Re: Deferred cleanup/early transfer

["Marty Walters" <marty_walters@terrasano.com>]

Lenny Siegel wrote:

> I hope someone who knows more about FISCO (Fleet Industrial Supply
> Center Oakland) will respond. I don't think procedural changes can save
> that much money.

Without knowing specifics about the project, I would think major cost
savings would be attributed to the fact that after transfer the Port of
Oakland is not required to do cleanup under CERCLA, but will be under the
authority of state cleanup laws. Perhaps political clout and lack of state
resources to oversee cleanup without DSMOA funds play a role. In addition,
isn't the Port of Oakland planning to address most of the contamination by
paving over areas and creating storage and transfer space for intermodal
containers? The paving probably isn't included in the cleanup cost estimate.
>
> [Early transfer of UXO properties] would make me very nervous, since we
still
don't have adequate
> technologies, generally accepted risk management strategies, or an
> agreed upon regulatory framework for UXO.

Does it make you feel any better that the military is proceeding with these
cleanups on their own without these strategies?

> I'm willing to consider early transfers only if 1) contamination is
> known to be minimal; 2) the transferee demonstrates that it can pay for
> cleanup faster than the military, and 3) public and regulatory
> involvement continues without reduction.

Compared to California, in Hawaii there is very little public and regulatory
agency involvement even with the military in the lead cleanup role.

> I'm interested in know how extensive non-BRAC transfers are these days,
> nationally as well as Hawaii, in the wake of Congressional resistance to
> the Defense Department's proposals for a new round of BRAC (base
> realignment and closure).

Some information about Hawaii:  only one installation (Barbers Point Naval
Air Station) was listed under BRAC. The military is, however, downsizing
many of its facilities, but the land is being transferred through the
General Services Administration as excess property. There seems to be very
little experience within GSA and the property receivers (usually State of
Hawaii or City of Honolulu) to even think of contamination issues, much less
ensure that the CERCLA property transfer covenant is fulfilled.

Marty Walters