CITY COUNCIL / LRA BOARD CITY OF RIVERBANK
SPECIAL
City Council and Local
Redevelopment Authority Board
Meeting
Mayor/Chair
Rachel Hernandez
Council/Authority Members
District 1 — Luis Uribe
District 2 — Cindy Fosi
Vice Mayor, District 3 — John Pimentel
District 4 — Stacy Call
Council Chambers
6707 Third Street, Suite B
Riverbank, CA 95367
SPECIAL MEETING AGENDA
TUESDAY, MARCH 24, 2026 — 6:00 PM
(THE AGENDA PACKET IS ONLINE AT HTTPS://RIVERBANKCA.PORTAL.CIVICCLERK.COM/)
1. CALL TO ORDER
2. FLAG SALUTE
3. ROLL CALL
4. AGENDA CHANGES
5. CONFLICT OF INTEREST
Any Council/Authority Member who has a direct Conflict of Interest on any scheduled agenda item to be considered is to declare their conflict at this time. Pursuant to Government Code Section 84308 (Levine Act), any Council /Authority Member who has received a contribution of $500 or more within the preceding 12 months from a party, participant, or their agent related to an item on the agenda must disclose that contribution on the record prior to participation in the discussion or decision on the item and may be required to recuse themselves, as applicable.
6. NEW BUSINESS
Item 6.1. Resolution Authorizing the City Manager to Execute Supplemental Lease Amendment No. 6 to Army Lease DACA0505-1-21-508 Thereby Extending the Interim Lease Through March 31, 2066
7. ADJOURNMENT
AFFIDAVIT OF POSTING
I hereby certify under penalty of perjury, under the laws of the State of California that the foregoing agenda was posted at the meeting location, on the North City Hall public exterior bulletin board, South City Hall public exterior Bulletin, Riverbank Community Center exterior bulletin, and the City’s website 72 hours prior to the meeting in accordance to the California Ralph M. Brown Act.
Posted this 23rd Day of March 2026. /s/Gabriela Hernandez, CMC, City Clerk
ADA COMPLIANCE STATEMENT
In compliance with the Americans with Disabilities Act, and the Governor’s Executive Order N-29-20, the City will make every effort to make reasonable modifications or accommodations from individuals with disabilities. Contact the Administration Dept. at (209) 863-7122 or the City Clerk at [email protected] at least (48) hours prior to the meeting to enable the City to make reasonable arrangements for accessibility.
NOTICE REGARDING NON-ENGLISH SPEAKERS
Pursuant to California Constitution Article III, Section IV, establishing English as the official language for the State of California, and in accordance with California Code of Civil Procedures Section 185, which requires proceedings before any State Court to be in English, notice is hereby given that all proceedings before the City of Riverbank City Council/LRA Board shall be in English and anyone wishing to address the Council is required to have a translator present who will take an oath to make an accurate translation from any language not English into the English language.
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Any documents that are not privileged or part of a Closed Session provided to a majority of the City Council / LRA Board after distribution of the agenda packet, regarding any item on this agenda, will be made available for public inspection at the City Clerk’s Office 6707 Third St., Suite A, Riverbank.
TELECONFERENCE/VIRTUAL PLATFORM PUBLIC PARTICIPATION
COMMENT PROCEDURES FOR CITY COUNCIL MEETING HELD IN
CONFORMANCE WITH THE BROWN ACT
PUBLIC "LIVE" VIEWING
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SUBMITTING PUBLIC COMMENTS FOR THE RECORD
Written comments must be received before 4:00 p.m. on the date of the meeting in order for them to be distributed to the Council prior to consideration of the matter.
Written comments will not be read aloud at the meeting, but will be reported as received for the record. If you do not receive an acknowledgement of receipt within an hour of submission or by 5:00 p.m., please call the City Clerk's Office at (209) 863-7198 or the Administration Dept. at (209) 863- 7122.
ACCEPTABLE METHODS OF SUBMITTING COMMENTS BEFORE THE 5:00 PM DEADLINE • Via Mail Service: Mail comments to City of Riverbank, Attn: City Clerk, 6707 Third Street, Suite A, Riverbank, CA 95367. (Call 209-863-7198 / 209-863-7122 to ensure they were received.)
• Via Email: [email protected]
(Note: This technology is not a guaranteed method.)
o Indicate Agenda Item # in the subject line. (Call 209-863-7198 / 209-863-7122 to ensure receipt.)
• Oral Comments In-Person: The Mayor will ask the public if anyone wishes to comment, at that time you may approach the podium.
• Oral Comments Via Zoom:The Mayor will announce when public comments may be made for a limit of 3 minutes on the agenda item being considered, at which time you will:
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This will alert staff that you wish to speak, and you will be unmuted. o Using a Phone — press *9 to “raise the hand”. This will alert staff that you wish to speak, and you will be unmuted.
o (Please make sure the volume on your device is on and that any nearby device or any nearby device is turned down.)
Teleconference Phone Number: (This system is a backup for ZOOM technical difficulties only when providing oral comments.) If there are technical difficulties or disconnection with ZOOM
Any documents that are not privileged or part of a Closed Session provided to a majority of the City Council / LRA Board after distribution of the agenda packet, regarding any item on this agenda, will be made available for public inspection at the City Clerk’s Office 6707 Third St., Suite A, Riverbank.
while making oral comments, please immediately call the teleconference phone number (209) 863-7151 so that Council may receive your comments. Council will be waiting for your call.
Thank you.
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Item 6.1. - CC / LRA – 3/24/2026
RIVERBANK CITY COUNCIL / LRA BOARD
AGENDA ITEM NO. 6.1.
SECTION : NEW BUSINESS
Meeting Date: 3/24/2026
Subject: Resolution Authorizing the City Manager to Execute Supplemental Lease Amendment No. 6 to Army Lease DACA0505-1-21-508 Thereby Extending the Interim Lease Through March 31, 2066
From: Marisela H. Garcia, City Manager
Submitted by: Melissa Holdaway, Administrative Analyst II Cody Bridgewater, Director of Public Works
RECOMMENDATION
It is recommended that the Local Redevelopment Authority ("LRA") Board of Directors ("Board") adopt a Resolution authorizing the City Manager to execute Supplemental Agreement No. 6 to the Army Lease DACA05-1-21-508 ("Interim Lease") and thereby extend the Interim Lease agreement through March 31, 2066.
SUMMARY
An Interim Lease was entered into on April 1, 2021, between the US Army and the City of Riverbank LRA for the former Riverbank Army Ammunition Plant, more recently known as the Riverbank Industrial Complex. The Interim Lease was amended in succession, exercising the right to extend the current term with Supplemental Agreements 1 through 5 for additional years, through March 31, 2026.
The LRA has previously requested a Long Term Interim Lease to ensure the financial sustainability of the site and allow for the Master Developer, Aemetis, to have a financeable location for their future development. The LRA requested via a letter to the Army on August 27, 2025 to include Army Parcel No. 4 (Stormwater Ponds) in the leased premises, extend the lease term so that the Lessee has a sufficient interest in the property to allow for the financing of infrastructure improvements on Federal land, and include standard financing terms similar to those provided in Army privatized housing leases; the Deputy Assistant Secretary of the Army for Installations, Housing, and Partnerships provided a determination of availability, dated February 19, 2026 for the current form Supplemental Agreement No. 6.
With approval, the attached resolution will authorize the City Manager to provide notice of intent to exercise an option to extend the term and also, upon receipt, execute the Supplemental Agreement No. 6 to extend the term another forty (40) years through March 31, 2066.
STRATEGIC PLAN
This action reinforces the City's core value of fiscal responsibility and is in line with the goal of improving and maintaining infrastructure and facilities and achieving and maintaining financial stability and sustainability,
Item 6.1. - CC / LRA – 3/24/2026
BACKGROUND
In 2005, the Defense Base Closure Commission recommended the closure of the Riverbank Army Ammunition Plant. This recommendation became law when Congress did not overturn the recommendation.
In 2006, the Riverbank Local Redevelopment Authority ("RLRA") was formed to serve as a single entity responsible for the decisions regarding reuse and development of the property.
In October 2008, the City of Riverbank adopted the Reuse Plan for the conversion of the former military site to civilian use. The Reuse Plan and Homeless Submission were forwarded to the U.S.
Army and to the Department of Housing and Urban Development (“HUD”) for review and approval in November 2008.
In March 2009, the RLRA received notification of approval from HUD and formal recognition from the Department of Defense (“DoD”) as an Implementing Local Redevelopment Authority. This designation authorizes the RLRA to begin to execute the Reuse Plan’s guidance for successful reuse of the property.
The RLRA submitted an EDC application for approval to the Army in May 2010. The RLRA received a letter dated December 2012 from the Army and concurrence from the Office of the Secretary of Defense on February 12, 2013, authorizing the use of an Economic Development Conveyance for the transfer of the Riverbank Army Ammuntion Plant.
In September 2017, an Economic Development Conveyance Memorandum of Understanding (“EDC MOA”) was negotiated to articulate the details and intent of the business deal between the Army and the RLRA. The EDC MOA defines certain rights and obligations of the RLRA and the Army and identifies the requirements, restrictions, reservations, conditions, exceptions and procedures for execution.
On October 17, 2017, the City received the quitclaim deed to Parcel B (24.40 approx acreage) and a bill of sale for certain associated personal property and salvage materials. The RLRA released an RFP for a Master Developer of the Riverbank Industrial Complex after reviewing submittals and interviewing candidates in early 2018, the Board began negotiating a contract with Aemetis. The agreement was executed on December 14, 2021. Aemetis officially took over operations of the Riverbank Industrial Complex in April 2022. Aemetis purchased Parcel B as agreed in July 2022.
The Master Developer Agreement included a sublease to the Army. The current Development Agreement will need to be renegotiated as the terms and conditions will change substantially once Amendment No. 6 is executed. Although Aemetis has committed to purchase Parcel 2 and 2a once conveyed to the City outside the Economic Development Conveyance ("EDC") Memorandum of Agreement ("MOA"), they have not committed to purchase Parcel 1 and 1a once they are conveyed to the City outside the EDC MOA.
UPDATED TERMS
Condition No. 3 - Term of Agreement extended for forty (40) additional years with a new expiration date of March 31, 2066.
Condition No. 4.a.(1) - Interim Lease to terminate upon the Tender of a Quitclaim Deed from the
Item 6.1. - CC / LRA – 3/24/2026
Army to the City/LRA.
Condition No. 7 - sets forth the requirements for how notice is to be remitted to either party.
Condition No. 8 - Premises shall be subject to the general supervision and approval of the Office of the Assistant Secretary of the Army for Installations, Energy, and Environment, Office of the Deputy Assistant Secretary of the Army for Environment, Safety, and Occupational Health, and the Base Realignment and Closure Directorate.
Condition No. 10.b. - Lessor has conducted an inventory and condition survey of the Leased Premises, including an assessment of environmental conditions, documented an updated Environmental Condition of Property Report, dated January 2026, attached hereto as Exhibit E-1, the "Condition Survey". Preceding expiration, revocation, or termination of the Interim Lease for any reason other than conveyance of the Leased Premises to the Lessee, the Lessor and the Lessee will jointly conduct a close-out survey.
Condition No. 21.a. - Lessee and any sublessee hereunder may only extract or use groundwater from the subsurface of the Leased Premises via wells identified under Water System No. 5000211, attached hereto as Exhibit K-1.
Condition No. 25 — The Lessee will use all reasonable means available to protect the environment and natural resources, and where damage nonetheless occurs from activities of the Lessee, the Lessee shall be liable to restore the damaged resources. Lessee shall submit to the Lessor, and maintain thereafter, an Environmental Compliance Plan within 180 days of the lease extension signature or any modification thereafter, which describes, in detail, the program for environmental management and method of compliance, by the user of any portion of the Leased Premises, whether Lessee, with all Lessor, Federal, State, and local laws and regulations for the use, management, generation, storage, treatment, and disposal of all hazardous waste, hazardous materials, and hazardous substances.
Condition No. 31 — The "Property Management Plan for Land Use Controls, Riverbank Army Ammunition Plant," dated January 2026 (hereafter the "Land Use Control Plan") is attached hereto as Exhibit H-1 and made a part of the Interim Lease. The Lessee is responsible for compliance with and adherence to the Land Use Control Plan and shall provide a copy to all subtenants.” Condition No. 43 - the Lessee or sublessee may encumber its (or their) leasehold interest(s) as well as its (or their) interest(s) in the improvements on the Leased Premises by one or more loans secured by a mortgage. The proposed holder of any such mortgage must be approved by the Government prior to the execution of such loan and, upon such approval, which shall not be unreasonably withheld, shall be referred to herein as the "Mortgagee".
Condition No. 44 - Lessee shall promptly discharge or cause to be discharged valid liens, rights in rem, claims, or demands of any kind, except one in favor of the Government, which at any time may arise or exist as a result of any action of Lessee or any sublessee with respect to the Leased Premises or materials or equipment furnished therefore, or any part thereof, and if the same shall not be promptly discharged by the Lessee, or should the Lessee or sublessee be declared bankrupt or make an assignment on behalf of creditors, or should this leasehold estate be taken by execution, the Government reserves the right to take immediate possession without any liability to the Lessee or any sublessee.
Item 6.1. - CC / LRA – 3/24/2026
Condition No. 45 - All of the Lessee’s obligations under this Interim Lease shall survive foreclosure or other transfer of leasehold interest in an insolvency proceeding and become the obligations of any successor for only those obligations arising during the period of ownership of said successor.
FINANCIAL IMPACT
The financial impact is unknown, although the RLRA has lost grant funding and relies on the annual Aemetis payments under the agreement and support of the General Fund. These costs to provide the administrative oversite required by the Army will continue until final conveyance of the land to the RLRA. The RLRA does have a contract with the Army for some operation and maintenance of the Riverbank Industrial Complex for landscape, security, fire, electrical and well maintenance. It remains a pass through that goes to the Master Developer for reimbursement.
ATTACHMENTS
1. LRA Resolution
2. DACA05-1-21-508 RBAAP Interim Lease SA 6 - DRAFT
3. Exhibit A-1 - Legal Description - RBAAP Leased Premises
4. Exhibit A-2 - RBAAP Leased Premises Map
5. Exhibit E-1 - RBAAP ECP Update 2026
6. Exhibit F-1 - Hazardous Substance Notification
7. Exhibit G-1 - RBAAP PCB Containing Equipment
8. Exhibit H-1 - RBAAP LUC Management Plan 2026
9. Exhibit J-1 - RBAAP Environmental Protection Provisions 2026
10. Exhibit K-1 - RBAAP Water System Details
Special CC/LRA - 03/24/2026
LRA Resolution 2026-
RIVERBANK LOCAL REDEVELOPMENT AUTHORITY
RESOLUTION 2026-
A RESOLUTION OF THE LOCAL REDEVELOPMENT AUTHORITY BOARD OF THE
CITY OF RIVERBANK AUTHORIZING THE CITY MANAGER TO EXECUTE AN INTERIM LEASE AMENDMENT TO THE LEASE NO. DACA05-1-21-508 BETWEEN
THE SECRETARY OF THE ARMY AND THE CITY OF RIVERBANK
THE RIVERBANK LOCAL REDEVELOPMENT AUTHORITY (HEREAFTER
REFERRED TO AS THE “LRA BOARD”) DOES HEREBY RESOLVE THAT:
WHEREAS, on April 1, 2021, the US Army (hereinafter the “Army”) and the City of Riverbank (hereinafter the “City”) entered into that certain Army Lease No.
DACA5-1-21-508 (hereinafter the “Interim Lease”), under authority of Title 10 United States Code section 2667 and Title 10 United States Code section 2667 for the Riverbank Army Ammunition Plant, Stanislaus County, California; and WHEREAS, the City and the Army entered into Supplemental Agreement No. 1 dated July 22, 2021, Supplemental Agreement No. 2 dated August 15, 2022, Supplemental Agreement No. 3 dated September 27,2023, Supplemental Agreement No. 4 dated August 14, 2024, and
WHEREAS, City and the Army entered into Supplemental Agreement No. 5 dated March 6, 2025 to exercise the third and final option year allowed by the Interim Lease; and
WHEREAS, the City provided a request letter via letter dated August 27, 2025, to include Parcel No. 4 in the leased premises, extend the lease term so that the City has a sufficient interest in the property to allow for the financing infrastructure improvements on Federal land, and include standard financing terms similar to those provided in Army privatizing housing leases; and, WHEREAS, the Deputy Assistant Secretary to the Army for Installations, Housing, and Partnerships provided a determination of availability, dated February 19, 2026, for the specific request of Leased Premises; and WHEREAS, the City would like to extend the term of the Interim Lease for Forty (40) years through March 31, 2066; and,
NOW, THEREFORE, be it resolved that the City Council of the City of Riverbank, reconstituted as the Local Redevelopment Authority Board of Directors hereby authorizes the City Manager to request an extension to the Interim Lease, and upon receipt, execute a Supplemental Agreement No. 6 to extend the term of the Interim Lease through March 31, 2066.
Special CC/LRA -03/24/2026
LRA Resolution 2026-
PASSED AND ADOPTED by the Local Redevelopment Authority Board of the City of Riverbank at a meeting held on the 24th day of March, 2026; motioned by Authority Member , seconded by Authority Member , and upon roll call was carried by the following vote of :
AYES:
NAYS:
ABSENT:
ABSTAIN:
ATTEST: APPROVED:
________________________ ________________________
Gabriela Hernandez,CMC Rachel Hernandez
LRA Secretary Chair
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SUPPLEMENTAL AGREEMENT NO. 6
AMENDING
DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
UNDER BASE REALIGNMENT AND CLOSURE (BRAC)
FOR THE
FORMER RIVERBANK ARMY AMMUNITION PLANT (RBAAP)
STANISLAUS COUNTY, CALIFORNIA
THIS SUPPLEMENTAL AGREEMENT NO. 6 is made and entered into by and between the SECRETARY OF THE ARMY, on behalf of the United States of America (hereafter the “Lessor”), and the CITY OF RIVERBANK, (hereafter the “Lessee”).
RECITALS
WHEREAS, on April 1, 2021, Lessor and Lessee entered into that certain Army Interim Lease No. DACA05-1-21-508, under authority of Title 10, United States Code, Section 2667 for the RBAAP, Stanislaus County, CA (hereinafter the “Lease”); and WHEREAS, on July 22, 2021, Lessor and Lessee entered into that certain Supplemental Agreement No. 1 to the Lease; and
WHEREAS, on August 15, 2022, Lessor and Lessee entered into that certain Supplemental Agreement No. 2 to the Lease; and
WHEREAS, on September 27, 2023, Lessor and Lessee entered into that certain Supplemental Agreement No. 3 to the Lease; and
WHEREAS, on August 14, 2024, Lessor and Lessee entered into that certain Supplemental Agreement No. 4 to the Lease; and
WHEREAS, on March 6, 2025, Lessor and Lessee entered into that certain Supplemental Agreement No. 5 to the Lease to exercise the third and final option year allowed by Condition No. 3. of the Lease extending the term through March 31, 2026; and WHEREAS, the Lessee provided a request via letter dated August 27, 2025, to include Army Parcel No. 4 in the Leased Premises, extend the lease term so that the Lessee has a sufficient interest in the property to allow for the financing of infrastructure improvements on Federal land, and include standard financing terms similar to those provided in Army privatized housing leases; and
WHEREAS, the Deputy Assistant Secretary of the Army for Installations, Housing, and Partnerships provided a determination of availability, dated February 19, 2026, for the specific request of Leased Premises;
NOW THEREFORE, Lease No. DACA05-1-21-508 is modified in the following particulars, but no others:
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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The term under Condition No. 3. is hereby extended for forty (40) additional years with a new expiration of March 31, 2066.
Condition No. 4.a.(1) shall now read:
“Termination Upon Tender of Deed. Upon the occurrence of either of the following, the passing of sixty (60) days after the Government tenders to Lessee, in accordance with applicable law, a good and sufficient Quitclaim Deed conveying fee title to any portion of the Leased Premises, or the acceptance by the Lessee of the Government tendered Quitclaim Deed, whichever occurs first, the Interim Lease shall automatically terminate as to the portion so conveyed as if such date were the stated expiration date contained herein and neither party shall have any further obligations under the Interim Lease, other than any obligations which otherwise would survive termination of the Interim Lease.” Condition No. 7. shall now read:
“7. NOTICES. Except as provided in paragraph 11.C of Exhibit J-1, all correspondence and notices to be given pursuant to the Interim Lease shall be addressed, if to the Lessee, to Executive Director, Riverbank Local Redevelopment Authority, 5300 Claus Road, Suite 1, Riverbank, California 95367, and if to the Lessor, to the Real Estate Contracting Officer, Attention: Chief, Real Estate Division, U.S. Army Corps of Engineers, Sacramento District, 1325 J Street, Sacramento, California 95814, or as may from time to time otherwise be directed by the parties. Notices must be given (1) in a property sealed envelope, addressed as aforesaid, and deposited postage prepaid by either registered mail, return receipt requested, (2) by certified mail, return receipt requested, in a post office regularly maintained by the United States Postal Service, or (3) by electronic mail to an address directed by the parties. Service of the notice shall be deemed complete upon receipt of said notice, or the refusal thereof, by the party to whom it is addressed.” Condition No. 8. shall now read:
“8. SUPERVISION OF THE LEASED PREMISES. The use and occupancy of the Leased Premises shall be subject to the general supervision and approval of Office of the Assistant Secretary of the Army for Installations, Energy and Environment (ASAIE&E), Office of the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health (DASA-ESOH), Base Realignment and Closure (BRAC) Directorate, hereinafter referred to as “Said Officer,” and to such rules and regulations as may be prescribed from time to time by Said Officer.”
Condition No. 10.b. shall now read:
“b. The Lessor has conducted an inventory and condition survey of the Leased Premises, including an assessment of environmental conditions, documented an updated Environmental Condition of Property Report, dated January 2026, attached hereto as Exhibit E-1, the "Condition Survey". Preceding expiration, revocation, or termination of
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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the Interim Lease for any reason other than conveyance of the Leased Premises to the Lessee, the Lessor and the Lessee will jointly conduct a close-out survey. The Lessor will prepare a close-out report. The Lessee shall fully fund the Lessor's preparation of an updated Condition Survey that will document the environmental condition of the Leased Premises at that time as part of the closeout survey. The close-out survey and report will refer to, and incorporate by reference, the updated Condition Survey. All significant variances from the initial Condition Survey shall be clearly documented in the close-out report. This close-out report will constitute the basis for settlement by the parties for any leased property shown to be lost, damaged, contaminated, or destroyed during the lease term, in determining any environmental restoration requirements to be completed by the Lessee, and restoration of the property as required in Condition No. 17. on RESTORATION.”
Condition No. 21.a. shall now read:
“a. The Lessee and any sublessee hereunder may only extract or use groundwater from the subsurface of the Leased Premises via wells identified under Water System No. 5000211, attached hereto as Exhibit K-1.”
Condition No. 25. shall now read:
“25. ENVIRONMENTAL PROTECTION
The Lessee will use all reasonable means available to protect the environment and natural resources, and where damage nonetheless occurs from activities of the Lessee, the Lessee shall be liable to restore the damaged resources. Neither the Lessee nor any sublessees shall discharge waste or effluent from the Leased Premises in such a manner that the discharge will contaminate streams or other bodies of water or otherwise become a public nuisance. The Lessee must obtain approval in writing from the District Engineer before any pesticides or herbicides may be applied to the Leased Premises.
b. The Lessee shall be solely responsible for obtaining at its own cost and expense any regulatory or environmental permits required for the Lessee's operation under the Interim Lease, independent of any existing Riverbank Army Ammunition Plant (“RBAAP”) permits and shall ensure that its sublessees obtain any environmental or other permit required for their operations and activities. The Lessee shall also be required to obtain its own EPA Identification Number, if applicable. c. The Lessor's rights hereunder specifically include a right of entry to allow the Lessor, its representatives, agents, employees, and contractors to inspect the Leased Premises for compliance with environmental, safety, and occupational health laws and regulations whether or not the Lessor is responsible for enforcing them, to oversee or inspect on-going environmental remediation and restoration work, or to undertake such work. Such inspections are without prejudice to the right of duly constituted enforcement
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
4 of 10
officials to make such inspections. The Lessor normally will give the Lessee twenty-four (24) hours prior notice of its intention to enter the Leased Premises unless it determines the entry is required for safety, environmental, operations, or security purposes; provided, however, that the Lessor shall have access to common areas of the Leased Premises at any time during normal working hours and without prior notice to the Lessee. The Lessee shall have no claim against the Lessor, its officers, representatives, agents, employees, or contractors on account of any entries within the Leased Premises made hereunder.
Lessor will use reasonable efforts to not interfere with Lessee’s activities. d. The Lessor acknowledges that the RBAAP is on the National Priorities List (“NPL”) under the Comprehensive Environmental Response, Conservation and Liability Act of 1980 (“CERCLA”), as amended (42 U.S.C. § 9601 et seq.). The Lessor also acknowledges that RBAAP has been issued a Hazardous Waste Facility Permit by the Department of Toxic Substances Control (“DTSC”). The Lessee acknowledges that the Lessor has provided it with a copy of the RBAAP Federal Facility Agreement (“FFA”), dated April 5, 1990, the Hazardous Waste Facility Permit, dated May 6, 2006, and any subsequent modifications to both documents. For so long as the Property remains subject to the FFA and any permits, the Lessee agrees that they will not interfere with the Unites States Department of the Army activities required by the FFA and any permits. In addition, should any conflict arise between the FFA and any permits, as they presently exist or may be amended, and the provisions of the Interim Lease, the FFA provisions shall take precedence. The Lessee further agrees that notwithstanding any other provision of the Interim Lease, the Lessor assumes no liability to the Lessee should implementation of the FFA or any permits interfere with the Lessee's use of the Leased Premises. The Lessee shall have no claim against the Lessor or its officers, agents, employees, or contractors on account of any such interference, other than for abatement of rent. e. The Lessee shall submit to the Lessor, and maintain thereafter, an Environmental Compliance Plan within 180 days of the lease extension signature or any modification thereafter, which describes, in detail, the program for environmental management and method of compliance, by the user of any portion of the Leased Premises, whether Lessee, with all Lessor, Federal, State, and local laws and regulations for the use, management, generation, storage, treatment, and disposal of all hazardous waste, hazardous materials, and hazardous substances. Each Environmental Compliance Plan for a portion of the Leased Premises, or request for waiver of the requirement for a plan due to the non-hazardous nature of the proposed use, must be submitted and approved in writing by the Lessor prior to occupancy of the intended portion of the Leased Premises. Thereafter, each such Environmental Compliance Plan shall be incorporated in the Lease and shall be included as an exhibit in the relevant sublease(s).
The Lessee shall be responsible for the overall compliance of its operations. The Lessee shall be responsible for ensuring the preparation of all documents, records, and reports associated with the environmental compliance of its operation. No liability or responsibility shall attach to the Leased Premises or the Lessor as a result of the Lessor’s review and approval of the Environmental Compliance Plan under this paragraph. The Lessee further agrees that in the event of any assignment or sublease of the Leased Premises, it shall
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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provide to the EPA Region 9, the DTSC, and the RWQCB Central Valley Office a copy of the assignment or sublease of the Leased Premises, by certified mail, within fourteen (14) days after the effective date of such transaction. The Lessee may delete the financial terms and any other propriety information from the copy of any assignment or sublease furnished pursuant to this condition.
f. The Lessor, the EPA, the California Department of Toxic Substances Control, and the Central Valley Regional Water Quality Control Board, their officers, agents, employees, contractors, and subcontractors are granted a right hereunder to enter upon the Leased Premises, upon reasonable notice to the Lessee, for purposes consistent with the applicable provisions of the FFA and for the following purposes:
(1) to conduct investigations and surveys, including, where necessary, drilling, soil and water sampling, test pitting, soil boring tests, and other activities related to the RBAAP Installation Restoration Program (IRP)P, FFA, and related environmental requirements;
(2) to inspect field activities of the Lessor and its employees, agents, contractors, and subcontractors in implementing the IRP, FFA, or related environmental requirements;
(3) to conduct any test or survey required by the EPA the California Department of Toxic Substances Control, or the Central Valley Regional Water Quality Control Board relating to the implementation of the FFA or environmental conditions at the Leased Premises, or to verify any data submitted to the EPA, the California Department of Toxic Substances Control, or the Central Valley Regional Water Quality Control Board by the Lessor relating to such conditions; and
(4) to construct, operate, or maintain any other response or remedial action as required or necessary under the IRP or FFA including, but not limited to, monitoring wells, soil removal, pumping wells, and treatment facilities. g. The Lessee agrees to comply with the provisions of any health or safety plan in effect under the FFA during the course of any above-described response or remedial action. Any inspection, survey, investigation, or other response or remedial action will, to the extent practicable, be coordinated with the Lessee. The Lessor will use reasonable efforts to not interfere with Lessee’s activities. The Lessee shall have no claim against the Lessor or any of its officers, agents, employees, contractors, or subcontractors on account of such entries. In addition, the Lessee shall comply with all applicable Federal, state, and local occupational safety and health regulations. h. The Lessee shall comply with the requirements of 10 U.S.C. § 2692(b)(9) and (10) to obtain the Lessor's approval for the storage, treatment, or disposal of any toxic or hazardous materials not owned by the Department of Defense on the Leased Premises.
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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i. The Lessee and its sublessees shall comply with the hazardous waste permit requirements under the Resource Conservation and Recovery Act (RCRA), or the State of California equivalent, and all other applicable environmental laws, rules, and regulations. Except as specifically authorized by the Lessor in writing, the Lessee and its sublessees must provide, at their own expense, such hazardous waste management facilities, including storage, treatment, or disposal facilities, complying with all applicable laws and regulations, as may be required. Hazardous waste management facilities of the Lessor will not be available to the Lessee. Any violation of the requirements of this provision shall be deemed a material breach of this Interim Lease. j. Any of Lessor's accumulation points for hazardous and other wastes shall not be used by the Lessee. The Lessee shall not permit its hazardous waste, or that of any sublessee or licensee, to be commingled with hazardous waste of the Lessor. k. Should the Lessor provide any personnel or equipment, whether for initial fire response and/or spill containment, or otherwise at the request of the Lessee, or because the Lessee was not, in the opinion of the Lessor, conducting timely cleanup actions, the Lessee hereby agrees to reimburse the Lessor for its reasonable response costs. The Lessee's hazardous waste, fuel and chemical spill response plan may be augmented to reflect changes in the Lessee's use, or its sublessees' use, of toxic, hazardous, or dangerous materials. Each sublessee shall provide the Lessee with individual emergency response and clean-up plans for its activities within its subleased portion of the Leased Premises prior to commencement of the sublessee's operations.
Sublessees' individual plans will be incorporated by the Lessee into its overall plan. l. The Lessee shall not construct or make, or permit its sublessees, licensees or assigns, to construct or make any substantial alterations, additions, or improvements to or installations upon or otherwise modify or alter the Leased Premises in any way which may adversely affect the Lessor’s investigations, restoration, or human health or the environment without prior written consent of the Lessor. Such consent may include a requirement to provide the Lessor with a performance and payment bond and such other requirements as may be deemed necessary to protect the interests of the Lessor. Except as such written approval shall expressly provide otherwise, all such approved alterations/additions/modifications, with the exception of any improvements that are lender-financed and required as security, shall become the Lessor’s property when annexed to the Leased Premises.
m. The Lessee shall not conduct or permit its sublessees to conduct any subsurface excavation, digging, drilling, or other disturbance of the surface without the prior written approval of the Lessor.”
Condition No. 26. shall be changed to Condition No. 26.a. and a new Condition No.
26.b. shall be added to read:
“b. The Lessee shall provide the Lessor with information regarding the types,
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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conditions, and quantities of toxic or hazardous materials (as listed in 29 CFR 1910 Subpart Z Toxic and Hazardous Substances) that may be temporarily stored, treated, or disposed of on the premises and hold the Lessor harmless from any and all liability for the same in accordance with Condition No. 16. of the Interim Lease.” Condition No. 31. shall now read:
“31. LAND USE CONTROLS. The "Property Management Plan for Land Use Controls, Riverbank Army Ammunition Plant," dated January 2026 (hereafter the "Land Use Control Plan") is attached hereto as Exhibit H-1 and made a part of the Interim Lease. The Lessee is responsible for compliance with and adherence to the Land Use Control Plan and shall provide a copy to all subtenants.” Condition No. 43. shall be added to read:
“43. MORTGAGE OF LEASEHOLD PREMISES
a. Except as herein provided, the Lessee or sublessee shall not: (a) engage in any financing or other transaction creating any mortgage upon the Leased Premises; (b) place or suffer to be placed upon the Leased Premises any lien or other encumbrance; or (c) suffer any levy or attachment to be made on the Lessee's interest in the Leased Premises; any such mortgage, encumbrance or lien shall be deemed a violation of this covenant on the date of its execution or filing of record, regardless of whether or when it is foreclosed or otherwise enforced.
b. During the term of the Interim Lease, the Lessee or sublessee may encumber its (or their) leasehold interest(s) as well as its (or their) interest(s) in the improvements on the Leased Premises by one or more loans secured by a mortgage. The proposed holder of any such mortgage must be approved by the Government prior to the execution of such loan and, upon such approval, which shall not be unreasonably withheld, shall be referred to herein as the "Mortgagee". Notwithstanding any foreclosure, the Lessee shall remain liable for the performance of all obligations of the Interim Lease, which by the terms hereof are to be carried out and performed by the Lessee, and any approved sublease shall remain subject to the terms and conditions of the Interim Lease in accordance with Condition No. 11.b.
c. The Lessee shall notify the Government promptly of any lien or encumbrance which has been created or attached to the improvements or the Lessee's or sublessee's interest in the improvements, whether by act of the Lessee or sublessee or otherwise, of which the Lessee or the sublessee itself has notice. If a Mortgagee or purchaser at foreclosure of the mortgage shall acquire the Lessee's or sublessee's interest in the improvements by virtue of the default by the Lessee or sublessee under the mortgage or otherwise, the Interim Lease shall continue in full force and effect so long as the Mortgagee or purchaser at foreclosure is not in default hereunder. The Mortgagee or purchaser at foreclosure may not appoint an agent or nominee to operate the Interim
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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Lease on its behalf without obtaining the prior written approval of the Lessor. For the period of time during which the Mortgagee or any purchaser at foreclosure of a mortgage holds the Lessee's or sublessee's interest, the Mortgagee or such purchaser shall become liable and fully bound by the provisions of the Interim Lease for those obligations arising during the period of ownership of said Mortgagee or purchaser. d. In no event shall the right granted herein to the Lessee or sublessee to mortgage or otherwise encumber Lessee's or sublessee's leasehold interest, created by and pursuant to the Interim Lease, be deemed or interpreted as a subordination of the Government's interest in the Leased Premises to the lien of such mortgage or encumbrance, it being expressly agreed that under no circumstances shall the Lessee or sublessee have the right to mortgage or encumber the interest of the Government in the Leased Premises or subordinate such interests to the lien of any mortgage or encumbrance that Lessee or sublessee may place upon its leasehold state created by and pursuant to the Interim Lease.
e. The Government consents to Lessee's or its sublessee's grant, if any, to the Mortgagee of a security interest in any fixtures, equipment, inventory and/or other personal property owned by the Lessee or its sublessees and located on the Leased Premises. The Government hereby waives any interest that the Government may have in such personal property, by virtue of the Interim Lease. f. Any mortgages, liens, encumbrances or other interests created pursuant to Condition No. 43. shall not be subject to the provisions of Condition No. 44. g. Estoppels Certificates. Provided the facts support such a statement, Government and Lessee shall within 10 days of written request by the other, certify by written instrument as to the following:
(5) That the Interim Lease as modified is in full force and effect; (6) That no default has occurred under the Interim Lease which has not been waived, and no event has occurred which, but for the passage of time and/or the giving of notice, would constitute a default under the Interim Lease; (7) That to their best knowledge, there are no existing claimed set-offs or defenses against the enforcement of any of the agreements, terms, covenants or conditions of the Interim Lease and any modifications of the Interim Lease on the part of the other party to be performed or complied with; and
(8) The date of expiration of the term.”
Condition No. 44. shall be added to read:
“44. LIENS. Subject to Condition No. 43. above, the Lessee shall promptly
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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discharge or cause to be discharged valid liens, rights in rem, claims, or demands of any kind, except one in favor of the Government, which at any time may arise or exist as a result of any action of Lessee or any sublessee with respect to the Leased Premises or materials or equipment furnished therefore, or any part thereof, and if the same shall not be promptly discharged by the Lessee, or should the Lessee or sublessee be declared bankrupt or make an assignment on behalf of creditors, or should this leasehold estate be taken by execution, the Government reserves the right to take immediate possession without any liability to the Lessee or any sublessee. The Lessee shall be responsible for all costs incurred by the Government in securing clear title to its property.” Condition No. 45. shall be added to read:
“45. LESSEE OBLIGATION SURVIVAL. All of the Lessee’s obligations under this Interim Lease shall survive foreclosure or other transfer of leasehold interest in an insolvency proceeding and become the obligations of any successor for only those obligations arising during the period of ownership of said successor.” All references to “District Engineer” are deleted and replaced with “Real Estate Contracting Officer.”
Exhibit “A” is deleted in its entirety and replaced with Exhibit “A-1” and Exhibit “A-2” attached hereto and made a part hereof.
Exhibit “E”, and any reference to Exhibit “E”, is deleted in its entirety and replaced with Exhibit “E-1” Environmental Condition of Property Report Update attached hereto and made a part hereof.
Exhibit “F” is deleted in its entirety and replaced with Exhibit “F-1” Hazardous Substance Notification attached hereto and made a part hereof.
Exhibit “G” is deleted in its entirety and replaced with Exhibit “G-1” PCB & PCB-Contaminated Transformers and Equipment attached hereto and made a part hereof.
Exhibit “H” is deleted in its entirety and replaced with Exhibit “H-1” Land Use Control Plan attached hereto and made a part hereof.
Exhibit “J”, and any reference to Exhibit “J”, is deleted in its entirety and replaced with Exhibit “J-1” Environmental Protection Provisions attached hereto and made a part hereof.
SUPPLEMENTAL AGREEMENT NO. 6
TO DEPARTMENT OF THE ARMY
INTERIM LEASE NO. DACA05-1-21-508
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Said Lease is amended in the above particulars only. All other terms and conditions of the Lease shall remain in full force and effect and this Supplemental Agreement No. 6 shall henceforth be considered a part of the said Lease as if fully and completely written therein.
IN WITNESS WHEREOF, I have hereunto set my hand by authority of the Secretary of the Army this _____ day of ____________ 2026.
By:
ADAM B. OLSON
Chief, Real Estate Division
Real Estate Contracting Officer
USACE Sacramento District
This Supplemental Agreement No. 6 to Interim Lease No. DACA05-1-21-508 is hereby executed by the Lessee this _____ day of _____________ 2026.
By:
MARISELA H. GARCIA
City Manager
City of Riverbank
Lease No. DACA05-1-21-508
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EXHIBIT A-1
Lease Description Riverbank Army Ammunition Plant
U.S. Tract No. A (South Portion) Stanislaus County, California
LAND DESCRIPTION
All that real property located in Lots 2, 3, and 4 of Section 31, Township 2 South, Range 10 East, Mount Diablo Baseline & Meridian in the County of Stanislaus, State of California, containing 112.02 acres, more or less, and described as follows:
A portion of that real property transferred by Quitclaim Deed on the 29th day of October, 1948, Document No. 22667 from the Reconstruction Finance Corporation to the United States of America filed in the Office of the Recorder of Stanislaus County described as follows:
Beginning at 2” Iron Pipe and Cap in a Monument Well marking the Southwest corner of Section 31, said corner also being the Southwest Corner of Township 2 South, Range 10 East of the Mount Diablo Baseline and Meridian. Thence leaving said Section corner and going with West line of Section 31 the following call:
North 00 degrees 30 minutes 19 seconds West, 2642.77 feet, more or less, to a Brass Cap in a Monument Well, being a point located in the southwest corner of Lot 2 Section 31 T 2 South, R 10 East of the Mount Diablo Baseline. Thence continuing with said section line the following call:
North 00 degrees 30 minutes 14 seconds West 358.62 feet, more or less, to the intersection of the west line and the southerly line of the Hetch Hetchy Water Supply Right of Way as described in the deed from R.C. Huper to the City and County of San Francisco, dated November 21, 1923 and recorded February 13,1924 in Volume 56, Page 71 of the Official Records of Stanislaus County. Thence going with the southerly line of said ROW, the following two calls:
(1) North 61 degrees 07 minutes 25 seconds East 1256.49 feet, more or less, (2) North 70 degrees 13 minutes 37 seconds East 354.43 feet, more or less, Thence leaving said ROW line and going the following two calls:
(1) South 00 degrees 30 minutes 33 seconds East 3,357.78 feet, more or less, (2) South 00 degrees 30 minutes 42 seconds East 368.26 feet, more or less, to a point in the southerly line of Section 31.
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Thence going with said southerly section line the follow call:
South 89 degrees 55 minutes 11 West 2755.40 feet, more or less, back to the POB Containing 112.02 acres, more or less.
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EXHIBIT A-1
Lease Description Riverbank Army Ammunition Plant
U.S. Tract No. A (North Portion) Stanislaus County, California
LAND DESCRIPTION
All that real property located in Lot 2 of Section 31, Township 2 South, Range 10 East, Mount Diablo Baseline & Meridian in the County of Stanislaus, State of California described as follows:
A portion of that real property transferred by Quitclaim deed on the 29th day of October, 1948, Document No. 22667 from the Reconstruction Finance Corporation to the United States of America filed in the Office of the Recorder of Stanislaus County described as follows:
Commencing at a 2" Iron Pipe and Cap in a Monument Well Marking the Southwest corner of said Lot 2, said corner also being the West ¼ Corner of said Section 31; thence N 00°30'14" W, a distance of 483.86 feet along the West line of said Section 31 to the Point of Beginning, said point of beginning also being the intersection of the said west line and the North line of the Hetch Hetchy Water Supply Right of Way as described in the deed from R.C. Huper to the City and County of San Francisco, dated November 21, 1923 and recorded February 13, 1924 in Volume 56, Page 71 of the Official Records of Stanislaus County. Thence leaving said Point of Beginning and going with the North line of said Hetch Hetchy Right of Way the following call:
North 61 degrees 07 minutes 25 seconds East 56.88 feet, more or less, to a point in the Easterly Right of Way line of Claus Road. Thence continuing along said North line of said Hetch Hetchy Right of Way the following two calls,
(1) North 61 degrees 07 minutes 25 seconds East 692.16 feet, more or less, (2) North 15 degrees 47 minutes 52 seconds West 20.89 feet, more or less, (3) North 28 degrees 00 minutes 19 seconds West 257.56 feet, more or less, (4) South 48 degrees 24 minutes 02 seconds West 643.00 feet, more or less, to the Easterly Right of Way line of Claus Road.
Thence continuing on the previous line the following call, South 48 degrees 24 minutes 02 seconds West 66.41 feet, more or less, to a point in the West line of Section 31. Thence going with said West line the following call, South 00 degrees 30 minutes 14 seconds East 138.24 feet, more or less, back to the Point of Beginning.
Containing 3.25 acres, more or less.
Lease No. DACA05-1-21-508
4 of 6
EXHIBIT A-1
Lease Description Riverbank Army Ammunition Plant
U.S. Tract No. A-106, A-107, A-108 Stanislaus County, California
LAND DESCRIPTION
All that portion of Lot 406 of the Re-plat of the Rush Addition as shown on the map thereof, filed on the 11th day of August, 1914 in Volume 8, Page 18 of the Official Records of Stanislaus County, described as follows:
For a Point of Commencement (POC), go to a point at the intersection of the northerly line of said Lot 406 and the Northwesterly line of the State Highway; reference the survey plat described above for a depiction of said northwesterly line and state highway. Thence going with said northerly lot line the following call:
South 89 degrees 35 minutes 00 seconds West 138.00 feet to a point in the common line of U.S. Tract Nos. A-106 and A-107. Said point being located in the common line between Lots 406 and 407 and being the Point of Beginning (POB) of this description. Thence leaving U.S.
Tract No. A-107 and going with the easterly line of U.S. Tract No. A-106 the following two calls:
(1) South 04 degrees 36 minutes 00 seconds West 320.00 feet, more or less. (2) North 89 degrees 35 minutes 00 seconds East 22.00 feet, more or less, to the Northwesterly line of said highway.
Thence along said northwesterly line the following three calls:
(1) South 16 degrees 05 minutes 00 seconds West 437.41 feet, more or less, (2) A curve to the right whose radius is 270.00 feet, having a central angle of 30°30’00” and a length of 143.73 feet,
(3) South 46 degrees 35 minutes 00 seconds West 200.32 feet, more or less, to a point in the most southerly corner of U.S. Tract No. A-106.
Thence leaving said corner and going with the westerly line of U.S. Tract No. A-106 the following six calls:
(1) North 26 degrees 12 minutes 00 seconds West 228.77 feet, more or less, (2) North 02 degrees 29 minutes 00 seconds West 124.87 feet, more or less, (3) North 13 degrees 23 minutes 00 seconds West 299.77 feet, more or less, (4) North 07 degrees 08 minutes 00 seconds West 224.80 feet, more or less,
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(5) North 01 degrees 38 minutes 00 seconds East 129.85 feet, more or less, (6) North 04 degrees 03 minutes 00 seconds West a distance 19.47 feet to the westerly common corner of U.S. Tract Nos. A-106 and A-107 being also a point in the common line of Lots 406 and 407,
Thence leaving U.S. Tract No. A-106 and going with the westerly line of U.S. Tract No. A-107 the following three calls:
(1) North 04 degrees 03 minutes 00 seconds West 180.57 feet, more or less, (2) North 17 degrees 14 minutes 00 seconds West 85.05 feet, more or less, (3) North 03 degrees 40 minutes 00 seconds West 55.47 feet, more or less, to a point in the common line between Lot 407 and 408.
Thence leaving Lot 40 and continuing with the westerly line of U.S. Tract No. A-107 the following four calls:
(1) North 03 degrees 40 minutes 00 seconds West 100.59 feet, more or less (2) North 15 degrees 27 minutes 00 seconds West 150.07 feet, more or less, (3) North 19 degrees 41 minutes 00 seconds East 70.01 feet, more or less, (4) North 04 degrees 06 minutes 00 seconds East 79.02 feet, more or less, to a point in the common line between Lot 408 and 409.
Thence leaving Lot 408 and continuing with the westerly line of U.S. Tract No.
A-107 the following two calls:
(1) North 04 degrees 06 minutes 00 seconds East 285.92 feet, more or less, (2) North 00 degrees 47 minutes 00 seconds East 215.95 feet, more or less, to the Westerly common corner of U.S. Tract Nos. A-107 and A-108.
Thence leaving U.S. Tract No. A-107 and going with the westerly line of U.S. Tract No. A-108 the following three calls:
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(1) North 00 degrees 47 minutes 00 seconds East 284.46 feet, more or less, (2) North 24 degrees 08 minutes 00 seconds East 145.18 feet, more or less, (3) North 01 degrees 34 minutes 00 seconds East 107.18 feet, more or less, to the northwest corner of U.S. Tract No. A-108.
Thence leaving said westerly line and going with the northerly line of said U.S. Tract the following call:
North 89 degrees 36 minutes 45 seconds East 247.48 feet, more or less, to a point in the northeasterly corner of said U.S. Tract. Thence leaving said northerly line and going with the easterly line of U.S. Tract No. A-108 the following call:
South 10 degrees 55 minutes and 00 seconds East 532.30 feet, more or less, to a point in the easterly common corner of U.S. Tract No. A-107 and A-108, being a point in the common line of Lots 410 and 409. Thence leaving U.S. Tract No. A-108 and going with the Easterly line of U.S. Tract No. A-107 the following call:
South 17 degrees 45 minutes 00 seconds East 524.00 feet, more or less, to a point in the common line of Lots 408 and 409. Thence leaving Lot 409 and continuing with the easterly line of said U.S. Tract the following call:
South 10 degrees 43 minutes 00 seconds East 382.90 feet, more or less, to a point in the common line of Lots 407 and 408. Thence leaving Lot 408 and continuing with the easterly line of U.S. Tract No. A-107 the following two calls:
(1) South 17 degrees 59 minutes 30 seconds West 201.70 feet, more or less, (2) South 01 degrees 10 minutes 00 seconds West 139 feet, more or less, to a point in the easterly common corner of U.S. Tract Nos. A-107 and A-106, also being a point in the common line of Lots 406 and 407. Said point, also being the POB.
Containing 28.84 Acres, more or less
i:z:a
I I
� t...:;...;;I
Leased Premises (144.18 acres)
USACE Fee Tracts
Disposed (2017)
RIVERBANK ARMY AMMUNITION PLANT
U.S. TRACT NOS. A, A-106, A-107, & A-108
STANISLAUS COUNTY, CALIFORNIA
US ARMY CORPS
OF ENGINEERS
BASE REALIGNMENT
AND CLOSURE
Lease No. DACA05-1-21-508
EXHIBIT "A-2"
Environmental Condition of Property Update Report
Riverbank Army Ammunition Plant
Riverbank, California
Prepared by:
Office of the Deputy Assistant Secretary of the Army
for Environment, Safety and Occupational Health (ESOH)
Base Realignment and Closure (BRAC)
January 2026
i
Table of Contents
1.0 Introduction ......................................................................................................................................1
2.0 Background ......................................................................................................................................2
3.0 Site Reconnaissance .........................................................................................................................3
4.0 Interviews.........................................................................................................................................4
5.0 Records Review................................................................................................................................4
6.0 Updated Environmental Conditions.................................................................................................5
6.1 Parcel 1 and 1A .........................................................................................................5
6.2 Parcels 2 and 2A........................................................................................................7
6.3 Parcel 4 (E/P Ponds)..................................................................................................8
6.4 Parcel A .....................................................................................................................9
6.4.1 Updates to Previously Identified Sites Discussed in Earlier ECP Updates...............9
6.4.1.1 Updates to RBAAP-001-R-01, Former Pistol Range (ECP Study Section 12/Parcel A)...............................................................................................................................9
6.4.1.2 Updates to IRP Site RBAAP-01, Landfill .................................................................9
6.4.1.3 Updates to IRP Site RBAAP-03: Groundwater Remediation..................................10
6.4.1.4 Updates to SWMU 1 IWTP (ECP Study Section 13)..............................................13
6.4.1.5 Updates to Building 11, Paint and Oil Storage (ECP Study Section 1011).............13
6.4.1.6 Updates to Structure 95, Substation No. 1 (ECP Study Section 1095)....................13
6.4.1.7 Updates to Structure 97, Substation No. 3 (ECP Study Section 1097)....................13
6.4.1.8 Updates to Structure 101, Substation spare (ECP Study Section 1101)..................14
6.4.1.9 Updates to Structure 145, Substation 17 (ECP Study Section 1145) ......................14
6.4.1.10 Updates to Building 162, Autodin A.B. Terminal Building (ECP Study Section 1162)........................................................................................................................14
6.4.1.11 Updates to Building 174, Hazardous Waste Storage Area (ECP Study Section 1174)........................................................................................................................14
6.4.1.12 Updates to Substation 2 (ECP study section 1096) .................................................14
6.4.2 Updates to PCB and Asbestos Containing Materials (ACM) Remediation Activities .................................................................................................................................15
6.4.2.1 Building Interior Activities Update .........................................................................15
6.4.2.2 Galbestos Panel Removal Update............................................................................16
6.4.2.3 Parcel A – South of Building 6 - PCB Contaminated Soil Activities and Stormwater Reservoir Conveyance System................................................................................16
6.4.2.4 PCB Equipment Update...........................................................................................16
6.4.2.5 Plastic Waste South of Building 6 ...........................................................................17
6.4.2.6 Former Substation 15, Building 100........................................................................17
6.4.2.7 ACM Survey Update ...............................................................................................17
6.4.2.8 Lead Based Paint (LBP) Survey Update..................................................................18
6.4.3 Preliminary Assessment/Site Inspection (PA/SI) Report ........................................18
6.4.4 Other Analysis.........................................................................................................19
6.4.5 Wood Debris Pile ....................................................................................................19
6.4.6 Perfluorinated Chemicals (PFCs):...........................................................................20
6.5 Potable Water System..............................................................................................20
7.0 Conclusion......................................................................................................................................20
8.0 Certification....................................................................................................................................21
9.0 BRAC Approval.............................................................................................................................21
10.0 References......................................................................................................................................22
ii
Tables
Table 1 Summary of Environmental Condition of the Property Findings Table 2 Notification of Hazardous Substance Storage, Release, or Disposal Table 3 PCB Equipment Status
Figures
Figure 1 Riverbank Parcel Map
Figure 2 Well Location Map (Main Production Area)
Figure 3 Well Location Map (E/P Ponds)
Figure 4 Groundwater Isocontour and COC Isoconcentration Map (2Q25, A'-Zone) Figure 5 Groundwater Isocontour and COC Isoconcentration Map (2Q25, B-Zone) Figure 6 Groundwater Isocontour and COC Isoconcentration Map (2Q25, C-Zone) Appendices
Appendix A Site Reconnaissance Photographs
Appendix B Table 1 from ACM Inspection Report: Asbestos Inventory Summary Appendix C Table 1 from LBP Inspection Report: Lead Based Paint Inventory Summary
iii
Acronyms
µg/L micrograms per liter
ACM Asbestos Containing Materials
AOC Area of Concern
AM Action Memorandum
AR Army Regulation
ASTM American Society for Testing and Materials
bgs below ground surface
BRAC Base Realignment and Closure
BTEX benzene, toluene, ethylbenzene and xylene
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
COC Chemical of Concern
CSM Conceptual Site Model
DTSC Department of Toxic Substances Control
ECP Environmental Condition of the Property
EDC Economic Development Conveyance
EDR Environmental Data Resources
E/P evaporation/percolation
EPA U.S. Environmental Protection Agency
ESCA Environmental Services Cooperative Agreement
ESD Explanation of Significant Differences
EW Extraction Wells
FeSO4 Ferrous Iron Sulfate
FYR Five Year Review
FOSET Finding of Suitability for Early Transfer
FOST Finding of Suitability for Transfer
FS Feasibility Study
GMP Groundwater Monitoring Program
GW Groundwater
GWTP Groundwater Treatment Plant
GWTS Groundwater Treatment System
HFCS high fructose corn syrup
IRP Installation Restoration Program
IWTP Industrial Wastewater Treatment Plant
LBP Lead Based Paint
LUC Land Use Control
iv
LUCRD Land Use Control Remedial Design
MCL Maximum Contaminant Level
mg/kg milligrams/kilogram
MW Monitoring Wells
NCC North County Corridor
NFA No Further Action
NPL National Priorities List
OID Oakdale Irrigation District
PA/SI Preliminary Assessment/Site Inspection
PCB polychlorinated biphenyl
PFC Perfluorinated Chemicals
PPM part per million
RBAAP Riverbank Army Ammunition Plant
REC Recognized Environmental Condition
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
RLRA Riverbank Local Redevelopment Authority
ROD Record of Decision
RSLs Regional Screening Levels
SLERA Screening level ecological risk assessment
SWMU Solid Waste Management Unit
TPH total petroleum hydrocarbons
TCRA Time Critical Removal Action
TSCA Toxic Substances Control Act
UFP-QAPP Uniform Federal Policy - Quality Assurance Project Plan USACE U.S. Army Corps of Engineers
UST underground storage tank
VOCs Volatile Organic Compounds
WDR Waste Discharge Requirements
1 1.0 INTRODUCTION
The Army performed an Environmental Condition of Property (ECP) Update for the former Riverbank Army Ammunition Plant (also referred to as the “Property” throughout this document) in accordance with Army Regulation (AR) 200-1 and applicable American Society for Testing and Materials (ASTM) standards. Under ASTM D 6008- 22 (reapproved, 2022) Standard Practice for Determining the Environmental Condition of Federal Property, the following components were completed: site reconnaissance, records review, and certification by the environmental professional responsible for the assessments (see Section 8.0).
The former Riverbank Army Ammunition Plant (RBAAP) is located at 5300 Claus Road, Riverbank, Stanislaus County, California, one mile south of the Stanislaus-San Joaquin County border and approximately five miles northeast of the city of Modesto. RBAAP occupied a total of 168 acres of land. It consists of two noncontiguous areas represented by the main plant area (approximately 139.2 acres) and the evaporation/percolation (E/P) ponds (28.8 acres). The main plant area of the Property was broken into six parcels and denominated: A, B, 1, 1A, 2, and 2A1
. The E/P ponds is the seventh parcel and is Parcel
4. Parcel B was transferred to the Riverbank Local Redevelopment Authority (RLRA) in September 2017. A parcel map of the former RBAAP is presented as Figure 1. This ECP Update evaluates only the current Army-owned property of the former RBAAP, as shown on Figure 1. The Army leased Parcels A, 1, 1A, 2 and 2A of the former RBAAP property to the RLRA for industrial/commercial reuse. The RLRA is responsible for maintenance, utilities and security of RBAAP.
This document reflects changes and updates from the May 2019 ECP Update Report for Parcels A, 1, 1A, 2, 2A and 4 (Army, 2019). A Finding of Suitability for Early Transfer (FOSET) is being prepared for all parcels in this ECP Update. A brief description of each of these parcels is below.
• Parcel A occupies 77.67 acres and includes most of the industrial buildings and facilities at RBAAP, as well as the Northwest Storm Water Reservoir. The Northwest Storm Water Reservoir is 3.25 acres and temporarily stores storm water from the industrial areas on Parcel A after rain events. Parcel A and the Northwest Storm Water Reservoir will be transferred to the RLRA through an Economic Development Conveyance (EDC). Updates to this parcel include updated soil and groundwater sampling results and Polychlorinated Biphenyl (PCB) contamination removal actions. All updates are described within this ECP Update Report.
• Parcel 1 is 8.46 acres and Parcel 1A is 4.37 acres. Parcels 1 and 1A are located south of and adjacent to Parcel A. The parcels were used for employee parking while RBAAP was operational. Remediation activities related to PCB releases are underway at this parcel. These parcels will be disposed of through a Negotiated Sale.
1 RBAAP was originally divided into parcels to facilitate transfer of areas as they became eligible for transfer. The Parcels now designate specific Land Use Controls but the entire property will now transfer under Early Transfer Authority as one parcel.
2 • Parcel 2 is 18.3 acres and is mostly open space. Parcel 2 is north of and adjacent to Parcel A, and south and southeast of the northwest storm water reservoir site.
A FOST was prepared for Parcel 2 in 2013 and again in 2024, but transfer did not occur. Parcel 2 will be sold via a Negotiated Sale to the RLRA for reuse. A separate ECP was finalized for this Parcel on March 26, 2024 (Army, 2024). • Parcel 2A is 3.3 acres. It is north and adjacent to Parcel A, and south of Parcel 2.
Parcel 2A is used for storage of mobile homes and recreational vehicles. Several monitoring and extraction wells which support the Installation Restoration Program (IRP) sites (RBAAP-01 and RBAAP-03) remain in place on this parcel.
This parcel will be conveyed under the FOSET due to the original groundwater contamination plume related to IRP site RBAAP-03. It will be sold via a Negotiated Sale to the RLRA for reuse.
• Parcel 4 (E/P ponds) was used for disposal of treated industrial wastewater from the former Industrial Wastewater Treatment Plant (IWTP) and is currently designed to receive treated discharge from the Groundwater Treatment Plant (GWTP) located on Parcel A when in operation. Parcel 4 is located approximately 1.5 miles north of RBAAP adjacent to but separated from the Stanislaus River by an elevated levee system. When the GWTP is operational, treated wastewater is piped from the GWTP on Parcel A to the E/P Ponds. The sale of Parcel 4 will include an Army flowage easement allowing disposal of GWTP effluent to the E/P Ponds for as long as the groundwater treatment system is required to operate. This parcel will be disposed of through Negotiated Sale.
2.0 BACKGROUND
The U.S. Army BRAC 2005 Environmental Condition of Property Report, Riverbank Army Ammunition Plant, Riverbank, CA was completed in November 2006 (CH2M Hill, 2006)2
. It is referenced as the “2006 ECP Report” throughout this document. The purpose of the 2006 ECP Report was to characterize the existing environmental conditions at RBAAP. It met the requirements of Title 40, Code of Federal Regulations (CFR) § 373.1; the Base Redevelopment and Realignment Manual DoDI 4165.66-M, AR 200-1; and closely parallels ASTM 6008-96 (2014) (now ASTM 6008-22). It was reviewed and found to meet the requirements set forth in 4.6.2 of ASTM D 6008-22 and the narrative discussion and findings of that report are incorporated by reference into this report as if contained here in its entirety.
Property is categorized in ECP reports into one of seven categories. The Area Types defined in the ASTM D5746 − 98 (Reapproved 2016) Standard Classification of Environmental Condition of Property Area Types for Defense Base Closure and Realignment Facilities (ASTM 2016). The seven ECP Area Types are as follows:
• Type 1: An area or parcel of real property where no release or disposal of hazardous substances or petroleum products or their derivatives has occurred 2 . CH2M Hill, 2006. U.S. Army BRAC 2005 Environmental Condition of Property Report, Riverbank Army Ammunition Plant, Riverbank, California. Prepared for United States Army by CH2M Hill, Santa Ana, California. November 17.
3 (including no migration of these substances from adjacent properties). • Type 2: An area or parcel of real property where only the release or disposal of petroleum products or their derivatives has occurred.
• Type 3: An area or parcel of real property where release, disposal, or migration, or some combination thereof, of hazardous substances has occurred, but at concentrations that do not require a removal or remedial action. • Type 4: An area or parcel of real property where release, disposal, or migration, or some combination thereof, of hazardous substances has occurred, and all remedial actions necessary to protect human health and the environment have been taken.
• Type 5: An area or parcel of real property where release, disposal, or migration, or some combination thereof, of hazardous substances has occurred and removal or remedial actions, or both, are under way, but all required actions have not yet been taken.
• Type 6: An area or parcel of real property where release, disposal, or migration, or some combination thereof, of hazardous substances has occurred, but required response actions have not yet been initiated.
• Type 7: An area or parcel of real property that is unevaluated or requires additional evaluation.
The 2006 ECP Report classified the study sections of the property into one of seven ECP categories. A total of 45.71 acres were classified as Category 1. The U.S. Environmental Protection Agency (EPA) Region IX concurred with the uncontaminated property designations on 4 May 2007 (via email). The remaining acreage was broken into the other six ECP categories.
An ECP Update Report for all the remaining Army owned RBAAP property was completed in 2019 and is referred to as the “2019 ECP Update Report” throughout this document. Table 1 compares the ECP categories between the 2019 and 2021 ECP Update Reports and this ECP Update Report. Other ECP Updates were prepared in 2017 and 2024 (Army 2017a, Army 2017b, Army 2024) and narratives are incorporated into this ECP Update.
3.0 SITE RECONNAISSANCE
A site reconnaissance for this ECP Update Report was performed to characterize on-site conditions and assess surrounding property uses and natural surface features that may have affected conditions of RBAAP. In addition, a reconnaissance was conducted of the surrounding roads and readily accessible adjacent properties to identify obvious potential environmental conditions. Photographs taken as part of the site reconnaissance are provided in Appendix A. The site reconnaissance took place on September 16-18, 2025.
All the site reconnaissance actions were conducted by the RBAAP BRAC Environmental Coordinator in a systematic manner focusing initially on the property boundaries and then the structures.
4 During the site reconnaissance, no obvious potential environmental issues were observed on the adjacent properties. The site conditions during the reconnaissance reflect the conditions described in the sections below.
4.0 INTERVIEWS
There were no new interviews completed for this update.
5.0 RECORDS REVIEW
A review of environmental documentation was conducted to support the preparation of transfer documents for the RBAAP. All known records and information associated with the environmental condition of the subject property have been documented in the 2006 ECP Report, 2017, 2019, and 2024 ECP Update Reports, with the exception of subsequent investigations of groundwater contamination, changes to the groundwater remedial approach, the Final 2021 Five Year Review (FYR) and other investigations described below.
Explanation of Significant Differences (ESD) #2: ESD #2 is in Draft Final status. ESD #2 formalizes restrictions on Parcels A, B, 1, 1A, 2, and 2A. Restrictions in the Draft Final ESD #2 include: the prohibition of residential reuse on Parcels A, 1, 1A, 2, and 2A; a sitewide groundwater restriction; a soil disturbance and soil management plan requirement for Parcels A, 1, 1A, 2A and the NW Storm Water Reservoir; site-wide restrictions on disturbing remedial activities; and land use controls to maintain the integrity of the landfill cap located on Parcel A. The ESD #2 is expected to be signed in 2nd Quarter FY2026.
Land Use Control Remedial Design (LUCRD): The LUCRD required by the ESD #2 is in draft form and under review. This formally documents how the Army will implement the restrictions selected in the ESD #2 on the Parcels A, B, 1, 1A, 2, and 2A.
Groundwater Reports: Groundwater sampling occurs during four events per year. The latest sampling results are provided in the RBAAP 2Q 2025 Groundwater Monitoring & Landfill Post-Closure Report (Ahtna, 2025). The groundwater treatment plant monitoring takes place monthly and is reported quarterly (Ahtna, 2025). 2016 Five Year Review: The 2016 FYR was completed and finalized by the Army in July 2020 (U.S. Army Corps of Engineers (USACE), 2020). The FYR concluded that the remedies in place for the landfill and groundwater contamination are short-term protective and that the overall site is protective of human health and the environment.
The Army committed to formalizing the institutional controls through the ESD #2. 2021 Five Year Review: The 2021 FYR was completed and finalized by the Army in March 2022 (USACE, 2022). The FYR concluded that the remedies in place for the landfill and groundwater contamination are short-term protective and that the overall site is protective of human health and the environment. The Army recommitted to continue formalizing the institutional controls through the ESD #2. The next FYR is due in September 2026.
Environmental Data Resources, Inc (EDR) Report: The records search for RBAAP, conducted by EDR in June 2006, searched for any potential environmental sites of concern located off Army property within corresponding ASTM search radius distances.
5 The EDR Report identified five sites located within one mile of the main plant and the E/P ponds. These sites were characterized as having a low potential to impact the property (EDR, 2006). The information presented in this report on adjacent properties remains accurate.
A new record search report was conducted by EDR in May 2013 (EDR, 2013) for the E/P ponds (Parcel 4) and in January 2014 (EDR, 2014) for Parcels A, 2, 2A, 1, and 1A. The results of these reports are consistent with the 2006 database search. An updated EDR search of environmental records for the Property and surrounding sites is not necessary.
The May 2013 (Parcel 4) and January 2014 EDR (Main Plant) are current and accurate because the land use at the Property and surrounding areas has not materially changed, and no potential sites of concern were identified in the EDR search.
6.0 UPDATED ENVIRONMENTAL CONDITIONS
This section documents investigations and/or findings, and updates any information associated with the remaining RBAAP Parcels (A, 1, 1A, 2, 2A and 4) since the completion of the 2019 ECP Update Report.
6.1 Parcel 1 and 1A
PCB-Contaminated Soil Remediation Update
As discussed in the 2017 and 2019 ECP Update Reports, the presence of liquid PCBs in surface soils at Parcels 1 and 1A was confirmed through an investigation completed in 2013 (report finalized in 2015) (USACE, 2015). The remedial action goals for soil and sediment were established during a meeting between RBAAP personnel, USACE and Department of Toxic Substances Control (DTSC) in 2017. The remedial action goals established were 0.99 mg/kg (milligrams/kilogram) for soil and 0.22 mg/kg PCBs for sediments.
The soil and sediment removal action began in June 2015 and was completed in December 2017. To achieve the remedial goals, the soils were excavated as planned to approximately 0.5 feet below ground surface (bgs). Several areas (approximately 67-foot squares) were excavated to depths greater than planned. In 44 of 80 areas planned for 0.5 feet, the areas were excavated deeper based on confirmation sample results. Ten areas were planned for excavation to 1.5 feet of which five were excavated deeper based on confirmation sample results. Two areas were planned for excavation to 2.5 feet one of which was excavated to 3 feet based on confirmation sample results. During this effort 43,306.88 tons of non-hazardous soil and 12,296.68 tons of Toxic Substances Control Act (TSCA) soil was removed and disposed of at the appropriate landfills.
After the soil was excavated, the area was partially graded to prevent run-off and fenced.
All confirmatory samples were below the established remedial actions goals in the confines of Parcels 1 and 1A. Four of the five grids covering the Oakdale Irrigation District (OID) Drainage Ditch north of Claribel Road and south of the fence line also yielded confirmation samples below the remedial action threshold. One of the grids (D11) yielded a confirmation sample result of 0.45 mg/kg of Aroclor after excavation below
1.5 feet bgs.
6 Subsequent comments by the regulatory agencies noted that the result of 0.45 mg/kg exceeded the risk threshold for ecological receptors. In addition, agency comments noted that the Army neglected to acquire sidewall samples during confirmation sample collection. In review of the historic aerial photo record, the Army noted that there were three areas that were not excavated.
In response to these data gaps and in consideration of the impending North County Corridor (NCC) project the Army undertook a Focused Supplemental Remedial Investigation (RI) to acquire data from discrete retroactive sidewall samples and discrete samples for previously unexcavated areas. The Focused Supplemental RI was also initially planned to be conducted in the OID ditches north and south of Claribel Road using the Incremental Sampling Method. However, the conditions in the north ditch led to the conclusion that collecting samples at predesignated depth intervals was infeasible due to native material being encountered before the targeted depth intervals.
Consequently, the north OID Ditch decision units were sampled instead at eight discrete locations per decision unit.
An Action Memorandum (AM) is in production and will document the work performed.
The AM will serve as a decision document for cleanup of the area impacted by the North County Corridor project. The recommended removal action involves removal and offsite disposal of soil containing PCB concentrations in excess of the screening level threshold of 0.99 milligram per kilogram (mg/kg) of PCBs in soil. The Work Plan was finalized in November 2015 (RORE, 2015). Exposed soil is soil that is not covered by infrastructure or hardscape. In addition, in the area where PCBs have been detected above 15 mg/kg (construction worker risk threshold) the soil will be excavated, stockpiled and disposed of as a separate and segregated waste stream. This approach for the limited area identified for remediation is based on based on conversations held between the Army and the agencies as part of the development of the AM.
An RI/FS will incorporate the findings into cleanup recommendations for the areas that are not part of the NCC Project. Because the ESD #2 will select Land Use Controls for Parcels 1 and 1A, the Record of Decision (ROD) for Parcels 1 and 1A will select No Further Action (NFA). Until the ESD #2 is signed, this area will remain an ECP Category 5.
Groundwater Monitoring Update
Based on groundwater contours, the 2006 ECP identified an area of Parcel 1A that was impacted by groundwater contamination from IRP site RBAAP-03 on Parcel A. Due to this, and the proximity of the Landfill (IRP site RBAAP-01), monitoring wells were installed on Parcels 1 and 1A. There is a cluster of four Groundwater (GW) monitoring wells (MW) on the eastern portion of Parcel 1 (MW61A, MW61A’, MW61B and MW61C). There is another cluster of three GW monitoring wells on the southeast portion of Parcel 1A (MW41A, MW41A’, and MW41B). Monitoring wells within the cluster MW41 have not been sampled since May 2004. Results for these wells never exceeded ROD cleanup levels. Monitoring wells within the cluster MW61 were most recently sampled during Q3-2023, Q4-2023 and Q1-2024. MW61-A and A’ have been dry during these periods. MW61-B and C yielded hexavalent chromium (Cr+6) results below the current action level of 10 µg/L. Results for these wells never exceeded ROD cleanup levels (Ahtna, 2020c). Even though, the GW monitoring wells on Parcel 1A
7 have not exceeded the ROD clean-up levels, MW145A’ yielded dissolved chromium results above the ROD goal of 50 µg/L and also yielded Cr+6 results above the ROD goal of 10 µg/L consistently from 2019 through the most recent round of sampling results. .
MW145B also yielded Cr+6 results above the ROD goal of 10 µg/L during Q2-2020, Q2- 2022 and Q4-2022.
MW145A’ is on the parcel line between Parcel A and 1A (Ahtna, 2020c). See Figure 4 for the Q2-2025 data. The groundwater contours and recent data indicate that there is a likelihood of Cr+6 concentrations above the ROD action levels on the western portion of Parcel 1A.
Effective October 1, 2024, the State of California began regulating Hexavalent Chromium in groundwater at 10 micrograms per liter (μg/L). This had impacts on multiple wells across the RBAAP well network and the Army is monitoring all wells accordingly.
Conclusion for Parcels 1 and 1A
Parcel 1 will remain a Category 5 until the ESD #2 formally documents the clean-up actions and future land use controls. Parcel 1A will remain Category 5 until the groundwater treatment is complete or proves to be Operating Properly and Successfully.
6.2 Parcels 2 and 2A
Groundwater Monitoring Update
There are monitoring wells on these parcels related to IRP site RBAAP-03 and the remediation on Parcel A. One monitoring well cluster (MW66) with three groundwater monitoring wells remains on Parcel 2. The wells associated with that cluster are MW66A’, MW66B and MW66C. Those wells are sampled annually. The most recent results for MW66B exceeded the 10 µg/L ROD goal for hexavalent chromium until Q2 2023. Therefore, the ECP Category for Parcel 2 has changed from Area Type 3 to Area Type 5.
There are two extraction wells (EW) located on Parcel 2A (EW72B and EW47C). The use of EW47C was discontinued prior to June 2004 due to sustained concentrations below ROD cleanup levels (Ahtna, 2019a). The Water Board approved of the plan to temporarily shut down EW72B to allow for a rebound study. All sample results have been below ROD cleanup levels for EW72B since 2014 (Ahtna, 2020c). The 2006 ECP report noted that the southern area of Parcel 2A will remain an ECP Category 5. The ECP Category may change to Category 4 if the selected groundwater remedy and treatment can be demonstrated to be Operating Successfully and Properly.
Conclusion
The groundwater under Parcels 2 and 2A is impacted by contamination and the groundwater remedy has not met the requirements for an Operating Properly and Successfully Determination. Therefore, both Parcels 2 and 2A are Area Type 5.
8 6.3 Parcel 4 (E/P Ponds)
Parcel 4 occupies 28.8 acres adjacent to the Stanislaus River and approximately 1.5 miles north of the main installation. The E/P Ponds were constructed in 1952 for the disposal of treated effluent generated at the IWTP (which has since been removed). The E/P Ponds were later used to dispose of water from the GWTP located on Parcel A serving the IRP Sites RBAAP-01: Landfill and RBAAP-03: Groundwater Contamination.
RBAAP continues to use the E/P Ponds for discharge of treated water. This discharge is regulated under Waste Discharge Requirements (WDRs) issued by the Central Valley Regional Water Quality Control Board. The WDRs require ongoing groundwater monitoring at the E/P Ponds. The influent and effluent are monitored monthly for the contaminants associated with the RBAAP groundwater treatment system extraction wells, total chromium and cyanide. The groundwater treatment plant was temporarily shut down to conduct the rebound study starting in April 2020. Extraction of groundwater and treatment of influent water was resumed in 2024. The extraction wells are sampled periodically.
Groundwater Monitoring Update
Due to historic chemicals of concern detected at the IRP sites on Parcel A (RBAAP-01 and RBAAP-03), there are five monitoring wells on Parcel 4 (MWP-1, MWP-2, MWP-3, MWP-4, and MWP-5). See Figure 3 for well locations and data. These wells are monitored quarterly for chromium, cyanide and other chemicals of concern (COCs). The Wells at the E/P ponds have historically yielded results for CoCs below action levels (Ahtna, 2020c). In May 2018, a request to modify the groundwater monitoring program (GMP) was submitted to the Water Board. This proposal requests sampling frequency reduction from quarterly to annually for the wells on Parcel 4 (Ahtna, 2019d).
Risk Assessment
As noted in the 2017 and 2019 ECP Update Report, the 1994 site wide ROD documented zinc contaminated soil. Based on RI findings, a removal action was required to address zinc contaminated soil in 1993. The 1994 site wide ROD documented removal action, and the ROD concluded that no further action was necessary at the ponds (USAEC, 1994). This site was also investigated for PCBs in the Galbestos investigation. None of the sediment samples in the E/P ponds contained PCBs exceeding the TSCA criteria (USACE, 2011a).
A Risk Screening evaluation was drafted, but not finalized, in December 2012. The purpose was to determine if the site constituents exceeded appropriate screening levels after the removal action and after PCB sampling described above. The constituents assessed during this action were metals, total petroleum hydrocarbons (TPH) and PCBs.
In February 2019, the Human Health Risk Assessment was finalized by reevaluating the data from the 2012 report, as well as addressing recent regulatory comments. During this evaluation, the maximum detected concentrations of the constituents were compared to the corresponding EPA November 2018 Residential Regional Screening Levels (RSL).
The risk characterization of these sites concluded that the levels within the soil are within acceptable levels for residential receptors. The zinc found within the groundwater is within background levels and under the ecological screening level (USACE, 2019a and
9 2019b). The EPA has since stated that there is a presumed ecological risk because of high concentrations of zinc. A screening level ecological risk assessment (SLERA) is planned to begin in FY 2026. The results may affect the 1994 ROD NFA conclusion.
Conclusion
There are no other updates to Parcel 4. Due to the planned SLERA, this area is now an ECP Category 5.
6.4 Parcel A
This parcel will be transferred to the RLRA under an EDC. See below for all environmental updates related to Parcel A. Table 1 lists all ECP property area types and the updated ECP Categories.
6.4.1 Updates to Previously Identified Sites Discussed in Earlier ECP Updates
6.4.1.1 Updates to RBAAP-001-R-01, Former Pistol Range (ECP Study Section 12/Parcel A)
This area was reportedly used for small arms target practice in the 1950s. During the 2008 site investigation, the former pistol range was investigated for the presence or absence of small arms munitions and lead contamination in the soil and around the site.
During this effort, a metal detector survey was completed, and soil samples were collected and analyzed for lead. The metal detector survey was negative for munitions, and the soil samples indicated that the levels of lead in the ground were below screening levels (USACE, 2008).
This area is adjacent to the stormwater ponds related to the stormwater conveyance system. This area is now part of the remediation efforts as described in Section 6.4.2.3 Parcel A – South of Building 6 PCB Contaminated Soil Activities and Stormwater Reservoir Conveyance System.
6.4.1.2 Updates to IRP Site RBAAP-01, Landfill
The landfill (inactive) is monitored in accordance with the Final Closure and PostClosure Maintenance Plan (USACE, 1996). The landfill cover is visually inspected weekly to ensure the remedial action is effective and cleanup objectives are attained. The cover shows no sign of degradation, no sink holes, and no surface water drainage, which indicates that the cover continues to be effective.
On April 8, 2025, a semi-truck pulling a trailer created some rutting within the drainage swale between the landfill vegetative cover terminus and the access road. The inspection of the rutting indicates no damage to the GCL liner. Once the drainage swale is restored the remedy will continue to function as designed.
The monitoring wells continue to be analyzed for cyanide (Ahtna, 2020c). These sampling events take place during sampling events for IRP Site RBAAP-03:
Groundwater Remediation. All levels of cyanide are below ROD cleanup levels [200 μg/L] (Ahtna, 2020c). Subsequent to the ROD, the cyanide levels were reduced to the State Maximum Contaminant Level (MCL) of 150 μg/L. The landfill remains an ECP
10 Category 4. The ESD # 2 formally documents the restriction of excavation of the landfill and groundwater usage as a remedy for the landfill. ESD # 2 is expected to be signed in 2nd Quarter FY 2026.
6.4.1.3 Updates to IRP Site RBAAP-03: Groundwater Remediation Background
The IRP Site RBAAP-03 contains chromium and cyanide groundwater contamination possibly resulting from leakage associated with the original IWTP. The original IWTP at RBAAP was constructed to treat the wastewaters generated from the electroplating, cleaning, and metal finishing processes that were operated on-site. From 1973 to 1980, the IWTP was upgraded. The upgraded IWTP, identified as Solid Waste Management Unit (SWMU) 1, was operated under a Resource Conservation and Recovery Act (RCRA) Part B Permit 05-SAC-06, and has since been closed (Ahtna, 2012, Ahtna 2013a through 2013m, and DTSC, 2016).
In 1985, groundwater samples from six wells located west of the RBAAP yielded concentrations of chromium above the MCL of 50 μg/L. As a result, the Army installed an interim groundwater treatment system (GWTS) and provided bottled drinking water to those affected residents followed by the extension of the Riverbank city water system to all potentially affected residents at the time. The original IWTP redwood tank area was identified as the major source of chromium contamination. The EPA added the RBAAP to the National Priorities List (NPL) on February 21, 1990, primarily due to the presence of groundwater contamination (cyanide and chromium) detected on and off-post.
The groundwater contamination was addressed in the site-wide ROD (USAEC, 1994). In accordance with the ROD, the Army began operating the existing GWTP in 1996 to treat groundwater contaminated with chromium and cyanide. Groundwater contamination plumes are currently identified as areas of groundwater that exceed the MCL for either hexavalent chromium [10 micrograms per liter (µg/L)] or cyanide (150 µg/L). The treated groundwater is discharged to the E/P Ponds under discharge permit 5B50NC00012. Analytical data from groundwater samples collected since initiation of the remedial action show that, overall, the GWTS has been effective at capturing the groundwater contamination plumes and treating groundwater to below the cyanide MCLs. However, the results of the studies indicate the GWTS system was not effective at reducing chromium concentrations to below the MCL in certain small, localized areas.
To reach the cleanup goal of 50 µg/L for dissolved chromium (at the time the regulatory threshold), a modified remedial approach using in situ treatment technologies was adopted and memorialized in ESD #1 (Army, 2013).
A Conceptual Site Model (CSM) for groundwater at the RBAAP site has been developed from 30 years of investigative and remediation data. According to the ROD, the two primary sources of groundwater contamination on-site are the landfill at the northeast end of RBAAP and potentially the former IWTP area in the east-central area of RBAAP. A secondary cyanide source area may lie between these two areas as well. Due to recent investigations and data analysis, the large, main production facility at the southern end of RBAAP was found to also be a potential chromium source area (USACE, 2014). Each of
11 these source areas has had remedial actions or remedial actions are in progress but may still provide a threat of continued groundwater degradation.
In-Situ Treatment Update
The Phase 1A of the in-situ treatment effort as described in the 2017 and 2019 ECP Update Report began August 2017. All completed actions were done in accordance with regulator approved plans. These actions included the installation of 15 injection wells in August/September 2017. All injection wells are located on Parcel A west of Building 13.
This effort consisted of two rounds of chemical injections into the injection wells. The first round of injections was completed in late September 2017 and consisted of injecting approximately 10,000 gallons of high fructose corn syrup (HFCS) into the wells. The second round of injections was completed 30 days later, in late October 2017, and consisted of injecting approximately 10,000 gallons of Ferrous Iron Sulfate (FeSO4) into the wells. The byproducts and other constituents from the injection wells have been analyzed and monitored quarterly starting in January 2018. Post-injection monitoring recommendations included to complete Phase 1B, which included reinjection into all in situ Phase I and IA injection wells in the Aʹ-Zone and B-Zones and monitoring the Aʹ-, B-, and C-Zone injection wells for dissolved, hexavalent, and total chromium. The objective of reinjection is to renew the Phase I reduction zones and provide additional treatment of dissolved chromium in the Building 13 and Landfill Areas groundwater.
The Phase IB reinjections took place in February 2020 in accordance with the work plan.
Ahtna, 2019e). Results are being monitored. A Uniform Federal Policy – Quality Assurance Project Plan (UFP-QAPP) for a new phase of in-situ treatment was completed in 2025. The new phase will consist of the injection to be accomplished in a field rather than a linear configuration.
Updated Groundwater Monitoring Results
Groundwater monitoring consists of four sampling events per year. There are four reports: two quarterly, one semiannual and one annual which include specific sets of wells completed in the various A, A,’ B, C and D portions of the aquifer. The locations of the monitoring wells are shown in Figure 2. The results of the groundwater sampling from the 2nd quarter of 2025 are shown on Figures 4, 5 and 6 (Ahtna, 2025).
Based on the Q2-2025 groundwater report, eleven A’-Zone wells yielded concentrations exceeding the hexavalent chromium Action Level (10 μg/L) in the reporting period:
MW65A’ (128 μg/L), EW69A’ (91 μg/L), MW105A’ (33.1 μg/L), MW110A’(99.1 μg/L), MW124A’(20.9 μg/L), MW125A’ (902 μg/L), MW143A’(159 μg/L), MW144A’ (249 μg/L), MW145A’ (136 μg/L), MW149A’ (209-218 μg/L), and MW152A’(33.7 μg/L). Data gaps remain in the characterization of the Building 13 Area hexavalent chromium plume boundaries in the A’-Zone (Figure 4).
• EW69A’, MW145A’, and MW149A’ yielded groundwater samples with Action Level exceedances in the reporting period, and no A’-Zone wells south-southeast of these locations were sampled.
• MW152A’ yielded groundwater samples with Action Level exceedances, and no wells are located downgradient (southwest) of this location.
12 Landfill Area dissolved chromium plume boundaries in the A’-Zone are identified in Figure 4.
Groundwater Monitoring Plan Information and Update
In 2016, Ahtna submitted an updated groundwater monitoring work plan that proposed to remove six annual sampling wells from the monitoring program, add eight annual sampling wells and add seven semiannual sampling wells to the program. In addition, the sampling frequency of ten wells was proposed to be reduced from quarterly to annual.
Also, this plan proposed to abandon 48 monitoring wells. This work plan was approved by the Water Board (Ahtna, 2016; DTSC, 2017 and Ahtna, 2017a). Since the completion of the 2017 ECP Update Report, those actions were completed and implemented. During 2018 additional modifications were requested. These modifications included the shutdown of EW72A and offsite extraction wells, installation of new offsite extraction wells and changing the frequency of sampling for the monitoring wells on the E/P pond parcel. EW72A was shut down in December 2018. A work plan was submitted and approved by Water Board in January 2019 (Ahtna, 2018d). The installation of additional wells off-site was also approved. That work was completed in 2021.
Rebound Study
The groundwater treatment system and EW63A’ was placed on standby mode (temporarily shut down) for at least eight quarters to complete a cyanide rebound study.
The goal of the rebound study was to determine whether cyanide levels have stabilized at a concentration below the action levels. During this study, groundwater from EW63Aʹ and several downgradient, cross-gradient, and upgradient monitoring wells were sampled and analyzed for cyanide, and additionally EW63Aʹ was sampled for dissolved and hexavalent chromium. The rebound study did not change the frequency of sitewide groundwater sampling. The results indicated that, for the time being, the pump and treat system is still warranted as a remedial action for cyanide. A work plan was submitted and approved in February 2020 (Ahtna, 2020a).
The rebound study began in April 2020. Recent cyanide and chromium concentrations led the State regulators to require a system restart to mitigate ongoing off-site migration and return the system to previously negotiated levels in the ROD. The Army is currently upgrading treatment system components to return the groundwater system to full time operation and will continue sampling and coordination with the regulators with regard to treatment system efficiency.
Tracer Study
The bromide tracer study (AGL, 2021) began in September 2021, and the sixth tracer study sampling event was performed in 2Q24. Six off-base downgradient wells (MW151A’, MW151B, MW152A’, MW152B, MW153A’, and MW153B) were added to the tracer study monitoring network ahead of the 2Q24 event to verify that the tracer had not migrated beyond the monitoring network without detection. Bromide was not detected at the MW150-series wells and not detected above site background levels at the IW130, IW132, or IW133-series wells. The continued tracer absence suggests groundwater velocities at the site may be slower than the historical values used to predict travel times for the Groundwater Tracer Study Work Plan (AGL, 2021).
13 6.4.1.4 Updates to SWMU 1 IWTP (ECP Study Section 13) There are no updates to the SWMU 1 IWTP. This remains an ECP Category 5 due to its proximity to the groundwater contamination plume IRP Site RBAAP – 03 (Groundwater Contamination).
6.4.1.5 Updates to Building 11, Paint and Oil Storage (ECP Study Section 1011) As discussed in the 2019 ECP report, this area was sampled for PCBs and TPH compounds. There was one area with the PCB concentrations above 1 mg/kg (7.4 mg/kg PCBs). The TPH sample results were less than the commercial/industrial worker risk levels. The recommendation for this area was to excavate soil that had PCB concentrations above 1 part per million (PPM) and not covered by hardscape. It was recommended to put a land use control on the areas that exceed 1 PPM but were under hardscape or near railroad tracks (Weston, 2018d). The UFP QAPP was approved in June 2020 (Weston, 2020). All actions were completed in accordance with the Time Critical Removal Action (TCRA) Action memo and associated work plan (Weston, 2018a and Weston, 2018b). The Final Completion Report Parcel A Soil/Sediment TCRA was completed in January 2022 (Weston, 2022) and this site will be incorporated into the Final ROD for Parcel A. This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
6.4.1.6 Updates to Structure 95, Substation No. 1 (ECP Study Section 1095) This area was excluded from further sampling, as this area is an active outdoor electrical substation. The area is fenced, secured and marked. Previous soil sample results from 2008 had a maximum concentration of 0.26 mg/kg PCBs. These levels are below any action level. The area will remain secured and marked (Weston, 2018d). It is recommended to leave this area as an electrical outdoor substation. Formal documentation is pending regulator approval. Historical dielectric fluid samples indicate that this transformer is PCB contaminated (125 mg/kg PCBs). This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
6.4.1.7 Updates to Structure 97, Substation No. 3 (ECP Study Section 1097) As part of the ESCA, this area underwent further PCB and TPH analysis to determine the extent of contamination. The maximum concentration for TPH as diesel was 6,600 mg/kg. The PCB concentrations in both the soil and concrete transformer pad were above 1 mg/kg PCBs. This transformer is inactive, and due to the PCB levels above 1 mg/kg PCBs, it was recommended that the remaining equipment be removed, as well as the contaminated soil and concrete pad (Weston, 2018d). The UFP-QAPP was approved in June 2020 (Weston, 2020). The removal action began in the summer of 2020. All actions were completed in accordance with the TCRA Action memo and associated work plan (Weston, 2018a and Weston, 2018b). The Final Completion Report Parcel A Soil/Sediment TCRA was completed in January 2022 (Weston, 2022) and this site will be incorporated into the Final ROD for Parcel A. This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
14 6.4.1.8 Updates to Structure 101, Substation spare (ECP Study Section 1101) As part of the ESCA, this area underwent further PCB analysis to determine the extent of contamination. The transformers are no longer present. The concrete was sampled, and the analytical results for the concrete yielded a PCB concentration of 6.8 mg/kg. The soil concentrations ranged from 0.074 mg/kg to 1.9 mg/kg PCBs. Due to the fact that this area is no longer used and has elevated levels of PCBs, it was recommended that the pad and contaminated soil be removed. The work plan received approval in June 2020 (Weston, 2018dcit). The UFP-QAPP was approved in June 2020 (Weston, 2020). All actions were completed in accordance with the TCRA Action memo and associated work plan (Weston, 2018a and Weston, 2018b). The Final Completion Report Parcel A Soil/Sediment TCRA was completed in January 2022 (Weston, 2022) and this site will be incorporated into the Final ROD for Parcel A. This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
6.4.1.9 Updates to Structure 145, Substation 17 (ECP Study Section 1145) This area is an active outdoor electrical substation. The area is fenced, secured, and marked. Previous soil sample results from 2008 yielded a maximum concentration of 9.5 mg/kg PCBs. Although these results are above Regional Screening Levels (RSLs), it is below the TSCA action levels. The area will remain secured and marked (Weston, 2018d).
During the site reconnaissance for the 2019 ECP effort, the transformers at substation 17 were found to be leaking (weapage). The leaking (weapage) was confirmed from the RLRA with report from an inspection of the transformers. Historical dielectric fluid samples indicate that one transformer within this substation is PCB contaminated, and the other two are non-PCB containing. The RLRA resampled in July 2024, and the western transformer contains 49 mg/kg PCBs. In response to the weapage, the RLRA sampled the transformer and the surrounding concrete. Additional remediation activities are under evaluation and will be incorporated into the Final ROD for Parcel A. This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
6.4.1.10 Updates to Building 162, Autodin A.B. Terminal Building (ECP Study Section 1162)
No updates. This area remains an ECP Category 5 due to its proximity to the groundwater contamination plume IRP Site RBAAP–03 (Groundwater Contamination).
6.4.1.11 Updates to Building 174, Hazardous Waste Storage Area (ECP Study Section 1174)
No updates. This area remains an ECP Category 5 due to its proximity to the groundwater contamination plume at IRP Site RBAAP–03 (Groundwater Contamination).
6.4.1.12 Updates to Substation 2 (ECP study section 1096) During site reconnaissance for the 2019 ECP effort, an observation was made that
15 Substation 2 was possibly leaking (weapage). Since then, the dielectric fluid was sampled by the RLRA, and the results were 3.1 mg/kg PCBs. The leaking transformer, transformer pedestal and soil were removed. All actions were completed in accordance with the TCRA Action memo and associated work plan (Weston, 2018a and Weston, 2018b). The Final Completion Report Parcel A Soil/Sediment TCRA was completed in January 2022 (Weston, 2022) and this site will be incorporated into the Final ROD for Parcel A. The transformer was disposed of offsite. The remaining transformer within Substation 2 is currently operational. This area is now ECP Category 5 due to its proximity to the groundwater contamination plume.
6.4.2 Updates to PCB and Asbestos Containing Materials (ACM) Remediation Activities
Background
PCBs were detected in Galbestos® panels on Buildings 1-8, 11, 12, 15, 33-39, 43, 45-50, 80-83, 107, 133 and 160 and attached structures prior to the completion of the 2017 ECP Update Report. Galbestos® is a galvanized sheet metal siding with a layer of asbestos felt on one side which has been dipped in an asphaltic coating containing PCBs. Over the years, the Galbestos® siding weathered, allowing a non-liquid form of PCBs to be released. Sampling results detected a release of PCBs from the Galbestos® panels above TSCA criteria as well as EPA RSLs in several locations within and adjacent to buildings in the main plant area as well as the Northwest and Southeast Storm Water Reservoirs (USACE, 2013). Studies to locate the areas with Galbestos® Panels (Weston, 2010 and USACE, 2011b), and investigate the asbestos and PCB present in air and dust at the facility (USACE, 2010) were completed.
6.4.2.1 Building Interior Activities Update
An ESCA (ESCA 1) was executed to remove PCB and Galbestos® containing dust from equipment at Riverbank. During these activities, the PCB contaminated paint on the walls below eight feet was removed, as well as the PCB paint from the pits and trenches throughout the industrial area. Seven presses were retained and remediated in-place for future use. A best management plan is in development and currently awaiting regulator approval. While the approval of a Long-Term Management Plan is pending, the Army and LRA are using an extension of the short-term Management Plan to sample areas of concern. Activities are coordinated with the regulators to ensure that there will be no unacceptable exposure to PCB containing dust and chipping paint from surfaces.
Due to the dust from the Galbestos® panels, equipment from inside the building and other materials were characterized and disposed of off-site as appropriate. This report is pending final comments from EPA TSCA.
Currently under the ESCA, various sections of the concrete floors in select buildings that were found to be contaminated with PCBs required scabbling to clearance levels in half inch intervals, or should contamination be deeper in flooring, sections were removed.
The scabbling and removal efforts are completed, and future monitoring will be included in the forthcoming ROD for Parcel A.
16 6.4.2.2 Galbestos Panel Removal Update
The Army and the RLRA executed a second ESCA (ESCA 2) to remove and dispose of the Galbestos® Panels from the buildings, as well as clean up any contamination inside the buildings, and investigate then remediate any soil contamination resulting from the deterioration of the Galbestos® outside the buildings (USACE, 2013). Galbestos® panels were removed and appropriately disposed of offsite during 2018. All actions are complete, the Army submitted the documentation in a Phase 1 report in 2020 and it is pending EPA approval.
As part of the first ESCA, the soil south of Building 6, which was contaminated with PCBs due to the Galbestos deterioration is addressed below. The outdoor, uncovered concrete spaces between the buildings, are referred to as the “courtyards.” In February 2019, a technical memo detailed all the sampling efforts that have taken place within the courtyard areas. It recommended that concrete with PCB results greater than 0.94 mg/kg PCBs be removed (Weston, 2019a). There are six areas that had PCB results above action levels, and they are located between Building 7 and 1, 2 and 3, and 4 and 5 need to have concrete removed. This work was integrated into the same work plan as other PCB remediation activities on site. The UFP - QAPP that includes this work was approved in June 2020 (Weston, 2020). It detailed that the areas that needed PCB removal actions would have concrete removed 10 feet by 20 feet, in half inch intervals until the action levels are achieved. The activities were complete in 2020 and are pending final documentation and will be incorporated into the Final ROD for Parcel A.
6.4.2.3 Parcel A – South of Building 6 - PCB Contaminated Soil Activities and Stormwater Reservoir Conveyance System
As part of preparation for the ESCA, sampling of soil in the industrial area at the south side of the plant near the railroad tracks took place and areas of soil contamination with liquid PCBs were discovered that may have been the result of dust suppression using spent oil containing PCBs during plant operations. This soil contamination was characterized and remediated as part of the ESCA 2 in 2018 as a TCRA. The actions for this area were completed as described by the TCRA Action Memo and Work Plan (Weston, 2018a and Weston, 2018b). During the remediation effort, the soil was excavated to approximately one to four feet bgs. All confirmatory samples were below the industrial action level of 0.95 mg/kg PCBs. As part of the same effort, the soil and sediment in the Northwest and Southeast storm water reservoirs were sampled for PCBs.
The concentrations are above industrial action levels. The storm water conveyance system was flushed and cleaned. Soil and sediment removal and restoration with clean fill has been completed. All actions were completed in accordance with the TCRA Action memo and associated work plan (Weston, 2018a and Weston, 2018b). The Final Completion Report Parcel A Soil/Sediment TCRA was completed in January 2022 (Weston, 2022). This area will remain an ECP Category 5 until this site is incorporated into the Final ROD for Parcel A.
6.4.2.4 PCB Equipment Update
The list of PCB-containing and contaminated equipment is provided in Table 3. Since
17 the completion of 2017 ECP Update Report, various PCB equipment was removed and disposed of properly offsite. During the 2019 ECP Update, a full inventory of transformers and other electrical equipment was completed. Additional PCB sampling will take place in the future to confirm the presence or absence of PCBs within the equipment with missing information.
Transformers at Substation 2 (ECP Study Section 1096) and Substation 17 (ECP Study Section 1145) were found to be leaking (weapage) dielectric fluid. Previous sampling of the Substation 2 transformers dielectric fluid indicate that they are non-PCB contaminated. Further information on Substation 17 can be found in Section 6.4.1.9.
Further analysis is being conducted to determine which potheads are operational.
Potentially PCB impacted equipment was observed inside Building 8 within the Production Area. This equipment was used as reservoir tanks, which part of the heavy metal presses previously used by the Army (11 units). Each unit stored approximately 100 gallons of oil, which was potentially contaminated with PCBs. The oil has been removed, and the equipment was properly disposed of offsite.
Site transformers are operational and properly labeled in accordance with federal and state regulations. Operation and maintenance procedures are in place to address operational transformers as well as leaking transformers that are discovered during inspection activities.
6.4.2.5 Plastic Waste South of Building 6
Plastic waste was stockpiled on top of a concrete area south of Building 6. The initial sampling indicates that there are low levels of PCBs. The plastic waste was addressed under the waste characterization plan approved with conditions by EPA in late 2020 (Weston, 2020). The remedial action for this site was completed and data incorporated into the Final Completion Report Parcel A Soil/Sediment TCRA (Weston, 2022) and will be incorporated into the Final ROD for Parcel A.
6.4.2.6 Former Substation 15, Building 100
Soil samples collected in May 2020 indicated PCB contamination within soil surrounding Former Substation 15 (Building 100) located in the east courtyard between Buildings 1 and 2. Two soil samples were collected and the results were 22 and 23 mg/kg PCBs.
The soil was further characterized and remediated. The concrete was scabbled and the soil removed to acceptable levels. The remedial action for this site was completed and data incorporated into the Final Completion Report Parcel A Soil/Sediment TCRA (Weston, 2022) and will be incorporated into the Final ROD for Parcel A. The remedial action for this site was completed and data incorporated into the Final Completion Report Parcel A Soil/Sediment TCRA (Weston, 2022) and will be incorporated into the Final ROD for Parcel A.
6.4.2.7 ACM Survey Update
An ACM survey was completed in 2018 and finalized in 2019 to assess the presence/absence and condition in structures and utilities for RBAAP. During this effort,
18 147 buildings were assessed. All of them are on Parcel A. Each building has a summary sheet within the final report that provides the condition and estimated quantity of each material tested. Examples of the types of materials found to be ACM are various thermal insulation, gaskets, floor tile mastic, floor tiles and various debris. The assessment confirmed the presence of friable and damaged ACM throughout various buildings (Ahtna, 2019b). An ACM re-inspection was completed in 2022 (Ahtna, 2022). See Appendix B for the table provided from the Asbestos Recertification Survey Report to see the summary of the buildings and ACM inventory.
6.4.2.8 Lead Based Paint (LBP) Survey Update
A LBP Survey was completed in 2018 and finalized in 2019 to identify the location, quantity and condition of the LBP in the buildings on RBAAP. During this effort, 147 buildings were assessed. All of them were on Parcel A. Each Building has a summary sheet within the final report that provides information on sample location, condition, sample results and estimated quantity. The assessment confirms that there is damaged LBP throughout buildings on RBAAP (Ahtna, 2019c). See Appendix C for a table from the final LBP report with a results summary for each building.
6.4.3 Preliminary Assessment/Site Inspection (PA/SI) Report During the document review, it was noted that ten areas previously had minimal site investigations, and received no further action; however, they still needed proper a PA/SI to be completed in accordance with CERCLA. The PA/SI was completed in May 2018, by Weston Solutions under the ESCA. The areas that are included in the PA/SI are listed below:
• Area of Concern (AOC) 1 – Mortar Line Accumulation Area (Building 4) (ECP Study Section 38)
• AOC 2 – Machine Shop Accumulation Area (Building 9) (ECP Study Section 39)
• AOC 3 – Vehicle Maintenance Accumulation Area (Building 15) (ECP Study Sections 40 and 1015)
• AOC 4 – Grenade Casing Line Accumulation Area (ECP Study Section 41) • RBAAP-07/AOC-7 – Phosphoric Acid Spill (Building 13, Second Floor) (ECP Study Sections 5, 7, 17, 44)
• AOC 15 – Temporary Wastewater Line (Building 13) (ECP Study Section 55) • Solid Waste Management Unit (SWMU) 13 – Incinerator (former Building 123) (ECP Study Section 25)
• SWMU-14 – Incinerator (Building 163) (ECP Study Section 1163) • SWMU 15 – Pesticide Storage Area (West of Building 11) (ECP Study Section 27)
• SWMU 16 – Pesticide Storage Area (Building 165) (ECP Study Section 28 and 1165)
19 The conclusion for the 10 sites listed above is No Further Action (Weston, 2018c).
These areas are located on Parcel A, which will have restrictions pending the finalization of the ESD #2.
6.4.4 Other Analysis
As discussed in the 2019 ECP Update report, as part of the ESCA, the soil around the following buildings were sampled and analyzed for various constituents. The building, constituent and summary of results are listed below. The details can be found in the FOSET Data Gap Report (Weston, 2019b).
• Tool Crib/Warehouse/ Offices, Building 10 (ECP study section 1010) – TPH:
The maximum result for TPH-diesel was 5.7 mg/kg, and the maximum result for TPH as motor oil was 38 mg/kg. All results were below commercial/industrial worker risk screening levels of 600 mg/kg (diesel) and 2,200 mg/kg (motor oil).
No action is recommended for this area but will have a LUC for restriction on residential reuse, pending final documentation. This area remains an ECP Category 5.
• Boiler House, Building 12 (ECP study section 1012) – TPH and Metals: One sample for TPH as diesel exceed the screening criteria, and the averages do not exceed the screening levels. PCBs within this area are above 1 mg/kg PCBs (maximum is 5.2 mg/kg) in two locations (Sample locations B012S02 and B012S04). The average for metals within the soil does not exceed the risk-based screening levels. The recommendation was to excavate the area with PCB contamination above 1 mg/kg PCBs (near sample B012S02), and to place a land use restriction on the area near B012S04 due to the impracticability of excavating the contaminated soil. The UFP-QAPP was approved in June 2020 (Weston, 2020). The soil removal is complete but pending final documentation. This area remains classified as ECP Category 5. The remedial action for this site was completed and data incorporated into the Final Completion Report Parcel A Soil/Sediment TCRA (Weston, 2022) and will be incorporated into the Final ROD for Parcel A.
• Paint Spraying Facility, Building 169 (ECP study section 1169) – Volatile Organic Compounds (VOCs): Only benzene, toluene, ethylbenzene and xylene (BTEX) compounds were found in the results, and all results were well below screening levels. No actions are recommended. The ROD is pending. This area remains an ECP Category 5.
6.4.5 Wood Debris Pile
During the ECP site reconnaissance, a wood debris pile was located on the northwest corner of Parcel A, next to the train tracks. It is believed that this wood debris pile was composed of treated railroad ties. The railroad maintenance removed the ties and no further investigation is needed.
20 6.4.6 Perfluorinated Chemicals (PFCs):
Due to the historical metal plating operations in the main production facility on Parcel A, the Army completed a PA and SI. The SI sampled for PFC compounds in the groundwater and confirmed the presence of PFCs (Leidos, 2023). A RI is underway, and the UFP-QAPP was approved in June 2025 (Leidos, 2025). The potable water from the kitchen sink was sampled for PFCs. The results were non-detect (USPHC, 2017). This has no impact on the ECP Category designations.
6.5 Potable Water System
There were a total of six water supply wells on Parcel A. The Army abandoned wells I02, I-03 and I-04. Wells I-05 and I-06 are now the primary water supply wells on the site. Well I-01 is held in reserve. As noted in Section 6.4.6, the potable water from the kitchen sink was sampled for PFCs. The results were non-detect (USPHC, 2017). In 2024 it was decided based on bacterial contamination concerns that the wells should not be used as a drinking water source. The use of groundwater will be restricted at RBAAP through ESD #2, except for the already permitted water production wells I-05 and I-06.
7.0 CONCLUSION
This ECP Update classifies the subject property into one of seven Department of Defense ECP categories as defined by ASTM D 5746-98 (2016, reapproved), Standard Classification of Environmental Condition of Property Area Types for Defense Base Closure and Realignment Facilities. Table 1 summarizes the ECP category by parcel, although all remaining Army owned parcels are planned for transfer under the FOSET.
In addition, Table 2 provides further details of the environmental condition of individual sites, as detailed in prior ECP reports.
21 8.0 CERTIFICATION
I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 40 CFR §312.10 of 40 Code of Federal Regulations 312 and I have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property.
The 2006 ECP Report, 2017, 2019, and 2024 ECP Update Reports were reviewed and found to meet the requirements set forth in §4.6.2 of ASTM D6008-22 and the narrative discussion and findings of that report are incorporated by reference into this ECP Report Update as if contained here in its entirety. __________________________ R. Curtis Payton, II BRAC Environmental Coordinator
9.0 BRAC APPROVAL
Jennifer Solomon
BRAC Program Manager
Office of the Deputy Assistant Secretary of the
Army (ODASA), Environment, Safety and
Occupational Health (ESOH)
22 10.0 REFERENCES
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Ahtna Engineering, 2013b. Closure Certification Report Hazardous Waste Management Unit #2 Coolant Recovery Unit RCRA Hazardous Waste Facility Permit Closure, RBAAP, California.
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Ahtna, 2019b. Ahtna Engineering, Asbestos Containing Material Survey, Riverbank Army Ammunition Plant, California. February.
Ahtna, 2019c. Ahtna Engineering, Lead Based Paint Survey, Riverbank Army
24 Ammunition Plant, California. February.
Ahtna, 2019d. 2019 Semiannual Groundwater Monitoring, Landfill and Groundwater Treatment Report (2019 Second Quarter), Riverbank Army Ammunition Plant, Riverbank, CA. October 2019.
Ahtna, 2019e. Addendum 2 to the Geochemical Fixation In Situ Treatment Work Plan, Riverbank Army Ammunition Plant, Riverbank, California. October 2019.
Ahtna, 2020a. Final EW63A’ Cyanide Rebound Study Work Plan, Riverbank Army Ammunition Plant, Riverbank, CA. March 2020.
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25 DTSC, 2016. Closure Certification for Hazardous Waste Facility Closure at Riverbank Army Ammunition Plant, Ca. August.
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Leidos, 2023. Site Inspection Report for Per- and Polyfluoroalkyl Substances at Riverbank Army Ammunition Plant, Riverbank, California, November.
Leidos, 2025. Final Uniform Federal Policy – Quality Assurance Project Plan, Per- and Polyfluoroalkyl Substances Remedial Investigation at Riverbank Army Ammunition Plant, Riverbank, California. June.
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USACE, 1996. Final Closure and Post-Closure Maintenance Plan, Riverbank Army Ammunition Plant Landfill, Riverbank, California, April.
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USACE, 2014. Technical Memorandum – RBAAP Source Area Assessment. April 9.
26 USACE, 2015. Final Southern Parcels 1&1A and OID Drainage Ditch Soil Data Gap Investigation Report, Riverbank Army Ammunition Plant, California. May.
USACE, 2019a. Final Evaporation/Percolation Pond Risk Screening Evaluation Memorandum, Riverbank Army Ammunition Plant, April.
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Weston, 2010. Riverbank Army Ammunition Plant – Phase II Sampling Activities, Letter Report. April 9.
Weston, 2018a. Final Action Memo Parcel A Soil/Sediment Time-Critical Removal Action. Former Riverbank Army Ammunition Plant, California. January.
Weston, 2018b. Final Work Plan Parcel A Soil/Sediment Time-Critical Removal Action.
Former Riverbank Army Ammunition Plant. February.
Weston, 2018c. Final Preliminary Assessment/Site Inspection, Former Riverbank Army Ammunition Plan, May.
Weston, 2019a. Final Courtyard Technical Memo, Riverbank Army Ammunition Plant, California, January.
Weston, 2019b. Final FOSET Data Gap Sampling Report. Former Riverbank Army Ammunition Plan, February.
Weston, 2020. Final Uniform Federal Policy – Quality Assurance Project Plan FOSET Data Gap and Courtyard Remediation. May.
Weston, 2022. Final Completion Report Parcel A Soil/Sediment Time Critical Removal Action, January.
Tables
TABLE 1
Summary of Environmental Condition of the Property Findings Parcel Acres ECP
2006
ECP
2019
ECP
2021
ECP
2026
Summary
A 77.67 6 6 5 Historic activities at RBAAP resulted in the release of hazardous substances within the main manufacturing area, Parcel A, including PCBs in soils, and chromium and cyanide in groundwater. Investigations were also conducted for VOCs, SVOCs, metals, propane, TPH, and releases from Galbestos® panel siding.
Much of the surface contamination has been completed but is pending regulatory or documentation approval.
Several groundwater remedies are in place or underway but have not been determined to be Operating Properly and Successfully.
1 8.46 5 5 5 Releases of dielectric fluid on Parcel 1 resulted in surface soil contamination of PCBs. Most of the remedial action is completed and the remainder of the contamination will be addressed in a FY26 Time Critical Removal Action (TCRA).
1A 4.37 5 5 5 Releases of dielectric fluid on Parcel 1 resulted in surface soil contamination of PCBs. Most of the remedial action is completed and the remainder of the contamination will be addressed in a FY26 Time Critical Removal Action (TCRA).
2 18.3 3 3 5 Much of the study areas on Parcel 2 were documented in the 1994 ROD as No Further Action because contamination fell below regulatory drivers or were closed under the Resource Conservation and Recovery Act Permit or Consent Order which documented no Corrective Action was necessary.
On October 1, 2025 the CA MCL for hexavalent chromium went into effect and the historic sampling data could no longer support a Area Type 3 designation.
Table 1
Summary of Environmental Condition of the Property Findings (continued) Parcel Acres ECP
2006
ECP
2019
ECP
2021
ECP
2026
Summary
2A 3.3 3 5 5 5 The chromium groundwater plume has migrated onto Parcel 2A. Several groundwater remedies are in place or underway but have not been determined to be Operating Properly and Successfully.
4 28.8 4 5 5 5 Parcel 4 is a non-contiguous parcel containing the Evaporation/Percolation Ponds (E/P Ponds). A removal action was completed prior to the 1994 ROD. In 2019, a Human Health Risk Assessment was finalized and found no unacceptable risk present for humans but no ecological risk assessment has been completed. Because additional remediation may be necessary once an ecological risk assessment is completed, the Property Area Type is updated to 5.
Environmental Condition of the Property Categories:
Category 1: Areas in which no release or disposal of hazardous substances or petroleum products has occurred, and to which there has been no migration of such substances from adjacent areas.
Category 2: Areas in which only release or disposal of petroleum products has occurred.
Category 3: Areas in which release, disposal, or migration of hazardous substances has occurred, but in concentrations that do not require a removal or other remedial response.
Category 4: Areas in which release, disposal, or migration of hazardous substances has occurred, but all removal or other remedial actions necessary to protect human health and the environment have been taken.
Category 5: Areas in which release, disposal, or migration of hazardous substances has occurred, and removal or other remedial actions are under way, but all required actions have not yet been taken.
Category 6: Areas in which release, disposal, or migration of hazardous substances has occurred, but required remedial actions have not yet been completed.
Category 7: Areas that have not been evaluated or require additional evaluation.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 1 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Parcel 2
42 AOC 5, Former
Windrowed
Area
3 3 3
Contamination in soil
No waste was stored in this area. NFA status
concurrence received from DTSC in June 1996
(as detailed in the April 15, 1996, Revision 2 of
the RFI Phase 1 Work Plan - CH2M HILL,
2002).
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2004 North Utilities 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
4, 24
RBAAP04/SWMU12,
IWTP Effluent
Sewer Line
Break
3 3 3
Contamination in soils
1994 ROD documented NFA required. DTSC
concurred with NFA status (October 30, 1995,
version of the RFI Phase 1 Work Plan) and
ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
10, 34 42 Sanitary
Wastewater
Settling
3 3 3 Contamination in soil Sampling completed in 1991. The site wide ROD (USAEC, 1994) documented NFA for this
site. Based on concerns raised about potential
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 2 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Ponds/Sludge
Beds (RBAAP10/SWMU 22)
data gaps, the Army is evaluating additional
investigation at this site.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1042 42
Building 42,
Sewage
Disposal Plant
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however. the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2010 West Open
Storage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2000 Open Land 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2000 Open Land 3 1 1 No contamination No known releases. 2001 North Railroad
area
1 1 1 No contamination No known releases.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 3 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Parcel 2A
Parcel 2A Open Space N/A 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Parcel 2A Open Space N/A 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is above the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Parcel 4 (E/P Ponds)
35, 1129,
2024
Percolation/Eva
poration Ponds
(E/P Ponds)
(RBAAP-11/
SWMU 23)
35 – 4
1129 – 3
2024 – 5 5 5 PCBs, Metals and TPH in soil
The ROD documented zinc-contaminated soil.
This removal action and concluded that no
further action was necessary at the ponds
(USAEC, 1994).
This area continues to be used for discharge of
treated water related to RBAAP-03 and is
regulated under WDRs. The WDRs require
ongoing groundwater monitoring at the E/P
Ponds. See RBAAP-03 (ECP Study Section 3)
for updates.
This site was investigated for PCBs in the
Galbestos investigation. None of the sediment
samples in the E/P ponds contained PCBs
exceeding the TSCA criteria (USACE, 2011).
In 2019 a risk assessment was finalized to
document that there is no risk to human health,
but the regulatory agencies have raised
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 4 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
additional concerns. A screening level
ecological risk assessment is planned for
FY26.
Parcel 1
49 AOC 10,
Former Solid
Waste Pile
(Southeast
Corner)
1 5 5 PCBs in soil
Investigations determined PCB contamination
was present in the soil in this area.
PCB soil remediation actions are completed.
Awaiting final documentation.
2012 South Open
Storage 1 5 5 PCBs in soil
Investigations determined PCB contamination
was present in the soil.
PCB soil remediation actions are completed.
Awaiting final documentation.
2003
South Parking
(Remainder of
Parcel 1)
1 5 5 PCBs in soil
Investigations determined PCB contamination
was present in the soil.
PCB soil remediation actions are completed.
Awaiting final documentation.
Parcel 1A
2003 South Parking 1 5 5 PCBs in soil
Investigations determined PCB contamination
was present in the soil.
PCB soil remediation actions are completed.
Awaiting final documentation.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 5 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
2003
South Parking
(remainder of
Parcel 1A)
1 5 5
PCBs in soil
Investigations determined PCB contamination
was present in the soil.
PCB soil remediation actions are completed.
Awaiting final documentation.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume. Data from the 3rd Quarter
2020 and subsequent sampling indicate that
the groundwater on the northeast corner of this
parcel is above the ROD action levels. The
groundwater contours indicate that
groundwater within this parcel is above ROD
action levels.
Parcel A
N/A NW of
Railroad
Wood Debris
Pile (Northwest
corner of
railroad tracks)
N/A 7 1 Contamination in soil
During the site reconnaissance, a debris pile
was observed. The debris appears to be
treated railroad ties. Railroad ties were
removed from the site.
1106,
1181,
2016
PCB
Contamination
Area south of
Building 6
3 6 5
PCBs in soils
Due to deteriorated Galbestos panels, the soils
to the area south of Building 6 was found to
have elevated PCBs within the soil. A TCRA
was completed and approved in 2018. The
removal actions were completed in 2017.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 6 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
N/A
Plastic Waste
South of
Building 6
N/A N/A 5 PCB in waste
A large stockpile of plastic waste has been
stored south of Building 6 on a concrete slab.
The plastic was characterized and properly
disposed of in 2023. Sampling of the concrete
below the waste indicated the risk are below
RSLs. This area will be closed out in the
planned Parcel A ROD.
1, 22, 23 Landfill
RBAAP-01,
Landfill
SWMU 10,
Landfill
(Southern
Portion)
SWMU 11,
Landfill
(Northern
Portion)
5 4 5 Cyanide and chromium
groundwater contamination
The landfill was investigated during the RI/FS
(completed in 1993). The RI concluded that it
was a major source of cyanide and a minor
source of chromium contamination to the
groundwater. The landfill underwent formal
closure in 1996 and received formal
“Construction Complete” certification on
October 30, 1995.
There are land use controls in place to
maintain the cap and conduct groundwater
monitoring as required by the 1994 site-wide
ROD.
Groundwater continues to be monitored. All
cyanide results are below ROD levels but
lowered hexavalent chromium levels and some
total chromium levels are above MCLs in the
northern portion of the landfill at MW-65 and
124 A’.
2, 30, 1161 161
RBAAP-02,
Waste Salt
Disposal Pit
(Located near
Building 161)
3 3 3
Contamination in soil NFA determination documented in 1994 Site Wide ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 7 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
See RBAAP-03 (ECP Study Section 3) for
updates.
3 RBAAP-03,
Groundwater
Contamination
5 5 5 Chromium groundwater
contamination
ROD signed in 1994 developed the remedial
goals for this groundwater contamination.
This remains a Category 5 due to the ongoing
pump and treat system, and as well the in-situ
injections. Groundwater monitoring wells have
been abandoned in accordance with the
approved groundwater plan from 2017. The
rebound study began in April 2020. The tracer
study began in 2021 and continues along with
groundwater monitoring. Additional in-situ
treatment activities are underway.
5, 7, 17, 44 13
RBAAP-05 -
Building 13,
Chromium
Pretreatment
RBAAP -
07/AOC-7
Phosphate Spill
SWMU 5
Chromium
Reduction Unit
(Building 13)
3 5 5
Contaminants in soil
RBAAP-05: NFA status documented in site
wide ROD.
RBAAP-07/AOC-7: NFA status documented in
letter from DTSC dated June 5, 1996, and is
detailed in the April 15, 1996, Revision 2 of the
RFI phase I Work Plan. PA/SI completed for
this area in May 2018. No further action.
Chromium groundwater
contamination from IRP Site
RBAAP-03
ECP Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 8 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
6, 43
RBAAP-06,
IWTP H2SO4
Spill
7 5 5
Sulfuric Acid in soil
This spill was given NFA Status based on
investigative results. Documented in closure
certifications.
The locations within SWMU 1 boundary. The
required remediation actions at SWMU 1
(IWTP) were completed in 2015.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going but levels in the area
are no longer above the MCL. See RBAAP-03
for updates.
8, 33, 1135 135
RBAAP-08/
SWMU 21
Southeast
Storm Reservoir
and Storm drain
basin
4 6 5
Chromium and cyanide in soils NFA status of chromium and cyanide in soils documented in 1994 Site Wide ROD.
PCBs in soils
This area collects storm water runoff from the
facility. After soils and storm water
conveyance system was cleaned, this area
was sampled and remediated as necessary
and in accordance with the TCRA. Pending
final documentation.
56 135 AOC 16,
Substation 5 4 4 4 PCBs in soil
Soil contaminated with PCBs (Arochlor-1260)
at concentrations greater than IPRGs has been
successfully removed from the gravel and soil
areas surrounding Substation 5 and the storm
water discharge basin. Confirmation samples
collected in 2003 from the excavation were
non-detect. Excavated soils were disposed of
properly. A ROD to properly document these
actions and decisions will be completed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 9 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
9, 32 127
RBAAP-09,
Northwest
Storm
Reservoir/
SWMU 20,
Northwest
Storm Reservoir
3 6 5
Chromium and cyanide in soils NFA documented in 1994 Site Wide ROD.
PCBs in soils
This area collects storm water runoff from the
facility. After soils and storm water
conveyance system is cleaned, the area was
remediated under a TCRA and impacted soils
removed.
12 RBAAP-001-R01, Former
Pistol Range
7 6 4
Metals in soil
NFA based on the results of the 2008 SI
changed to Category 1. The area was
remediated under a TCRA and impacted soils
removed.
PCBs in soils
This area is adjacent to the storm water
reservoir ponds which collected runoff from the
facility. After soils and storm water
conveyance system was cleaned, this area
was sampled and remediated as necessary
and in accordance with the TCRA.
13, 16, 19,
20, 31,
1043,
1044, 1173
IWTP Area
SWMU 1,
Industrial
Wastewater
Treatment Plant
(IWTP)
SWMU 4
SWMU 7
7 5 5
RCRA Permit Closure
Originally, Category 7 based on location within
SWMU 1 boundary. The required remediation
actions at SWMU 1 (IWTP) were completed in
2015/2016. Closure granted from DTSC in
August 2016. See closure reports.
Galbestos Panels Building 43 was identified to have Galbestos panels. The panels have been removed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 10 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
SWMU 8
SWMU 19 Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
Chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
14,
1174 174
SWMU 2,
Hazardous
Waste Storage
Area (Drum
Storage Facility)
5 5 5
RCRA Permit Closure
Site is the subject of the Closure Certification
Report Hazardous Waste Management Unit #3
Chromium Reduction Unit – Batch Process
RCRA Hazardous Waste Facility Permit
Closure, RBAAP, 2013. Required actions
completed in 2015/2016. DTSC granted
closure in August 2016.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going but are no longer
above the MCL. See RBAAP-03 for updates.
15 20
SWMU 3,
Empty Drum
Storage Area
(Railroad Car
Off-Loading
Area)
5 5 5
VOCs and metals in soil
Investigated during RI as potential source area.
Soil and soil gas samples collected. No metals
above background in soil samples. Soil gas
results area unlikely source of VOC
contamination. NFA documented in 1994 site
wide ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past but are no longer
above the MCL. Groundwater remediation is
on-going. See RBAAP-03 for updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 11 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
18,
1180 1
SWMU 6,
Chromium
Reduction Unit
(Building 1)
5 5 5
RCRA permit closure Site closed under RCRA permit. See closure reports. NFA.
Galbestos Panels Building 1 was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
21,
1177 177
SWMU 9,
Equipment
Wash Facility
(Building 177
Triple Rinse
Area)
5 5 5
RCRA permit closure Site closed under RCRA permit. See closure reports. NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
25 123
SWMU 13,
Incinerator
(Building 123)
5 5 5
Contamination in soils No reported releases. PA/SI completed for this area in May 2018. NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
26, 1163 163 SWMU 14,
Incinerator
5 5 5 Contamination in soils No reported releases. PA/SI completed for this area in May 2018. NFA.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 12 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
(Building 163)/
Incinerator Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
27 11
SWMU 15,
Pesticide
Storage Area
(West of
Building 11)
5 5 5
Pesticides in soils PA/SI completed for this area in May 2018.
NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
28,
1165 165
SWMU 16,
Pesticide
Storage Area
(Building 165)
5 5 5
Pesticides in soils
Samples previously collected indicate that no
contamination was detected above residential
levels. PA/SI completed for this area in May
2018. NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
29,
1170 170
SWMU 17,
Pesticide
Storage Area
(Building 170)
5 5 5 Pesticides in soils
Concrete sump removed and chlordane
contaminated soil remediated in 1994 with
Stanislaus County Environmental Resources
Department oversight. A ROD to properly
document these actions and decisions will be
completed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 13 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
36 N/A
SWMU 24,
Industrial Waste
Pipe Leak
4 5 5
Contamination in soils
Soil excavated to repair the IWPT pipe leak
was disposed of offsite. Site investigated as
part of the 1991 RI; no contamination detected.
Documented in Site Wide 1994 NFA ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
37 1, 2, 3, 4,
5, 6, 7, 12,
15, 77,
137, 170
SWMU 25,
Former
Underground
Storage Tanks
1, 6, 11A, 12,
12A, 12B, 15A,
15B, 22, 23, 24,
25, 26, 27, 28,
29, 30, 31, 32,
33, 36, 37, T77,
T137
1, 6 – 7
1, 7, 12,
15, 77, 170
- 5
2, 3, 4, 5, 6
– 3
137 - 2
3 4
UST abandonment
Tanks 11A, 24, 25, 26, 27, 28, 29, 30, 31, and
32 were removed or closed in-place. NFA
status based on closures.
Galbestos Panels
Buildings 1, 2, 3, 4, 5, 6, 7, 12 and 15 was
identified to have Galbestos panels. The
panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 14 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
38 4
AOC 1, Mortar
Line
Accumulation
Area (Building
4)
3 5 5
Contamination in soil
After closure of unit, the concrete pad that it
was on was in good condition. No sampling
required. PA/SI completed for this area in May
2018. NFA.
Galbestos Panels Building 4 was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
39 9
AOC 2,
Machine Shop
Accumulation
Area (Building
9)
5 5 5
Contamination in soil
After closure of unit, the concrete pad that it
was on was in good condition. No sampling
required. PA/SI completed for this area in May
2018. NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
40,
1015 15
AOC 3, Vehicle
Maintenance
Accumulation
Area (Building
15)
5 5 5
Contamination in soil
After closure of unit, the concrete pad that it
was on was in good condition. No sampling
required. PA/SI completed for this area in May
2018. NFA.
Galbestos Panels Building 15 was identified to have Galbestos panels. The panels have been removed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 15 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
41 N/A
AOC 4,
Grenade Line
Accumulation
Area
5 5 5
Contamination in soil
After closure of unit, the concrete pad that it
was on was in good condition. No sampling
required. PA/SI completed for this area in May
2018. NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
45 75
AOC 8A,
Horizontal
Aboveground
Storage Tanks -
Propane
Storage Tanks
5 5 5
Propane in soils
ASTs were not used for waste. Only propane
was stored within the tanks. No further action
required.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
46 85
AOC 8B,
Horizontal
Aboveground
Storage Tanks -
Transformer Oil
5 5 5 PCBs in soil
ASTs were cleaned and removed. The lines
were drained, cleaned and capped (filled with a
cement slurry). Known releases. A ROD to
properly document these actions and decisions
will be completed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 16 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Storage Tanks
(including the
Transformer Oil
Distribution
System)
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
47,
1076 76
AOC 9A,
Vertical
Aboveground
Storage Tanks
– Fuel Oil
Storage Tanks
3 3 3
AST Removal
ASTs were removed. Prior to removal, the
tanks were cleaned and visually inspected.
The tanks showed no signs on leaks. NFA
status based on investigation results.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
48,
1139 139
AOC 9B,
Vertical
Aboveground
Storage Tanks -
Fire Sprinkler
Storage Tank
1 1 1 No releases
No release or disposal of hazardous
substances or petroleum products has
occurred. Does not fall within the area of
groundwater contamination.
50, 1126,
1127 125, 126
AOC 11A,
Loading Racks
– Propane Farm
Loading/Unloadi
ng
50, 1126 –
5 1127 - 3
5 5
Propane in soil
NFA because the physical characteristics of
propane would cause it to vaporize if there
were a release. There is no potential for soil or
groundwater to be contaminated.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 17 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
51, 1137 137
AOC 11B,
Loading Racks
– Fire Sprinkler
Pumping
Station
2 2 2 POL in soil
Category 2 based on small lens of petroleum
contaminated soil remaining beneath Building
137, associated with UST T137.
52 Prod. Area
and IWTP
AOC 12,
Industrial
Wastewater
Collection
System
3 3 3
Contamination in soil
Soil investigations involving collection of soil
samples from within and adjacent to the sumps
and trenches associated with production lines
2, 3, 4 and 5 were completed in accordance
with DTSC-approved work plans. Soil samples
were collected from both the production line
trenches and sumps. The investigations did
not identify contaminants at elevated
concentrations in the soil samples. A ROD to
properly document these actions is in
production.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
53, 1178 178
AOC 13, Draw
Lube System
(Building 178)
5 5 5 POL in soils
In March 1993, during layaway activities in
Building 13, contamination was discovered on
the south side of Building 178. Thirteen soil
samples were collected and elevated oil and
grease concentrations were detected at two
locations. Soil excavation took place to
remove the contamination, an area 6-feet wide
by 16-feet long was excavated immediately
adjacent to Building 178. A ROD to properly
document these actions and decisions is in
development.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 18 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
Chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
54 Prod. Area
and IWTP
AOC 14, ZincCyanide
Wastewater
Collection
System
3 3 3
Cyanide in soils
Soil samples previously collected below and
near sump 6-11 at depths of 11 to 13 feet did
not identify elevated cyanide contaminant
concentrations. The soil investigation
completed for the portions of the cyanide
wastewater collection system near production
lines 2 through 5 did not identify any significant
elevated concentrations. A ROD to properly
document these actions and decisions is in
development.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
55 13
AOC 15,
Building 13
Temporary
Wastewater
Line
3 5 5
Temporary wastewater line
The temporary wastewater line was removed
from Building 13 and is capped outside the
building. There is no documentation of any
spills or releases associated with this unit.
PA/SI completed for this area in May 2018.
NFA.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 19 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1001 1 Production Line 7 7 5
PCBs in soils
An ESCA was executed to investigate and
remove PCBs and Galbestos in the main
production buildings located in Parcel A.
Remedial actions will be delineated in the
forthcoming ROD for Parcel A.
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates
1002 2 Production Line 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1003 3
Central and
Eastern portion
of Production
Line 3
Sumps: 3-1, 3-
2, 3-3, 3-6, 3-7,
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 20 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
3-8, 3-9, 3-10,
3-11
See RBAAP-03 (ECP Study Section 3) for
updates.
1003 3
Western portion
of Production
Line 3
Sumps: 3-1, 3-
2, 3-3, 3-6, 3-7,
3-8, 3-9, 3-10,
3-11
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the western area of this
study section currently exceeds the chromium
MCLs as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1004 4
Central and
Eastern portion
of Production
Line 4
Sumps: 4-1, 4-
2, 4-3, 4-4, 4-5,
4-6, 4-7, 4-8, 4-
9, 4-10, 4-11
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1004 4
Western Portion
of Production
Line 4
Sumps: 4-1, 4-
2, 4-3, 4-4, 4-5,
4-6, 4-7, 4-8, 4-
9, 4-10, 4-11
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the western area of this
study section currently exceeds the chromium
MCLs as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 21 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1005 5
Central and
Eastern portion
of Production
Line 5
Sumps: 5-1, 5-
2, 5-3, 5-5, 5-6,
5-8, 5-10, 5-11
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1005 5
Western portion
of Production
Line 5
Sumps: 5-1, 5-
2, 5-3, 5-5, 5-6,
5-8, 5-10, 5-11
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the western area of this
study section currently exceeds the chromium
MCLs as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1006 6 Production Line 7 7 5
PCBs in soil
An ESCA was executed to investigate and
remove PCBs and Galbestos in the main
production buildings located in Parcel A.
Remedial actions will be delineated in the
forthcoming ROD for Parcel A.
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Groundwater contamination within the western
area of this study section currently exceeds the
chromium MCLs as defined by the ROD.
Groundwater remediation on-going. See
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 22 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
updates related to RBAAP-03 (ECP study
Section 3).
1006 6
Building 6: Zinc
Plater Cyanide
Sump
7 7 5
PCBs in soil
An ESCA was executed to investigate and
remove PCBs and Galbestos in the main
production buildings located in Parcel A.
Remedial actions will be delineated in the
forthcoming ROD for Parcel A.
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Groundwater contamination within the western
area of this study section currently exceeds the
chromium MCLs as defined by the ROD.
Groundwater remediation on-going. See
updates related to RBAAP-03 (ECP study
Section 3).
1007 7
Building 7:
Production Line 5 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1008 8
Building 8:
Production Line
– Press Room
7 7 5 PCBs in soil
An ESCA was executed to investigate and
remove PCBs and Galbestos in the main
production buildings located in Parcel A.
Remedial actions will be delineated in the
forthcoming ROD for Parcel A.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 23 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Production Line
Sump
4500 Ton Press
Pit (Building 8)
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1009 9
Building 9 -
05Machine
Shop/Offices
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1010 10
Crib/Warehouse
/Offices, Former
National Guard
5 5 5
TPH in soil
Samples were collected in 2018 (FOSET Data
gap Report). The maximum result for TPHdiesel was 5.7 mg/kg, and the maximum result for TPH as motor oil was 38 mg/kg. All results
were below commercial/industrial worker risk
screening levels of 600 mg/kg (diesel) and
2,200 mg/kg (motor oil). No action is
recommended for this area. Documentation is
pending.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 24 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1011 11
Paint and Oil
Storage, Oil
Recycling and
Transport See
EBS 1998
(Building 11)
7 6 5
PCBs and TPH in soils
Was originally Category 7 based on soil
samples that identified Aroclor-1260 at
concentrations ranging from 0.4 mg/kg to 1
mg/kg (above the Industrial PRG of 0.74
mg/kg).
Samples were completed in 2018 (FOSET
Data gap). There was one area with the PCB
concentrations above 1 mg/kg (7.4 mg/kg
PCBs). The TPH sample results were less
than the commercial/industrial worker risk
levels. The recommendation for this area is to
excavate soil that has PCB concentrations
above 1 mg/kg that is not covered by
hardscape. It is recommended to put a land
use control on the areas that exceed 1 mg/kg
but are currently under hardscape or near
railroad tracks. The Uniform Federal Policy
QAPP was approved in June 2020 (Weston,
2020). Removal action completed in 2020, and
pending final documentation.
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1012 12 Boiler House 7 6 5 TPH, Metals and PCBs in soil Was previously Category 7 based on soil
samples that identified chromium in one
sample at a concentration of 144 mg/kg (above
the industrial PRG of 64 mg/kg).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 25 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Samples were collected in 2018 (FOSET Data
gap Report). One sample for TPH as diesel
exceed the screening criteria, and the
averages do not exceed the screening levels.
PCBs within this area are above 1 mg/kg PCBs
(maximum is 5.2 mg/kg) in two locations
(Sample locations B012S02 and B012S04).
The average for metals within the soil does not
exceed the risk-based screening levels. The
recommendation is to excavate the area with
PCB contamination above 1 mg/kg PCBs (near
sample B012S02), and to place a land use
restriction on the area near B012S04 due to
the impracticability of excavating the
contaminated soil. The Uniform Federal Policy
QAPP was approved in June 2020 (Weston,
2020). Removal action completed in 2020, and
pending final documentation.
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1013 13 Production Line 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 26 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1014 14
Dispensary/
Locker Rooms,
Security Office
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1016 16 Offices and
Gate House 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1017 17 Administrative
Offices 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1018 18 Cafeteria and
Offices 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1019 19 Production
Restrooms 3 3 4
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1021 21 Plant Cafeteria 3 3 4
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 27 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1022 22
Aisleway and
Office (within
Bldg. 160)
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1022 22A
Training Room
(within Bldg.
160)
(between
Building 1 and
2)
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2 and 3
Courtyard
between
Buildings 2 and
3 N/A 3 5 PCB contamination in concrete
In February 2019, a technical memo detailed
all the sampling efforts that have taken place
within the courtyard areas. It recommended
that concrete with PCB results greater than
0.94 mg/kg PCBs be removed (Weston, 2019.
The are six areas that had PCB results above
action levels, and they are located between
Building 7 and 1, and 1 and 2 need to have
concrete removed. This work was integrated
into the same work plan as other PCB
remediation activities on site. The Uniform
Federal Policy QAPP that includes this work
was approved in June 2020 (Weston, 2020). It
detailed that the areas that needed PCB
removal actions would have concrete removed
10 feet by 20 feet, in half inch intervals until the
action levels are achieved. The activities were
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 28 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
completed in 2020 and are pending final
documentation.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1023 23
Aisle way and
Office
(between
Building 3 and
4)
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates
1024 24
Aisleway and
Gage
Laboratory
(between
Building 4 and
5)
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
4 and 5
Courtyard
between
Buildings 4 and
5 N/A N/A 5 PCB contamination in concrete
In February 2019, a technical memo detailed
all the sampling efforts that have taken place
within the courtyard areas. It recommended
that concrete with PCB results greater than
0.94 mg/kg PCBs be removed (Weston, 2019).
The are six areas that had PCB results above
action levels, and they are located between
Building 7 and 1, 2 and 3 and 4 and 5 need to
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 29 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
have concrete removed. This work was
integrated into the same work plan as other
PCB remediation activities on site. The
Uniform Federal Policy QAPP that includes this
work was approved in June 2020 (Weston,
2020). It detailed that the areas that needed
PCB removal actions would have concrete
removed 10 feet by 20 feet, in half inch
intervals until the action levels are achieved.
The activities were completed in 2020 and are
pending final documentation.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1025 25
Aisleway and
Acctg Storage
Area
(between
Building 5 and
6)
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1026 26
Aisleway and
Instrument
Storage Area
(South of
Building 6)
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 30 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1027 27
Restroom and
Passage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1028 28 Restroom and
Passage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1029 29 Restroom 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1030 30 Restroom and
Passage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1031 31 Restroom and
Passage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 31 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1032 32 Restroom and
Passage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1033 33
Passage and
Distribution PNL
–
S.S. No. 1
(West passage
between
Building 7 and
1)
5 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates
1034 34
Passage and
Office (West
passage
between
Buildings 1 and
2)
5 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1035 35
Passage and
Emerg. Gen No.
7 (West passage
between
Buildings 2 and
3)
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
ECP Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 32 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1036 36
Passage
(West passage
between
Buildings 3 and
4)
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3)
1037 37
Passage and
Office
(West passage
between
Buildings 5 and
6)
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1038 38
Passage
(West passage
between
Buildings 6 and
7)
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1039 39 Central Salvage
Area 3 5 5 Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 33 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1045 45 Production Line 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1046 46 Production Line 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1047 47
Production Line
and Emerg.
Gen No. 2
(Generator
Removed)
3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 based on groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation is on-going. See RBAAP-03 (ECP
Study Section 3) for updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 34 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1048 48 Production Line
and Office 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1049 49
Production Line
and Emerg.
Gen No. 4 and
5 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1050 50
Production Line
and Emerg.
Gen No. 6
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1051 51
Laboratory,
Chemical and
Metallurgical
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 35 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1052 52
Transformer
Area –
Substation No.
10 3 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
56, 1053 53
AOC-16;
Transformer
Area –
Substation No.
5 4 4 4
PCBs in soil
Soil contaminated with PCBs (Arochlor-1260)
at concentrations greater than IPRGs has been
successfully removed from the gravel and soil
areas surrounding Substation 5 and the storm
water discharge basin. Confirmation samples
collected in 2003 from the excavation were
non-detect. Excavated soils were disposed of
properly. The final RFI recommended NFA for
AOC 16b (CH2M HILL 2005a). DTSC
concurred by approving the Final RFI Report.
ROD to properly capture PCB remediation to
be completed. The transformers have been
removed from Substation 5.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1054 54
Transformer
Area –
Substation No.
13 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1055 55 Transformer
Area –
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 36 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Substation No.
9 See RBAAP-03 (ECP Study Section 3) for
updates.
1056 56
Transformer
Area –
Substation No.
7 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1057 57
Transformer
Area –
Substation No.
12 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1058 58
Transformer
Area –
Substation No.
8 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1059 59
Transformer
Area –
Substation No.
6 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1060 60
Transformer
Area –
Substation No.
11 3 3 4
Galbestos Panels
The building where this substation is located
was identified to have Galbestos panels. The
panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 37 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
See RBAAP-03 (ECP Study Section 3) for
updates.
1061 61 Cooling Tower
Control House 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1062 62 Facilities Eng.
Store House 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1064 64
Fuel Oil
Unloading Serv.
Bldg.
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
Chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1073 73
Hose Cart
House No. 1,
Storage
7 5 5
Contaminants in soil
This area is within the boundary of SWMU 1
(IWTP). The required remediation actions at
SWMU 1 were completed in 2015/2016.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
Chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1074 74
Compressor
House, Propane
Storage. Area
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 38 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
See RBAAP-03 (ECP Study Section 3) for
updates.
1075 75 Propane
Storage Area 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1077 77
Sulfuric Acid
and Caustic
Soda Storage
7 5 5
Contaminants in soil
This area is within the boundary of SWMU1.
The required remediation actions at SWMU 1
(IWTP) were completed in 2015/2016.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1078 78 Oil Room
Building 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1080 80
Varnish
Stripping
Building
3 3 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 39 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1081 81 Production Line 3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1082 82
Tocco
Generator and
Emergency.
Generator No. 9
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1083 83 Plating Rack
Repair Area 3 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
1084 84 Loading Dock
with Canopy 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 40 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1085 85 Transformer Oil
Pump Building 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1087 87 Storage
Building 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1095 95
Transformer
Area –
Substation No.
1 7 6 5
PCBs in soil
This area was excluded from further sampling,
as this area is an active outdoor electrical
substation. The area is fenced, secured and
marked. Previous soil sample results from
2008 had a maximum concentration of 0.26
mg/kg PCBs. These levels are below any
action level. The area will remain secured and
marked (Weston, 2018d). The
recommendation is to leave this area as an
electrical substation and maintain the area as
such. This recommendation is pending
regulatory concurrence.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1096 96
Transformer
Area –
Substation No.
2 3 7 5 PCBs in soil
During the site reconnaissance, western
transformer was within this Substation was
found to be leaking (weapage). The PCB
concentration of the leaking transformer was
3.6 mg/kg PCBs. The transformer was taken
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 41 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
offline and the area remediated. Remedial
actions will be delineated in the forthcoming
ROD for Parcel A.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates
1097 97
Transformer
Area –
Substation No.
3 7 6 5
TPH and PCBs in soil
Category 6 based on potential for PCBs to
have impacted the soil adjacent from two
transformers (PCB concentrations of 64 mg/kg
and 33 mg/kg).
As part of the FOSET Data gap report effort,
this area underwent further PCB and TPH
analysis to determine the extent of
contamination. The maximum concentration
for TPH as diesel was 6,600 mg/kg. The PCB
concentrations in both the soil and concrete
transformer pad were above 1 mg/kg PCBs.
This transformer is inactive, and due to the
PCB levels above 1 mg/kg PCBs, it was
recommended that the remaining equipment
be removed, as well as the contaminated soil
and concrete pad (Weston, 2018d). The
Uniform Federal Policy QAPP was approved in
June 2020 (Weston, 2020). Removal action
completed in 2020 and is pending final
documentation in the Parcel A ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
The groundwater contamination within this
area has exceeded chromium MCLs in the
past. Groundwater remediation is on-going.
See RBAAP-03 for updates
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 42 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1098 98
Transformer
Area –
Substation No.
4 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1099 99
Transformer
Area –
Substation No.
14 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1100 100
Transformer
Area –
Substation No.
15 3 3 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
PCBs in soil
PCB contaminated soil was discovered in a
May 2020 sampling event. Concrete and soil
remediation was completed in 2024, and
further action will be included in the Parcel A
ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 43 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1101 101
Transformer
Area –
Substation
Spare
7 6 5
PCBs in soil
In 2018 as part of the FOSET Data gap effort,
this area underwent further PCB analysis to
determine the extent of PCB contamination.
The transformers are no longer present. The
concrete was sampled, and the results for
PCBs were 6.8 mg/kg. The soil concentrations
ranged from 0.074 mg/kg to 1.9 mg/kg PCBs.
Because this area is no longer used and has
elevated levels of PCBs, it is recommended
that the pad and contaminated soil be
removed. The Uniform Federal Policy QAPP
was approved in June 2020 (Weston, 2020).
Removal action completed in 2020, and further
action will be included in the Parcel A ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
The groundwater contamination within this
area has exceeded chromium MCLs in the
past. Groundwater remediation is on-going.
See RBAAP-03 for updates.
1102 102 Water Well No.
1 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1103 103 Water Well No.
2 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This is the area of a former potable water well.
This well was abandoned.
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 44 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1104 104 Water Well No.
3 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
This is the area of a former potable water well.
This well was abandoned.
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1105 105 Water Well No.
4 4 5 5
Well This is the area of a former potable water well.
This well was abandoned.
PCBs in soil
Originally Category 4 based on location with
AOC 8B.
ASTs were cleaned and removed. The lines
were drained, cleaned and capped (filled with a
cement slurry). No known releases. A ROD to
properly document these actions and decisions
will be completed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCL
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1106 106 Water Well No.
5 3 3 4 PCBs in soils
This area represents a used potable water
well.
This is within the area of the PCBcontaminated soils due to deteriorated Galbestos panel. A TCRA was completed and
approved in 2018. The removal actions were
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 45 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
completed in 2018. Awaiting final
documentation.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1107 107 Covered
Passage 5 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates
1108 108
Main
Transformer
Subst. No. 1
3 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1109 109
Main
Transformer
Subst. No. 2
and 3
7 5 5 PCBs in soil
Originally a Category 7 based on potential for
PCBs to have impacted the soil adjacent from
two transformers.
Transformers are currently not leaking.
Historical dielectric sampling for these
transformers indicate that these are non-PCB
containing transformers.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 46 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
Chromium groundwater
contamination from IRP Site
RBAAP-03
The groundwater contamination within this
area currently exceeds chromium MCLs as
defined by the ROD. Groundwater remediation
on-going. See updates related to RBAAP-03
(ECP study Section 3).
1110 110 Terminal House 4 5 5
PCBs in soil
Originally a Category 4 because of its location
within AOC 8B. ASTs were cleaned and
removed. The lines were drained, cleaned and
capped (filled with a cement slurry). Known
releases. A ROD to properly document these
actions will be completed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1114 114
Tank, Water,
Storage,
100,000
Gallons
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1117 117 Cooling Tower,
Main Plant 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1118 118 Cooling Tower,
Boiler House 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 47 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
remediation is on-going. See RBAAP-03 for
updates.
1119 119 Cooling Tower,
Steel Plant 7 5 5
Contaminants in soil
Originally Category 7 based on location within
SWMU 1 boundary. The required remediation
actions at SWMU 1 (IWTP) were completed in
2015.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1120 120
Steel Plant and
Emerg. Gen.
No. 10
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1121 121 Loading Dock,
Steel Plant 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1122 122
Crane Runway
and Steel
Storage Area
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1127 127
Storage
Sewage
Disposal Plant
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 48 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
See RBAAP-03 (ECP Study Section 3) for
updates.
1130 130 Garage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1131 131
Process Water
Tank and
System
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1133 133
Aisleway from
Bldg. 10 to Line
7 5 5 5
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1134 134 Restroom at
Line 7 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 49 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1145 145
Transformer
Substation No.
17 7 6 5
PCBs in Soil
Originally Category 7 based on potential for
PCBs to have impacted the soil adjacent from
two transformers (PCB concentrations of 28
mg/kg and 134 mg/kg).
This area was excluded from further sampling,
as this area is an active outdoor electrical
substation. The area is fenced, secured and
marked. Previous soil sample results from
2008 had a maximum concentration of 9.5
mg/kg PCBs. Although these results are
above RSLs, it is below the TSCA action
levels. The area will remain secured and
marked (Weston, 2018d).
During the site reconnaissance in 2019 and
then confirmed by the RLRA in 2020, one
transformer was within this substation was
found to be leaking (weapage). Historical
dielectric fluid sampling indicates that
easternmost transformer is PCB contaminated,
and the other two are non-PCB containing.
The transformer pad was double rinse washed.
Additional remediation activities will be
incorporated into the Final ROD for Parcel A.
This area is now ECP Category 5 due to its
proximity to the groundwater contamination
plume.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Groundwater contamination within this area
has exceeded chromium MCLs in the past.
Groundwater remediation is on-going. See
RBAAP-03 for updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 50 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1146 146
Transformer
Substation No.
18 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1147 147
Transformer
Substation No.
19 3 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
1148 148 Cooling Tower,
Building 13 3 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
1150 150 Compressor, Air 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1151 151 Compressor, Air 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1152 152
Motor
Generator
Housing
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 51 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
remediation is on-going. See RBAAP-03 for
updates.
1154 154 Compressor, Air 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1155 155 Compressor, Air 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1156 156
Production
Building – Heat
Treat
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1157 157 Compressor, Air 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1158 158 Water Well No.
6 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area represents a used potable water
well.
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 52 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1159 159 Sandblast
Building 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1160 160
Covered
Storage
Warehouse
3 3 4
Galbestos Panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates
1162 162
Autodin A.B.
Terminal Bldg. -
Training Rm
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1164 164 Paint Pumping
Building 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1166 166 Paint Pumping
Building 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1167 167 Air Compressor
No. 8 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 53 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1169 169 Paint Spraying
Facility 5 5 5
VOCs in soil
Samples collected in 2018 (FOSET Data gap):
BTEX compounds were found in the results,
but all results were below screening levels.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1171 13
Austempter
Facility –
Furnace room
3 3 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
1172 172 Former Fire
Department 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1175 175 Generator
Building 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1176 176
Switching
Station
(Electrical)
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 54 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1177 177
Equipment
Wash Facility,
Sump, Oil water
separator.
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. S ee RBAAP-03 for
updates.
1181 181 Phosphate
Facility 3 3 5
PCBs in soils
This is within the area of the PCB
contaminated soils due to deteriorated
Galbestos panel. A TCRA was completed and
approve in 2018. The removal actions were
completed in 2018 and further action will be
included in the Parcel A ROD.
Chromium groundwater
contamination from IRP Site
RBAAP-03
The groundwater within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
1182 182
Ground Water
Treatment
Facility
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1184 184
Flammable
Storage
Warehouse
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 55 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1185 185 Air Compressor
Building 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1186 186
Haz-Bin
Storage
Containment
Structure
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1187 187
Haz-Bin
Storage
Containment
Structure
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1188 188
Haz-Bin
Storage
Containment
Structure
1 1 1 No contamination
No release or disposal of hazardous
substances or petroleum products has
occurred. Does not fall within the area of
groundwater contamination.
1189 189
Land Vehicle
Fuel Disp Sta
Gas/Diesel
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1190 190
Land Vehicle
Fuel Disp Sta
Propane
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 56 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
1192 192
Ground Water
Treatment Plant
Office
3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
1195 195
Transformer
Substation No.
20 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
1196 196
Transformer
Substation No.
21 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2002 West Parking 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2003 South Parking 3 3 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume, and the northwestern
portion of this location is within an area that
has exceeded chromium MCLs. See RBAAP03 (ECP Study Section 3) for updates. 2005 West Utilities 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 57 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
2006 East Utilities 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2007 Southeast
Utilities 1 1 1 No contamination
No release or disposal of hazardous
substances or petroleum products has
occurred. Does not fall within the Area of
groundwater contamination.
2007 Southeast
Utilities 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2008 South Utilities 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area currently
exceeds the chromium MCLs as defined by the
ROD. Groundwater remediation on-going.
See updates related to RBAAP-03 (ECP study
Section 3).
2009 North Open
Storage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2011 Central Storage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 58 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
2013
North
Warehouse
Storage
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2014
West
Warehouse
Storage
5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2015 Water Storage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2016
South
Warehouse
Storage
3 6 5
PCBs in soils
This is within the area of the PCB
contaminated soils. The soils are
contaminated with PCBs due to deteriorated
Galbestos panels. A TCRA was completed
and approved in 2018. The removal actions
were completed in 2018. Final actions will be
included in the forthcoming ROD for Parcel A.
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the chromium contaminated
groundwater plume; however, the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates
2017 West Railroad
Storage 3 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within the area of this study
section currently exceeds the chromium MCLs
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 59 ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
as defined by the ROD. Groundwater
remediation on-going. See updates related to
RBAAP-03 (ECP study Section 3).
2018 East Railroad
Storage 3 3 3
Chromium groundwater
contamination from IRP Site
RBAAP-03
This area is within the Chromium contaminated
groundwater plume, however the groundwater
is below the MCLs as defined by the ROD.
See RBAAP-03 (ECP Study Section 3) for
updates.
2019 Fuel Storage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2020 Hazardous
Waste Storage 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2021 Administration
Open Area 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
2022 Medical Open
Area 5 5 5
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 60 Environmental Condition of the Property Categories:
Category 1: Areas in which no release or disposal of hazardous substances or petroleum products has occurred, and to which there has been no migration of such substances from adjacent areas.
ECP
Section
(2006)
Location
(Building or
Feature #)
Site
Name/Identifier
(Location)
ECP
Category
(2006)
ECP
Category
(2019)
ECP
Category
(2026)
Constituent
(potential and confirmed) Remedial actions
2023 7
Production
Open Area
(courtyard area
within Building
7)
5 7 5
PCB Contamination in Concrete
In February 2019, a technical memo detailed
all the sampling efforts that have taken place
within the courtyard areas. It recommended
that concrete with PCB results greater than
0.94 mg/kg PCBs be removed (Weston, 2019).
The are six areas that had PCB results above
action levels, and they are located between
Building 7 and 1, and 1 and 2 need to have
concrete removed. This work was integrated
into the same work plan as other PCB
remediation activities on site. The Uniform
Federal Policy QAPP that includes this work
was approved in June 2020 (Weston, 2020). It
detailed that the areas that needed PCB
removal actions would have concrete removed
10 feet by 20 feet in half-inch intervals until the
action levels are achieved. The activities were
completed in 2020 and are pending final
documentation in the Parcel A ROD.
Galbestos panels This building was identified to have Galbestos panels. The panels have been removed.
Chromium groundwater
contamination from IRP Site
RBAAP-03
Category 5 because groundwater
contamination within this area has exceeded
chromium MCLs in the past. Groundwater
remediation is on-going. See RBAAP-03 for
updates.
Table 2
Notification of Hazardous Substance Storage, Release, or Disposal Environmental Condition of Property Report Update (2026) 61 Category 2: Areas in which only release or disposal of petroleum products has occurred.
Category 3: Areas in which release, disposal, or migration of hazardous substances has occurred, but in concentrations that do not require a removal or other remedial response.
Category 4: Areas in which release, disposal, or migration of hazardous substances has occurred, but all removal or other remedial actions necessary to protect human health and the environment have been taken.
Category 5: Areas in which release, disposal, or migration of hazardous substances has occurred, and removal or other remedial actions are under way, but all required actions have not yet been taken.
Category 6: Areas in which release, disposal, or migration of hazardous substances has occurred, but required remedial actions have not yet been completed.
Category 7: Areas that have not been evaluated or require additional evaluation.
Transformer Location
Transformer
Volume (Gallons)
Manufacture
Date
Containing Oil
During Operation
(Yes/No)
Condition
(Good/Poor)
Laboratory Results (mg/L)
(Year Sampled)
Main #1 1,633 Unknown Y G 10 (1996); 14 (2001)*; 18 (2002)* Main #2 1633 Unknown Y G 7 (1996)
Main #3 1633 Unknown Y G 13 (1996)
SUB 1 450 Unknown Y G 125 (1996)
SUB 2 East 450 Unknown Y G 3 (1996)
SUB 2 West 450 Unknown Y P 14 (1996) SUB 2 West leakng.
SUB 4 East 129 Unknown Y G Unknown
SUB 4 Center 129 Unknown Y G Unknown
SUB 4 West 129 Unknown Y G Unknown
SUB 6 600 1986 Y G 50 (2002)*; 44.6 (2016)
SUB 7 680 Unknown Y G Unknown
SUB 8 680 1954 Y G 4.2 (2016)
SUB 9 Unknown Unknown Y G Unknown
SUB 10 680 1954 Y G 7 (2002)*; 5.8 (2016)
SUB 11 unknown unknown Y G Unknown
SUB 12 975 1952 Y G 2.1 (2016)
SUB 13 West 800 1952 Y G 60 (1996); 53 (2002)*
SUB 13 Center 750 1952 Y G 57 (1996); 46 (2002)*
SUB 13 East 750 1952 Y G 443 (1996); 363 (2002)*
SUB 14 West 145 Unknown Y G 3 (1996)
Sub 14 Center 145 Unknown Y G <1 (1996)
Sub14 East 145 Unknown Y G <1 (1996)
SUB 16 210 Unknown Y G 73 (1996)
SUB 17 Center 750 Unknown Y P 44 (1996); 34 (2001)*; 38 (2002)* SUB 17 is leaking.
SUB 17 West 750 Unknown Y P 196 (1996); 163 (2001)*; 187 (2002)* SUB 17 is leaking.
SUB 17 East 750 1952 Y P 50 (1996); 30 (2001)*; 33 (2002)* SUB 17 is leaking.
SUB 18 966 Unknown Y G 5246.5 (2016)
SUB 19 Unknown Unknown Y G Unknown
SUB 20 Not Oil Containing Unknown N G ------
SUB 21 Not Oil Containing Unknown N G ------
SUB 22 536 2004 Y G 3.4 (2016)
SUB 8 12 Unknown Y P Unknown 1 Pothead
SUB 9 12 Unknown Y P Unknown 1 Pothead
SUB 10 12 Unknown Y P Unknown 1 Pothead
SUB 12 12 Unknown Y P Unknown 1 Pothead
Former Sub 15 (Building 1) 12 Unknown Y P Unknown 1 Pothead Building 8 12 Unknown Y P Unknown 1 Pothead
Building 13 12 Unknown Y P Unknown 2-Potheads
Table 3: RIVERBANK AAP TRANSFORMERS AND OTHER PCB CONTAINING EQUIPMENT Comment
Potheads
11 Units located within
Building 8 100 each (1,100 total) Unknown Y Unknown
Each oil reservoir tank stores approximately 100 gallons of oil. Equipment no longer in use and oil has been drained.
This equipment is stored inside. They will be disposed of offsite.
SUB 3 450, 450 Unknown Y ------ Unknown
SUB 5 1250, 1250, 1250 Unknown Y ------ 24 (2016)
When operational, had three transformers within this
substation. All have been removed.
SUB 15 680, 680 Unknown Y ------ Unknown
Note: The table was taken from the 2019 ECP Update Report. During the 2019 ECP Update, a full inventory of transformers and other electrical equipment was completed.
Sources:
2016 = Applied Power Testing Inspection Lab Sheets
2001 and 2002 *= SD Meyers Inspection Report Data
1996 = Norris Industries Transformer Inpsection Lab data * Source does not have Labsheets. Data came from Lab Inspections from SD Meyers 2005 Transformer Equipment Removed from RBAAP
Oil Reservior Tanks
Figures
Min iear
Ave
Reich Ln
MW122C
MW122A�MW122
MW122B
MW121A'._,MW121C MW121B
Townsend Ave
C _,
1?
3 ;:B
QJ
u
C
·.:::
Prince-Andrew Dr
MWlllC
,��uw
MWllOA' IMW110B
MW152A' & MW152B MW153B MW153A'
• • Claribel Rd • •
J-1,W60A
•MW119A'
•MWSSA
��mR•
eMW41A
I
11 @
Building 13
Area
.... i,,;.-.---.1-- Groundwater Treatment
Plant (GWTP)
MW5A� ■
MWSB• •
Mwsc•
.
•
.
Riverbank
0.25 Miles
-
Notes:
0 225
O" 1/2"
450 Feet
l"
Well Location Map
Figure
2 MW145A' & MW145B ••
Monitoring Well
Extraction Well
Inaccessible Monitoring Well
Inaccessible Extraction Well
Injection Well
Production Well
Streets
Highways
RBAAP Boundary
Landfill Boundary
Parcel 2
Parcel 2A
APN 075023007
APN 075023005
We bste r R d
Ce ntral Ave
Autre y Ct
Pa
ved
Acce ss R oad
Me sa Dr
Ad am s Grave l Plant R d
Sne d igar R d
State Hw y 108
Figure
0 150 300 Fe e t
³3
0" 1/2" 1"
Evaporation/Percolation Pond Map
Pond 4
Pond 1
Pond 2
Pond 3
MWP-2
MWP-3
MWP-5
MWP-1
MWP-4
Monitoring Well
Highways
Streets
Evaporation/Percolation
Pond Boundary
(approximate; not a
product of survey)
Notes:
MW151A' GW: 62.4 Cr(6): ND
Cr(d): ND
CN: NSS
MW152A' GW: 60.7 Cr(6): 30.5 Cr(d): 28.6 CN: NSS MW153A' GW: 61.8 Cr(6): 0.145 J Cr(d): ND
CN: NSS
MW121A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW146A' GW: 63.2 Cr(6): 19.5 J- Cr(d): 5.05 CN: 2.80 J
MW105A' GW: 62.6 Cr(6): 6.05
Cr(d): 8.43 CN: NSS MW110A' GW: 62.3 Cr(6): 72.8 (74.2) Cr(d): 76.4 (74.9) CN: NSS
MW117A' GW: NSD
Cr(6): NSD
Cr(d): NSD
CN: NSD
MW41A' GW: 62.4 Cr(6): 6.49
Cr(d): 7.99 CN: NSS MW145A' GW: 62.5 Cr(6): 90.1 Cr(d): 99.0 CN: NSS EW69A' GW: 63.2 [1] Cr(6): 68.6 Cr(d): 68.1 CN: NSS
MW144A' GW: 62.6 Cr(6): 236 Cr(d): 246 CN: NSS MW143A' GW: 62.9 Cr(6): 66.3 Cr(d): 73.0 CN: NSS MW125A' GW: 63.1 Cr(6): 97.2 Cr(d): 104 CN: NSS
MW34A' GW: 64.1 Cr(6): 5.59
Cr(d): 6.41 CN: NSS MW147A' GW: 63.5 Cr(6): 14.5 Cr(d): 16.1 CN: NSS MW149A' GW: 63.0 Cr(6): 407 Cr(d): 448 CN: NSS
MW62A' GW: 64.0 Cr(6): NSS
Cr(d): NSS CN: 132 MW14A' GW: 64.5 Cr(6): NSS
Cr(d): NSS CN: 14.9 MW119A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
EW63A' GW: 64.1 Cr(6): 4.32
Cr(d): 4.62 CN: 25.2
EW71A' GW: NSD
Cr(6): NSS
Cr(d): NSS CN: NSD
MW65A' GW: 65.0 Cr(6): 427 Cr(d): 423 CN: 2.65 J
MW124A' GW: 64.9 Cr(6): 107 Cr(d): 110 CN: 5.72
500 feet
N
MW122A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW123A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW111A' GW: 63.6 Cr(6): 6.85
Cr(d): 13.3 CN: 18.0 MW5A' GW: NSD
Cr(6): NSD
Cr(d): NSD
CN: NSD
MW66A' GW: NSD
Cr(6): NSD
Cr(d): NSD
CN: NSD
IW128A' GW: 65.0 Cr(6): ND [2] Cr(d): ND
CN: NSS
MW61A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW102A' GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW73A' GW: 65.2 Cr(6): 4.95
Cr(d): 13.2 MW74A' CN: ND GW: 64.7 Cr(6): 34.8 Cr(d): 35.9 CN: ND MW150A' GW: 63.3 Cr(6): 8.72
Cr(d): 8.55 CN: NSS
MW17A' GW: NSD
Cr(6): NSD
Cr(d): NSD
CN: NSS
MW109A' GW: 63.0 Cr(6): 7.02
Cr(d): 7.97 CN: NSS
MW126A' GW: 63.2 Cr(6): 37.5 Cr(d): 41.2 CN: NSS MW148A' GW: 63.6 Cr(6): 77.0 Cr(d): 80.5 CN: NSS 65 ?
10 ?
?
10 50
50 10
250
10 ?
? ?
?
?
?
?
?
?
?
250 50
10 10
?
?
?
?
64 63
62 61
?
?
Figure
4 Notes:
[1] The groundwater elevation from EW69A' was
excluded from the contouring analysis.
[2] The hexavalent chromium concentration at
IW128A' was excluded from the contouring
analysis. · The Action Levels are 10 ug/L for hexavalent chromium, 50 ug/L for dissolved chromium and
150 ug/L for cyanide. Concentrations exceeding
the Action Levels are indicated in BOLD and with
yellow data boxes · Results from field duplicate samples are provided in parentheses · CN: Cyanide
· COC: Constituent of concern
· Cr(6): Hexavalent chromium
· Cr(d): Dissolved chromium
· GW: Groundwater elevation it feet above mean
sea level (2-3 June 2025) · J: Estimated value, (+/-) high or low bias · ND: Analyte not detected · NSD: No sample, dry well or insufficent water
for sampling
· NMS: No measurement scheduled
· NSS: No sample scheduled
Legend
Groundwater Well
Lines of equal groundwater
elevation
10 Hexavalent chromium
concentration in
microgams per liter (ug/L)
Lines of equal hexavalent
chromium concentration
Groundwater Flow
Direction
?
Indicates uncertainty in
the plume extents
consequent to data gaps
Groundwater Isocontour and
COC Isoconcentration Map
(2Q25, A'-Zone)
Semiannual Groundwater
Monitoring, Landfill, and
Groundwater Treatment Report
(2025 Second Quarter)
Riverbank Army Ammunition Plant
Riverbank, California
MW111B GW: 63.6 Cr(6): NSS
Cr(d): NSS CN: 7.01 EW109B GW: 63.3 Cr(6): NSS
Cr(d): NSS CN: 4.57 J
MW151B GW: 62.4 Cr(6): ND
Cr(d): 1.27 J CN: NSS
MW152B GW: 61.7 Cr(6): ND
Cr(d): ND
CN: NSS MW41B GW: 62.4 Cr(6): 4.66 (4.45)
Cr(d): 4.61 (4.38) CN: NSS MW145B GW: 61.4 [1] Cr(6): 0.243 J Cr(d): 1.94 J CN: NSS
MW125B GW: 63.0 Cr(6): 4.75
Cr(d): 4.50 CN: NSS
EW54B GW: 62.3 Cr(6): 9.05
Cr(d): 10.3 CN: NSS MW126B GW: 63.2 Cr(6): 0.165 J
Cr(d): 1.11 J CN: NSS MW118B GW: 62.9 Cr(6): 12.1 Cr(d): 15.2 CN: ND EW52B GW: Obs Cr(6): 6.08 (6.07)
Cr(d): 6.36 (6.89)
CN: 82.0 (89.3) MW146B GW: 63.2 Cr(6): 4.38 (4.42)
Cr(d): 4.93 J (22.0 J)
CN: ND (6.23)
EW72B GW: Obs Cr(6): NSS
Cr(d): NSS CN: 3.14 J MW14B GW: 64.4 Cr(6): NSS
Cr(d): NSS CN: ND
MW153B GW: 61.5 Cr(6): ND
Cr(d): ND
CN: NSS 500 feet N
MW5B GW: 64.8 Cr(6): 2.00
Cr(d): 2.85 CN: NSS
MW61B GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS 10
25 10
MW62B GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS MW34B GW: 63.4 Cr(6): 8.07
Cr(d): 9.74 CN: NSS
MW102B GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW105B GW: 62.5 Cr(6): 15.3 Cr(d): 18.1 CN: NSS MW110B GW: 62.1 Cr(6): 38.4 Cr(d): 30.8 CN: NSS MW121B GW: NMS Cr(6): NSS Cr(d): NSS CN: NSS
MW122B GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW123B GW: 61.0 Cr(6): 5.85
Cr(d): 7.31 CN: 3.29 J
MW143B GW: 62.9 Cr(6): 1.89
Cr(d): 1.71 J CN: NSS MW144B GW: 62.5 Cr(6): 0.714
Cr(d): 2.17 CN: NSS
MW147B GW: 63.5 Cr(6): 0.781
Cr(d): 3.58 CN: NSS MW148B GW: 63.4 Cr(6): 3.77
Cr(d): 4.45 CN: NSS MW149B GW: 62.6 Cr(6): 2.17
Cr(d): 2.90 CN: NSS
MW150B GW: 63.3 Cr(6): 1.58
Cr(d): 3.01 CN: NSS
MW66B GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
64 63
63 62
62 ?? ? ?
Figure 5
Notes:
[1] The groundwater elevation at MW145B was
excluded from the contouring analysis due to a
suspected erroneous measurement. · The Action Levels are 10 ug/L for hexavalent chromium, 50 ug/L for dissolved chromium and
150 ug/L for cyanide. Concentrations exceeding
the Action Levels are indicated in BOLD and with
yellow data boxes · Results from field duplicate samples are provided in parentheses · CN: Cyanide · COC: Constituent of concern · Cr(6): Hexavalent chromium · Cr(d): Dissolved chromium · GW: Groundwater elevation it feet above mean sea level (2-3 June 2025) · J: Estimated value, (+/-) high or low bias · ND: Analyte not detected · NMS: No measurement scheduled · NSS: No sample scheduled · Obs: Water level could not be measured due to an obstruction in the well
Legend
Groundwater Well
Lines of equal groundwater
elevation
10 Hexavalent chromium
concentration in
microgams per liter (ug/L)
Lines of equal hexavalent
chromium concentration
Groundwater Flow
Direction ?
Indicates uncertainty in
the plume extents
consequent to data gaps
Groundwater Isocontour and
COC Isoconcentration Map
(2Q25, B-Zone)
Semiannual Groundwater
Monitoring, Landfill, and
Groundwater Treatment Report
(2025 Second Quarter)
Riverbank Army Ammunition Plant
Riverbank, California
EW47C GW: 63.8 Cr(6): NSS
Cr(d): NSS CN: 8.01MW34C GW: 63.7 Cr(6): 3.38
Cr(d): 4.00 CN: NSS
EW54C GW: 62.3 Cr(6): 3.62
Cr(d): 3.86 CN: NSS
EW52C GW: 63.2 Cr(6): 5.09
Cr(d): 4.33 CN: 27.5
MW102C GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
500 feet N
MW105C GW: 62.4 Cr(6): 6.32
Cr(d): 8.21 CN: NSS MW121C GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW122C GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW123C GW: 61.0 Cr(6): 11.1 Cr(d): 12.9 CN: 11.7
MW125C GW: 62.9 Cr(6): ND
Cr(d): ND
CN: NSS
MW126C GW: 63.1 Cr(6): 1.70
Cr(d): 1.70 J CN: NSS MW143C GW: 62.8 Cr(6): ND
Cr(d): ND
CN: NSS
MW5C GW: 63.6 Cr(6): 2.87
Cr(d): 3.56 CN: NSS
MW61C GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS
MW62C GW: NMS Cr(6): NSS
Cr(d): NSS CN: NSS 10 ? ?
63 62
Figure 6
Notes: · The Action Levels are 10 ug/L for hexavalent
chromium, 50 ug/L for dissolved chromium and
150 ug/L for cyanide. Concentrations exceeding
the Action Levels are indicated in BOLD and with
yellow data boxes · Results from field duplicate samples are provided in parentheses · CN: Cyanide · COC: Constituent of concern · Cr(6): Hexavalent chromium · Cr(d): Dissolved chromium · GW: Groundwater elevation it feet above mean sea level (2-3 June 2025) · J: Estimated value, (+/-) high or low bias · ND: Analyte not detected · NMS: No measurement scheduled · NSS: No sample scheduled Legend
Groundwater Well
Lines of equal groundwater
elevation
10 Hexavalent chromium
concentration in
microgams per liter (ug/L)
Lines of equal hexavalent
chromium concentration
Groundwater Flow
Direction ?
Indicates uncertainty in
the plume extents
consequent to data gaps
Groundwater Isocontour and
COC Isoconcentration Map
(2Q25, C-Zone)
Semiannual Groundwater
Monitoring, Landfill, and
Groundwater Treatment Report
(2025 Second Quarter)
Riverbank Army Ammunition Plant
Riverbank, California
Appendix A
Site Reconnaissance Photos
ENCLOSURE 1 – RBAAP Parcel A – 2025 Reconnaissance Photos Building 7 – View toward East
16 SEPTEMBER 2025
Courtyard Between Bldgs. 7 & 1 – View toward East
16 SEPTEMBER 2025
Building 1 – View toward East
16 SEPTEMBER 2025
Courtyard Between Bldgs. 1 & 2 – View toward East
16 SEPTEMBER 2025
Building 2 – View toward East
16 SEPTEMBER 2025
Bldg. 160 Between Bldgs. 2 & 3 – View toward East
16 SEPTEMBER 2025
Building 3 – View toward East
16 SEPTEMBER 2025
Bldg. 16 Between Bldgs. 3 & 4 – View toward East
16 SEPTEMBER 2025
Bldg. 4 – View toward East
16 SEPTEMBER 2025
Bldg. 80 Between Bldgs. 3 & 4
16 SEPTEMBER 2025
Bldg. 83 Between Bldgs. 3 & 4
16 SEPTEMBER 2025
Bldgs. 147 & 157 Between Bldgs. 4 & 5
16 SEPTEMBER 2025
Bldg. 6 – View toward East
16 SEPTEMBER 2025
Bldg. 5 – View toward West
16 SEPTEMBER 2025
Bldgs. 43 &173 – View toward Southwest
16 SEPTEMBER 2025
Bldg. 12 – View toward South
16 SEPTEMBER 2025
Bldg. 12 – View toward Northeast
16 SEPTEMBER 2025
Bldg. 120H – View toward West and Northwest
16 SEPTEMBER 2025
Bldg. 120 – View toward South
16 SEPTEMBER 2025
Bldg. 172 – View toward East
16 SEPTEMBER 2025
Bldg. 169 – View toward Northeast
16 SEPTEMBER 2025
Bldg. 159 – View toward North
16 SEPTEMBER 2025
Bldg. 11 – View toward South
16 SEPTEMBER 2025
Bldg. 11 – View toward South
16 SEPTEMBER 2025
Bldg. 137 – View toward Southeast
16 SEPTEMBER 2025
Bldg. 156 – View toward Southwest
16 SEPTEMBER 2025
Bldg. 15 – View toward West
17 SEPTEMBER 2025
Bldg. 130 – View toward Northwest
17 SEPTEMBER 2025
Poles at Rail Spur – View toward Southeast
17 SEPTEMBER 2025
Bldg. 9 – View toward South
17 SEPTEMBER 2025
Bldg. 15 – View toward East
17 SEPTEMBER 2025
Bldg. 8 – View toward South
18 SEPTEMBER 2025
Bldg. 46 – View toward West
18 SEPTEMBER 2025
Bldg. 48 – View toward Southwest
18 SEPTEMBER 2025
Bldg. 49 – View toward West
18 SEPTEMBER 2025 Bldg. 5 – View toward West
18 SEPTEMBER 2025
Bldg. 50 – View toward Southwest
18 SEPTEMBER 2025
Bldg. 120 – View toward East
18 SEPTEMBER 2025
RECONNAISSANCE PHOTOS OF TRANSFORMER SUBSTATIONS
Substation 4 – View toward Southwest
17 SEPTEMBER 2025
Substation 1 – View toward East
17 SEPTEMBER 2025
Substation 12 – View toward Northeast
17 SEPTEMBER 2025
Substation 12 – View toward West
17 SEPTEMBER 2025
Substation 7 – View toward North
17 SEPTEMBER 2025
Substation 7 – View toward South
17 SEPTEMBER 2025
Transformer West of Building 13 –
View toward West
17 SEPTEMBER 2025
Substation 18 – View toward Southeast
18 SEPTEMBER 2025
Substation 18 – View toward Southeast
18 SEPTEMBER 2025
Substation 17 (west transformer) –
View toward South
18 SEPTEMBER 2025
Substation 17 (center transformer) –
View toward South
18 SEPTEMBER 2025
Substation 17 (east transformer) –
View toward South
18 SEPTEMBER 2025
Substation 14 (east transformer) –
View toward South
18 SEPTEMBER 2025
Substation 14 (center transformer) –
View toward South
18 SEPTEMBER 2025
Substation 14 (west transformer) –
View toward South
18 SEPTEMBER 2025
Appendix B
Table 1 from ACM Inspection Report: Asbestos Inventory Summary
Asbestos Survey Report Table 1. Asbestos Inventory Summary Riverbank Army Ammunition Plant Riverbank, CA Ahtna Environmental, Inc. Page 1 of 4 Begin End Asbestos PLM Asbestos Point Count 1 Former Production Line Area 1951 34,201 7/11/2018 7/12/2018 78 3 Yes Yes Yes Yes Yes 2 Former Production Line Area 1951 34,201 7/12/2018 7/12/2018 54 0 Yes Yes Yes Yes Yes 3 Former Production Line Area 1951 34,201 7/13/2018 7/13/2018 54 0 Yes Yes Yes Yes Yes 4 Former Production Line Area 1951 34,201 7/16/2018 7/16/2018 51 0 Yes Yes Yes Yes Yes 5 Former Production Line Area 1951 34,201 7/13/2018 7/13/2018 66 0 Yes Yes Yes Yes Yes 6 Former Production Line Area 1951 34,201 7/16/2018 7/16/2018 87 0 Yes Yes Yes Yes Yes 7 Former Production Line Area 1951 71,622 7/17/2018 7/17/2018 140 6 Yes Yes Yes Yes Yes 8 Former Production Line Area 1951 48,225 7/17/2018 7/18/2018 66 3 Yes Yes Yes Yes Yes 9 Machine Shop Offices 1951 37,800 7/3/2018 7/4/2018 114 0 Yes Yes Yes Yes No 10 Crib/Warehouse/Office National Guard 1951 20,338 6/27/2018 6/28/2018 85 0 Yes No Yes No No 11 Paint & Oil Storage, Recycling & Transport 1951 12,451 7/3/2018 7/4/2018 54 0 Yes No Yes Yes Yes 12 Former Boiler House - Now Tenant Occupied 1951 6,240 6/26/2018 6/26/2018 54 0 Yes No Yes Yes No 13 Production Line - Rectifier House 1951 38,000 6/28/2018 6/29/2018 125 0 Yes Yes Yes Yes Yes 14 Security Office & Locker Rooms 1951 10,888 7/2/2018 7/2/2018 78 6 Yes No Yes No No 15 Transformer Servicing Facility 1951 3,200 6/27/2018 6/27/2018 21 0 Yes Yes Yes No No 16 Office and Gate House 1951 3,740 7/3/2018 7/4/2018 93 0 Yes Yes Yes Yes No 17 Administrative Office 1951 7,308 7/3/2018 7/4/2018 87 3 Yes No Yes No No 18 Cafeteria and Offices 1951 2,819 7/2/2018 7/2/2018 57 3 Yes Yes Yes Yes No 19 Production Restrooms 1951 501 6/19/2018 6/19/2018 33 3 Yes Yes Yes Yes No 20 Empty Barrel Storage 1951 14,800 6/5/2018 6/5/2018 0 0 No NA NA NA No 21 Plant Cafeteria 1951 6,916 7/9/2018 7/9/2018 78 4 Yes Yes Yes No No 22 Aisleway and Office 1951 1,976 6/20/2018 7/9/2018 39 0 Yes No Yes Yes No 23 Aisleway and Office 1951 2,652 6/20/2018 6/20/2018 60 3 Yes No Yes Yes No 24 Aisleway and Gage Laboratory 1952 1,976 7/9/2018 7/9/2018 54 0 Yes No Yes Yes No 25 Aisleway and Accounting Storage Area 1952 2,652 6/13/2018 6/19/2018 60 6 Yes No Yes Yes No 26 Aisleway and Instrument Storage Area 1951 1,976 6/18/2018 6/18/2018 69 3 Yes No Yes Yes No 27 Restroom and Passage 1951 1,053 7/9/2018 7/9/2018 45 3 Yes No Yes Yes Yes 28 Restroom and Passage 1951 1,053 7/9/2018 7/9/2018 48 0 Yes No Yes Yes No 29 Restroom 1951 1,053 6/19/2019 6/19/2019 33 2 Yes No Yes No No 30 Restroom and Passage 1951 1,053 6/13/2018 6/20/2018 66 0 Yes Yes Yes No No 31 Restroom and Passage 1951 1,053 6/20/2018 6/20/2018 45 0 Yes No Yes Yes No 32 Restroom and Passage 1951 1,053 7/5/2018 7/5/2018 51 6 Yes No Yes Yes No 33 Passage and Distribution PNL 1951 1,520 6/21/2018 6/21/2018 24 0 Yes No Yes Yes No 34 Passage and Office 1952 1,539 7/5/2018 7/6/2018 39 3 Yes Yes Yes Yes No 35 Passage and Emergency Generator #7 1952 1,539 7/5/2018 7/6/2018 39 0 Yes Yes Yes Yes No 36 Passage 1952 1,053 6/21/2018 6/21/2018 24 3 Yes Yes Yes No No 37 Passage and Office 1952 1,539 7/5/2018 7/6/2018 30 3 Yes Yes Yes Yes No 38 Passage 1951 1,539 6/21/2018 6/21/2018 19 0 Yes Yes Yes No No 39 Central Salvage Area 1952 2,112 7/5/2018 7/6/2018 21 0 Yes No Yes No No 43 Acid Neutralization/Cyanide Lab 1952 1,558 6/6/2018 6/6/2018 33 0 No NA NA NA No Asbestos Debris? Building No. Name Year Built Area (ft2) Survey Dates Number of Samples Asbestos? Friable? Non- Friable? Damaged ACM?
Asbestos Survey Report Table 1. Asbestos Inventory Summary Riverbank Army Ammunition Plant Riverbank, CA Ahtna Environmental, Inc. Page 2 of 4 Begin End Asbestos PLM Asbestos Point Count Asbestos Debris? Building No. Name Year Built Area (ft2) Survey Dates Number of Samples Asbestos? Friable? Non- Friable? Damaged ACM? 44 Acid Neutralization/Cyanide Destruction 1952 12,240 6/7/2018 6/7/2018 15 0 Yes No Yes No No 45 Production Line 1952 7,293 7/10/2018 7/18/2018 18 0 Yes Yes Yes Yes No 46 Production Line 1952 8,200 7/10/2018 7/18/2018 21 0 Yes Yes Yes Yes No 47 Production Line and Emergency Gen #2 1952 8,360 7/10/2018 7/18/2018 30 3 Yes Yes Yes Yes No 48 Production Line and Office 1952 8,400 7/10/2018 7/18/2018 30 0 Yes Yes Yes Yes No 49 Production Line and Emergency Gen #4/5 1952 10,548 7/11/2018 7/18/2018 39 0 Yes Yes Yes Yes No 50 Production Line and Emergency Gen #6 1952 10,420 7/11/2018 7/18/2018 33 0 Yes Yes Yes Yes No 51 Laboratory Chemical and Metallurgical 1952 3,800 6/19/2018 6/19/2018 24 2 Yes Yes Yes Yes No 52 Transformer Area - Substation #10 1951 700 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 53 Transformer Area - Substation #5 1952 1,200 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 54 Transformer Area - Substation #13 1952 1,200 6/4/2018 6/4/2018 0 0 Yes Yes Yes Yes No 55 Transformer Area - Substation #9 1952 1,868 6/4/2018 6/4/2018 0 0 Yes No Yes No No 56 Transformer Area - Substation #7 1952 600 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 57 Transformer Area - Substation #12 1952 600 6/4/2018 6/4/2018 0 0 Yes Yes Yes Yes No 58 Transformer Area - Substation #8 1952 600 6/5/2018 6/5/2018 0 0 Yes No Yes Yes No 59 Transformer Area - Substation #6 1952 600 6/5/2018 6/5/2018 0 0 Yes No Yes Yes No 60 Transformer Area - Substation #11 1952 564 7/10/2018 7/10/2018 0 0 Yes No Yes No No 61 Cooling Tower Control House 1952 300 6/11/2018 6/18/2018 15 6 Yes No Yes Yes No 73 Tuff Shed Unknown 455 7/19/2018 7/19/2018 6 0 No NA NA NA No 74 Compressor House, Propane Storage Area 1951 1,240 6/8/2018 6/8/2018 12 0 Yes No Yes No No 75 Propane Storage Area 1952 83,400 6/8/2018 6/8/2018 9 0 Yes No Yes No No 76 Fuel Oil Storage Area, Water Tanks (2) 1951 1,600 6/5/2018 6/5/2018 21 0 No NA NA NA No 77 Sulfuric Acid and Caustic Soda Storage 1952 1,591 6/6/2018 6/6/2018 3 0 No NA NA NA No 78 Oil Room Building 1951 1,100 6/20/2018 6/20/2018 33 0 Yes No Yes No No 79 Scale House 1952 66 6/25/2018 6/25/2018 3 0 No NA NA NA No 80 Varnish Stripping Building 1953 2,211 7/5/2018 7/5/2018 36 0 Yes Yes Yes Yes No 81 Production Line 1953 11,001 7/10/2018 7/10/2018 33 0 Yes Yes Yes Yes No 82 Tocco Generator & Emergency Gen #9 1953 1,638 7/10/2018 7/19/2018 18 0 Yes No Yes Yes No 83 Plating Rack Repair Area 1951 714 6/13/2018 6/13/2018 24 0 Yes No Yes No No 84 Loading Dock with Canopy 1951 764 7/5/2018 7/6/2018 9 0 No NA NA NA No 85 Transformer Oil Pump Building 1951 169 6/6/2018 6/6/2018 18 0 Yes No Yes No No 87 Storage Building 1951 270 6/28/2018 6/28/2018 21 0 Yes No Yes No No 95 Transformer Area - Substation #1 1951 280 6/4/2018 6/4/2018 0 0 Yes No Yes No No 96 Transformer Area - Substation #2 1952 540 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 97 Transformer Area - Substation #3 1952 1,050 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 98 Transformer Area - Substation #4 1953 400 6/5/2018 6/5/2018 0 0 Yes No Yes Yes No 99 Transformer Area - Substation #14 1953 600 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 100 Transformer Area - Substation #15 1952 600 6/5/2018 6/5/2018 0 0 No NA NA NA No 101 Transformer Area - Substation Spare 1953 600 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 102 Water Well #1 1951 64 6/6/2018 6/6/2018 24 0 Yes No Yes No No
Asbestos Survey Report Table 1. Asbestos Inventory Summary Riverbank Army Ammunition Plant Riverbank, CA Ahtna Environmental, Inc. Page 3 of 4 Begin End Asbestos PLM Asbestos Point Count Asbestos Debris? Building No. Name Year Built Area (ft2) Survey Dates Number of Samples Asbestos? Friable? Non- Friable? Damaged ACM? 106 Water Well #5 1951 199 6/8/2018 6/8/2018 18 0 Yes No Yes Yes No 107 Covered Passage 1951 178 7/6/2018 7/6/2018 33 0 Yes No Yes Yes No 108 Main Transformer Substation #1 1951 8,050 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 109 Main Transformer Substation #2 and 3 1951 9,650 6/4/2018 6/4/2018 0 0 Yes No Yes No No 109A Transformer Substation Unknown 900 6/4/2018 6/4/2018 0 0 Yes No Yes No No 110 Terminal House 1951 270 6/4/2018 6/4/2018 0 0 Yes No Yes No No 114 Tank Water Storage 100,000 Gallons 1951 NA 6/6/2018 6/6/2018 3 0 No NA NA NA No 117 Cooling Tower, Main Plant 1952 NA 6/11/2018 6/11/2018 0 0 Yes NA NA NA No 120 Former Steam Plant & Emergency Generator #10 1953 58,066 6/25/2018 6/25/2018 100 6 Yes Yes Yes Yes Yes 120H Addition to Building 120 2006 28,000 6/22/2018 6/22/2018 24 0 Yes No Yes No No 121 Loading Dock, Steel Plant 1953 420 6/25/2018 6/25/2018 3 0 Yes NA NA NA No 122 Crane Runway and Steel Storage Area 1953 18,332 6/25/2018 6/25/2018 3 0 Yes No Yes No No 125 Unloading Station No. 1 Propane 1951 8 6/8/2018 6/8/2018 6 0 Yes No Yes No No 126 Unloading Station No. 2 Propane 1951 48 6/8/2018 6/8/2018 9 0 Yes No Yes Yes No 127 Storage Sewage Disposal Plant 1951 160 7/19/2018 7/19/2018 6 0 Yes No Yes No No 130 Garage 1954 2,280 6/27/2018 6/25/2018 6 0 No NA NA NA No 131 Process Water Tank & System 1953 441 6/12/2018 6/12/2018 18 0 Yes No Yes No No 133 Aisleway from Building 10 to Line 7 1951 183 6/27/2018 6/28/2018 24 0 Yes No Yes No No 134 Restroom at Line 7 1953 82 7/6/2018 7/6/2018 36 2 Yes No Yes No No 135 Storm Drain Station 1953 108 6/7/2018 6/7/2018 6 0 No NA NA NA No 137 Pump House - Sprinkler System 1956 400 6/11/2018 6/11/2018 24 0 Yes No Yes No No 138 Transformer Substation No. 16 1956 120 6/7/2018 6/7/2018 0 0 Yes No Yes No No 139 Tank Water Storage 1,000,000 Gallons 1952 2,739 6/11/2018 6/11/2018 6 0 Yes No Yes No No 145 Transformer Substation #17 1967 1,321 6/4/2018 6/4/2018 0 0 Yes Yes Yes Yes No 146 Transformer Substation #18 1967 406 6/4/2018 6/4/2018 0 0 Yes No Yes Yes No 147 Transformer Substation #19 1967 960 6/13/2018 7/19/2018 15 0 Yes No Yes No No 148 Cooling Tower Building 13 1966 368 6/6/2018 6/6/2018 9 0 Yes No Yes No No 150 Compressor Air 1969 150 6/6/2018 6/6/2018 12 0 Yes No Yes No No 151 Compressor Air 1969 150 6/28/2018 6/28/2018 9 0 Yes No Yes No No 152 Motor Generator Housing 1967 636 6/28/2018 6/28/2018 3 0 Yes No Yes Yes No 154 Compressor Air 1969 168 6/13/2018 6/13/2018 9 0 Yes No Yes No No 155 Compressor Air 1969 150 6/11/2018 6/11/2018 12 0 Yes No Yes Yes Yes 156 Production Building - Heat Treat 1970 5,286 6/18/2018 6/18/2018 69 0 Yes No Yes Yes No 157 Compressor Air 1969 725 6/12/2018 6/12/2018 15 0 Yes No Yes No No 158 Water Well #6 1969 240 6/11/2018 6/11/2016 30 0 Yes No Yes No No 159 Sandblast Building 1972 144 6/5/2018 6/5/2018 6 0 Yes No Yes No No 160 Covered Storage Building 1969 21,033 7/16/2018 7/16/2018 12 0 Yes No Yes No No 162 Autodin A.B. Terminal Building 1971 1,036 6/12/2018 6/12/2018 48 2 Yes No Yes Yes No 163 Incinerator 1971 27 6/6/2018 6/6/2018 9 0 Yes No Yes No No 164 Paint Pumping Building 1974 506 7/11/2018 7/11/2018 3 0 No NA NA NA No