Since the base closure in 1995, the US Navy has been going through the process of identifying and remediating residual contamination from its historical operations as a fuel depot. Numerous studies have clearly identified the areas of the Site affected by petroleum compounds, and in some instances, small areas of other contaminants, and the Navy has remediated many of the areas on the Site. Each of the 20 approximately 2-million-gallon fuel tanks have been cleaned and closed by the Navy, the on-site landfill has been capped, sand blast grit areas excavated, and surface oil impoundments excavated and disposed of at approved off-site landfills. Environmental closure of most of the storage tanks (monitoring and remediation of usually small contaminated areas around each tank) is underway.

Draft feasibility studies and risk assessments have been completed by the Navy for remaining areas of the Site; however, the State of California Regional Water Quality Control Board (RWQCB) and the Navy have yet to come to agreement on cleanup approach for the large oil sump area (IR Site 3) and Drum Lot 2. The Navy’s studies have concluded that these areas do not pose a significant risk to health or the environment. RWQCB policies favor a more aggressive cleanup approach. Given budgetary constraints and concerns over precedent, the Navy has indicated it would not undertake an aggressive cleanup of these areas, taking a wait-and-see approach to verify if existing residual contamination will migrate to San Francisco Bay. Although this approach may or may not pose a long-term environmental problem, it would delay any public use of the Site would be delayed for many years, even decades.

Early Transfer Process
Given its desire to implement the goals of the Base Reuse Plan and acquire the remaining approximately 50 acres still owned by the Navy, the City of Richmond requested an Early Transfer of those parcels in 2005. Early transfer negotiations between City staff, representatives of Upstream, and the Navy have been ongoing since then. In April 2008, these negotiations reached a breakthrough. The parties agreed on a strategy for a more aggressive cleanup on the remaining parcels using a combination of funding from the Navy and Upstream Point Molate LLC/Guidiville Band of Pomo Indians. The result of this pending agreement will be a more rapid and complete cleanup of the Site than would be possible under Navy ownership. Assuming no significant process delays, cleanup would be completed in 2010.

Under the early transfer strategy, the City and Upstream/Guidiville will complete remediation plans, implement remediation, and conduct long-term monitoring for the property. Under the pending agreement, the Navy will transfer the deed for the remaining approximately 50 acres to the City of Richmond along with a funding package of $28.5 million by early 2009. Upstream/Guidiville will provide additional funds for the difference between the Navy approach and the cost estimate for the more aggressive cleanup proposed. The Navy’s funding package will also provide for comprehensive environmental insurance to cover the City, Upstream/Guidiville, and the federal government for cost overruns and third-party liabilities arising from residual contamination on the property. Upstream/Guidiville’s contribution will cover insurance deductibles.

The City/Upstream/Guidiville cleanup approach was presented to the City’s citizen Restoration Advisory Board (RAB) on June 4, 2008, and received a favorable response. Under the plan presented by Upstream/Guidiville, the RAB would continue to provide citizen oversight of cleanup activities even after the Site is transferred from the Navy to the City.

Upstream/City Plan for Site Remediation
The current Land Disposition Agreement (LDA) calls for Upstream to manage and undertake required cleanup obligations once the property is transferred. Navy funds will go to a City-established escrow from which Upstream will receive funds as needed to complete the cleanup. Under the pending agreement, the City receives reimbursement for its costs to-date and for future oversight. The City will be named as discharger under a new RWQCB Board Order. Upstream/Guidiville will transition to the primary discharger under the Order when the property is transferred.

Regulatory and Site Remediation Status Summary
The following summarizes regulatory and remediation status for the major operational units on the Site:

• IR Site 1 – Landfill and IR Site 2 – Sand Blast Grit Areas: Signed Record of Decision.
• IR Site 1 – Landfill: Post-Closure Monitoring and Maintenance Plan to be transitioned to City/Upstream/Guidiville.
• IR Site 3 – Oil Sump Pond Area: Significant petroleum compounds remain in the ground. Draft remediation documents have been submitted by Navy, but not approved by RWQCB. City proposes aggressive cleanup here.
• IR Site 4 – Drum Lot 1: Navy risk assessment submitted indicates no significant risk. Monitoring and soil management plan are recommended.
• IR Site 4 – Drum Lot 2: Navy risk assessment submitted indicates no significant risk due to small area of volatile organic compounds (VOCs). City proposes aggressive cleanup here as well.
• Corrective Action Plan already implemented for underground storage tanks and pipelines. Remaining environmental closure of 13 tanks to be completed by the City/Upstream/Guidiville.

Detailed Discussion of IR Site 3 – Oil Sump Area
From 1940s to 1974, IR Site 3 was a disposal area for contaminated fuel, pond bottoms, and other liquids. Disposal of these materials occurred during filling of this area with approximately 20 feet of fill on top of the existing Bay Mud. Soil mixed with oily waste in the sump during backfilling created the “fuel saturated soils” present throughout this area. From 1974 to 2003, the sump pond was filled and unlined wastewater treatment ponds constructed on top. These conditions caused petroleum seepage along the shoreline of San Francisco Bay, and necessitated remediation along the Bay beginning in 1995.

IR Site 3 – Sump Area Remediation To Date
The conditions described above created two main environmental risks:

• Direct contact between site users and residual petroleum.
• Migration of free-phase petroleum to San Francisco Bay creating a sheen.

The Navy previously excavated the surface oily waste impoundments and disposed of those soils at an off-site approved landfill, however underlying soils within the water table were not remediated. Currently, risks are managed through land use controls and a groundwater capture and extraction system. The groundwater capture system includes a 1,100-foot sheetpile containment wall and 12 extraction wells, which remove fuel on the groundwater as it migrates toward the shoreline. Extracted water is treated in an on-site system and then discharged under permit. Although studies have shown no significant dissolved petroleum in groundwater, free-phase heavy fuel is still present in portions of IR Site 3 soils, both above and below the water table.

IR Site 3 – City/Upstream/Guidiville Program Proposes Aggressive Cleanup Approach
Although the Navy proposed removing only a small area of affected soils below the water table and monitoring the area for 10 years, the City and Upstream/Guidiville are developing an aggressive cleanup plan that would include the following elements:

• Remove shallow soils to residential cleanup standards (3 feet below ground surface [bgs]) and deeper soils up to 10 feet bgs to commercial cleanup standards.
• Remove fuel-saturated soils throughout IR Site 3 where free product has been observed in monitoring wells.
• Remove soils 100-feet upgradient from groundwater containment system to the underlying Bay Mud (approximately 20 feet bgs).
• Backfill the excavation with clean and sorptive material to provide added contingency.
• Breach sheetpile to allow water to flow at bottom of the wall.
• Conduct long-term monitoring along the shoreline.

Specific remediation plans and design documents would be submitted to the RWQCB under a new cleanup order. Public participation by the RAB and the public at-large would be included in the plan prior to formal acceptance by the RWQCB.