Alameda Point: Environmental Justice Progress Report

EPA lacks Resources to Evaluate 1993 Indoor Air Hazards
Housing Area Reportedly the EPA's Priority at Alameda

The EPA stated at the November 2000 RAB meeting that it does not have the resources to address contamination that is seeping into the former Navy housing units called Marina Village Family Housing. The housing units are located adjacent to Site 25 which is the highest priority cleanup site at Alameda Point Superfund Site. At the November 1999 RAB meeting the US Navy, US EPA and Cal-EPA were criticized for misrepresenting contamination beneath Marina Village Family Housing in maps distributed to the Coast Guard families occupying these residences.

The Navy discovered groundwater contamination prior to constructing the housing in 1991-92. Following construction, air sampling in the units showed high levels of the groundwater contaminants. The Navy requested a public health consultation from the Agency for Toxic Substance and Disease Registry (ATSDR). ATSDR recommended annual air testing inside the residences, and cleanup of groundwater contamination. The Navy failed to act on either ATSDR recommendation.

Marina Village Family Housing is also another example of Cal-EPA's misguided brownfields policy. Throughout the Bay Area, Cal-EPA has promoted the development of contaminated properties, "brownfields." As a result of Cal-EPA policies, hundreds of low-income families are now living on uncontrolled toxic waste sites.

The decision to build housing on a Navy hazardous material storage area with significant contamination in shallow groundwater violated state and federal laws. The Navy and Cal-EPA have failed to support the actions taken at Marina Village Family Housing in a Record of Decision or Remedial Action Plan.

While the cleanup of contamination at Site 25 is the stated priority at Alameda Point, the same contamination, shown on Navy maps beneath George Miller Elementary School, and a pre-school is not being addressed. The same contamination beneath Marina Village Family is being ignored.

Proposed Schedule for Final Cleanup Decisions
At Least Five years to go at Alameda Point

This is only a draft. EJPP repeats. This is only a draft.

With some reluctance since publishing a cleanup schedule in EJPP Volume 2 that was never adhered to, here is the latest word from the US Navy and US EPA on the cleanup schedule for the Alameda Point Superfund Site. The US Navy and US EPA added five years onto the cleanup schedule for all operable units. The US Navy and US EPA added five additional Operable Units. The US Navy and US EPA added five additional installation restoration sites.

An Operable Unit (OU) is a group of toxic waste sites that have similar contamination problems.

An Installation Restoration (IR) Site refers to one of 29 areas where toxic waste releases to air, soil, groundwater and bay sediments are being investigated as part of the Superfund cleanup program.

	SCHEDULE MILESTONES	OU 1 SITES	OU 2A SITES	OU 2B SITES	OU 2B SITES	OU 3 SITES	OU 4A SITES	OU 4B SITES	OU 5 SITES	OU 6 SITES
	Remedial Investigation Report soil and water test results	November 2002	August 2002	December 2002	February 2003	January 2001	November 2001	October 2002	September 2002	May 2003
	Feasibility Study (FS) Report - cleanup alternative analysis	April 2003	December 2002	June 2003	August 2003	January 2002	April 2002	June 2003	April 2003	October 2003
	Community Comment - public meetings	October 2003	July 2003	December 2003	February 2004	July 2002	October 2002	December 2003	September 2003	April 2004
	Record of Decision (ROD) - cleanup agreement/plan	March 2004	January 2004	May 2004	July 2004	December 2002	May 2003	June 2004	March 2004	October 2004

OU 1: IR sites 6, 7, 8, 14, 15, 16
OU 2A: IR sites 9, 13, 19, 22, 23
OU 2B: IR sites 3, 4, 11, 21
OU 2C: IR sites 5, 10, 12
OU 3: IR sites 1
OU 4A: IR sites 2
OU 4B: IR sites 17, 20, 24, 29
OU 5: IR sites 25
OU 6: IR sites 26, 27, 28

Allegations of Navy Dumping Requires Investigation
Toxic Waste Site Investigation Results Invalidated

A former Navy employee has informed EJPP that hazardous waste caused the death a large number of migratory birds at Site 3. These revelations invalidate the results of investigations at Site 3 that occurred prior to this incident.

Prior to 1993, the Navy's hazardous waste storage area (Toxic Waste Site 19) was unroofed. Rainwater would accumulated in the storage areas which was designed to contain hazardous waste spills that frequently occurred at the site. The Navy's protocol was to pump the rainwater into a tanker truck and spray the water on Site 3, and the Parade Grounds on the north side of City Hall West. On one occasion following the disposal of contaminated rainwater a large number of migratory birds were found dead at Site 3.

The Navy's protocol violated conditions of the interim hazardous waste storage and treatment permit held by the Navy. The Navy's poisoning of migratory birds violated international treaties. As a result of these violations, the Site 3 investigation should be repeated since previous testing was invalidated by the Navy's subsequent disposal of rainwater contaminated with hazardous waste.

Quotes of the Month

"The City of Alameda became a National Priorities List (NPL) Site in April 1999."

This quote comes from the City of Alameda's request for a statement of qualifications for potential master developers of Alameda Point. The City of Alameda is not a NPL site. Only areas of Alameda Point are a considered a Superfund or NPL site. Alameda Point became a NPL site in July 1999 not April 1999. The quote demonstrates the City of Alameda's understanding of toxic waste issues at Alameda Point - complete ignorance.

June's Proposed Plan for Marsh Crust/Groundwater Changed - Piecemeal Cleanup Approach Against State Law

The Remedial Action Plan (RAP) and the Proposed Plan to address the Marsh Crust contamination will reportedly be changed. The RAP and Proposed Plan will not address the impact of the Marsh Crust Contamination on groundwater as proposed in June 2000 drafts. Groundwater will be addressed separately. As a result, the RAP will be inconsistent with the California Health and Safety Code which requires that a RAP evaluate the contamination's impact on water groundwater resources.

Cal-EPA has also violated CEQA by further piecemealing the environmental review of the Marsh Crust contamination, and failing to consider the cumulative environmental impacts of the series of cleanup decisions. As reported in the November 2000 EJPP, Cal-EPA also failed to comply with CEQA requirements to make the Negative Declaration available to the public when the RAP was originally released for public comment in June 2000.

Cal-EPA is legally obligated to propose a comprehensive cleanup plan for the marsh crust that addresses contamination on both Navy and non-Navy property, and in both soil and groundwater. Cal-EPA is also legally obligated to recirculate the Negative Declaration for this modified Remedial Action Plan.

Question Authority - "When will the Navy come clean?"

EJPP is requesting that the investigation of Site 3 begin anew. Any cleanup remedy that does not evaluate the toxic residues from the Navy's dumping, ensures that any health and environmental impacts from this illegal activity are over-looked. The Navy has lacked the moral leadership to disclose known public health hazards to the regulators and the public. The Navy's deliberate withholding of information such as the dumping at Site 3, needlessly delay the cleanup process and ultimately result in a higher costs to the US government and taxpayers. Cal-EPA, the US EPA and the City of Alameda continue to waste years negotiating with the Navy without any meaningful cleanup results. Ask them: "When will the Navy come clean?"

• Michael McClelland, Navy Program Coordinator, mcclellandme@afdsw.navfac.navy.mil
  
• Steve Edde, Navy Program Coordinator, sledde@efawest.navfac.navy.mil
  
• Phillip Ramsey, US Environmental Protection Agency, ramsey.phillip@epamail.epa.gov
  
• Anne-Marie Cooke, US Environmental Protection Agency, cook.anna-marie@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.