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Volume 33, July 2000

Table of Contents

Explanation of Marsh Crust Contamination a Fairy Tale
Final Plan calls for No Cleanup of School, Housing Sites

The Draft Remedial Action Plan/Record of Decision (June 20, 2000) for the 700 acre marsh crust toxic waste site is such a fairy tale that your imagination is required to agree with the characterization of this contamination. If the fair tale is true, its preferred solution demonstrates that the US EPA, Cal-EPA and US Navy are unprepared to deal with a public health and environmental disaster the size and complexity of the marsh crust. These agencies must simply lack the talent.

Repeating the mantra that "no exposure equals no risk" the RAP/ROD is the US EPA's, Cal-EPA's and US Navy's way of approving the construction of housing and schools on top of contaminated soil. Soil that is so dangerous to the environment that it would require treatment to reduce contaminant levels before it could be placed in a secure toxic waste landfill.

At issue is a 700 acre former marsh that was filled during the early 1900's. The Navy maintains that a Chevron Oil Refinery in Alameda (1880-1900) and a PG&E gas manufacturing plant in Oakland (1880-1930) dumped wastes on the surface of the marsh which were then covered by fill. This layer of waste on the marsh surface has been referred to as the marsh crust. The proposed cleanup plan is to do nothing.

How did the US EPA, Cal-EPA and US Navy prove that Chevron and PG&E caused the marsh crust contamination? They simply stated that these corporations operated plants one mile away from the marsh that produced waste products similar to those found in the marsh crust. That is the level of scientific proof that Cal-EPA and the US EPA accepted.

How did the US EPA, Cal-EPA and US Navy demonstrate that these marsh crust contaminants are found only at depth? They didn't. The data collected showing the depth of the marsh crust was exclusively collected from a ten acre area. There is no information on the depth of contaminants or the existence of contaminants outside of this ten acre area. Again this is the level of scientific proof that Cal-EPA and the US EPA accepted.

How did the US EPA, Cal-EPA and US Navy demonstrate that these marsh crust contaminants would not migrate to the ground surface? They didn't. In fact data demonstrate that dangerous levels of PNAs have migrated to the ground surface in existing parks and residential areas. Again Cal-EPA and the US EPA ignore irrefutable scientific data to the contrary, to reach a conclusions that that PNAs will not migrate from the marsh crust.

It is EJPP's opinion that no ethical and competent scientist would approve the RAP/ROD for the marsh crust. Because the members of the Alameda BCT intend to approve the RAP/ROD, EJPP to believes that outside influences have interfered with BCT members ability to reason.

Quotes of the Month

"...the major concept in the federal government regarding radiation [exposure] is known as ALARA, (as low as reasonably achievable)."

Steve Dean of the US EPA provided a presentation on radiation to the July 2000 Alameda Point Restoration Advisory Board. Imagine if the federal government had a concept that included reducing exposure to carcinogens to as low as reasonable achievable. It is a concept that is foreign to the US Navy's cleanup program at Alameda Point. With the support of Cal-EPA and US EPA the US Navy has supported no cleanup for school, housing, and park sites at Alameda Point with significant cancer risks.

Question Authority - " Why does it take five years to complete a RAP/ROD that proposes no cleanup? "

Five years after the Remedial Investigation Report of the Marsh Crust was completed a draft RAP/ROD has finally been issued. The Final Remedial Investigation Report, April 1996, marked the completion of sampling, analysis and risk assessments for the Marsh Crust. The US EPA, Cal-EPA and the US Navy have since spent five years selecting the no cleanup option. Five years to select a no cleanup option that the RAP/ROD describes as a matter of fact conclusion.

Contact a regulator and tell them that you expect a bit more productivity from these bureaucrats. Ask them. Why does it take five years to complete a RAP/ROD that proposes no cleanup?

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 ejpp@toxicspot.com.

June 2000 Edition
July 30, 2000