|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||12 Jul 2005 21:55:10 -0000|
|Subject:||[CPEO-IRF] Air Force bases in comparison to Emeryville, CA|
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
-- 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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