Alameda Point: Environmental Justice Progress Report

EPA Cites Navy PCBs in Food Chain
Alameda Point Considered for Superfund

The US EPA released a formal public notice that it proposes to add the Alameda Point Naval Air Station to its list of the most dangerous toxic waste sites in the country. Alameda Point received a Hazard Ranking System (HRS) score of 50, well above the 28.5 score needed to be recommend for the Superfund National Priority List. The HRS score was entirely attributed to the impact of Polychlorinated Biphenyls on the Human Food Chain.

EPA's HRS scoring process considered the health impacts of one of 25 toxic waste sites at Alameda Point. The HRS score places Alameda Point among the top 200 uncontrolled hazardous waste sites in the country. Lawrence Livermore National Laboratory is the only current Superfund site in Alameda County. US Navy facilities at Hunter's Point, Treasure Island, and Moffett Field are also on the Superfund National Priority List.

The only toxic waste site considered in the HRS score for Alameda Point was IR Site 2, the West Beach Landfill. Highly contaminated sediments dredged from the Sea Plane lagoon (IR Site 17) were disposed of in the West Beach landfill in 1981. From 1940 to 1975, the Sea Plane lagoon received 350,000 to 575,00 gallons per day of untreated industrial waste containing a collection of metals, solvents and oils.

The only chemical considered by the EPA during the HRS was polychlorinated biphenyls (PCBs). Cal-EPA found PCBs in 100 percent of fish tissue samples collected from San Francisco Bay. PCBs is one of the chemicals responsible for a public health advisory on consuming more than four ounces of fish from San Francisco Bay per month. Children and pregnant women are suggested to avoid eating fish from San Francisco Bay altogether.

Superfund listing was proposed to get the Navy to take full responsibility for the environmental and human health impacts of their operations in Alameda. The impact of Navy operations on the San Francisco Bay fishery and subsistence fisherman is a National Health Priority in the eyes of the US EPA.

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Is Coast Guard Housing Safe?
Toxic Hot Spots in Play Areas

At the Restoration Advisory Board (RAB) meeting in May 1999, the Base Cleanup Team (Cal-EPA, US EPA and US Navy) indicated that the Coast Guard Family Housing (Parcel 181) was still under consideration for inclusion in the Toxic Waste Site Cleanup Program at Alameda Point. Seventy soil samples were collected from Parcel 181 in February and April 1999. Chemical analysis of these samples revealed that widespread contamination at the now closed Estuary Park has spread into the surrounding Coast Guard Family Housing. Estuary Park was added to the Toxic Waste Site Program in May 1998.

During February 1999 sampling of the Coast Guard Family Housing the highest levels of Polynuclear Aromatic Hydrocarbons (PAHs) were found in a playground equipment area. This toxic hot spot remains accessible to the children of Coast Guard families. Soil samples were also collected from the rear yards of six residents (see inside for addresses and results).

PAHs were found in 100 percent of the 55 sample locations from the Coast Guard Housing Area. Concentrations of total PAHs ranged from 0.05 milligrams per kilogram (mg/kg) to the 115 mg/kg found in the play equipment area. Over 80 percent of the samples exceeded the total PAH level of 0.9 mg/kg that was recently used for cleanup of a California residential area with PAH contaminants.

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Quote of the Month

"No one took responsibility for the problem."

Cal-EPA representative five years after benzene was discovered beneath the Coast Guard Housing at Alameda Point.

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City Digs Up Toxic Waste at Dog Park
Poor Site Controls Pollute Estuary

An estimated 600 tons of lead contaminated soil excavated at the Main Street Dog Park during a City of Alameda Public Works project was trucked to a Class I Hazardous Waste landfill during May. The discovery of toxic wastes at the City of Alameda Dog Park is another example of the unreliability of the Navy's Environmental Baseline Surveys that are currently used to evaluated toxic hazards prior to transfer and reuse. Concerns about contamiantion at the Dog Park were expressed in a letter to the City of Alameda Planning Director in July 1998.

The City of Alameda Public Works installed a storm drain through the middle of the Dog Park which was apparently once a toxic waste landfill. Inadequate measures to control storm water pollution were reported to City, State and Federal agencies on multiple occasions during the February to May 1999 project. Soil piles were left uncovered and allowed to erode into the Bay during rainstorms. Excavated soils were exposed to winds speeds that exceeded 50 mph creating dust that also entered the Estuary .

Problems with air quality impacts and water quality impacts from contaminated soil excavations at Alameda Point have been an ongoing problem. Despite diligent public oversight, clear and convincing evidence of violations, environmental regulatory agencies continue their practice of discriminatory enforcement of public safety laws.

Toxics in Alameda Point public parks is nothing new. Estuary Park contains the highest estimated toxin risk of any property at Alameda Point. Concerns raised about the Spike and Pitch Park stopped the use as a public park. The Main Street Soccer Field was added to the toxic waste site cleanup program in December 1998.

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Backyard Soil Sample Results Summary

	Backyard Soil Samples from Coast Guard Housing Areas						Health Standards
Carcinogenic Polynuclear Aromatic Hydrocarbons	2002A Monterey P181-16	202B Moseley P181-17	2008A Monterey P181-18	2004F Lakehurst P181-19	2001E Lakehurst P181-20	2004A Mayport P181-21	Prop 65 Significant Risk Level	Preliminary Remediation Goals
	(mg/kg)	(mg/kg)	(mg/kg)	(mg/kg)	(mg/kg)	(mg/kg)	(mg/kg)	(mg/kg)
Benzo(a)anthracene	0.26	1.86	1.11	0.36	0.91	0.33	0.2	0.56
Benzo(a)pyrene	0.44	2.98	1.76	0.57	1.61	0.54	0.30	0.056
Benzo(b)fluoranthene	0.60	3.04	2.44	0.80	1.61	0.77	0.2	0.56
Benzo(k)fluoranthene	0.11	0.57	0.47	0.21	0.37	0.17		0.56
Chrysene	0.29	1.94	0.92	0.40	0.94	0.33	1.0	5.6
Dibenz(a,h)anthracene	0.03	0.28	0.10	0.03	0.12	0.03		0.056
Ideno(1,2,3-CD)pyrene	0.14	1.46	0.52	0.17	0.66	0.17		0.56
Total PAHs	4	29	16	6	14	5
Total Cancer Risk	10	71	42	14	37	13

NOTES

1. Sample results shown in bold exceed one of the screening standards.
   
2. Based on Proposition 65 No significant risk levels for Benzo(a)anthracene (0.04 µg/day), Benzo(a)pyrene (0.06 µg/day), Benzo(b)fluoranthene (0.04 µg/day),and Chrysene (0.2 µg/day) and estimated childs intake of 200 mg/day soil.
3. Preliminary Remediation Goals were developed by the Region IX Environmental Protection Agency.
   
4. Total PAHs include sum of 17 PAHs. Cal-EPA used a cleanup value of 0.9 mg/kg total PAHs during cleanup of a residential area in Alhambra, California.
   
5. Residential cancer risk is number of excess cases in a population of one million. A cancer risk of 1.0 is considered acceptable.
   

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Navy's Toxin Surveys Miss Toxic Hot Spot
Playground Built Amidst Toxic Wastes

According to minutes of the June 1998 Restoration Advisory Board meeting the Navy explicitly approved construction of play ground equipment areas at Parcel 181. Sampling completed in February and April 1999 indicate that the playgrounds are located in toxic hot spots. In fact the highest concentration of benzo(a)pyrene of 15.5 mg/kg was found in Sample P181-03-0.5 located in a play equipment area on Moseley Avenue. The concentration of benzo(a)pyrene in soil was 276 times the Preliminary Remediation Goal, representing a cancer risk in excess of 100 additional cancer cases in a population of one million.

The benzo(a)pyrene concentration found in soils should have resulted in a fence and warning signs being installed around the unsafe play equipment areas. The fact that these actions have not take place is inconsistent with federal and state policies for human health risk assessments. Parcel 181 is another clear example of the inadequacy of Navy Environmental Baseline Surveys which have consistently over-looked significant toxic waste disposal areas. People's lives depend on the quality of the EBS Reports, and the 1998 EBS for Parcel 181 did not even identify PAHs as chemicals of concern.

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Coast Guard Housing's Benzene Plume
Navy Model Unprotective of Indoor Air

Risk estimates made using a computer model available from the US EPA's web-site indicates that benzene found in groundwater at concentrations of 1.4 milligrams per liter beneath Coast Guard housing represents an unacceptable cancer risk of 80 in one million. The risk model evaluates subsurface vapor intrusion into buildings. The US Navy has relied on a less protective and controversial method to estimates cancer risks in buildings that overlie groundwater contamination. The Navy estimated 1.6 excess cancer cases in a population of one million.

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Developers of Subsidized Luxury Housing Insult the Public at Forum

Details were promised in advertisements for a May 26, 1999 public forum on East Housing. Catellus Development Corporation's latest architectural renderings of their gated community did little to deliver on this promise. Questions about the number of houses, the sizes of houses and the price of houses were simply not answered.

It was clear that many in attendance at the public meeting were insulted by the City's and Catellus' indifference to community housing concerns and the lack of details presented to the public.

Residents of Catellus' future development will enjoy police and fire protection that is paid for by the very people insulted at the public meeting. The same people the gates and the housing prices at Catellus' development intend to keep out.

Why are low-income people subsidizing a luxury-home development? All property taxes in the Alameda Point Improvement Project redevelopment area must be spent on capital improvements and economic development. There are no property tax revenues to pay for public services.

If the development of Alameda Point is to be subsidized by the community it should be developed in a manner that is responsive to community needs. Catellus and the City have made it clear they will not be responsive to the community.

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Question Authority - Imminent and Substantial Endangerment already

The conditions reported in the Coast Guard Housing area Parcel 181 should have resulted in an imminent and substantial endangerment determination by the Base Cleanup Team (BCT) when results of February 1999 soil sampling was originally reported. Instead the BCT attempted to collect additional soil samples to average down the risk. This risk averaging was also tried at the now closed Estuary Park Toxic Waste Site, where it too was largely unsuccessful. There remains a serious public health problem in a play equipment area and the BCT's solution is to allow additional families to move-in and be exposed to this high cancer risk. Call the BCT and ask them if Parcel 181 is considered perfectly safe just what does constitutes a human health risk?

• Steve Edde, Navy Program Coordinator, sledde@efawest.navfac.navy.mil
  
• Lyn Suer, US Environmental Protection Agency, suer.lynn@epamail.epa.gov
  
• Anne-Marie Cooke, US Environmental Protection Agency, cook.anna-marie@epamail.epa.gov
  
• Mary Rose Cassa, California Environmental Protection Agency, MCASSA@HW1.cahwnet.gov
  

The Environmental Justice Progress Report is the newsletter of West End Concerned Citizens (WECC). WECC has been monitoring the toxic cleanup planning process at the Alameda Point Naval Air Station (NAS) since 1995. Our community members have become increasingly frustrated at the lack of response to the public's concerns, the inadequate information provided to the public, and the lack of opportunities for the public to participate in the decision making process.

To receive a free copy of the this monthly report of for more information, please contact us at clearh2orev@toxicspot.com.