Environmental Justice Progress Report

Cleanup Schedule Update
Tiered Screening Introduced

• Is tiered-screening an environmental justice issue?
  
• Tiered-screening workshop scheduled
  

Community Acceptance Criteria Update

• Proposed Community Acceptance Criteria for soil Excavation
  

Is the Northwest Territory Going To Waste?

Group 1: IR sites 3, 6, 7, 8, 9, 11, 12, 14, 15, 16, 22, 23

Group 2: IR sites 4, 5, 10, 13, 19, 21

Group 3: IR sites 1, 2

Group 4: IR sites 17, 18, 20

Alameda NAS has been divided into 206 separate parcels of land. Environmental baseline surveys of these 206 parcels will be used to determine if land pollution, or construction materials (lead paint or asbestos) prevents the property from being leased or from being transferred to the City of Alameda.

Alameda NAS created the Tiered Screening Method to evaluate the land pollution identified in the 206 environmental baseline surveys. The method will be used to determine which of the 206 parcels require no pollution cleanup and which parcels should be placed in one of three land pollution cleanup programs: Superfund, Hazardous waste treatment or storage sites, and leaking underground storage tank sites.

Currently at NAS, 23 properties are being handled under the Superfund cleanup program, 22 properties are being handled under the hazardous waste cleanup programs, and approximately 60 sites are being handled under the leaking underground fuel storage tank cleanup program.

The principle concern raised by regulators with the tiered-screening method is its consistency with the existing state and federal regulations and requirements. Questions remain on whether tiered screening will provide an equivalent or greater level of protection from pollution as the standard method for evaluating land pollution. It is uncertain if the tiered screening may also create regulatory burdens for future property users such as (Proposition 65) disclosure requirements which may not exist if the standard method was used.

The use of a novel property evaluation method such as tiered screening was also a concern addressed at the February RAB. Does it hamper community participation and understanding and the ability for independent experts to review pollution cleanup decisions? Does it overly restrict future land uses?

A workshop on the Tiered Screening Method will be hosted by Alameda NAS to address some of these community concerns which were raised at the RAB meeting. The workshop will be held at the RAB Library in Building 1, at 7 pm, March 18, 1997. The public is welcome, call (510) 263-3706 for more information.

The community acceptance criteria was prepared by West End Concerned Citizens and is intended to be a proactive demonstration of community involvement. WECC members have become increasingly frustrated at the lack of response to the publicÕs concerns, the inadequate information provided to the public, and the lack of opportunities for the public to participate in the decision making process during the land pollution cleanup at NAS. An updated draft of the Community Acceptance Criteria was distributed at the February RAB meeting.

Normally the communityÕs opinions are sought after much time and effort has been invested by the Navy and regulators in planning a cleanup strategy. Community involvement has the effect of delaying cleanup or increasing cleanup costs when the community feels their concerns are not addressed by the NavyÕs proposed cleanup plans.

The community acceptance criteria are intended to provide the Navy and regulators with guidance during the cleanup planning stage increasing the likelihood that the final cleanup plans are consistent with the local communities environmental and economic sustainability goals.

Due to the ongoing mismanagement of contaminated soil at NAS specific criteria have been developed to address handling of contaminated soils to prevent off-site impacts (dust or stormwater pollution). Regulators and the Navy have been preparing a similar soils handling protocol for over six months but have not allowed for community participation in the protocol development nor has the Navy released a final report on this issue.

Excavation: No soil is to be excavated or handled when the wind speed exceeds 15 mph. Projects involving the excavation of over 1,000 cubic yards should include ambient air quality monitoring for dust and contaminants. Ambient air monitoring should be performed when performing contaminated soil excavation in sensitive areas such as Site 16 adjacent to Encinal High School.

Soil stockpiling: Contaminated soils should be handled in dedicated areas with adequate storm water run off protection. Stock piles should be placed a minimum distance of 2,000 feet from residences and 500 feet from surface water and seasonal wetlands. Soil stockpiles should be covered and the covers should be inspected daily with repairs to cover made immediately. No soil stockpiling shall be performed unless adequate project funding is available to remove soil.

Transportation: All dump trucks are to be covered when traveling on or off base. Off island transportation should follow approved routes for hazardous materials. Travel times should be limited to the weekday hours of 8 am to 4 pm.

Wet Weather Work (October - May): All work sites and nearby storm drains should be protected from soil and contaminated runoff during all soil excavation work.

It is difficult to argue that the northwest territory has become a dumping ground for contaminated soil. The territory was already the site of four of the 23 IR sites (sites 2, 14, 15, 20), and five RCRA corrective action sites. The territory has become the disposal area for Site 15 soils contaminated with PCBs and lead. A washwater recycling plant, part of the Site 18 storm water cleanup project is located in this area. The plant which produces a lead and petroleum contaminated sludge was cited for hazardous waste violations by Cal-EPA in November 1996. In January 1997 soils contaminated with motor oil and jet fuel was moved from Site 13 and disposed of in the northwest territory. Several months after being excavated during the performance of a technology demonstration project at Site 2, soils potentially contaminated with chlorinated solvents remain stockpiled along the shoreline.

The manner in which the soil disposal occurred in the territory has created serious obstacles to property reuse and raises concerns about the long-term effectiveness of cleanup decisions at NAS.