Re: [CPEO-MEF] Moffett Field - Hangar 1

[Lenny Siegel <lsiegel@cpeo.org>]

[A member of the Moffett Field Restoration Advisory Board forwarded my 
message on regulatory authority at Hangar 1 to Andrea Espinoza, the 
Navy's BRAC Environmental Coordinator for Moffett Field. Below is 
Espinoza's response. - LS]



Thank you for your e-mail, the information and suggestions you have 
provided.

The Navy and NASA are working together with State and Federal regulatory 
agencies to evaluate and take the steps necessary to protect human 
health and the environment with regard to Hangar 1.  As with the rapid 
response actions taken last year, the steps in the Hangar 1 cleanup 
process will continue to be made jointly by the Navy (the former owner) 
and NASA (the current owner).

With those actions successfully completed, the next steps in the cleanup 
process are underway.  The Navy and regulators drafted an overall 
cleanup schedule for the site, and the first milestone of that schedule 
was met with the recent publication of the draft Remedial Investigation 
Work Plan for Hangar 1 (September 2004).  As with other Moffett 
projects, the Navy's part of the Hangar 1 cleanup is following the 
CERCLA process.  This means that there will be a thorough regulatory 
review of each document produced.  That is exactly what is happening now 
with the draft Work Plan, and regulatory comments will be resolved 
before proceeding onto the next step.   The process we follow is 
designed to ensure that all issues related to protection of human health 
and the environment are addressed.

Hangar 1 is a complicated and significant cleanup for the Federal 
government.  We have just begun the cleanup process, and so issues such 
as how the interior and exterior will be evaluated and cleaned-up, and 
how NASA and the Navy will complete the cleanup will take time to 
resolve. Please be assured that there will be an on-going involvement 
and discussion with the community and other interested parties each step 
of the way until completion - a process which will take several years to 
complete.

We appreciate your time and thoughtfulness and look forward to a 
successful cleanup of Hangar 1 with your continued participation as a 
valued member of the Former NAS Moffett Field Restoration Advisory Board.


Regards,
Andrea M. Espinoza
BRAC Environmental Coordinator, Former Naval Air Station, Moffett Field
Base Realignment and Closure Program Management Office West
1230 Columbia Street, Suite 1100
San Diego, CA  92101-8571
<andrea.espinoza@navy.mil>




Lenny Siegel wrote:
> I've posted messages before about Hangar 1, the huge blimp hangar at the 
> former Moffett Naval Air Station. Moffett Field is in/adjacent to my 
> community of Mountain View, California. Most of the former Navy property 
> at Moffett is now owned and managed by NASA's Ames Research Center. 
> Moffett has been on the "Superfund" National Priorities List since 1987. 
> Hangar 1 is a protected historic landmark.
>
> NASA's environmental team determined, a couple of years back, that 
> Hangar 1 coatings and structural materials were a major source of the 
> deposits of polychlorinated biphenyls (PCBs) in the Moffett wetlands. 
> They actually traced to the hangar the unique PCB congeners found in the 
> sediment. In addition, lead paint from the Hangar has also been found in 
> Moffett run-off.
>
> In response, the Navy acted quickly, implementing a challenging but 
> effective time-critical removal action, coating the hangar to reduce 
> releases. NASA closed off the building.
>
> However, as it began its investigation of long-term remedies to halt 
> releases of toxic substances from the Hangar 1 structure, the Navy 
> asserted that the inside of Hangar 1 was not subject to regulatory 
> oversight under CERCLA (the Superfund law).
>
> The Defense Department has made similar assertions at other 
> closed/closing military bases. In particular, it argues that it is not 
> required to abate lead paint and intact asbestos in military housing 
> before transferring that housing to non-federal parties. I don't accept 
> that argument, but now, at Moffett, the Navy is going further.
>
> Despite evidence that contaminants from the inside of Hangar 1 are 
> migrating, through the stormwater management system at Moffett, into the 
> Moffett wetlands, the Navy is asserting that the inside of the building 
> is exempt. This claim appears to have no legal basis, and I believe the 
> Navy should abandon the argument and instead work with NASA, regulators, 
> and the local community to find a reasonable remedy for halting releases 
> from both the inside and the outside of the historic structure.
>
> This is a challenging site. I don't of anyone who has yet come up with a 
> viable response. But we'll never know if the Navy continues to argue the 
> inside, a large share of the problem, is exempted from the cleanup 
> program that governs the rest of Moffett Field.
>
> Lenny


--
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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