PB99-963110
                              EPA541-R99-040
                              1999
EPA Superfund
      Explanation of Significant Difference
      for the Record of Decision:
      Treasure Island Naval Station
      Hunters Point Ship Yard Site, Parcel B
      San Francisco, CA
      10/20/1998

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                                                                         SFUHO RECORDS CTR
                                                                           3033-00587
                  EXPLANATION OF SIGNIFICANT DIFFERENCES        SFUND RECORDS CTR
                                                                         SD"l5 # 46832
                         Parcel B, Hunters Point Shipyard Site
                               San Francisco, California

                                   August 24,1998                          ~

I.      Introduction

       This Explanation of Significant Differences ("BSD") is for a change to the remedy
selected hi the Record of Decision for Parcel B, Hunters Point Shipyard dated October 7,1997
("Parcel B ROD"). The selected remedy for Parcel B included the excavation of contaminated
soils to the groundwater table, offsite disposal of the excavated soils, ground water monitoring to
ensure protection of San Francisco Bay from contaminated groundwater and institutional
controls prohibiting all uses of groundwater and governing handling of any residual
contaminated soils.

       Hunters Point Shipyard (the "Site") is a deactivated Naval base located in San Francisco,
California.  In 1989, the Site was placed on the National Priorities List ("NPL") and in 1991 was
selected for closure under the Base Realignment and Closure ("BRAC") program. The lead
agency for investigation and cleanup of the Site is the United States Navy ("Navy"). The lead
support agency is the United States Environmental Protection Agency, Region IX ("EPA").
State support agencies include the California Environmental Protection Agency, Department of
Toxic Substances Control ("DTSC") and the Regional Water Quality Control Board
("RWQCB").

       Preparation and public notice of this ESD is required pursuant to section 117{c} of the
Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA" or
"Superfund"), 42 U.S.C.  section 967 l(c).  This ESD will become part of the Administrative
Record for the Site.  The Administrative Record is available for review at two information
repositories: the Anna E. Waden Branch Library located at 5075 Third Street in San Francisco;
and, the City of San Francisco's Main Library located at 100 Larkin, during normal library hours.

       In the Parcel B ROD, the Navy's selected remedy for contaminated soils located on
Parcel B was excavation to the groundwater table  followed by offsite disposal. The depth to
groundwater below Parcel B was believed to typically occur at 10 feet below ground surface
("bgs"). However, in early 1998, fieldwork on the Site indicated that the depth to groundwater
beneath Parcel B could be as shallow as 2.3 feet bgs.  This ESD revises the selected remedy of
the Parcel B ROD to require cleanup of contaminated soils to a cleanup level of 10"6 cancer risk
(residential) or to a maximum depth of 10 feet bgs instead of to the groundwater table to ensure
that the Parcel B remedy is protective of human health and the environment.

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 II.    Summary of Site History and Selected Remedy

        The Site is a deactivated shipyard located in southeastern portion of San Francisco,
 California, adjacent to San Francisco Bay.  In 1940, the Navy obtained ownership of the shipyard
 for ship building, repair and maintenance activities. After World War II, activities shifted from
 ship repair to submarine servicing and testing. Between 1976 and 1986, the Navy leased most of
 the Site to Triple A, a private ship-repair company. The Site was an annex of Naval Station
 Treasure Island until March 1994 when the Navy's Engineering Field Activity West in San
 Bruno, California assumed management of it. The Site consists of 936 acres, 493 on land and
 443 under water in San Francisco Bay.

        In 1987, contamination was confirmed at a number of Site locations. This finding,
 combined with the proximity to an off-site drinking water source (the aquifer used by the Albion
 Springs water bottling company), resulted in the EPA placing the Site on the National Priorities
 List ("NPL"), in 1989. In 1991, the Department of Defense listed the Site for closure.

        In January 1992, the Navy, the EPA, DTSC and RWQCB entered into a Federal Facilities
 Agreement to better coordinate the environmental investigation and cleanup of the Site. To
 expedite the investigation and cleanup, the Site was divided into six parcels. Each of the six
 parcels was assigned a letter to it, ranging from A to F.  Parcel F is an offshore parcel.
 Fieldwork has been completed for all six parcels. The fieldwork showed that the soils and
 groundwater of the Site are contaminated with a variety of hazardous substances including
 metals, polychlorinated biphenyls ("PCBs"), volatile organic compounds ("VOCs"), semi-
 volatile organic compounds ("SVOCs"), polyaromatic hydrocarbons ("PAHs"), and pesticides.
 In addition, total petroleum hydrocarbons (TPH) are present in Parcel B soil and groundwater.  A
 no-action Record of Decision was signed for Parcel A in November 1995. Little contamination
 was detected on Parcel A and Navy intends to transfer Parcel A to the City of San Francisco in
 Fiscal Year 1999. Remedial investigations and feasibility studies continue for Parcels C through
 F. A number of non-time critical removals have also been completed at the Site. All six parcels
 are scheduled to reach final remedy decisions by the end of 1999 and upon cleanup be transferred
 to the City of San Francisco.                                                  -

       In the Parcel B ROD, with regard to contaminated soils the Navy selected excavation and
 offsite disposal  as the final remedy.  The major components of the selected remedy for the Parcel
B contaminated soils are:

             o     Excavation of contaminated soil to the groundwater table or to a 10"6
                    excess lifetime cancer risk (residential).
             o     Offsite disposal of the contaminated soil.
             o     Placement of clean backfill in the excavated areas.
             o     Deed notification that soil below the groundwater table in remediated
                    areas may be contaminated.
             o     Institutional controls governing handling of residual contaminated soils.

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        The ROD also requires that the groundwater be monitored for up to 30 years to ensure
 that contamination plumes do not impact the San Francisco Bay and so that VOC contamination
 present at IR-10 does not result in air pathway exposures at unacceptable levels. In addition,
 steam and fuel lines are to be removed, the storm drains are to be lined and pressure grouted as
 appropriate and all future uses of groundwater will be prohibited by a deed restriction. This BSD
 addresses only the soil portion of the Parcel B selected remedy.

 III.    Description of Significant Differences and the Basis for those Differences

        During the remedial investigation for Parcel B, human health risks posed by Parcel B
 soils were evaluated to a depth of 10 feet. This depth was selected because residential
 construction scenarios (house foundations, swimming pools, etc.) typically occur at depths of 10
 feet or less.  In addition, the proposed reuse plan for Parcel B includes utilities at 8 feet bgs.
 Finally, the  community expressed an interest in growing produce on Parcel B in conjunction with
 residential reuse.

       Early drafts of the Parcel B ROD required cleanup of contaminated soils to a depth of 10
 feet. The depth to groundwater beneath Parcel B was believed to average from 8 to 10 feet bgs.
 In one of the final drafts, the Parcel B ROD was revised to include language requiring cleanup to
 the groundwater table. Since remedial investigation and feasibility study data indicated that the
 average depth to groundwater was 8 to 10 feet bgs, the change to the selected remedy appeared to
 be minimal so the revision was included in the Parcel B ROD.

       After the Parcel B ROD was signed in 1997, the Navy took groundwater measurement
 levels in early  1998 in the vicinity of several Parcel B installation restoration ("IR") sites as part
 of a soil gas treatability study. These were the first groundwater measurement levels taken on
 Parcel B since 1995.  The water level measurements found that groundwater beneath Parcel B to
 be as shallow as 2.3 feet to 4 feet bgs.

       Since reuse of Parcel B will include residential uses, such as housing, excavation of
 contaminated soil to the groundwater would not be adequately protective because during the
 1997-98 rainy season, depths to groundwater beneath Parcel B were measured as shallow as 2.3
 to 4 feet bgs. Further, the institutional controls outlined in the Parcel B ROD would no longer be
protective of construction workers during redevelopment of the property. This is because if the
redeveloper believes that all soils below the groundwater table have been cleaned up and the
groundwater table fluctuates and exposes soils that have not been cleaned up, the workers could
be exposed to residual contaminated soils while believing they are protected as long as they do
not dig into the saturated zone.

       This BSD revises the Parcel B ROD to include cleanup of contaminated soils to a cleanup
level of 10^ cancer risk (residential) or to a maximum depth of 10 feet bgs to ensure that the
Parcel B remedy is protective of human health in both the short and long term.

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 IV.   Support Agency Comments

       In a letter dated June 26,1998, the State of California Regional Water Quality Control
 Board concurred with this BSD for Parcel B. The BRAC Cleanup Team (BCT) representative
 for the State of California Department of Toxic Substances Control for the Hunters Point Site
 reviewed the Draft BSD for Parcel B and only had minor comments, all of which are addressed
 in this Final BSD for Parcel B.                                                ~

 V.    Affirmation of the Statutory Determinations

       It is the determination of the Navy, the EPA, and the State of California that this modified
 remedy continues to satisfy the statutory requirements of cleanup under the Superfund process.
 Considering the information that has been developed during implementation of the remedy and
 the proposed changes to the selected remedy, the Navy, the EPA, DTSC and the RWQCB
 believe that the remedy will remain protective of human health and the environment, will comply
 with Federal and State requirements that are applicable or relevant and appropriate to this
 remedial action, and will be cost effective. In addition, the revised remedy will continue to use
 permanent cleanup solutions for the Site to the maximum extent practicable.  However, the
 revised remedy still does not satisfy the statutory preference for remedies that employ treatment
 to reduce toxicity, mobility and volume as a principal element.  This is due to numerous
 comments received during the public comment period voicing strong opposition to on-site
 treatment and disposal contaminated soils, the alternative initially proposed by the Navy in its
 Proposed Plan for the Parcel .B contaminated soils. In response to community concerns, the
 Navy selected excavation and off-site disposal for the Parcel B contaminated soils.

 VI.    Public Participation Activities

       The Administrative Record for this Site is available for review  and comment by any
 member of the public at the two information repositories mentioned in Section I of this BSD. No
public meetings are proposed for this BSD unless public interest indicates that such a meeting is
warranted.  However, the Navy intends to discuss this BSD for Parcel B with the Restoration
Advisory Board for Hunters Point Shipyard at its next scheduled meeting.

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Adichael McClelland                                  Date
 BRAC Environmental Coordinator
 Hunters Point Shipyard
 Daniel Opalski                                       Date
 Chief
 Federal Facilities Cleanup Branch
 U.S. Environmental Protection Agency Region IX
 Anthony J. L^fali^X                               Date
 Chief, Northern California Operations
 Office of Military Facilities
 Department of Toxic Substances Control
 California Environmental Protection Agency
 Loretta K. Barsamian                                  Date
 Executive Director
 California Regional Water Quality Control Board
 San Francisco Bay Region

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