[CPEO-MEF] Former NAS Alameda

[marty martinson <martymartinson@yahoo.com>]

THIS IS A CONDENSED HISTORY OF IR SITE 15, WHERE NAS CIVILIAN=20
FIREFIGHTERS WORKED FROM THE MID 70S UNTIL EARLY 1994. THE UNDER=20
SECRETARY OF THE NAVY RECENTLY ACKNOWLEDGED TO THE OSC THAT THE NAVY=20
VIOLATED OSHA LAW BY NOT NOTIFYING THE FIREFIGHTERS OF THE=20
CONTAMINATION. THE PROBLEM NOW IS THAT THE NAVYS ENVIRONMENTAL CENTER=20
CONDUCTED A HEALTH RISK ASSESSMENT ON THE FIREFIGHTERS, AND DETERMINED=20
THAT THERE WAS NO INCREASED CANCER RISK OR ANTICIPATION OF ANY FUTURE
MEDICAL PROBLEMS. THIS THOROUGHLY CONTRADICTS THE NAVY  SITE STUDIES=20
=2E...AND NOW THE NAVY CONSIDERS THIS MATTER CLOSED AND WILL NOT ANSWER=20
ANY CORRESPONDENCE FROM THE FORMER FIREFIGHTERS. THE RAB WILL NOT=20
ADDRESS THE ISSUE, THEY SAY IT IS A "LEGAL DISPUTE" AND NOT A RAB=20
FUNCTION. OSHA WILL NOT DO ANYTHING AS THE BASE IS CLOSED. WHY DOESNT=20
BRAC CLOSURE GUIDELINES ADDRESS THE ISSUE OF HEALTH RISK ASSESSMENTS=20
OR DOSE RECONSTRUCTION STUDIES FOR FORMER WORKERS OR NEARBY RESIDENTS
WHO HAD POTENTIAL CONTACT WITH THE BASE IR SITES?
=2E......................................................................
*  In 1983 Site 15 was first confirmed to be contaminated with PCBs=20
(NEESA study 13-014).

* The May 1985  Verification Step Confirmation Study conducted by Wahler=20
Associates  reconfirmed the presence of PCBs at Site 15.

* The  February 1990 Remedial Investigation/Feasibility Study  Sampling=20
Plan by Canonie Environmental   was performed to determine the exact=20
amount and extent of the contamination at Site 15. This was done  by=20
conducting a systematic sampling of soil to increase the statistical=20
accuracy and  precision of the  analytical results.

* In October 1992 PRC Environmental prepared the Data Summary Report=20
RI/FS (Phases 2B and 3. This  report acknowledges the site as being a=20
NAS fire department storage yard. Some of the contaminants that  were=20
detected in this study other then PCBs were: Beryllium, Chromium,=20
Copper,  Lead, Mercury, Nickel,   Pesticides, Acetone, Methylene=20
Chloride and Benzo(a)pyrene.

* In October 1994 PRC Environmental released the Site 15 EE/CA. The=20
report states the purpose of  the  removal  action was to remediate=20
moderate levels of PCBs and lead at Site 15.  The objectives were to
mitigate the risk to human health and the environment associated with=20
potential exposure to the contaminated  soil by excavation. The=20
estimated volume of  contaminated soil was 3,700 cubic yards.

* It is important to note the Navy determined  that a removal action was=20
 appropriate for Site 15  based on the  following factors established by=20
CFR Title 40 Part  300.415(b)(2):

        (i)    Actual or potential exposure to nearby human             =20
  populations, animals, or the food chain
               from hazardous substances, pollutants, or contaminants

        (iv)  High levels of hazardous substances or pollutants or      =20
            contaminants in soils largely at or near the surface that   =20
           may  migrate

        (v)   Weather conditions that may cause hazardous substances or =20
             pollutants or contaminants =20

* A removal action was also justified by the Navy for Site 15 because=20
the chemical release met the CERCLA Sec. 104  criteria for response=20
action.=20

* The Alameda Point Installation Restoration program identifies the most=20
polluted properties on the former  base,  Site 15 has been categorized=20
as BRAC 6  (requires cleanup).

*  Highest levels of detected PCBs at Site 15 were 52 ppm. Land disposal=20
is prohibited at levels above 50 ppm.=20

* Navy cleanup goals of PCBs at Site 15 are 1.0 ppm.=20

* US EPA Region IX cleanup goals for industrial property are .34 ppm.

* US EPA Region IX cleanup goals for residential property are .066 ppm.

* Bay Water Quality would be impacted by storm water runoff at .30 ppm.

* In May 1995 the Site 15 Removal Action  was heavily criticized for the=20
failure of the Navy to follow legally  mandated public notification=20
requirements. In the closure report for the Removal Action the US EPA =20
had informed the Navy that they failed to conform with public=20
notifications for the illegal hazardous waste landfill they constructed.

* In June 1995 the Navys=92  attempt at on-site treatment to cleanup the=20
PCB contaminated soil at Site 15 failed.

* In November 1995 the contaminated soil from Site 15 was removed to an=20
illegally constructed Corrective  Action Management Unit.

* This illegal landfill was removed for safety reasons in September=20
1997. The contaminated soil was again   excavated and then transported=20
to an US EPA registered class =93A=94 landfill.

* The Federally required Environmental Baseline Survey for Site 15=20
states that the Residential Tier 1 Risk  Screen indicates an=20
unacceptable cancer risk.
=20
* The Alameda Point Installation Restoration program identifies the most=20
polluted properties on the former  base, and Site 15 has been=20
categorized as BRAC 6  (requires cleanup).

* Cleanup costs for Site 15 alone were $2 million as of January 1997.

ALL THIS AND THE NAVY SUGGESTS THAT WE HAD NO EXPOSURE TO ANY HARMFUL
CHEMICALS, AND NO ANTICIPATION OF ADVERSE HEALTH AFFECTS??


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