CERCLA Exemptions

[WJASmith <wjasmith@aol.com>]

To Interested Parties:

The Oakland Army Base in California has significant amounts of lead in soils
near the approach to the San Francisco Bay Bridge. The Army, and possibly the
US EPA, claim that there is an exemption in CERCLA for lead deposited in 
soils
by automotive traffic. The Army does not even intend to investigate the
extent of the lead contamination near the bridge approach, the freeway, and
other roads.

This base is located in a vibrant and rich, although poor, community of 
color.
Can anyone confirm that there is a CERCLA exemption for lead from 
automobiles?
And if so, does this mean that a poor community is once again going to be
stuck with a long term environmental problem for which no organization is
going to take responsibility? Any experience to pass along on this issue.

Also at Oakland, the Army does not plan to clean up lead from leaded paint in
soil. Their argument here is that the EPA does not require other responsible
parties to clean up lead in soil - so why should the Army go beyond what 
other
parties are required to do? Can anyone provide me with an example of where
the EPA has required lead contaminated soils to be cleaned up?

The next meeting of the Oakland Army Base RAB is at 6:00 p.m. on Wednesday,
Feb. 25th at the Mastick Senior Center at the corner of 18th Street and
Adeline Ave. in West Oakland, CA.

Bill Smith
Sierra Club
East Bay Military Base Conversion Task Force