[CPEO-IRF] Air Force bases in comparison to Emeryville, CA

[Lenny Siegel <lsiegel@cpeo.org>]

The July 4, 2005 edition of Superfund Report, contains an article, "Air 
Force moves to Adopt Brownfields Approach at BRAC, Waste Sites" (pp. 
6-7). In response to a U.S. EPA source who called typical brownfields 
cleanups "small, non-complicated," Superfund Report summarized an Air 
Force official's position:

"The Air Force spokeswoman counters that brownfields programs have been 
successfully used to address sites that are far worse contaminated than 
many Air Force properties. She points to the example of Emeryville, CA, 
where local authorities have successfully been using the state's 
brownfields law to purchase contaminated property, clean it up and 
resell it to a developer, while simultaneously pursuing reimbursement 
from the responsible polluters. Properties in Emeryville were frequently 
more contaminated than properties in the Air Force's inventory, she says."

Emeryville is a small city at the East end of the San Francisco Bay 
Bridge. Much of the historically industrial city is contaminated, and 
the city has a well regarded Brownfields program. But I know of no 
property in Emeryville that ranks even close to a typical major Air 
Force Base in magnitude or complexity of contamination.

Certain Brownfields tools may prove useful at heavily contaminated 
military bases, but it would be a serious mistake to ignore the process 
or substance of the National Contingency Plan at such properties.

Several years ago the Navy asked the National Academy of Sciences to 
review the applicability of a key Brownfields tool, Risk-Based 
Corrective Action, at major military bases. The Academy found:

"The characteristics of Navy facilities that make them different from 
other hazardous waste sites include the wide range of activities that 
generate waste, the large amounts and types of chemicals that have been 
disposed of, the poor record-keeping associated with hazardous waste 
disposal, and the rushed time line on which many of the facilities are 
expected to close. These features of Navy installations require the 
adoption of a highly flexible, yet protective, risk-based methodology, 
if one is to be adopted at all. Significant weaknesses of existing 
risk-based methodologies prevent the committee from fully endorsing 
their use at Navy facilities unless those weaknesses are corrected."

"Environmental Cleanup at Navy Facilities: Risk-Based Methods," National 
Research Council Commission on Geosciences, Environment and Resources 
(CGER), 1999, available on line at
http://books.nap.edu/catalog/6330.html

Lenny Siegel

--
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
http://www.cpeo.org


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