Alameda Point: Environmental Justice Progress Report

Navy Considers Six Incinerators for Alameda Point
Dioxin Emissions would Exceed Toxic Screening Levels

The Navy announced at the November RAB meeting that cleanup of six solvent spill sites at Alameda Point would begin during 2001. The cleanup alternatives being considered by the Navy rely heavily on incineration and other oxidation technologies which will add significant levels of dioxin to the West End environment. For chlorinated solvents, incinerators and oxidation reactions are known to produce dioxin as a by-product.

For one chlorinated solvent in particular, incineration and oxidation are a recipe for dioxin. Two parts 1,2-dichlorobenzene, one part oxygen, yields one part 2,3,7,8-tetrachlorodibenzo-p-dioxin.

In terms of cancer potency, the only chemical that compares with dioxin is hexavalent chromium. Hexavalent chromium was both the subject of the movie "Erin Brokovich" and the Air Toxic Hot Spot Assessment the Navy prepared for Alameda Point in 1993. In 1993, the Bay Area Air Quality Management District notified West End residents that discharges of hexavalent chromium into the atmosphere by the US Navy created a significant health risks.

Will West End residents soon receive a notice about significant health risks resulting from the dioxins emitted by Navy incinerators? Unless the Navy considers groundwater cleanup alternatives that do not involve incineration and oxidation, the groundwater cleanup will create a greater public health risk and environmental damage than the existing spills. The Navy's current plans make an air toxic hot spot out of a groundwater toxic hot spot.

Alameda Point Tenants Not Paying Their Own Way
Asthmatics Health-Care Costs Subsidize City's Reuse Plan

The US Department of Transportation (DOT) is the biggest tenant and the biggest polluter at Alameda Point. West End air quality is significantly impacted by daily emissions of soot and paint fumes from DOT's ready reserve fleet. Air pollution impacts that significantly impact West End residents with respiratory disease. West End residents continue to face increased health care costs, because they continue to live down-wind from federal air pollution sources. Federal air pollution sources that have the blessing of the City of Alameda.

Past Removal Actions for Soil and Sewer Lines Disasters
Navy, Contractors Violated Laws and the Public's Trust

Navy removal actions have had a consistent theme. Past removal action have violated public participation requirements, water quality permits, health and safety laws, and hazardous waste laws. One removal action has been the subject of an emergency spill response. Will proposed removal actions during 2001 be any different?

At Site 5, Navy contractors violated state laws requiring proper support of trench side walls. The Navy violated NPDES permit limits for discharge of pollutants to San Francisco Bay. An unlabeled, uncovered and leaking container of radioactive waste was the subject of an emergency response action on October 18, 1999.

At Site 13, the Navy failed to complete the removal action. High concentrations of lead were left behind in an unfenced dirt area that is currently being used as an off-road motorcycle track.

At Site 15, the Navy selected a removal action method that was not considered during the public comment period. This method failed, leading to the construction of an illegal hazardous waste landfill. The cost to operate the illegal landfill was excessive so the illegal landfill design was modified without public input. The Navy violated public notification requirements during the landfill operation.

At Site 16, the Final Health and Safety Plan and the Navy's responses to US EPA and community comments were finalized the day after the 60 day removal action was completed.

At Site 18, the Navy contractor violated hazardous waste laws.

Quotes of the Month

"It should be noted that the geographical scope of the City ordinance encompasses a much larger area than the specific marsh crust/subtidal area that is subject to this RAP/ROD."

This is the US Navy's and Cal-EPA's response to a community comment that Coast Guard Housing, George Miller Elementary School, and the Woodstock (Preschool) Child Development Center are excluded from the geographical scope of the City's Marsh Crust Excavation Ordinance. Coast Guard Housing, George Miller Elementary School and the Woodstock Child Development Center are within the specific marsh crust/subtidal area that is the scope of the RAP/ROD cleanup plan. The RAP/ROD proposes the excavation ordinance to prevent public health and environmental impacts from the marsh crust hazardous waste deposits that will be left in place. Let's hope the US Navy, Cal-EPA, and the City of Alameda can all agree on the geographical extent of the marsh crust remedy before this contamination kills someone.

Time Critical Removal Action at Future Playground Site
Toxic Hot Spot at Existing Playground Left Behind

For the second time in six months the Navy has performed an illegal removal action at Alameda Point. During the week of October 25, 2000 the Navy began excavating toxic soil from a 0.25 acre area within the 60 acre Toxic Waste Site 25. The objective of the Navy's Removal Action was the construction of a playground for the Coast Guard housing residents.

EJPP believes the Navy will misrepresent the time available to plan the removal action, and the rationale for the removal action in future documents. EJPP believes the Navy will state the removal action was necessary to protect public health. However, the fact is that that an island of clean dirt in a sea of contamination isn't protecting anyone.

The removal action was not performed because the Navy believes that "clean" playgrounds will provide Coast Guard residents with a safe refuge from the extensive contamination found throughout their housing area. If the Navy had believed that they would have performed a time-critical removal action 18 months ago, when a toxic hot spot was identified in an existing and extensively used Coast Guard playground area (See EJPP Volume 23).

The US Navy has continued to ignore their legal obligation to follow the public participation requirements for removal actions. As a result the public remains confused about the objectives of the these removal actions and the Navy's cleanup priorities. A time-critical removal action that was recently performed at East Housing, addressed contamination that has never been found at East Housing. Prioritizing cleanup of contamination that has never been documented adds to the public's confusion about the intent of Navy removal actions.

Question Authority - "When violations of Superfund laws occur in the West End, will the violators be prosecuted?"

The Navy failed to report a Reportable Quantity release of chlordane, a carcinogenic and bioaccumulative toxic substance, following the release discovery in 1995. A West End resident discovered the release by reviewing Navy sampling data that was obtained through Congressman Dellums office in 1997. Clearwater Revival Company reported the release to Cal-EPA, US EPA, and the Navy in written comment in October 1997. In August 1999, the Navy sent a letter to Senator Barbara Boxer stating that all issues raised by Clearwater Revival Company's October 1997 written comments had been addressed by February 1998. The Navy's August 1999 letter is a deliberate attempt by the Navy to conceal community concerns about the unreported Chlordane release. Information distributed by the Navy at the November 2000 Restoration Advisory Board continues to ignore the RQ release of chlordane at Parcel 168.

EJPP is calling for the arrest and prosecution of the former commanding officers at Alameda Naval Air Station for violating federal laws that required this individual to report the Chlordane release within 72 hours of its discovery. As a result of the failure to report the Chlordane release, illegal storage and disposal of hazardous waste has occurred at Alameda Naval Air Station. Since these violations have occurred in the plain view of the US EPA and Cal-EPA, ask them: - "When violations of Superfund laws occur in the West End, will the violators be prosecuted?"

• Steve Edde, Navy Program Coordinator, sledde@efawest.navfac.navy.mil
  
• Phillip Ramsey, US Environmental Protection Agency, ramsey.phillip@epamail.epa.gov
  
• Mary Rose Cassa, California Environmental Protection Agency, mcassa@dtsc.ca.gov
  
• Dina Tasini, City of Alameda Environmental Coordinator, dtasini@ci.alameda.ca.us
  

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.