Alameda Point: Environmental Justice Progress Report

Audubon Trashes Landfill Study for Site 2
Experts Question Conclusions about Public and Wildlife Safety

A presentation at the March 6, 2001, Restoration Advisory Board (RAB) meeting provided substantial criticism of the Navy's Remedial Investigation (RI) Report of contamination at Toxic Site 2. Three experts hired by the Golden Gate Audubon Society told RAB Members that the conclusions of the Navy's RI Report were not substantiated by data collected from the site. A state regulator also expressed strong criticism about the quality of the Site 2 RI Report.

The boundaries of the proposed Alameda Point National Wildlife Refuge include one of the Navy's 29 identified toxic waste sites. Toxic Waste Site 2 is a 60 acre landfill that operated in the southeast corner of Alameda Naval Air Station from 1956 until it was ordered closed by the San Francisco Bay Regional Water Quality Control Board in 1983. The Navy has never fully complied with the Water Board's 1983 order to properly secure the leaking landfill to stop the ongoing contamination of San Francisco Bay.

The Golden Gate Audubon Society has an interest in the adequacy of the Navy's investigation and cleanup of contamination at Site 2. Contamination from Site 2 threatens the viability of an endangered species, the California Least Tern. The terns fish in areas where sediments have become contaminated by leaks from the Site 2 landfill. The Site 2 boundaries also include a significant wetlands habitat. In addition to the possible impacts of Site 2 contamination on wildlife, Audubon is concerned about potential exposure to elementary school students touring the refuge site.

The Navy's RI Report provided the chemical analyses results for soil and water samples collected from Site 2. The RI Report indicates very low levels of contamination were found during sampling. The Navy concluded that natural processes had detoxified 1.6 million tons of military waste, a conclusion that Audubon's Executive Director likened to a "miracle."

RAB Members expressed concern over the five year delay in completing the RI Report and the further delays required to revise the report to reflect actual contamination at Site 2. RAB Members were particularly concerned that the Navy's consultant, Neptune and Associates, may be working on cleanup projects in other areas of the base. Estuary Park/Coast Guard Housing (Site 25) and the Catellus Development site at the FISC/Annex are projects that the consultant is involved with.

A portion of Site 2 and the future Alameda National Wildlife Refuge extends into San Francisco.

Clearwater Revival Company Gags Vocal Refuge Opponent
Polluter's Supplemental Environmental Project benefits Wildlife

In December 1999, the City of Alameda illegally dumped oil contaminated water into a wetlands that drains to San Francisco Bay. Clearwater Revival Company reported the illegal discharge and provided photographs to regulatory agencies. After the City of Alameda waived their right to a hearing, the Regional Water Quality Control Board fined the City $21,400 at their September 2000 meeting. About 80 percent of the fine will be spent on a Supplemental Environmental Protection.

The Supplemental Environmental Project approved by the Water Board will direct $8,000 to the future site of the Alameda National Wildlife Refuge. The funds will be used to enhance the habitat of the California Least Tern, a migratory bird expected to return to Alameda in April. About 250 nesting pairs of this endangered species established residence near the Navy's former runways. The Water Board fine was used to coordinate a volunteer effort to remove weeds from the disintegrating runways to discourage foraging by raptors.

Ironically, the City of Alameda has been the most vocal opponent of the wildlife refuge. The City tried unsuccessfully to encroach on this endangered species habitat delaying the environmental review of the communities reuse plan of the base for years.

The Supplemental Environmental Project approved by the Water Board directs $9,000 of the fine to a training program for City of Alameda employees. These employees will be trained on regulatory requirements for handling contaminated soil and groundwater that is found throughout Alameda Point. This portion of the project is a waste of money. It is the City management, not the City employees that refuse to comply with public health laws.

Quote of the Month

"The Navy report says there is no problem and toxic materials are not present in amounts to worry about ......... The Navy's conclusions are not supported by their own analyses."

Golden Gate Audubon had a team of scientists with expertise in evaluating the potential for human and wildlife health risks analyze the Navy's Remedial Investigation Report on Site 2. The scientists reached this conclusion. The Navy has made similar conclusions at most of their contaminated sites.

Mercury, Radiation Contamination missed in Navy Notifications
Over-sight at Building 66 Part of Scary Pattern

Federal Law requires that the Navy disclose in any lease or sales contract, any hazardous material that was stored at a site for more than one year, and any hazardous material that was released to the soil or groundwater. The Navy has summarized this information in Environmental Baseline Survey reports.

The survey reports include interviews with former employees familiar with hazardous material handling and spill events. According to interviews documented in the Environmental Baseline Survey Reports, mercury was "released often" over a "period of decades" in Building 66, located at the corner of West Atlantic Avenue and Ferry Point. The survey reports also show the presence of radioactive materials (cesium and uranium oxide) in the building.

Despite these documented interviews with past employees, releases of mercury, uranium oxide and cesium do not appear on a list of chemicals stored or released at Building 66. The Environmental Baseline Surveys also over-looked a documented release of chlordane at Parcel 168, a documented release of pentachlorophenol at Parcel 182, and the documented disposal of unexploded ordinance at Parcel 2.

The unexploded ordinance was fortunately "rediscovered" by a radiation survey crew and no one was killed. The mercury, uranium oxide, cesium, chlordane, and pentachlorophenol were "rediscovered" by Clearwater Revival Company during the review of Navy reports. Neither the US EPA, California EPA, US Navy nor Navy environmental contractors identified these significant hazards during the review of their own work.

Question Authority
"Why hasn't the Navy been fined for storing PCB wastes in violation of State Hazardous Waste Laws?"

Leaking PCB Ballasts from discarded fluorescent light fixtures were left in a Navy parking lot for several months in violation of hazardous waste storage laws. The leaking ballasts were not containerized or labeled and were stored in excess of 90 days. Cal-EPA is aware of these violations, but has not enforced the law. Contact the Navy, Cal-EPA, the US EPA and the City of Alameda. Ask them: "Why hasn't the Navy been fined for illegally storing PCB wastes?"

• 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
  

Light Fixture near Former Hazardous waste Area	These Leaking Ballasts are known to contain PCBs

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.