on CO II-E.

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

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# 6.2 C ARVE 

# -O UT 

# II-M (F IGURE 

# 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 th e potential for the landfill to contain radioactive

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

laboratory analyses of soil samples were conducte d 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 Radiol ogical 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 unacceptab le 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 C ARVE 

# -O UT 

# B UILDING 

# 746 (F IGURE 

# 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. Secti on 6.1, above, details CO II-Q. Similar to CO IIE, neither of the petroleum plumes associated w ith Tank Farm 5 or Building 398 will encroach into

CO Building 746.

7. COVENANTS

The deed for transfer of any property on which “an y hazardous substance was stored for one year or

more, [or] known to have been released, or dispo sed...” 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 acti on 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 Environmen tal Response, Compensation, and Liability Act

of 1980 remaining on the property has been taken be fore 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 petrol eum 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 gr ant 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 reme dial action or corrective action is found to be

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

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

April 2010 Former MCAS El Toro, California to Transfer

16 

# 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 Tempor ary Accumulation Area Site 115,

Former Marine Corps Air Statio n 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 Relea se of Defense Reutilization and Marketing

Office (DRMO) Yard 3, Former Nuclear, Biol ogical 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 fo r Underground Storage Tank (UST) 115B.

January 7.

______. 1998b. No Further Action Concurrence Letter fo r 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 fo r 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 fo r 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 R adiological 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 Demonstrati on 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 fo r Underground Storage Tank (UST) 850A,

850B, and Oil/Water Separator 850E. August 28.

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

April 2010 Former MCAS El Toro, California to Transfer

18 

# ______. 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 fo r 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 Te mporary 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) A pproval: Marine Corps Air Station

(MCAS) El Toro . July 23.

______. 1998. No Further Action Concurrence Letter fo r 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 Envi ronmental Baseline Survey dated September 25.

______. 2003b. No Further Action Concurrence Letter fo r 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 Concu rrence 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 fo r 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 Le tter 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 Le tter 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 fo r 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 w ith 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 w ith 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 Natura l 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 Un ited States Department of Defense.

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

Earth Tech. 2003. Final Environmental Baseline Surv ey, 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 Potentia l Release Locations, Site Inspection,

Former Marine Corps Air Sta tion, El Toro, California. October.

———. 2008b. Final Summary Report for Group IV Poten tial 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 Con servation 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, Californ ia, 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, an d 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 Affa irs 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. Memo randum for T.J. Zagrobelny, Commander, Naval

Facilities Engineering Command, referenc ing U.S. EPA memorandum on disposal

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

Containing PCBs.

______. 1990. Southwest Division, Naval Fac ilities 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 St ation 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 Environmen tal 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 Demonstrati on 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 Pote ntial 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 an d 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:

< = beforeFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 2Page 1 of 1Table 2: Environmental Requirements and NotificationsApplicable to PropertyCarve OutEnvironmental Factors ConsideredI-FI-KI-NI-OI-SII-EII-LII-MII-RBuilding746Presence of Hazardous Substances (Notification)Y N N N N Y Y Y Y NCERCLA/RCRA (Response/Corrective Action)Y N N N N Y Y Y Y NPresence of Petroleum Products and Derivatives (Notification) Y Y Y Y Y Y N Y Y NUST/AST Storage Tanks (Closure/Removal)Y Y Y Y Y Y N Y Y NMunitions and Explosives of Concern – Response Actions N N N N N N N N N NAsbestos-Containing Material (Abatement, Notification) N N Y N N Y N N N YLead-Based Paint (Non-Residential Buildings Notification) N N Y N N Y N N N NPolychlorinated Biphenyls (Notification)Y N N N Y Y N N Y NSchool Site ConsiderationsY Y Y Y Y Y Y Y Y YNotesAST = aboveground storage tankCERCLA = Comprehensive Environmental Response, Compensation, and Liability ActN = NoRCRA = Resource Conservation and Recovery ActUST = underground storage tankY = YesFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 3Page 1 of 2Table 3: Potential Release LocationsLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFI LetterAgency/DateNotesCarve-Out II-EPRL 118 118 Maintenance Hangar Summary Reportfor Group I PRLsSite Insepction(SI) by EarthTech, March2005 (EarthTech 2005a)U.S. EPA04/07/2005DTSC 07/13/2005Records review, VSIs, and soil sampling were conducted for PRL118 from 2002 to 2004, to evaluate whether the release ofhazardous substances or pollutants into the environment hasoccurred. Based on the results of these investigations, no furtherinvestigation (NFI) was recommended for this PRL in the SummaryReport for Group I PRLs and regulatory concurrence was obtained.PRL 643 643 Fixed Aircraft Start System Summary Reportfor Group IIIPRLs SI by EarthTech, October2005 (EarthTech 2005b)U.S. EPA11/03/2005DTSC 02/03/2006Records review and VSIs were conducted for PRL 643 to evaluatewhether the release of hazardous substances or pollutants into theenvironment has occurred. Based on the results of theseinvestigations, NFI was recommended for this PRL in SummaryReport for Group III PRLs and regulatory concurrence was obtained.Carve-Out II-MPRL 442 442 Aviation Armament/MissileMaintenance EquipmentShopSummary Reportfor Group I PRLsSI by EarthTech, March2005 (EarthTech 2005a)U.S. EPA04/07/2005DTSC 07/13/2005Records review, VSIs, and soil sampling were conducted for PRL442 from 2002 to 2004, to evaluate whether a release of hazardoussubstances or pollutants into theenvironment has occurred. Basedon the results of these investigations, NFI was recommended forthis PRL in the Summary Report for Group I PRLs and regulatoryconcurrence was obtained.PRL 673 673 Aircraft Ground SupportEquipment ShopSummary Reportfor Group I PRLsSI by EarthTech, March2005 (EarthTech 2005a)U.S. EPA04/07/2005DTSC 07/13/2005Records review, VSIs, and soil sampling were conducted for PRL673 from 2002 to 2004, to evaluate whether a release of hazardoussubstances or pollutants into theenvironment has occurred. Basedon the results of these investigations, NFI was recommended forthis PRL in the Summary Report for Group I PRLs and regulatoryconcurrence was obtained.Carve-Out II-RPRL 457 457Dental Clinic Summary Reportfor Group IVPRLs SI by EarthTech, March2008 (EarthTech 2008b)DTSC 08/21/2008U.S. EPA04/17/2008Site identified as a former SRU at a photography laboratory in adental clinic (SRU 3C). Records review, VSIs, and soil samplingwere conducted for PRL 457 from 2002 to 2005, to evaluatewhether a release of hazardous substances or pollutants into theenvironment has occurred. Based on the results of theseinvestigations, NFI was recommended for this PRL in the SummaryReport for Group IV PRLs and regulatory concurrence wasobtained.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 3Page 2 of 2Table 3: Potential Release LocationsLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFI LetterAgency/DateNotesSource: Earth Tech 2003.DTSC = Department of Toxic Substances ControlID = IdentificationLOC = Location of ConcernNFI = No Further InvestigationPRL = Potential Release LocationSI = Site InspectionSRU = Silver Recovery UnitU.S. EPA = Environmental Protection AgencyVSI = Visual Site InspectionFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 1 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesCarve-Out I-FAPHO 26 Crash Crew PitNo. 2Disturbed Groundand ExcavationSummary Report,APHO 2610/30/1999byNAVFAC SWDTSC 01/04/2000 APHO 26, also known as SAIC anomaly 189, was identified on anaerial photograph dated 08/28/1968. SAIC description: "There is anexcavation (EX) with possible liquid(LQ) located at the intersectionof the taxiways, about 1,200 feet north of Runway 25R and 1,100feet west of Runway 34L. The purpose of the excavation isunknown. Investigation of site's history is recommended." Historicalfacility records were reviewed, visual inspections were conducted,and the findings were documented in the Summary Report dated10/30/1999. No further action is required.APHO 92 Compass RoseNo. 1Stain InformationPackage, APHOs83, 91, and 9204/17/2003byNAVFAC SWRWQCB 08/14/2003DTSC 04/20/2004APHO 92, also known as SAIC anomaly 117, was identified on anaerial photograph dated 06/28/1960 photograph. SAIC description:"There is a possible stain (ST) around abandoned Compass RoseNo. 1, near K Street and N 1st Place. Additional investigation isrecommended." Historical facility records were reviewed, visualinspections were conducted, and the findings were presented in the“Information Package, APHO 83 (SAIC 8), APHO 91 (SAIC 112),and APHO 92 (SAIC 117), Former Marine Corps Air Station, ElToro, California” dated 04/17/2003. DTSC concurred with no furtheraction on 04/20/2004. RWQCB concurred with no further action on08/14/2003. No further action is required.TAA 5A5< 90-DayAccumulation PointSummary Report,TAA 5A 07/17/2002byITDTSC 03/04/2003 TAA 5A, also known as SWMU/AOC 25, was identified during a1991 visual site inspection. Lightstains were observed on theconcrete surrounding the TAA. However, during subsequentinspections from 1993 through 2000, nostains or significant crackswere observed. No visible signsof a release were noted during the2002 VSI conducted in support of the EBS. NFA was recommendedand DTSC concurred with NFA. No further action required.TAA 5B5< 90-DayAccumulation PointClosure Report,TAA 5B 11/24/2008byBRAC PMO WestRWQCB 11/24/2008DTSC 04/08/2009TAA 5B, also known as SWMU/AOC26, was identified as stainedsoil during a site visit conducted in support of the RFA. Subsequentsoil sampling identified TPH in the soils at levels below residentialPRGs. The removal of contaminated soils was conducted in May2008. A closure report was distributed on 11/24/2008recommending NFA. RWQCB concurred with NFA in a letter dated11/24/2008, and DTSC concurred with NFA in a letter dated04/08/2009.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 2 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesUST 6B6 500-Gallon Fuel OilTankUST RemovalReport, UST 6B01/30/1997byGeofonOCHCA 03/27/1997 UST 6B and approximately 45 feet of associated piping wereremoved on 11/07/1996 under OCHCA plan check 96-163. Siteclosed by OCHCA in a letter dated 03/27/1997. No further actionrequired.UST 1016168-Gallon DieselTankFinal SummaryReport, Former USTSite 10108/21/2003byCDM FederalPrograms Corp.RWQCB 10/20/2003DTSC 09/17/2003Former UST Site 101 is located at the former location of Building101, a former standby power building for Building 6. UST 101, a168-gallon tank, was used to store diesel fuel for the standbygenerator. Building 101 was demolished in 1969. The approximatelocation of the former tank site was estimated from information onhistorical facility plans. Exploratory trenches were excavated at theformer tank site in November 2002 and no evidence of a former tankwas observed. It is possible that UST 101 was removed duringdemolition of Building 101. Soil samples were collected from twoborings located at the former tank location in May 2003, and theresults were presented in a Summary Report that was submitted tothe RWQCB and DTSC. Both RWQCB and DTSC concurred withNFA. No further action is required.UST 850A 850 5,000-Gallon JP-5TankTank Removal &Site Closure Report,UST 850A, UST850B, and OWS850E05/30/2008byBRAC PMO WestRWQCB 08/28/2008 UST 850A (SWMU 288), UST 850B (SWMU 289), OWS 850E, andapproximately 400 feet of associated piping were removed inFebruary 2000. Approximately 912 tons of fuel-impacted soils wereexcavated and removed from the former site of UST 850A, UST850B, and OWS 850E during January and February 2001. During2003 and 2004, soil samples were collected from borings and a siteassessment report was submitted in 2004. Site closed by RWQCBin a letter dated 08/28/2008. No further action required.UST 850B 850 5,000-Gallon JP-5TankTank Removal &Site Closure Report,UST 850A, UST850B, and OWS850E05/30/2008byBRAC PMO WestRWQCB 08/28/2008 UST 850A (SWMU 288), UST 850B (SWMU 289), OWS 850E, andapproximately 400 feet of associated piping were removed inFebruary 2000. Approximately 912 tons of fuel-impacted soils wereexcavated and removed from the former site of UST 850A, UST850B, and OWS 850E during January and February 2001. During2003 and 2004, soil samples were collected from borings and a siteassessment report was submitted in 2004. Site closed by RWQCBin a letter dated 08/28/2008. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 3 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesOWS 850E 850 1,500-Gallon JP-5/water storage tankTank Removal &Site Closure Report,UST 850A, UST850B, and OWS850E05/30/2008byBRAC PMO WestRWQCB 08/28/2008 OWS 850E, UST 850A, and UST 850B were removed in February2000. Approximately 912 tons of fuel-impacted soils were excavatedand removed during January and February 2001. During 2003 and2004, soil samples were collected from borings and a siteassessment report was submitted in 2004. Site closed by RWQCBin a letter dated 08/28/2008. No further action required.MSC B1850Inactive Burn Pit Site AssessmentReport, FirefighterTraining Burn PitMSC B1 02/11/2000by OHM andAddendum to SiteAssessment Report,MSC B1 02/15/2001by OHMRWQCB 10/11/2001 MSC B1, an inactive circularconcrete burn pit structure, was locatednear IRP Site 16. Initial field sampling was conducted in December1999, and additional sampling was conducted following the receiptof RWQCB comments dated 10/20/2000. Results were presented ina Site Assessment Report and an Addendum to the SiteAssessment Report. The concrete structure was demolished duringOctober and November 2000. Site closed by RWQCB in a letterdated 10/11/2000. No further action is required.MSC B2850Inactive Burn Pit Summary Report,Former FirefighterTraining Burn PitMSC B2 12/29/1999by OHMRWQCB 10/10/2000 MSC B2 was a rectangular-shaped concrete lined structure locatednear MSC B1 that was reportedly used only once. Field samplingwas conducted in 1999; the results were presented in a SummaryReport dated 1999, and the RWQCB concurred with no furtheraction on 10/10/2000. The concrete structure was demolishedduring October and November 2000. Site closed by RWQCB in aletter dated 10/10/2000. No further action is required.PCB T16Pad mountedtransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatesoriginal transformer replaced with a non-PCB transformer; noevidence of release. No PCB releases identified through the recordssearch or VSIs conducted for the 2003 EBS.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 4 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesIRP Site 16 NA Crash Crew Pit No.2 (OU-3)Associatedgroundwater plumeand buffer zoneN/A DTSC10/18/2007U.S. EPA04/10/2007RWQCB 2007Site was operational from 1972 to 1985. JP-5, AVGAS, hydraulicfluid, crankcase oil, white phosphorus, magnesium phosphate, andnapalm were burned in unlined pits for fire training.Final RI (BNI 1997), FS (BNI 2000 and BNI 2002), PP, and ROD(DON 2003) completed. Pilot study conducted during 2000-2001.Monitored natural attenuation has been implemented as a remedyfor ground water. A final Operating Properly and Successfully(OPS) Report was completed in September 2007. Regulatoryconcurrence with the conclusions of the OPS report has beenobtained.IRP Site 25 NA Major Drainages(OU-2A)Draft Final Recordof Decision, OU 2A& 3A, No ActionSites09/30/1997byNAVFAC SWU.S. EPA, DTSC,RWQCB09/30/1997IRP Site 25 consisted of fourdrainage channels that flow throughor adjacent to the Station and receive storm water discharges fromthe Station. Concentrations ofmetals, pesticides, and petroleumproducts below levels requiring response actions were detected atthe site. ROD that selected no action as the remedy was signed inSeptember 1997.Carve-Out I-KUST 6868500-Gallon DieselTankSummary Report,FormerUndergroundStorage Tank Site68 09/04/1997byNAVFAC SWRWQCB 10/03/1997 Removal completed on 02/06/1992. Site closed by RWQCB in aletter dated 10/03/97. No further action required.UST 7070500-Gallon DieselTankClosure Report,USTs 70 and 7204/16/2008byECSRWQCB 07/15/2008 Tank removed during construction of Building 718. Closure reportsubmitted to RWQCB in 2001. Site closed by RWQCB in a letterdated 07/15/2008. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 5 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesUST 7272500-Gallon DieselTankClosure Report,USTs 70 and 7204/16/2008byECSRWQCB 07/15/2008 Tank removed during construction of Building 718. Closure reportsubmitted to RWQCB in 2001. Site closed by RWQCB in a letterdated 07/15/2008. No further action required.UST 718718 4,000-Gallon FuelOil TankTank Removal FieldActivities, Tank 71808/05/1993OCHCA 12/09/1996 Tank removed in 1993. Site closed by OCHCA in a letter dated12/09/1996. No further action required.Carve-Out I-NAST 1155-Gallon DieselTankTank ClosureReport,AbovegroundStorage Tank (AST)1 12/18/2000by ITRWQCB 01/17/2001 Tank operated from mid-1940s to 1999; Tank was used as a fueltank for an emergency generator. Tank has been removed. Noreleases identified. Site closed by RWQCB in a letter dated01/17/2001. No further action required.UST 1A1500-Gallon DieselTankSite AssessmentReport, FormerUndergroundStorage Tank, Site1A 09/11/1996by OHMRWQCB 10/02/1996 Removal completed on 02/06/1992. Site closed by RWQCB in aletter dated 10/02/1996. No further action required.UST 1B1500-Gallon DieselTankSummary Report,UndergroundStorage Tank (UST)1B 08/05/2008by NAVFAC SWRWQCB 10/10/2008 UST 1B and associated fill pipe were removed on 11/27/1999.Remedial actions were completed in June 2008. Site closed byRWQCB in a letter dated 10/10/2008. No further action required.Carve-Out I-OUST 98A981,500-Gallon FuelOil TankSummary Report,UndergroundStorage Tank Site98ARWQCB 10/06/2008 The UST was demolished in-place on 10/30/1997. Site closed byRWQCB in a letter dated 10/06/2008. No further action required.Carve-Out I-SFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 6 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesUST 147147 280 Gallon DieselTankInformationPackage, FormerUST Site 14708/18/2003byNAVFAC EFDSouthwestRWQCB 11/24/2003 Fuel tank for former booster pump for water supply system. Pumpwas located inside Building 147. Exploratory trenching in November2002 identified a former tank excavation that had been filled withpea gravel. RWQCB concurred with NFA in a letter dated11/24/2003. No further action required.UST 273273 300 Gallon Fuel OilTankSite AssessmentReport, FormerUndergroundStorage Tank Site273 09/09/1996byOHMRWQCB 10/3/1996 Removal completed on 02/28/1994. Site closed by RWQCB in aletter dated 10/13/1996. No further action required.UST 273B 273 1,400 Gallon FuelOilTankSummary Report,FormerUndergroundStorage Tank Site273B 10/22/2008byBRAC PMO WestRWQCB 12/12/2008 Cylindrical concrete storagetank used for storage of fuel oil.Removal completed on 08/26/2004. Verification sampling wasconducted in 2004 and 2005. Contaminated soil was removed on08/12/2008-08/13/2008. Closure report was distributed on10/22/2008. Site closed by RWQCB in a letter dated 12/12/2008.PCB T36 147Pad mountedtransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatestransformer has been replaced; newtransformer appears to be ingood condition, with no indication of PCBs; no evidence of releaseobserved. No PCB releases identified through the records search orVSIs conducted for the 2003 EBS.PCB T37 147Pad mountedtransformerFinal EBS(09/12/2003)by Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatestransformer has been replaced; new transformer appears to be ingood condition, with no indication of PCBs; no evidence of releaseobserved. No PCB releases identified through the records search orVSIs conducted for the 2003 EBS.PCB T38 147Pad mountedtransformerFinal EBS(09/12/2003)by Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatestransformer has been replaced; newtransformer appears to be ingood condition, with no indication of PCBs; no evidence of releaseobserved. No PCB releases identified through the records search orVSIs conducted for the 2003 EBS.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 7 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesCarve-Out II-ERFA 14606Drop Tank FuelStorage AreaSummary Report,Site Verification atFormer Aircraft DropTank Fuel StorageArea near Building606, SWMUNumber 1411/09/1999byNAVFAC SWRWQCB 03/31/2000 RWQCB concurred with NFA in a letter dated 03/31/2000. No furtheraction required.RFA 43139 Drum Storage Area Closure Report,Solid WasteManagement Unit43 05/09/2006byCDM FederalPrograms Corp.DTSC 06/05/2006 Site also identified as SWMU 43. RFA site 43 was associated withBuilding 139, and received site closure concurrence from DTSC in2006.RFA 150 605 (on tarmac) Aircraft Wash Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 Aircraft wash area situatedon tarmac. Site is inactive. OWS 605C isassociated with this wash rack. NFA status identified in Final RFAReport (JEG 1993) and DTSC concurred with NFA recommendationin a letter dated 07/23/1996. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 8 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesRFA 152 606 (on tarmac) Aircraft Wash Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report 5/1996by Bechtel NationalDTSC 07/23/1996 Aircraft wash area on the tarmac outside of Building 606(Maintenance Hangar). Site is inactive. NFA status identified in FinalRFA Report (JEG 1993) and DTSC concurred with NFArecommendation in a letter dated 07/23/1996. No further actionrequired.RFA 267605Drop Tank FuelStorage AreaFinal RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 NFA status identified inFinal RFA Report (JEG 1993) and regulatoryconcurrence obtained. Nofurther action required.TAA 115 115/914< 90-DayAccumulation PointClosure Report,Former TemporaryAccumulation AreaSite 115 07/20/2006ByBrown and CaldwellDTSC 12/28/2006 Site also identified as SWMU/AOC 39. Sampling results belowresidential PRGs. No visible signsof release noted during 2002 VSIconducted in support of the EBS. NFA recommended based on RFAsampling results and the 2002 VSI. DTSC concurrend with NFA. Nofurther action required.TAA 605 605/912< 90-DayAccumulation PointClosure Report,TAA 605byShawEnvironmental Inc.DTSC 09/13/2004 SWMU/AOC 149. Sampling results below residential PRGs. NFAwas recommended and DTSC concurred with NFA. No furtheraction required.TAA 606 606/913< 90-DayAccumulation PointClosure Report,TAA 605byShawEnvironmental Inc.DTSC 09/16/2004 Site also identified as SWMU/AOC 255. Sampling results belowresidential PRGs. NFA was recommended and DTSC concurredwith NFA. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 9 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesAPHO 37 115 Stains and Wet Soil Summary Report,APHO 37, PossibleStain 08/20/1999byNAVFAC SWDTSC 09/09/1999U.S. EPA11/04/1999RWQCB 03/31/2000Records reviews, site visits, and comparison of LOCs in the vicinityof the site identified no evidence of releases. No evidence ofstaining or a release identified during 2002 VSI conducted in supportof the EBS. Regulatory agency concurrence of NFArecommendation has been obtained. No further action required.APHO 99 139Soil StainsInformationPackage, APHO 87,90, 98, 99, 100, and109 05/2003byNAVFAC SWRWQCB 08/14/2003 Identified on a 1967 photograph. The anomaly was recorded asthree parallel lines on the westerly side of Facility 139. Facility 139was a public works shop located east of former Tank Farm 4. Thearea of the anomaly is within the former tank farm boundaries. Allfuel tanks were removed and the site was closed in 1996. Based onthe location and the fact that all sites within the former tank farm areclosed, no further action was recommended for APHO 99. Based ona VSI conducted in June 2003, RWQCB concurred with no furtheraction in a letter dated 08/14/2003.APHO 110 121LiquidInformationPackage, APHO110 04/28/2003byNAVFAC SWRWQCB 08/14/2003 Identified on a 1974 photograph. The facility associated with thisAPHO is a fire station and the liquid flowing from the facility isprobably water used in routine operations at the fire station. Basedon a VSI conducted in June 2003, RWQCB concurred with nofurther action in a letter dated 08/14/2003.APHO 119 Edge of AircraftApron between605 and 606Stains InformationPackage, APHO119 04/22/2003 byNAVFAC SWandNFA Determinationfor APHOs (site visitby DTSC on06/13/2003)DTSC 06/25/2003RWQCB 08/14/2003Identified on a 1983 photograph. The APHO area was visuallyinspected in April 2003. No evidence of staining was found. An inletfor the storm drain was noted in that location. Two TAAs (TAA 605[SWMU 149] and TAA 606 [SWMU 255]) are between Facility 605and 606. NFA has been obtained for these TAAs (see above).Based on a Visual Site Inspection conducted in June 2003, DTSCand RWQCB concurred with recommendation of NFA for APHO119. No further action required.UST 115A 115 650-Gallon Fuel OilTankSite AssessmentReport, Former USTSite 115A11/13/1996byOHMRWQCB 12/16/1996 Removal completed on 02/28/94. Site closed by RWQCB in a letterdated 12/16/1996. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 10 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesUST 115B 115 560-Gallon Fuel OilTankSite AssessmentReport, UST Site115B 12/10/1997byOHMRWQCB 01/07/1998 Removal completed on 06/17/1993. Site closed by RWQCB in aletter dated 01/07/1998. No further action required.UST 116116 500-Gallon DieselTankSite AssessmentReport, Former USTSite 116 01/12/1999byOHMRWQCB 08/31/2000 Tank has been removed. Site closed by RWQCB in a letter dated08/31/2000. No further action required.UST 117117 500-Gallon DieselTankSite AssessmentReport, UST Site11712/10/1997RWQCB 01/07/1998 Tank has been removed. Site closed by RWQCB in a letter dated01/07/1998. No further action required.UST 605A 605 1,700-Gallon DieselTankTechnicalMemorandum,FormerUndergroundStorage Tank Sites114A, 295, 296,435, 455, 605A, and606A 03/21/1997byNAVFAC SWRWQCB 04/11/1997 Removal completed 10/08/1991. Site closed by RWQCB in a letterdated 04/11/1997. No further action required.UST 605B 605 500-Gallon DieselTankTank Removal FieldActivities, Tank605B & OWS 605C09/09/1999OCHCA 12/09/1999 Removal completed on 09/09/1999. No evidence of a release wasidentified. Site closed by OCHCA in a letter dated 12/09/1999. Nofurther action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 11 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesUST 606A 606 1,700-Gallon DieselTankTechnicalMemorandum,FormerUndergroundStorage Tank Sites114A, 295, 296,435, 455, 605A, and606A 03/21/1997byNAVFAC SWRWQCB 04/11/1997 Tank has been removed. Site closed by RWQCB in a letter dated04/11/1997. No further action required.UST 643A 643 185-Gallon WasteOil TankTank Removal andSite Closure Report,UST 643A andOWS 643B06/12/1997byOHMOCHCA 07/11/1997 Site also identified as SWMU/AOC 162. Removal completed on03/06/1997. Site closed by OCHCA in a letter dated 07/11/1997. Nofurther action required.OWS 605C 605500-GallonOil/WaterSeparatorTank Removal FieldActivities, Tank605B & OWS 605C09/09/1999OCHCA 12/09/1999 Site also identified as SWMU/AOC 151. OWS was installed in 1984.OWS was removed in 1997. OWS associated with UST 605B. Sitewas investigated; the RFA recommended leak test/inspection ofOWS. No significant soil contamination identified at this site. Siteclosed by OCHCA in a letter dated 12/09/1999. No further actionrequired.OWS 643B 643100-GallonOil/WaterSeparatorTank Removal andSite Closure Report,UST 643A andOWS 643B06/12/1997byOHMOCHCA 07/11/1997 Site also identified as SWMU/AOC 163. OWS was installed in 1982.OWS was removed in 1997. OWS was associated with UST 643A.Site was investigated, and no significant soil contamination wasidentified at this site based on the results of soil sampling. Siteclosed by OCHCA in a letter dated 07/11/1997. No further actionrequired.OWS 892 8921,375-GallonOil/WaterSeparatorSite AssessmentReport, OWS Site892 07/09/1999byOHMRWQCB 07/07/2000 OWS installation date unknown. OWS closed in place. OWS wasnot associated with a UST. Site was investigated. Site closed byRWQCB in a letter dated 07/07/2000. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 12 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesPRL 605605MaintenanceHangarSummary Report forGroup III PRLs SIby Earth Tech,October 2005 (EarthTech 2005b)Summary Report forGroup VI PRLs SIby Earth Tech,October 2008 (EarthTech 2008a)U.S. EPA11/03/2005DTSC 11/26/2008Records review, VSIs, and soil sampling were conducted for PRL605 from 2002 to 2008, to evaluate whether the release ofhazardous substances or pollutants into the environment hasoccurred. Based on the results of these investigations, NFI wasrecommended for this PRL in the Summary Report for Group III(Earth Tech 2005) and Group VI PRLs (Earth Tech 2008). U.S. EPAconcurred with NFI recommendation in a letter dated 11/03/2005.DTSC concurrence on NFI was received in November 2008.PRL 606606MaintenanceHangarSummary Report forGroup III PRLs SIby Earth Tech,October 2005 (EarthTech 2005b)Summary Report forGroup VI PRLs SIby Earth Tech,October 2008 (EarthTech 2008a)U.S. EPA11/03/2005DTSC 11/26/2008Records review, VSIs, and soil sampling were conducted for PRL606 from 2002 to 2008, to evaluate whether the release ofhazardous substances or pollutants into the environment hasoccurred. Based on the results of these investigations, NFI wasrecommended for this PRL in Summary Report for Group III (EarthTech 2005) and Group VI PRLs (Earth Tech 2008). U.S. EPAconcurred with NFI recommendation in a letter dated 11/03/2005.DTSC concurrence on NFI was received in November 2008.PCB T15 115Pad-MountedTransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatedno evidence of release. No PCBreleases identified through therecords search or VSIs conducted for the 2003 EBS.PCB T16 118Pole-MountedTransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatedoriginal transformer replaced with a non-PCB transformer; noevidence of release. No PCB releases identified through the recordssearch or VSIs conducted for the 2003 EBS.PCB T81 605Pad-MountedTransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatedno evidence of release. No PCBreleases identified through therecords search or VSIs conducted for the 2003 EBS.PCB T82 606Pad-MountedTransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Replaced with a non-PCB transformer. 1994 field survey indicatedno evidence of release. No PCBreleases identified through therecords search or VSIs conducted for the 2003 EBS.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 13 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesPCB 643643 3 oil-filled cutouts Final EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/20033 oil-filled cutouts with less than 1 ppm PCB located at the northernportion of the building.PCB 892892 3 oil-filled cutouts Final EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/20033 oil-filled cutouts with less than 0.005 ppm PCB, noted to beleaking during 2003 inspection.Carve-Out II-LIRP Site 25 NAMajor Drainages(OU-2A)Draft Final Recordof Decision, OU 2A& 3A, No ActionSites09/30/1997U.S. EPA, DTSC,RWQCB09/30/1997IRP Site 25 consisted of FourDrainage channels that flow throughor adjacent to the Station and receive storm water discharges fromthe Station. Concentrations ofmetals, pesticides, and petroleumproducts below levels requiring response actions were detected atthe site. ROD was signed in September 1997.PRLRunwayInfield AreaNorthwestQuadrantStation’s Runways Summary Report forGroup VI PRLs SIby Earth Tech,October 2008 (EarthTech 2008a)U.S. EPA11/20/2008DTSC 11/26/2008This PRL was identified becausewaste petroleum products mayhave been applied as dust control agents along the unpavedshoulders of the installations runways and taxiways.Soil sampling conducted in 2003 and 2004 indicated the presence ofPAHs exceeding residential PRGs in samples collected along thelength of the runway. Surface soil extending 50 feet from the edgeof the runway was removed during runway demolition and gradingoperations performed by the developer, pursuant to the ProjectEnvironmental Review Form (PERF) completed for this project(11/01/2006). Therefore, soil sampling was conducted in May 2008at this PRL to characterize the current distribution of PAHs aftergrading operations. Based on the results of this soil sampling, NFIwas recommended for this PRL in the Summary Report for Group VIPRLs, and regulatory concurrence was obtained.Carve-Out II-MRFA 178673 Vehicle Wash Rack Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 Inactive vehicle wash rack.OWS 673A is associated with this washrack. NFA status identified in Final RFA Report (JEG 1993) andDTSC concurred in a letter dated 07/23/1996. No further actionrequired.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 14 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesRFA 181673 Land/Farming Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 NFA status identified inFinal RFA Report (JEG 1993) and regulatoryconcurrence obtained. Nofurther action required.RFA 182673 Drum Storage Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 Not located during RFA; no releases identified. Photographs of drumstorage areas were taken during a site visit by the Department ofHealth Services (DHS) on 10/29/1980.NFA status identified in FinalRFA Report (JEG 1993) and regulatory concurrence obtained. Nofurther action required.RFA 183673 Drum Storage Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 Not located during RFA; noreleases identified. Photographs of drumstorage areas were taken during a site visit by the DHS on10/29/1980. NFA status identified in Final RFA Report (JEG 1993)and regulatory concurrence obtained. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 15 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesRFA 184673 Drum Storage Area Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 Not located during RFA; noreleases identified. Photographs of drumstorage areas were taken during a site visit by the DHS on10/29/1980. NFA status identified in Final RFA Report (JEG 1993)and regulatory concurrence obtained. No further action required.RFA 185673 Drum Storage Area InformationPackage, SolidWaste ManagementUnit 185 12/07/2005byNavy BRAC PMOWestDTSC 07/31/2006 RFA site 185 was associated with Building 673, and received siteclosure concurrence in 2006.RFA 264 DRMO Yard No. 3 DRMO Yard No. 3 Final RCRA FacilityAssessment (RFA)Report July 1993 byJacobs EngineeringGroupandFinal Addendum toRFA Report May1996 by BechtelNationalDTSC 07/23/1996 NFA status identified inFinal RFA Report (JEG 1993) and regulatoryconcurrence obtained. Nofurther action required.TAA 673673< 90-DayAccumulation PointClosure Report,Former TemporaryAccumulation Area673 05/21/2003byShawEnvironmentalDTSC 09/24/2004 Site also identified as SWMU/AOC 186. DTSC concurred with NFAin a letter dated 09/24/2004. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 16 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesTAA 772772< 90-DayAccumulation PointClosure Report,TAA 77206/26/2003byOHMDTSC 11/07/2003 Site also identified as SWMU/AOC 225. Soil sampling identifiedcontaminants between residential and industrial PRGs. Due toresults of risk screening, soil management recommended. DTSCconcurred with NFA in a letter dated 11/07/2003. No further actionrequired.APHO 20 DRMO Yard No. 3 Disturbed Groundand ExcavationSummary Report,APHO 20 & APHO21 11/30/1999byNAVFAC SWDTSC 03/03/2000 Regulatory agency concurrence of NFA recommendation has beenobtained. No further action required.APHO 27 DRMO Yard No. 3 Stains and Wet Soil Summary Report,APHOs 23, 27, 58(Area 2) 03/07/2000byNAVFAC SWRWQCB 10/18/2000 No evidence of stainingor a release identified during 2002 VSIconducted in support of the EBS. Sampling results below residentialPRGs. Regulatory agency concurrence of NFA recommendation hasbeen obtained. No further action required.APHO 38 1789 Disturbed Groundand ExcavationSummary Report,APHO 3812/19/2003 by ShawEnvironmentalandRadiologicalRelease Report,IRP Site 1, DRMOYard 3, NBC, APHO38, Paved Areasouth of Building295 04/12/2007 byWeston SolutionsDTSC 04/06/2005CDPH 08/20/2007APHO 38 was associated with Building 1789, and received siteclosure concurrence from DTSCin 2005 pertaining to release ofnon-radiological constituents.Radiological investigations were conducted at APHO 38 and resultspresented in a radiological release report ((Weston 2007). Based onthe results of these investigations, CDPH concurred with therecommendation for unrestricted release of APHO 38 in a letterdated 08/20/2007. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 17 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesAPHO 46 Golf Course –Hole No. 5;overlaps IRP Site5Disturbed Groundand ExcavationSummary Report,APHO 46 January2005 by Earth TechandRadiologicalRelease Report,IRP Sites 3 and 5(including APHO46), AA 3, andBuilding 244December 2006by Weston SolutionsDTSC 05/17/2004U.S. EPA03/08/2004RWQCB 05/01/2003CDPH 05/19/2006The extent of the anomaly has been investigated by subsurfacegeophysical survey, which identified only a relatively small area ofsurficial debris. Surface debris was also observed during 2002 VSIconducted in support of the EBS. Characterization of debris pilesand associated areas was conducted as part of the pre-designinvestigation for IRP Site 5. Based on the results of theinvestigations, NFA was recommended in the Summary Report.DTSC concurred with no further investigation pertaining to nonradiological constituents in a letter dated 02/26/2001.Radiological investigations at APHO 46 were conducted inconjunction with IRP Site 5 and results presented in a radiologicalrelease report (Weston 2006). Based on the results of theseinvestigations, CDPH concurred with the recommendation forunrestricted release of APHO 46 in a letter dated 05/19/2006. Nofurther action required.APHO 51 673 Stains and Wet Soil Summary Report,APHO 5102/24/2000byNAVFAC SWDTSC 06/14/2000RWQCB 10/18/2000No evidence of staining or a release identified during 2002 VSIconducted in support of the EBS. Regulatory agency concurrence ofNFA recommendation has been obtained. No further actionrequired.UST 442442 110-Gallon Fuel OilTankTank Removal FieldActivities05/27/1993OCHCA 12/09/1996 Tank removed in 1993. Site closed by OCHCA in a letter dated12/09/1996. No further action required.OWS 673A 673895-GallonOil/WaterSeparatorSite AssessmentReport, OWS 673A04/12/1999byNAVFAC SWRWQCB 01/17/2001 Site also identified as SWMU/AOC 179. OWS installed in 1982.OWS closed in place. OWS was associated with UST 673B. Sitewas investigated and NFA was recommended by the RFA based onthe results of soil sampling. Site closed by RWQCB in a letter dated01/17/2001. No further action required.OWS 832 832500-GallonOil/WaterSeparatorSummary Report,APHO 3812/19/2003byShawEnvironmentalDTSC 04/20/2005 OWS identified during geophysical survey of APHO 38 on03/24/2003. OWS was removed and sampling conducted in May2003. Site closure was received in 2005.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 18 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesRADDRMODRMO Yard 3(RFA 264)Outside storagearea used byDRMO to storescrap and excessmaterials andequipment awaitingdisposition. Areahad been inoperation since the1950s.RadiologicalRelease Report,IRP Site 1, DRMOYard 3, NBC, APHO38, Paved Areasouth of Building295 04/12/2007byWeston SolutionsDTSC 07/23/1996CDPH 08/20/2007The yard was restricted from receiving and/or storing equipment andcomponents containing radioactive material. There were no officialrecords or direct knowledge ofradiological materials being handledby the El Toro DRMO. However, during an employee interview, itwas stated that, “Marines couldhave stored small quantities ofradium painted parts and gauges at the storage yard, since it is aregional storage yard.” No releases were identified at this site. Sitehas been determined to require nofurther action. Concurrence onthe no further action determination was obtained from DTSC in aletter dated 07/23/1996. During the year 2000, a stationwideHistorical Radiological Assessment (HRA) was conducted. The HRArecommended further radiological investigation for the DRMO Yard3 prior to final disposition. A radiological survey was completed in2001 and the results were presented in a radiological release report(Weston 2007). CDPH concurred with recommendation forunrestricted release in a letter dated 08/20/2007.RAD NBC NBC Area(Buildings 787,1789, and 1803and surfaceimpoundments[APHO-38])Buildings andsurfaceimpoundments aresituated north ofthe intersection ofEast Marine Wayand El ToroBoulevard.Buildings supportedtraining ofpersonnel forreadiness fornuclear, biological,and/or chemicalweapons attack.RadiologicalRelease Report,IRP Site 1, DRMOYard No. 3, NBC,APHO 38, PavedArea south ofBuilding 29504/12/2007byWeston SolutionsCDPH 08/20/2007 Building 1789 contained a 4 foot by 6 foot concrete structure insidefor storing non-licensed, radioactivesources. Building 787 and 1803housed NBC training facilities. These buildings were utilized asoffices, training/instruction areas, and training group storage areas.It is not known whether impoundments at the site were associatedwith NBC training operations. During the year 2000, a stationwideHRA was conducted. The HRA recommended further radiologicalinvestigation for the NBC Areaprior to final disposition. Aradiological survey was completed in 2001. CDPH concurred withrecommendation for unrestricted release in a letter dated08/20/2007.MSC D1 DRMO Yard No. 3 Desert StormSupply StorageAreaSite AssessmentReport, DesertStorm MaterialStaging Area, MSCD1 03/01/2000byOHMRWQCB 09/28/2000 Desert Storm supply storage area near DRMO Yard No. 3. Site isinactive. NFA concurrence obtained from RWQCB in a letter dated09/28/2000.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 19 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesMSC 673T3 673RCRA StorageFacilityFinal ClosureCertification Report,Hazardous WasteContainer StorageArea Nov 1995byOHMDTSC 03/08/1996 Former RCRA-permitted facility. Site is inactive. NFA concurrenceobtained from DTSC in a letter dated 03/08/1996. No further actionrequired.PRL 354354Former SkeetRangeSummary Report forGroup VI PRLs SIby Earth Tech,October 2008 (EarthTech 2008a)U.S. EPA11/20/2008DTSC 2009bSite is a former skeet range, utilized between 1943 and 1948, thatwas situated in the current location of the golf course. Recordsreview, VSIs, and soil sampling were conducted for PRL 354 from2002 to 2008, to evaluate whether a release of hazardoussubstances or pollutants into the environment has occurred. Basedon the results of these investigations, NFI was recommended for thisPRL in the Summary Report for Group VI PRLs. U.S. EPAconcurrence on NFI was received on 11/20/2008; DTSCconcurrence was received on 09/25/2009.Carve-Out II-RRFA 244457PCB Spill AreaNear Building 457Closure Report,Solid WasteManagement Unit244 10/28/1998byOHMDTSC 12/17/1998 Site was also identified as SWMU/AOC 244. Removal of impactedsoils was completed in 1997. All required response actions havebeen completed. DTSC concurred with NFA in a letter dated12/17/1998. No further action required.APHO 42 457 Stains and Wet Soil Summary Report,APHO 4212/15/1999byNAVFAC SWDTSC 03/27/2000RWQCB 10/18/2000Records reviews, site visits, and comparison of LOCs in the vicinityof the site identified no evidence of releases. No evidence ofstaining or a release identified during 2002 VSI conducted in supportof the EBS. Regulatory agency concurrence of NFArecommendation has been obtained. No further action required.UST 457457 2,000-Gallon DieselTankTank Removal FieldActivities05/27/1993OCHCA 12/09/1996 Tank removed in 1993. Site closed by OCHCA in a letter dated12/09/1996. No further action required.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 4Page 20 of 20Table 4: Locations of ConcernLOC IDBuildingNumber/LocationDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesSRU 3C457Dental Clinic Summary Report forGroup IV PRLs byEarth Tech (March2008)DTSC 08/21/2008U.S. EPA04/17/2008Site identified as a former SRU at a photography laboratory in adental clinic (SRU 3C). Site was recommended for further evaluationfor potential discharges of contaminants to the building drainagesystem. SRU 3C was investigated as part of PRL 457 (see Table 3).The investigations included records review, VSI, and soil sampling.Based on the results of these investigations, no further investigationwas recommended in Summary Report for Group IV PRLs andregulatory concurrence was obtained.PCB T74 457Pad-MountedTransformerFinal EBS(09/12/2003)By Earth TechDTSC 09/25/2003U.S. EPA09/25/2003Site was also identified as SWMU/AOC 290. Replaced with a nonPCB transformer. A response actionwas required for releases oftransformer oil containing PCBs at Building 457 (SWMU/AOC 244).Shallow soil samples that were collected in the area affected by thePCB release identified PCBs in one of the seven samples collected.The transformer was replaced and impacted soil was removed. Theresponse action was completed and the LOC was closed inDecember 1998. No evidence of a release was observed during theVSIs conducted for the 2003 EBS. All required responses havebeen completed. No further action required.AOC = Area of ConcernAPHO = Aerial Photograph AnomalyAST = aboveground storage tankAVGAS = aviation gasolineBNI = Bechtel International, Inc.CDPH = California Department of Public HealthDHS = Department of Health ServicesDON = Department of the NavyDRMO = Defense Reutilization and Marketing OfficeDTSC = Department of Toxic Substances ControlEBS = Environmental Baseline SurveyFS = Feasibility StudyHRA = Historical Radiological AssessmentID = IdentificationIRP = Installation Restoration ProgramJEG = Jacobs Engineering GroupJP-5 = Jet Propulsion Fuel, Grade 5< = less thanLOC = Location of ConcernMCAS = Marine Corps Air StationMSC = miscellaneousNA = not applicableN/A = not availableNAVFAC SW = Naval Facilities Engineering Command,SouthwestNBC = Nuclear, Biological, ChemicalNFA = No Further ActionOCHCA = Orange County Health Care AgencyOHM = OHM Remediation Services Inc.OPS = Operating Properly and SuccessfullyOU = Operable UnitOWS = oil/water separatorPCB = polychlorinated biphenylPP = Proposed Planppm = part per millionPRG = preliminary remediation goalRAD = radiologicalRCRA = Resource Conservation and Recovery ActRI = Remedial InvestigationRFA = RCRA Facility AssessmentROD = Record of DecisionRWQCB = Regional Water Quality Control BoardSAIC = Science Applications InternationalCorporationSRU = Silver Recovery UnitSWMU = Solid Waste Management UnitTAA = Temporary Accumulation AreaUST = underground storage tankU.S. EPA = United States EnvironmentalProtection AgencyVSI = visual site inspectionFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 5Page 1 of 1Table 5: Locations of Concern With Ongoing Petroleum Corrective ActionsLOC IDDescriptionClosure ReportTitle/DateNFA LetterAgency/DateNotesCarve-Out I-FMSC B3Inactive Burn PitPendingPending MSC B3 was the main fire fighting crash crew pit, and wasapproximately 67 feet in diameter, and two to three feet deep.During training exercises, this pit was filled with water and coveredwith mixtures of JP-5, AVGAS, crank case oil, and other combustiblefluids. MSC B3 is addressed as a petroleum corrective action site.AVGAS = aviation gasolineID = IdentificationJP-5 = jet propulsion fuel, grade 5MSC = MiscellaneousNFA = No further actionFinal Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 6Page 1 of 2Table 6: Summary of Asbestos SurveysBuildingNumberDescriptionSquareFeetYear BuiltHistorical Asbestos SurveyInformationCommentsCarve-Out I-N1 Squadron Headquarters TelephoneExchange15,768 1943 CABACO/Tait (06/15/1999): Stucco Non-FAD ACM found.Carve-Out II-E115 Aircraft Maintenance Hangar25,414 1966 IT Corp (1989): Floor tile, transite, pipeinsulation. CABACO/Tait (06/15/1999):Stucco, pipe elbows, floor tile & mastic,window putty, boiler flue, exterior mastic,wall panels, drywall joint compoundNon-FAD ACM found.118 Aircraft Maintenance Hangar6,240 1943 IT Corp (1989): No ACM FoundCABACO/Tait (07/22/1999): StuccoNon-FAD ACM found; no interior ACMobserved.119 Aircraft Maintenance Hangar6,240 1943 IT Corp (1989): No ACM FoundCABACO/Tait (06/15/1999): StuccoNon-FAD ACM found; no interior ACMobserved.139 3rd Marine Air Wing Embarkation area 6,240 1943 IT Corp (1989): No ACM FoundCABACO/Tait (10/15/1999): StuccoNon-FAD ACM found; no interior ACMobserved.605 Maintenance Hangar23,598 1965 e&e (1991): Floor tile, roofing, pipe fittinginsulation, damper gaskets, carpet.CABACO/Tait (06/15/1999): Floor tile &mastic, window putty, pipe elbowsFAD ACM found.606 Maintenance Hangar23,598 1965 e&e (1991): Floor tile, roofing, pipe fittinginsulation, damper gaskets, carpet.CABACO/Tait (06/15/1999): Floor tile &mastic, window putty, pipe elbowsFAD ACM found.639 Electric Power Plant Building144 1969 e&e (1991): No ACM FoundNo ACM found.640 Electric Power Plant Building144 1969 e&e (1991): No ACM FoundNo ACM found.641 Electric Power Plant Building144 1969 e&e (1991): No ACM FoundNo ACM found.695 Line Maintenance Shelter900 1975 e&e (1991): Floor tile, roofingNon-FAD ACM found; not surveyedsince 1997.696 Line Maintenance Shelter900 1975 e&e (1991): Floor tile, roofingNon-FAD ACM found; not surveyedsince 1997.697 Line Maintenance Shelter900 1975 e&e (1991): RoofingNon-FAD ACM found; no interior ACMobserved; not surveyed since 1997.Final Finding of Suitability to Transfer #5April 2010Former MCAS El Toro, CaliforniaTable 6Page 2 of 2Table 6: Summary of Asbestos SurveysBuildingNumberDescriptionSquareFeetYear BuiltHistorical Asbestos SurveyInformationCommentsCarve-Out Building 746746 Flight Simulator22,516 1984 e&e (1991): Floor tile, drywall, carpet.CABACO/Tait (06/15/1999): Floor tilemasticNon-FAD ACM found.Source: USMC/SWDIV 2003.Note: The information presented in thistable was obtained from the listed source.ACM = Asbestos-containing materialCABACO = 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** 

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 **215**



#  **405**



# Former MCAS

**El Toro** Pacific Ocean 

# 

 **10** 

#  **210**



# San Bernardino County

**Riverside County**

**San Diego County Los Angeles County** 

**Orange County**

**Irvine C**  **osta Mesa Santa Ana**  **Anaheim Fullerton** 

**Orange**

**Tustin**

**El Toro Norwalk** 



# 1 **Figure VICINITY MAP** 

**F INDING OF SUITABILITY TO TRANSFER** 

**(FOST #5)**

**FORMER MCAS EL TORO**

**CALIFORNIA April 2009**  

# .**C:/Projects/eltoro/ArcGIS/fost5/VicinityMap_FOST5.mxd** 

# State Boundary 

# LEGEND

**County Boundary Interstate Highway** 

**6 0**  **6**

**3** 

# Miles 

# L **o c**  **a t**  **i o**  **n INSET MAP** 

**Project**

**L ocation** 



# Final

# T **r a**  **b u**  **c o**  **R o**  **a d**  **A l**  **t o**  **n P**  **a r**  **k w**  **a y**  

# T **r a**  **b u**  **c o**  **R o**  **a d** 



# I **r v**  **i n**  **e B**  **o u**  **l e** 

**v a**  **r d** 

**S a**  **n d**  **C a**  **n y**  **o n**  **A v**  **e n**  **u e** I-FI-OBuilding 746II-EI-KI-NII-RII-MII-LI-SFigure 2Carve-Out Area Location MapFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**Final Environmental Baseline Survey, F** **ormer Marine Corps Air Station El Toro, California. Earth Tech 2003.** SOURCELEGEND**Roads Property Boundary** **Leased Areas (Carve-Outs) Transfered Area** **Building/Facility Non-leased Navy Property** **Carve-Out Number (only carve-outs included in FOST #5 are shown)** II-E**Carve-Out Area (FOST #5)**.**3,400 0** **3,400 1,700** **Feet**

**Z:/eltoro/ArcGIS/fost5/fost5.mxd Final** **April 2010**#*))))#VAAAAAAAAAAAAAAAAAAAAAAAAA!=!=I-F**UST 101 APHO 33** **UST 6B 257** **IRP Site 16 MSC B1** **MSC B2 OWS 850E** **APHO 26 APHO 92** **MSC B3 UST 850A** **UST 850B PCB T1** **16 DGMW81 16 GE1** **16 DBMW52 16 MW12** **16 MW13 16 MW08** **16 MW09 16 MW5** **16 MW11 16 VM1** **16 VEW2 16 MW7** **16 VEMP2 16 MPE1** **16 VEMP1 16 MW6** **16 VEW1 16 MW1** **16 MW4 16 MW14** **16 MW15 16 MW16** **16 MW10 TAA-5A** 

**I R**  **P S**  **i t**  **e 2**  **5 -**  **B e**  **e C**  **a n**  **y o**  **n W**  **a s**  **h 16 MW3** **16 MW2 16MW17** **Main Pit TAA-5B** **399 Figure 3** **Carve-Out I-F Finding of Suitability** **to Transfer (FOST #5) Former MCAS El Toro, California** **Final April 2010** . 

# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transferred to Caltrans** **601 II-V** **LEGEND Carve-Out** **Roads**I-F**Miscellaneous (MSC) LOC Ar** **ea Requring Institutional Controls**#I**PCB Transformer/Equipment Oi** **l/Water Separator (OWS) Underground Storage Tank (UST)** #***Gro undwater/Vapor Well** A**Installation Restoration Program (IRP) Site**!=**Temporary Accumulation Area (TAA) Ae** **rial Photograph Anomaly (APHO) Area No Dig Area for Ongoing** **Petroleum Corrective Action (MSC B3) Not Part of Carve-Out I-F Transfer** **SOURCE Final Environmental Baseline Survey,** **Fo rmer Marine Corps Air Station** **El Toro, California. Earth Tech 2003.**)**200 0** **200 100** **Feet**))))I-KUST 70UST 68UST 72UST 718

**Z:/eltoro/ArcGIS/fost5/CarveOut_I_K.mxd**Figure 4Carve-Out I-KFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 50** **100 25** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**I-K**Roads Carve-Out** )**Underground Storage Tank (UST)**!())I-N1420UST 1AUST 1BAST 1

**Z:/eltoro/ArcGIS/fost5/CarveOut_I_N.mxd**Figure 5Carve-Out I-NFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 25 50 12.5** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND Roads** **Buldings Carve-Out Area (FOST #5)** )**Underground Storage Tank (UST)**!(**Aboveground Storage Tank (AST)**)I-OUST 98A

**Z:/eltoro/ArcGIS/fost5/CarveOut_I_N.mxd**Figure 6Carve-Out I-OFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 25 50 12.5** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**I-O**Roads Carve Out** )**Underground Storage Tank (UST)**)))#0#0#0UST273UST273BUST147PCB T36PCB T38PCB T37

**Z:/eltoro/ArcGIS/fost5/CarveOut_I_S.mxd**Figure 7Carve-Out I-SFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 25 50 12.5** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**I-SI-S**Roads Buldings** **Carve-Out Area (FOST #5)**)**Underground Storage Tank (UST)**#0**PCB Transformer/Equipment**[[[[#*#*#*))))))))!=!=!=$+$+$+$+$+#V#V#V#V#V#V#V697115939643640696606639892695119605118940139912913914937641972936RFA 43RFA 14RFA 150RFA 267RFA 152TAA 605TAA 606TAA 115UST 115AUST 116UST 606AUST 643AUST 605BUST 605AUST 117UST 115BPCB 892PCB T81PCB T16PCB T82PCB T15PCB 643PRL 606PRL 643PRL 118PRL 605OWS 605COWS 892OWS 643BAPHO 37APHO 99APHO 110APHO 119

**Z:/eltoro/ArcGIS/fost5/CarveOut_II-E.mxd**Figure 8Carve-Out II-EFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **Fo rmer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 100 200 50 Feet** 



# I **r v**  **i n**  **e B**  **o u** 

**l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**II-EII-EII-Q**Roads Buldings** **Carve-Out Aerial Photograph Anomaly (APHO) Area** $+**RCRA Facility Assessment (RFA) Site**#***Oil/Water Separator (OWS)**)**Underground Storage Tank (UST)**!=**Temporary Accumulation Area (TAA)**[**Potential Release Location (PRL)**#V**PCB Transformer/Equipment**[

**Z:/eltoro/ArcGIS/fost5/CarveOut_II-L.mxd Figure 9** **Carve-Out II-L Finding of Suitability** **to Transfer (FOST #5) Former MCAS El Toro, California** **SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 100** **200 50** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601 II-V** **LEGEND**II-LII-L

**I R**  **P S**  **i t**  **e 25**  **- B**  **e e**  **C an**  **y o**  **n W**  **ash PRL** **Runway Infield Area Roads** **Carve-Out Installation Restoration Program (IRP) Site** [**Potential Release Location (PRL)**#*#*)!=!=$+$+$+$+$+$+$+!![[[[RAD NBCRAD DRMOMSCPRL 442PRL 354 B u f f e r Z o n e

**I R**  **P S**  **i t**  **e 5** **469**APHO 20APHO 51APHO 38APHO 27APHO 46RFA 181

R F A 1 7 8RFA 264RFA 182RFA 183RFA 185RFA 184OWS 673AOWS 832UST 442MSC D1637T3PRL/TAA673TAA 772Figure 10Carve-Out II-MFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**. 

# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-VII-MII-H**LEGEND Carve-Out** **Roads**II-M**Oil/Water Separator (OWS) U** **nderground Storage Tank (UST)**#*!=**Temporary Accumulation Area (TAA)**$+**RCRA Facility Assessment (RFA) Site A** **erial Photograph Anomaly (APHO) Area**!**Radiological (RAD) Site I** **nstallation Restoration Program (IRP) Site Miscellaneous (MSC) LOC** **250 0 250 125** **Feet Buffer Zone** [**Potential Release Location (PRL)**))$+#V!.[PRL 457APHO 42RFA 244SRU 3CPCB T74UST 457

**Z:/eltoro/ArcGIS/fost5/CarveOut_II-R.mxd**Figure 11Carve-Out II-RFinding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 25 50 12.5** **Feet**



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**II-RII-R**Roads Carve-Out Area (FOST #5)** **Aerial Photograph Anomaly (APHO) Area**$+**RCRA Facility Assessment (RFA) Site**)**Underground Storage Tank (UST)**#V**PCB Transformer/Equipment**!.**Silver Recovery Unit (SRU)**[**Potential Release Location (PRL)**! 

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**Z:/eltoro/ArcGIS/fost5/CarveOut_faa.mxd**Figure 12Carve-OutBuilding 746Finding of Suitabilityto Transfer (FOST #5)Former MCAS El Toro, California**SOURCE Final Environmental Baseline Survey,** **F ormer Marine Corps Air Station** **El Toro, California. Earth Tech 2003. Final** **April 2010**.**0 50 100 25 Feet** 



# I **r v**  **i n**  **e B**  **o u**  **l e**  **v a**  **r d**  **T r**  **a b**  **u c**  **o R**  **o a**  **d Transfer red to Caltrans** **601**II-V**LEGEND**746Building 746II-DII-QIRPSite 3**Roads Buldings** **Carve-Out Installation Restoration Program (IRP) Site** **Buffer Zone**

!!!**Approximate Boundary of Tank Farm 5 Plume**

# Attachment 1

Comments/Response to Comments

# This Page Intentionally Left BlankApril 2010Response to CommentsPage 1 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponseSPECIFIC COMMENTS1. Page ii Table of Contents.Section 9 (Finding of Suitability to Transfer) ismissing. Please add SectionThe TOC has been updated to include Section 9.2. Page iii Table of Contents. The title for Attachment 3 should be changed to“RCRA Corrective Action Package”. The package would includethe FOST Concurrence Letter, Letter to Heritage Fields, LLC, andany Navy FOST Public Notices. There would be no ResourceConservation and Recovery Act (RCRA) Facility Boundary Mapincluded since the RCRA facility boundary will not be revisedThe recommended title change has been incorporated intothe updated text. The package would not include a NavyPublic Notice.3. Page 1,Section 2 firstbullet.Please change the second sentenceto read, “...approximately 0.92acres, which includes Building 399.”The recommended change has been incorporated into theupdated text.4 Page 1,Section 2, COsII-E and II-L.According to Figure 2, theseCOs appear to be located in thenorthwest portion of the base, not northeast.These COs are closer tothe northeastern boundary thanthey are to the northwestern boundary, therefore nochange is required.5. Page 2,Section 3.1Please insert the following languageat the end of Section 3.1:“DTSC has not made a RCRA Corrective Action CompleteDetermination for the property associated with FOST 5. Rather, itplans to issue a letter to the transferee (Heritage Fields, LLC)clarifying the corrective action obligations for property associatedwith FOST 5, as well as COs I-L and I-M, previously transferredunder FOST 4. The RCRA Corrective Action Package can befound in Attachment 3The recommended change has been incorporated into theupdated text except for “(Heritage Fields)”.6. Page 3,Section 3.2,Paragraph 3.Please verify that No-Further-Action (NFA) letters issued by theRegional Water Quality Control Board (RWQCB) and OrangeCounty Health Care Agency (OCHCA) for sites covered in thisFOST actually state that NFA determinations were based uponSection 2721(e), Title 23 California Code of Regulations (CCR).(FOST 4 only referred to the RWQCB).The text will be clarifiedthat both OCHCA and RWQCBhave delegated authority from the State Water ResourcesBoard and their NFA determinations are based on Section2721(e), Title 23 California Codeof Regulations (CCR) Asfollows:"NFA letters issued by the RWQCB and OCHCA are inaccordance with Section 2721(e)of the regulations listedabove which provides "Upon completion of requiredcorrective action, the regulatory agency shall inform theresponsible party in writing that no further work is requiredat that time, based on available information."April 2010Response to CommentsPage 2 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponse7. Page 3,Section 3.2,Paragraph 5Please delete the last sentence, as DTSC has not made adetermination that investigations and cleanups conducted underthe oversight of the RWQCB andOCHCA on property identified inthis FOST have satisfied the corrective action requirements underRCRA and the Hazardous Waste Control Law. (FOST 4 did notinclude the sentence either)The sentence has been revised as follows:“While DTSC has not made a RCRA CorrectiveAction Complete Determination for propertyassociated with FOST 5, DTSC does plan to issuea letter to the transferee clarifying the correctiveaction obligations for property associated withFOST 5, including property that was investigatedand cleaned up under the oversight of theRWQCB and the OCHCA (Attachment 3).”8 Page 4,Section 3.3,Line 4Please change “Section 4.1.3” to “Section 4.1.1”. (The reference toIRP Site 25)The recommended change has been incorporated into theupdated text.9. Page 4,Section 4, LastParagraph,Sentence 3.IRP Site 16 should be included as a Location of Concern (LOC)that has not received regulatoryagency concurrence of NFA. Itdoes have regulatory agency concurrence of Operating Properlyand Successfully (OPS) but not NFAIRP Site 16 is included as an LOC in Table 4. The text hasbeen modified to include mention of the ongoing responseaction at IRP Site 16.10 Page 8,Section 4.3,Paragraph 2a. This language was not included in FOST 4. It is not clearwhose requirements theyare. 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 materialsa. This text clarifies the situations when additionalsurveys need to be conducted to assess the presenceof FAD, non-FAD and ACM.b. The recommended change has been incorporated inthe updated text.11 Page 9,Section 4.5.4a. According to Table 1 and Figure 11, Building 457 appearsto have been demolished. If true,please note this fact inthe text of this paragraph.b. The text refers to SWMU 244,but there is also referenceto RFA 244 in the FOST. Please use a consistentdesignation if these two designations refer to the samesite.a. Building 457 has been demolished to it’sfoundation. The recommended change has beenincorporated into the updated text.b. The text has been updated to refer to RFA 244.The following text has been added to the Notesportion of Table 4:“Site was also identified as SWMU/AOC 244.”12 Page 10,Section 5.1.1a. The second sentence in thefirst paragraph refers to thearea requiring institutional control (ARIC). Please expandthe text to (i) indicate that this ARIC is different (and how)from the one in the Record of Decision and Remediala. The second sentence in the first paragraph in Section5.1.1 has been revised as follows: “The area subjectto these restrictions isidentified on Figure 3 as thearea requiring institutionalcontrols (ARIC). ThisApril 2010Response to CommentsPage 3 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponseDesign for Site 16, (ii) provide an explanation for thechange, and (iii) indicatethat the change receivedconcurrence from FFA signatories.b. Since the land use controls (LUCs) will not beincorporated into the quitclaim deed and DTSC Covenantexactly as written, please change the last sentence in thesame paragraph as follows: “The following list of LUCs areconsistent with the FinalRemedial Design Report (CDM2006) and will be similarly incorporated into the quitclaimdeed and the DTSC Covenantc. In the second bullet, please insert “within the arearequiring institutional controls” after the word “groundwaterd. Please change the text in the third bullet to read, “Thetransferee shall not alter, disturb, or remove existing orfuture wells and associated equipment within the arearequiring institutional controls without prior review andwritten approval from the FFA signatories; ande. In the fourth bullet, pleaseinsert “within the area requiringinstitutional controls” after the word “areaf. Please change the non-bulleted sentence near the bottomof the page to read, “The Navy will also include thefollowing specific additional requirements in the quitclaimdeed and will work with DTSC to incorporate similarlanguage into the DTSC Covenant:”rectilinear area is different than the curvilinear ARICthat was depicted in the ROD and the Final RemedialDesign Report (CDM 2006). The ARIC was slightlyexpanded in lieu of area encompassing the VOCimpacted groundwater plumeand its associated bufferzone. The revised ARIC was reviewed by andreceived concurrence fromthe FFA signatories.b. The recommended change has been incorporated inthe updated text.c. The recommended change has been incorporated inthe updated text.d. The recommended change has been incorporated intothe updated text.e. The recommended change has been incorporated intothe updated text.f. The recommended change has been incorporated intothe updated text.13. Page 11,Section 5.2.1.Please change the second paragraph toread, “In order to protectpresent and future human health, safety, and the environment, thetransferee shall refrain from the following acts within the areadesignated on Figure 3 as the nodig area for ongoing petroleumcorrective action, without priorreview and approval from the DONand RWQCB until cleanup objectives have been achievedThe recommended change has been incorporated into theupdated text.14. Page 12,Section 5.3.2Please add the 1999 survey to the first sentence. (See Table 6) The recommended change has been incorporated into theupdated 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 been incorporated into theupdated text.April 2010Response to CommentsPage 4 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponse16. Page 13.Section 5.4.2The date of construction for Building 605 is listed as 1962. Table 1lists it as constructed in 1965. Please reconcile.Table 1 has been corrected to state 1962.17. Page 13,Section 6.1Please expand the text at the end of the paragraph to explain whyneither of the petroleum plumes inCO II-Q is projected to encroachonto CO II-E, e.g., plumes arewell characterized, remedy ismonitored natural attenuation,plume size is decreasing,contaminant concentrationsare decreasing, etcThe text has been modified to read “Based on themonitoring data collected to date itis projected that both ofthese petroleum plumes willnot encroach on CO II-E.”18. Page 14,Section 6.3The last sentence states “Similar toCO II-E, the petroleum plumesassociated with Tank Farm 5 did not encroach onto CO Building746.” Please either use the singular form of plume or change thetext to read “... associated with Tank Farm 5 and Tank 398 did not...”. (See Comment #24 also)The sentence will read as follows: “ Similar to CO II-E,neither of the petroleum plumes associated with Tank Farm5 or Building 398 will encroach into CO Building 746.19 Table 1 Buildings/Structures/Facilities. Since Building 399 is shown onFigure 3, it is recommended thatit be included in Table 1 with afootnote explaining thatit was previously transferred, similar towhat is stated on Page 1, firstbullet. Also, please see Comment#17 above regarding the construction date for Building 605As the FAA Parcel transfer is not subject to this FOSTBuilding 399 will not be added to the table. The correctdate for Building 605 has been inserted.20 Table 6 Summary of Asbestos Surveys.Please change thedefinition of theFAD acronym in the Footnote toread, “Friable, Accessible, andDamagedThe recommended change has been incorporated into theupdated text21. Figure 8 Carve-Out II-E. PRL 119 islisted on this figure. It was notincluded in the draft FOST and it isalso not listed on Tables 3 or 4of this draft final FOST. Please explain.PRL 119 has been removed from the subject figure as itdoes not exist.22. Figure 10 Carve-Out II-M.a. The upper left corner of the buffer zone for IRP Site 5spills over onto property thatwas previously transferred(CO II-G [FOST 4]). The Navy is working with regulatoryagencies to modify the boundary of the buffer zone in thisarea to follow CO II-G boundary. Since regulatory agencyconcurrence with the boundary modification is expected tohappen prior to finalization of the FOST, Figure 10 needsupdating once concurrence is received.b. The Figure shows a TAA 673. Table 3 lists a PRL 673.Please confirm whether theyare the same. If they area. Comment noted; regulatory concurrence has beenreceived, and the figure has been updated.b. PRL/TAA 673 are collocated. Figure 10 has beenmodified to reflect both LOCs.April 2010Response to CommentsPage 5 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponsenot, please include PRL 673 in the figure.23 Carve-OutBuilding 746The figure refers to the plume as JP5 Truck Fueling Area Plumeboth in the figure and the legend. Sections 6.1 & 6.3 refer to theplume as Tank Farm 5 Plume.Please use a consistent plumedesignation. (see Comment #18 also)The figure has been changed to refer to Tank Farm 5Plume.24. Attachment 4bPage 7 of 8,Footnote (c)It is DTSC’s position that the Navy must address any levels ofpesticides or herbicides that create a risk to human health or theenvironment. Therefore, please:Delete statements that are based on the Navy's belief thatpesticides were not applied "inconsistent with labeling and inaccordance with FIFRA..." and "[t]the Grantor knows no use...".Delete the last sentence thatbegins, "The grantor shall have noobligationThe Navy asserts that legally applied pesticides (i.e appliedin accordance with FIFRA), do not constitute a release, asdefined in CERCLA, that wouldwarrant a response action.Health and Safety Code Section 25321(d) provides that theterm “Release” does not include any of the following:...”d)The normal application of fertilizer, plant growth regulants,and pesticides.” The recommended changes to the texthave not been made. However,the text for the footnotewas modified to:“The Property may contain pesticide residue frompesticides that have been applied in themanagement of the Property. The Grantor knowsof no use of any registered pesticide in a mannerinconsistent with its labeling and believes that allapplications were made in accordance with theFederal Insecticide, Fungicide, and RodenticideAct (FIFRA - 7 U.S.C. Sec. 136, et seq.), itsimplementing regulations, and according to thelabeling provided with such substances. It is theGrantor’s position that itshall have no obligationunder the covenants provided pursuant to Section120(h)(3)(A)(ii) of the ComprehensiveEnvironmental Response, Compensation, andLiability Act of 1980,42 U.S.C. Section9620(h)(3)(A)(ii), for the remediation of legallyapplied pesticides.”EDITORIAL COMMENTS1. Page 5 Section4.1.1,APHO Sites. Please delete the word “and”. The recommended change has been incorporated into theupdated textApril 2010Response to CommentsPage 6 of6Document 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, andBuilding 746, FormerMarine Corps Air Station El Toro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated18 February 2010CommentNo.Section/ PageNo.CommentResponse2. Page 13,Section 6.2,Paragraph 1.On line 3, the acronym “bgs”should be inserted after “belowground surface” since it is used down on line 8The recommended change has been incorporated into theupdated text3. Figure 2,Carve-OutArea LocationMapPlease use a darker shade of yellow for Building/Facility. Thecurrent shade does not show upvery well against the white,“transferred areas”.The recommended change has been incorporated into theupdated Figure 24. Figure 3,Carve-Out I-Fa. Please ensure that all ofthe lines extending out from awell actually point to a well location. In order to easilyview the well details, it is suggested that either the figurebe placed on an 11x17 sheet ofpaper or the right half ofthe CO be presented as anadditional figure (Figure 3aperhaps).b. The legend says “GroundwaterMonitoring Well”, but notall the wells are groundwater monitoring wells. Pleasemodify the legend.a. An 11x17 Figure has been used and the leaderarrows will point to cited wellb. The legend has been revised to“Groundwater/Vapor Well”5 Figure 10,Carve-Out IIM.The figure shows no groundwater monitoring wells so please deletethe reference in the legend.The recommended change has been incorporated into theupdated Figure 106. Figure 11,Carve-Out II-RPlease change the color of the APHO, UST and PCB sites (figureand legend) to match the colors used in the other figures.The recommended change has been incorporated into theupdated Figure 11.January 2010Response to CommentsPage 1 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseGENERAL COMMENTS1.Please confirm that the current lessees (Heritage Fields,City of Irvine) are the proposedtransferees for the propertycovered in this FOST.Confirmed.2.Building 746 is not a Carve-Out (CO) previously identifiedin the 2004 Finding of Suitability to Lease (FOSL) datedJuly 2004. The COs and their boundaries were designatedin the FOSL, which is a formal finding by the Navy. TheFOSL said it was prepared in accordance with Departmentof Defense (DoD) guidance documents and that thefindings were based on the Environmental Baseline Survey(EBS). Typically, the Navy proposes to transfer COs intheir entirety once they are deemed by the Navy to besuitable for transfer. This is the first time the Navy isproposing to transfer a portion of a CO. In this case, thenew CO Building 746 is a portionof the existing CO II-D.Changing the CO boundaries would be a change to theFOSL. Please inform DTSC whether (a) there is aprocedure for changes to the FOSL, e.g., notification toregulatory agencies and the public, and (b) the DoDguidance 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, butthen throughout the restof the FOST it is referred to as“CO Building 746”. Is the Environmental Condition of theProperty 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 aFinding Of Suitability To Transfer (FOST)/Findingof Suitability to Lease (FOSL) is to document that land areas areenvironmentally suitable for transfer or lease. There is noreference to “Carve-Outs” in Department of Defense (DoD) FOSTguidance. Therefore, ifthere are no environmental concerns with aland area (in this case CO Building 746) there is no required“procedure change” notice.Building 746 and its associated landwere evaluated as part of COII-D in the 2004 FOSL. The FOSL concluded that CO II-D issuitable for lease, subject tothe conditions, notifications, andrestrictions set forth in thatdocument. These notifications andrestrictions apply to the entire CO, including the portion thatencompasses Building 746. Thus, no changes to the FOSL arenecessary. Building 746 and its associated land are now beingconsidered for transfer, separate from CO II-D. The legaldescription for CO II-D includes the boundaries of CO Building 746.There is no requirement, otherthan preparation of a FOST, todocument that this property is now suitable for transfer.The reference to “property associated with bldg 746” has beendeleted from Section 1.CO Building 746 is separate fromCO II-D, and therefore will haveits own notifications and restrictions as noted in this FOST.Additional text has been added to Section 2. The reference to COBuilding 746 now reads as follows: “...consists of approximately1.6 acres that were previously partof CO II-D, and is located in.....”January 2010Response to CommentsPage 2 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponse3.PRL 354, which is locatedin CO II-M, has not received asite closure concurrence fromDTSC. Section 4.1.4, Table4, and Page 18 of Section10 (References) need to bechanged to reflect this fact. DTSC and the Navy are indiscussion on the issue of polycyclic aromatichydrocarbons (PAHs) detection in shallow soil and onwhether DTSC can concur withthe no further investigationrecommendation by the Navy.DTSC has concurred on the NFI recommendation in the SummaryReport that includes the site and has agreed to NFI for this PRL.Section 4.1.4, Section 10 (References), and Table 4 (page 19)have been revised to indicate NFI concurrence, with a date of09/25/2009.4.DTSC presently cannot make a RCRA Corrective ActionComplete Determination (RCACD)for IRP Site 16. Thesite, which has the remedy ofmonitored natural attenuation(MNA) with institutional controls (IC), has yet to meetcleanup goals identified in the 2003 Final Record ofDecision (ROD). In addition, there is still ongoingpetroleum corrective action at MSC B3 at Site 16. ARCACD cannot be made at a site with ongoing correctiveaction, including ongoing petroleum corrective action. (SeeSpecific Comment No. 3f)With concurrence on the Operating Properly Successfully (OPS)Report for IRP Site 16 by all Federal Facility Agreement (FFA)signatories, the Navy considers CO I-F environmentally suitable fortransfer as documented in this FOST.Based on recent agreement between DTSC and the Navy, underthe FFA, the Navy will continue to be responsible for conducting itscleanup in a manner that integratesthe requirements of CERCLA,RCRA and other applicable state or federal laws. Therefore, DTSCwill not make a RCACD for the properties subject to this FOST.5.There is a “Monitoring/Bioventing/SVE Wells” notificationand restriction in the FOSL for COs I-F, I-N, and II-M.Please ensure that the notification and restriction arecarried over to this FOST, if applicable.The following language has been inserted in the first paragraph ofSection 5.1.1 for CO I-F:“In addition to the LUC objectives to restrict use of theproperty, the wells listedon Table 7 and identified onFigure 3 will be protected.”The wells in COs I-N and II-M are no longer present; they weredecommissioned in accordance with applicable regulations.6.Radon was listed as a notification in the 2004 FOSL andshould be carried over as a notification in this FOST. Thiswas done in FOST 4.Although inserted as part of FOST4, the notification tables havebeen further refined for consistency with DoD FOST Guidance.Radon is not listed as anotification requirement.January 2010Response to CommentsPage 3 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseSPECIFIC COMMENTS1. Section 3.1(RCRA Permitand Subtitle CCorrectiveAction)a. Paragraph 2 describesa determination that allnecessary RCRA Subtitle C corrective action has beencompleted. Note that this determination is made byDTSC.b. Paragraph 6 has a placeholder for CACD/CEQAactions, to be added in the Draft Final FOST.a. Text has been revised based on recent agreement betweenDTSC and DON.b. Text has been revised based on recent agreement betweenDTSC and DON.2. Section 3.3(CERCLA)This section describes responseactions that were initiatedon the COs proposed to be transferred. The status of theresponse action, e.g., completed or ongoing, should beincluded. References to where additional information canbe found should also be provided, as was done in FOST 4.The following text has been added to Section 3.3; “IRP Site 16(CO I-F) has received operating properly and successfully (OPS)concurrence, as noted in Section 4.1.1. CERCLA responseactions have been completed at IRPSite 25, as noted in Section4.1.3. Additionally, PRLs354, 605 and 606, and the RunwayInfield Area were investigated under CERCLA, and received NFI.See Sections 4.1.4, 4.1.2, and 4.1.3, respectively.3. Section 4(Summary ofEnvironmentalConditions andNotifications)a. Paragraph 1 should cite 40 CFR part 373, ReportingHazardous Substances Activity When Selling orTransferring Federal Real Property, which containsapplicable notification requirements and criteria.b. Paragraph 3 should make reference to Table 4 forPRLs 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 “DTSC2008a”.e. Paragraph 4 should have a discussion on PRLsbecause they are listed in Table 4, unless a referenceto Table 4 is added to the discussion on the PRLs inParagraph 3.f. Paragraph 4 describes ongoing petroleum correctiveaction at MSC B3. Please note that a corrective actioncomplete determination cannot be made at a site witha. The following text has been added to introduce Attachments4a and 4b – “Pursuant to 40 Code ofFederal Regulations Part373, the deed for each CO will contain a notice of hazardoussubstances stored, released, ordisposed of, if any, within theCO. This notice is provided inAttachment 4b, the HazardousSubstances Notification Table.Attachment 4a, the PetroleumProducts Notification Table, lists the LOCs associated withpetroleum products only.”b. The text has been revised as follows:“PRLs 605, 606, 354, and Runway Infield Area required amore comprehensive investigation;therefore, a site inspectionunder CERCLA was conducted atthese PRLs (see Section4.1 and Table 4).”c. PRL 643 has been added to the first bullet.d. The reference has been revised to “DTSC 2008a.”e. PRLs have been added to the paragraph 4 listing of LOCJanuary 2010Response to CommentsPage 4 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseongoing corrective action, including ongoing petroleumcorrective 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 concurrencefrom DTSC on April 8, 2009. Please revise the sectionand Table 4 to reflect this fact.b. IRP Sites section: The section describes a covenantbetween the Navy and DTSC for Site 16 (DTSCCovenant). The cited restrictions (Section 5.1.1)should be consistent with the remedy in the Site 16ROD and any restrictions inthe Operating Properlyand Successfully (OPS) determination and RemedialDesign Report and should be included in the DTSCCovenant itself. Note thatSection 5.1.1 states therestrictions will apply tothe entire CO I-F.a. The DTSC site closure concurrence dateof 04/08/2009 hasbeen added to the RWQCB site closure concurrence date of11/24/2008 in Section 4.1.1 and Table 4, page 1.b. The cited restrictions in Section 5.1.1 are consistent with theIRP Site 16 ROD and Land Use Control Remedial Design, andare included in the DTSC Covenant.The text of Section 5.1.1has been changed to clarify thearea requiring institutionalcontrols within CO I-F.5. Section 4.1.4(Carve-Out IIM)According to the FOSL, a portion of IRP Site 5 hasradiological (RAD) issues. Please include a discussion onSite 5 under RAD Sites in this section.CO II-M is the subject of Section 4.1.4. IRP Site 5 and AerialPhotographic Anomaly (APHO) 46 are within CO II-H and are notincluded in FOST #5. However, the following text related toradiological issues has been added to Section 6.2, which discussesCO II-H in relation to its proximity to CO II-M:“Due to the potential for the landfill to contain radioactivematerial at depths of several feet below ground surface,on-site radiological survey and laboratory analyses of soilsamples were conducted for IRP Site 5 from June throughNovember 2001 and during March 2004. Detaileddescriptions of the survey activities, results, analyses, andrecommendations are presented in the RadiologicalRelease Report (Weston 2006). Based on the surveyresults, and risk and dose calculations, it was concludedthat Radium-226 concentrationsin surface soil (up to 18inches bgs) do not pose unacceptable risk. However,since there is potential for the landfill to containJanuary 2010Response to CommentsPage 5 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseradioactive material, IRPSite 5 was recommended forrestricted radiological release.”The last paragraph has been revised as follows:“APHO 46 has received regulatory concurrence on NFAfor both radiological and non-radiological issues (U.S. EPA2004, RWQCB 2003c, DTSC 2004b, CDPH 2006,RWQCB 2006); therefore, there is no concern regardingprevious contamination concerns of this APHO betweenthe 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 follows: U.S. EPA 2008a, DTSC2008a.7. Section 4.2(PetroleumProducts andDerivatives)Additional language about the DTSC’s RCACD is to beadded to this section in the Final FOST.Based on recent agreement between DTSC and the Navy,insertion of this language is no longer required.8. Section 4.2.1(Carve-Out I-F)Please address the status ofUST 399 in CO 1-F. (seeFOSL)UST 399 was located adjacent to Building 399 within the FAAParcel 2, which is not included in FOST #5. The following text hasbeen added to Page 1, Section 2, Property Description, CO I-F:“CO 1-F encompasses a Federal Aviation Administration(FAA) parcel of approximately0.92 acres. This parcelwas transferred to the FAA under a separate conveyanceaction.”9. Section 4.2.5(Carve-Out IS)a. The FOSL does not containCO I-S. The sheet in thefront cover pocket of the FOSL binder (labeled FOSLCross Reference Table of Carve-out Identifiers) showsthat CO I-S became CO I-Q. The FOSL Errata Sheet#1, Item #3, states that COI-S is a new CO of about 1acre in size and includes UST 273B and Buildings 273a. Buildings 273 and 147 were included in FOST #1.Subsequently, a previously unknown was discovered adjacentto Building 273 (the concrete UST identified in Item #3 of bothFOST Errata Sheet #1 and FOSL Errata Sheet #1). As aresult, new CO I-S was designated to encompass Buildings273 and 147. The newly-identified UST was designated USTJanuary 2010Response to CommentsPage 6 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseand 147. This Errata Sheet does not indicate thatthere 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 concurrence by RWQCB in aletter dated 12/12/2008.b. The reference has been revised to 2003d.10. Section 4.3(AsbestosContainingMaterial)a. This section should describe the number of asbestossurveys that are still tobe done for the COs proposedfor transfer.b. A reference should be made in the first paragraph tothe DoD1994 Asbestos, Lead Paint, and RadonPolicies at BRAC Properties, as done in FOST 4.a. There is no regulatory requirement for the Navy to performadditional asbestos surveys on COs proposed for transfer.b. The reference has beenadded to Section 10, page 21.11. Section 4.4(Lead-BasedPaint)Please add a statement about the number of residentialbuildings, if any, present onthe COs proposed for transfer.The following text has been added tothe end of the first paragraphin Section 4.4:“None of the buildings listed in Table 1 have been used forresidential purposes.’12. Section 4.5.2(Carve-Out IS)Please explain why transformers PCB T36, T37, and T38were not listed in the FOSL, yet they are included in thisFOST for CO I-S.The three transformers were included in FOST #1. Subsequent tofinalization of the 2004 FOST andFOSL documents, some of thecarve-outs areas were slightlymodified to better capture therelevant LOCs. At that timeit was determined that, although thethree transformers were associated with Building 272 (Parcel I-A),they were physically located within Building 147 (CO I-S). All FFAsignatories were notified of these changes in a letter dated 20 May2005. The letter included ErrataSheets identifying the changesand updated maps.13. Section 5.1.1(Carve-Out I-F)This section describes the restrictions that will apply to theentire CO through a quitclaim and a land use covenantbetween DTSC and the Navy (DTSC Covenant). Since theactivities associated with the Site 16 remedy of MNA areestimated to continue for 19 years, the land use restrictionsare essential for ensuring remedial action effectiveness.Consistent with the March10, 2000 MOA between the Navy andDTSC, the transfer deed and the DTSC covenant will containappropriate environmental restrictions and the DTSC covenant willbe processed and recorded atthe time of transfer.January 2010Response to CommentsPage 7 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseTo ensure that the land use restrictions are in place,transfer of the property toa nonfederal entity should notoccur until after the DTSC Covenant has been fullyexecuted by the Navy and DTSC.14. Section 5.2.1(Petroleum,Carve-Out I-F)a. MSC B3 – Please refer to General Comment No. 4and Specific Comment No. 3f.b. The third paragraph states that certain restrictions onCO I-F may be released when the RWQCB hasconcurred that cleanup objectives have been achievedand a release document recorded with the CountyClerk. Please note that any release by the RWQCBwould not affect land use restrictions in the DTSCCovenant for CO I-F. Any release by the RWQCBwould not affect DTSC’s authority with respect tomaking a RCACD for CO I-F.a. Comment noted. Please seeresponse to General CommentNo. 4.b. Comment noted.The following text will be addedat the end ofthe paragraph:“However the DTSC Covenant, as discussed in Section5.1, will remain in effect.”15. Section 5.4(Lead-BasedPaint)Please add the following sentence tothis section. “In itsuse and occupancy of the property, including but not limitedto demolition of buildings,structures, and facilities, andidentification and/orevaluation of any LBP hazards, thetransferee shall be responsible for managing LBP and LBPhazards in accordance withapplicable local, state, andfederal laws, and other requirements relating to LBP andLBP hazards.” This is consistent with FOST 4.Text has been added as suggested.16. Section 6.3(Carve-OutBuilding 746)The EBS (page A.14) indicatesthat there was a 20-gallonhydraulic fluid tank in the building but the FOST does not.Please explain.The tank referenced in EBS Table A-1 was part of the building’sroll-up door system. No visible staining was observed at the timeof the visual site inspection.As such, the tank was not designatedas an LOC and thus it was not included in the FOSL or in thisFOST.17. Section 7(Covenants)This section states that the deed for transfer of property onwhich hazardous substances were stored, known to havebeen released or disposed “as a result of former activitiesconducted by the U.S.” will include a covenant madepursuant to CERCLA section 120(h)(3)(A)(ii) and (B). NoteComment noted.Current text is consistent withDepartment of Defense Instruction(DoDi) 4165.72, for insertionof covenant language into a deed.January 2010Response to CommentsPage 8 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponsethat the CERCLA section does notlimit storage, release ordisposal to that resulting only from former activitiesconducted by the U.S.Note that the first quotation from CERCLA section 120(h)regarding the covenant shouldread: The covenant willwarrant that “all remedial action necessary to protecthuman health and the environment with respect to anysuch substance remaining on the property has been takenbefore the date of such transfer . . . .”18. Table 7(Monitoring/Bioventing/SVEWells):a. This table lists several wells on COs I-F, I-N, and II-Mthat cannot be easily identified as monitoring wells.The FOST should describe what these wells are beingused for and how their presence and use affects theCOs proposed for transfer.b. What is the status of1BSVE-01 located in CO I-N andwhy are there no notifications or restrictions associatedwith the well?c. What is the statusof 18 BGMW02A, C, D, and Elocated in CO II-M and whyare there no notificationsor restrictions associated with the wells?d. It appears that there is no reference to Table 7 in theFOST text. Please verify.a. Table 7 has been updated to accurately list what wells remain.As stated in response to Comment#5, all wells within COs I-Nand II-M have been decommissioned. A “Purpose” columnhas been added to the table toidentify the purpose of eachwell.b. CO I-N no longer contains any wells. Table 7 has beenupdated accordingly.c. CO II-M no longer contains any wells. Table 7 has beenupdated accordingly.d. Reference to Table 7 has been added to Section 5.1 .1.19. Section 8,AccessClause:CERCLA Section 120(h) (3) (A) (iii) would not apply to COsI-K, I-N, I-O, and I-S because they are proposed forconveyance “as is” without aCERCLA Covenant, therefore,please change the first sentence to read, “The deed willreserve and the transferee shall grant to the U.S. (DONand U.S. EPA) access to COs I-F, II-E, II-L, II-M, II-R, andBuilding 746 pursuant to CERCLA Section 120(h) (3) (A)(iii)”.Text has been revised as follows:"The deed will reserve and the transferee shall grant tothe U.S. (DON and U.S. EPA) access to COs I-F, II-E, IIL, II-M, II-R, and Building 746 pursuant to CERCLASection 120(h) (3) (A) (iii)."20. Table 1:Buildings/Struca. The 2004 FOSL shows Building 939 as demolished.a. Building 939 exists as depicted on Figure 8.January 2010Response to CommentsPage 9 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponsetures/Facilities Please reconcile.b. The year of construction for Buildings 936 and 939 islisted as “unknown” and theyear of construction forBuildings 937 and 940 is listed as “<1997”. Pleaseensure the appropriate LBP restrictions are in place forthese buildings.b. Structures 936, 939, 937, and940 were built during the 1990s,so LBP restrictions are not necessary. Table 1 has beenupdated to reflect these changes.21. Table 2 Environmental Requirements and Notifications: Pleasemark “Y” for “School Site Considerations” for COs I-S andBuilding 746.Text has been revised as suggested.22. Table 4(Locations ofConcern),Page 6 of 20,UST 273BThe table lists the removal completion date as 8/27/2004but the 2004 FOST Errata Sheet#1 lists a different date.Please reconcile.Table 4 has been revised to state that the removal occurred on08/26/2004.23. Table 6:Summary ofAsbestosSurveysSome of the descriptions don’t match thedescriptions in Table 1. Please reconcile. COs I-N andBuilding 746 need to be included in Section 5.3 becauseboth COs include a building where a previous surveydetected non-FAD ACM. Restrictions apply.Descriptions behave been made consistent between Tables 1 and6.CO I-N is now included in Section5.3, Summary of Restrictions,Asbestos-Containing Material, as Section 5.3.1.CO II-E is now included in Section5.3, Summary of Restrictions,Asbestos-Containing Material, as Section 5.3.2.CO Bldg 746 is now included in Section 5.3, Summary ofRestrictions, Asbestos-ContainingMaterial, as Section 5.3.3.24. Figure 3(Carve-Out I-F)a. Building 399 is shown in dark green and the legendexplains 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 toIRP Site 16 Restrictions”a. See response to Comment #8.Additional text has been addedto clarify.b. The reference has beenrevised as suggested.c. Text and figure have been clarified to distinguish the variousrestricted areas. The ARIC boundaries encompass almost theentire CO, this is now more clearly reflected in the figure. TheJanuary 2010Response to CommentsPage 10 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponseand a “No Dig Area for Ongoing Petroleum CorrectiveAction”. Sections 5.1.1and 5.2.1 also discuss threedifferent boundaries for restrictions. It is difficult tounderstand exactly what property is going to berestricted, what the restrictions will be, and themechanisms that will be in place to implement therestrictions. This confusion/ambiguity should beclarified so it will notpose a problem when preparingthe quitclaim deed and DTSC Covenant.footprint associated with the petroleum corrective actionoverlaps with the area subject to the IRP Site 16 Main Pit arearestrictions. However, this distinction is necessary in order toaccurately describe what area will be the subject of DTSC’scovenant and the restrictions associated with the Navy’s ongoing petroleum corrective action.25. Figure 8(Carve-Out IIE)If applicable, please show the petroleum plumesassociated with CO II-Q.The petroleum plumes associated donot fall within CO II-E. Textdescribing the plumes has beenadded to Section 6.1, but theplumes will not be added to Figure 8.26. Figure 10(Carve-Out IIM)Figure 10 (Carve-Out II-M):Please show the buffer zonefor IRP Site 5 on the figure.The IRP Site 5 buffer zone has been added to Figure 10.27. Figure 12(Carve-OutBuilding 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 added to Figure 12.28. Attachment 4a(PetroleumProductsNotificationTable, CO I-S,UST 273B)The Attachment shows the dateof operation as “unknown”.The 2004 FOSL, Errata Sheet #1 shows “1944-1994”.Please reconcile.Attachment 4a has been revised toshow dates of operation of1944-1994.29. Attachment 4b(HazardousSubstancesNotificationTable)PCB T74 is listed, but notthe other PCB transformers.Please explain.PCB T74 was the only site at which a response action was requiredfor releases of transformer oil containing PCBs. COs I-F, I-S, andII-E had PCB-containing transformers at one time, but no evidenceof a release was noted at thosesites, thus no notification isrequired.EDITORIAL COMMENTS1. Page i In the column of page numbers on the right side, please Alignmentof the page number has been corrected.January 2010Response to CommentsPage 11 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponse(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 addition to Section 3.4 isno longer necessary.3. Page 1 Please revise the descriptions of location of some COs tobe more precise, e.g., the first 5 COs, CO II-E, and CO II-Mare in the northwestern, central, and southern portion of theformer Base, respectively.Text has been revised to be more precise.4. Section 4.1,first sentenceThe word “parcels” should be deleted. Texthas been revised, “parcels” has been deleted.5. Section 4.1.1,IRP SitesParagraph 2 refers to the Covenant to Restrict Use ofProperty as the “DTSC Covenant”. Please ensure thisreference is used appropriately throughout the FOST, e.g.,Section 5.1.1.References to the DTSC Covenant have been revised such thatthey are capitalized in Section 5.1.1 and Section 9.6. Page 17,ReferencesReference RWQCB 2008f on Page 17 of the Referencesshows “27bB” instead of “273B” for the UST. Pleasecorrect.Text has been revised to “273B”.7. Table 3 Potential Release Locations: Please include “SI” in the listof acronyms at the end of the table.SI has been added to the acronym list.8. Table 4:Locations ofConcerna. Page 7 of 20 – RFA 14: Please correct the twotypographical errors in the “Closure Report Title/Date”column.b. Page 9 of 20 – APHOs 99and 110: Please correct thegrammatical 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” inline 5.d. Page 13 of 20: Pleasedelete the second row (PCB643). It’s a repeat of the one above.a. Spelling of the words, “Aircraft” and “Area” have beencorrected.b. The extraneous “s” has been removed from the word, “letter”.c. A space has beenadded as suggested.d. The second instance ofPCB 643 has been deleted assuggested.e. The term “MSC” has been inserted before “673T3”.f. Acronyms have been revised as suggested.January 2010Response to CommentsPage 12 of12Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Quang Than, Project Manager, California Department of Toxic Substances Control, Brownfields and Environmental Restoration Program, Letter dated16 April 2009CommentNo.Section/ PageNo.CommentResponsee. Page 19 of 20: In row #1,column #1, please insert“MSC” before “673T3”.f. Page 20 of 20: Please add the following acronyms tothe list: DON, DRMO, PERF, and OPS. Also, pleasecorrect the typographical error with “SRU”. “Sliver”should be changed to “Silver”.9. Figure 3(Carve-Out I-F)There are two different colorsof green used in the legend.The colors are difficult to distinguish. Please change oneof the shades of green to a different color.The shading surrounding Building 399 has been revised to a bluecolor.10. Attachment 4b(HazardousSubstancesNotificationTable)a. Please delete “Non-Trans” fromthe list of acronyms atthe bottom of the table, and add “SRU”.b. Please include Radian 1996 in Section 10,References.Text has been revised as suggested.January 2010Response to CommentsPage 1 of1Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: John Broderick, California Regional Water Quality Control Board, Santa Ana Region, Email dated 22 April 2009CommentNo.Section/ PageNo.CommentResponseGENERAL COMMENTS1.A 22 April 2009 e-mail fromRWQCB stated that the agencyhad no comments on the Draft FOST.Comment noted.January 2010Response to CommentsPage 1 of2Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Rich Muza, Remedial Project Manager, United States Environmental Protection Agency Region 9, Federal Facilities and Site Cleanup Branch, Letterdated 3 April 2009CommentNo.Section/ PageNo.CommentResponseGENERAL COMMENTS1.EPA previously providedthe following comment to theNavy with regard to the proposed plans for the on-goingPetroleum Corrective Action Program closure efforts atMSC-3:“While the EPA strives to support the Navy’s goalsfor cleaning up the former MCAS El Toro underboth the Federal Superfund and State CorrectiveAction programs, in thisinstance the correctiveaction to be performed will have a temporaryimpact on a Superfund remedy in place anddefined by EPA to be operating properly andsuccessfully at IRP Site 16. Of particular concernto EPA is the destruction and post-correctiveaction replacement of three ground-watermonitoring wells located inthe source area of theIRP Site 16 TCE plume. Since the Superfundremedy for IRP Site 16 is monitored naturalattenuation, EPA deems these monitoring wells tobe a significant component of that remedy. Assuch, EPA will not concur with the Finding ofSuitability to Transfer for this parcel until we havebeen provided with a report that includes 1) welllogs and construction details for all replacementmonitoring wells and the comparison of the resultsof a round of ground-water quality sampling fromthe replacement monitoring wells to the TCE trendfrom the destroyed monitoring wells and 2) detailson the post-corrective action site re-grading effortsto assure proper drainage in the TCE plumesource area as mandated by the Record ofDecision for IRP Site 16.”Due to the Navy’s intent to finalize FOST #5 in FY09 andthe unknown timing of the on-going Petroleum CorrectiveAction Program closure effortsat MSC-3, it may be in theNavy’s best interest to remove Carve-Out I-F from thisThe Petroleum Corrective Action Program (PCAP) closure effortsat Miscellaneous Site of Concern (MSC) B3 will not beimplemented until after property conveyance. Based on receipt ofthe Federal Facility Agreement (FFA) signatories comments, whichincludes a recommendation to re-evaluate the monitoring wellnetwork in the main pit area, additional time is necessary to resolvesubstantive technical comments andcoordinate fieldwork efforts.As such, Installation Restoration Program (IRP) Site 16 hasreceived concurrence on an operating properly and successfully(OPS) determination. As you know, an OPS determinationapproved by U.S. EnvironmentalProtection Agency (EPA) isrequired to document that all remedial action necessary to protecthuman health and the environment has been taken and support thecovenant required by Section 120(h)(3)(A)(ii)(I) of theComprehensive EnvironmentalResponse Compensation andLiability Act (CERCLA). U.S. EPAprovided OPS concurrence in aletter dated February 2, 2009. At the time of property conveyance,all appropriate IRP Site 16 remedy components will be in-place andtherefore, IRP Site 16 can betransferred in accordance withCERCLA.The Navy will continue to work closely with the FFA signatories toensure that the objectives ofboth the PCAP (e.g. MSC B3) andCERCLA (e.g. IRP Site 16) programs are met.January 2010Response to CommentsPage 2 of2Document 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 Building746, Former Marine Corps Air Station ElToro, CaliforniaReviewer: Rich Muza, Remedial Project Manager, United States Environmental Protection Agency Region 9, Federal Facilities and Site Cleanup Branch, Letterdated 3 April 2009CommentNo.Section/ PageNo.CommentResponseFOST. 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 anticipatedfor the various parcels. Of particular concern is whether ornot the buildings will be reused or demolished. Forexample, if the reuse ofa parcel is residential and thebuilding(s) will be used, then adeed restriction – not just anotice -- is needed that will prohibit residential reuse ofstructures until 1) bothasbestos and lead-based paintsampling programs have been performed and 2) anynecessary remediation has been completed. It isrecommended that the Draft Final FOST address futurereuse to address this concern and add corresponding deedrestriction language, if necessary.Navy FOST policy (March 2006 BRRM) does not contain arequirement to address “potential reuses." The FOST contains allappropriate notifications and restrictions related to building reusewhich is incorporated into the deed which is the authoritativedocument on how buildings are reused.Specific reuse of propertyis often fluid and dependent on a myriad of factors outside DoNcontrol. Accordingly, it is not appropriate for a FOST document todiscuss planned reuse.

# Attachment 2

Unresolved Comments

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# (There are no unresolved comments for FOST #5)

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# Attachment 3

RCRA Corrective Action Package

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# Attachment 4a

Petroleum Products Notification Table

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# 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 Respons e, 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 BlankFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 1 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteCarve-Out I-FI-F5TAA 5A Substances associatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999DI-F850 MSC B1 JP-5, Solvents, Waste Oil NA NA NA Unknown1999DI-F850 MSC B2 JP-5, Solvents, Waste Oil NA NA NA 1988DI-F850 MSC B3 JP-5, Solvents, Waste Oil NA NA NA Unknown1999DI-F850 OWS 850E Oil/Fuel/ Water NA NA NA Unknown1999DI-FNA IRP 16 JP-5, AVGAS, hydraulicfluid, crankcase oil, whitephosphorus, magnesiumphosphate, and napalmNA NA NA 1972-1985 DI-FNA IRP 25 Substances associatedwith storm waterdischarges and drainagechannelsNA NA NA Unknown1999DI-F NA APHO26 Unknown NA NA NA Unknown1999NDI-F NA APHO92 Unknown NA NA NA Unknown1999NDFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 2 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteCarve-Out II-EII-E NA APHO119 Unknown NA NA NA Unknown1999NDII-E 115 TAA115 SubstancesAssociatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999DII-E 115 APHO37 Unknown NA NA NA Unknown1999NDII-E118 PRL 118 Solvents, WasteOils NA NA NA Unknown1999NDII-E 121 APHO110 Unknown NA NA NA Unknown1999NDII-E 126 N/A EthylbenzeneP-XyleneM-XyleneToluenePerchloroethylene1,1,1-TrichloroethaneO-Xylene17.41 lbs8.70 lbs17.41 lbs17.41 lbs17.41 lbs17.41 lbs8.70 lbs100-41-4106-42-3108-38-3108-88-3127-18-471-55-695-47-6N.E.N.E.N.E.U220U210U226N.E.Unknown1999UnknownII-E 126 N/A 1,4-DichlorobenzenePerchloroethyleneDichloromethaneNapthalene0.81 lbs1.01 lbs0.60 lbs12.09 lbs25321-22-6127-18-475-09-291-20-3N.E.U210N.E.U165Unknown1999UnknownII-E139 RFA 43 Substances Associatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999NDII-E139 APHO 99 Unknown NA NA NA Unknown1999NDII-E605 PRL 605 Fuels, PaintsNA NA NA Unknown1999NDFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 3 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteII-E605 RFA 14 Unknown NA NA NA Unknown1999SII-E605 RFA 150 Solvents NA NA NA Unknown1999DII-E605 TAA 605 Substances Associatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999DII-E605 OWS 605C Oil/Water NA NA NA Unknown1999DII-E 605 PRL605 Pesticides NA NA NA Unknown1999NDII-E606 PRL 606 Paint NA NA NA Unknown1999NDII-E606 RFA 152 JP-5, Solvents,Lubricating OilsNA NA NA Unknown1999DII-E606 TAA 606 Substances Associatedwith Materials StorageNA NA NA Unknown1999DII-E 606 NA Pesticides NA NA NA Unknown1999NDII-E 643 PRL643 Fuels NA NA NA Unknown1999NDII-E643 UST 643A Waste OilNA NA NA 1982-1997 DII-E 643 OWS643B Oil/Water NA NA NA 1982-1997 DII-E892 OWS 892 Oily waterNA NA NA Unknown1999DCarve-Out II-LII-L NA PRLRunwayInfield AreaWaste OilNA NA NA 1943-1999 NDFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 4 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteII-LNA IRP 25 Substances associatedwith storm waterdischarges and drainagechannelsNA NA NA Unknown1999DCarve-Out II-MII-M1789 APHO 38 Disturbed Ground andExcavationNA NA NA Unknown1999DII-M354 PRL 354 Lead and Other Metals NA NA NA Unknown1999NDII-M442 PRL 442 Hazardous Wastes NA NA NA Unknown1999NDII-M673 PRL 673 Hazardous Wastes,Battery Acid, SolventsNA NA NA Unknown1999NDII-M673 RFA 178 Washwater from vehicles NA NA NA Unknown1999DII-M 673 RFA181 SubstancesAssociatedwith Land-farming AreasNA NA NA Unknown1999DII-M 673 RFA182 SubstancesAssociatedwith drum storage areasNA NA NA Unknown1999SII-M 673 RFA183 SubstancesAssociatedwith drum storage areasNA NA NA Unknown1999SII-M 673 RFA184 SubstancesAssociatedwith drum storage areasNA NA NA Unknown1999SII-M 673 RFA185 SubstancesAssociatedwith drum storage areasNA NA NA Unknown1999NDII-M 673 TAA673 SubstancesAssociatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999DII-M 673 APHO51 Unknown NA NA NA Unknown1999NDII-M673 OWS 673A Oil/Oily WaterNA NA NA 1982-1999 DFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 5 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteII-M673 MSC 673 T3 Solvents, Waste Oil, Fuel,Asbestos, Lead paint,PCBs, and othersubstances associatedwith aircraft maintenance,repair, cleaning, greaseand paintingNA NA NA Unknown1995SII-M 673 N/A EthylbenzeneP-XyleneM-XyleneToulenePerchloroethylene1,1,1-TrichloroethaneO-Xylene2.901.452.902.902.902.901.45100-41-4106-42-3108-38-3108-88-3127-18-471-55-695-47-6N.E.N.E.N.E.U220U210U226N.E.Unknown1999UnknownII-M 673 N/A P-XyleneM-XyleneTouleneAcetoneO-Xylene39.6779.34105.14198.0239.67106-42-3108-38-3108-88-367-64-195-47-6N.E.N.E.U220U002N.E.Unknown1999UnknownII-M 673 N/A P-XyleneM-XyleneTouleneEthylene GlycolMonobutyl EtherAcetoneO-Xylene16.1332.25193.502.58322.5016.13106-42-3108-38-3108-88-3111-76-267-64-195-47-6N.E.N.E.U220N.E.U002N.E.Unknown1999UnknownII-M 772 TAA772 SubstancesAssociatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999DII-M832 OWS 832 Oil/Oily WaterNA NA NA Unknown1999NDFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 6 of 7Attachment 4b: Hazardous Substances Notification TableCarve-outIDBuildingNumberArea Type IDHazardousSubstances(a)(b)ReportableQuantity(lb/year)(c)CAS NumberRCRA WasteCodeDates ofOperationActivitiesConducted atSiteII-M DRMO Lot No.3RFA 264 Substances Associatedwith DRMO Storage YardoperationsNA NA NA Unknown1999SII-M DRMO Yard RAD DRMO Potential RadiologicalMaterialsNA NA NA Unknown1999NDII-M DRMO Yard 3 APHO 20 Disturbed Ground andExcavationNA NA NA Unknown1999NDII-M DRMO Yard 3 APHO 27UnknownNA NA NA Unknown1999NDII-M DRMO Yard 3 MSC D1 Substances Associatedwith less than 90-dayaccumulation of wastesNA NA NA Unknown1999SII-M Golf Course APHO 46UnknownNA NA NA Unknown1999DII-MRAD Area RAD NBC Potential RadiologicalMaterialsNA NA NA Unknown1999NDCarve-Out II-RII-R 457 PCBT74 PCBs NA NA NA Unknown1999DII-R 457 RFA244 PCBs NA NA NA Unknown1999DII-R 457 PRL457 PhotographicDevelopment ChemicalsNA NA NA Unknown1999NDII-R 457 APHO42 Unknown NA NA NA Unknown1999NDII-R457 SRU 3C Photographic Chemicals NA NA NA Unknown1999NDFinal Finding of Suitability to Transfer #5April 2010 Former MCAS El Toro, California Attachment 4bPage 7 of 7Notes:(a)This table was prepared in accordance with 40 CFR 373 and 40 CFR 302.4. The substances which do not have chemicals-specific breakdown (and associated annual reportable quantity) are not listed in 40 CFR 302.4, and therefore have no corresponding ChemicalAbstracts Services (CAS) number, no regulatory synonyms, no Resource, Conservation, and Recovery Act (RCRA) waste numbers, andno reportable quantities.(b)The Property may contain pesticide residue from pesticides thathave been applied in the management of the Property. The Grantorknows of no use of any registered pesticidein a manner inconsistent with its labeling and believes that all applications weremade inaccordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA - 7 U.S.C. Sec.136, et seq.), its implementingregulations, and according to the labeling provided with such substances. It is the Grantor’s position that it shall have no obligation underthe covenants provided pursuant to Section 120(h)(3)(A)(ii) of the Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980, 42 U.S.C. Section 9620(h)(3)(A)(ii), for the remediation of legally applied pesticides.(c)Reportable QuantityFor Buildings with chemical-specific break down and associatedreportable quantity, the information was obtained from the Air EmissionsSource Survey, Final Submittal, MCAS El Toro. The reportable quantity was assumed to be the estimate of the air emissions value thatwas calculated based on a quantity used during the year. For non-VOCs, the specific chemicals are listed and the quantity is unknown.Sources: Earth Tech 2003, Radian 1996.APHO = Aerial Photograph Feature/AnomalyAVGAS = aviation gasolineCAS = Chemical Abstracts ServicesD = Disposal of wastesDRMO = Defense Reutilization and Marketing OfficeID = IdentificationIRP = Installation Restoration ProgramJP-5 = Jet Propulsion Fuel, Grade 5lb = poundMSC = miscellaneousNA = not applicableNBC = Nuclear, Biological, ChemicalN.E. = Not EstablishedND = Operations at site are Not DeterminedOWS = Oil Water SeparatorPCB = polychlorinated biphenylsPRL = Potential Release LocationRAD = RadiologicalRCRA = Resources Conservation and Recovery ActRFA = RCRA Facility AssessmentS = Storage of Hazardous Material or WasteSRU = Silver Recovery UnitTAA = Temporary Accumulation AreaUST = underground storage tank