2009 CPEO Military List Archive

From: Lenny Siegel <lennysiegel@gmail.com>
Date: Fri, 16 Jan 2009 07:16:44 -0800 (PST)
Reply: cpeo-military
Subject: [CPEO-MEF] VOCs: Re: REUSE: Army Reserve Center at Moffett Field (CA)
There is no community opposition to the planned use of much of the former Orion Park military housing area as an Armed Forces Reserve Training Center - unlike in other communities, such as Middletown, Connecticut.

But many of us are concerned that the plume of volatile organic compounds (VOCs), such as TCE, in the shallow groundwater is not being addressed.

The Orion Park Housing Area originally was part of the Moffett Field Naval Air Station. When the Navy pulled out in 1994, most of base went to NASA Ames Research Center, which lies between the main Navy facility and the housing area. But all base housing was transferred to the Air Force, which operates the Onizuka Air Force Station nearby. In the 1995 round of base closures, the Air Force was told to surplus the housing, which was then transferred to the Army. Both the Army and Air Force made the residences available to other armed services and sometimes other federal employees.

Initially, the Army included Orion Park and two other housing complexes in its privatized Residential Communities initiative. That is, it selected a private firm to operate and rebuild its former Navy housing.

However, in the early 2000s, a previously undiscovered VOC plume was detected in Orion Park. The Navy contended that the housing area wasn't really part of the Moffett Superfund site, and it reluctantly conducted limited sampling. It originally argued that vapor intrusion was not occurring, but EPA and community oversight eventually led to sampling that proved that residents were exposed to unacceptable levels of TCE.

Other parties looked at the groundwater data from Orion Park, and the concentration pattern seemed to demonstrate conclusively that a major portion of the TCE on site came from a release on the property. The exact source is unknown, and it may have occurred before the Navy acquired the land in the 1950s.

The Navy, however, argued that all of the contamination was migrating from unknown sources south of Bayshore Freeway (U.S. 101). It said it could not use its funds to sample upgradient, so EPA conducted limited sampling confirming that some of the VOCs were coming from the south. Still, the high concentrations on site appear to have originated at Orion Park. The Navy continued to argue, because the source was off site and it did not consider this part of the Moffett Superfund site, that it did not need to conduct a Remedial Investigation and subsequent steps under the Superfund law.

Meanwhile, the private backers of the new housing project got cold feet, because of liabilities associated with the contamination, and the Army's partner restricted its activities to the other two housing areas. So for the 2005 base closure round the Army proposed successfully to construct a centralized regional Reserve Training Center at Orion Park.

The Army acknowledges that there is contamination on site, and that the contamination could potentially volatilize into the new buildings. It promises to build state-of-the-art vapor mitigation systems into the buildings, but it has revealed no long-term plans to ensure that building occupants are not exposed to the contamination.

In 2008, the Defense Department transferred responsibility for Orion Park contamination from the Navy to the Army, and the Army took up the Navy's argument that the contamination originated off site. I have been watching (on my regular bike rides along the nearby Stevens Creek Trail) the deconstruction/demolition of the northern portion of the old military housing for weeks, and on January 10 the Army broke ground for the new 270,000-square-foot, 39-acre facility.

That is, the Army is building a major new training center on a Superfund site with high levels of TCE in shallow groundwater. Yet there is no plan to characterize the site fully, let along clean it up. NASA Ames Research Center, where the Orion Park plume is migrating, is building a barrier remediation system at the property boundary, but its calls for on-site cleanup have been ignored.

Members of the Moffett Field Restoration Advisory Board (including me) have repeatedly called upon the Navy and now the Army to take full responsibility for the site. RAB members don't believe a private developer would be able to undertake such a major construction project on highly contaminated property without cleanup, or at least remediation plans, in place. Regulators from U.S. EPA and the regional Water Board have made efforts to move the cleanup process forward, but the Defense Department appears unwilling to accept their authority at the site.


Lenny Siegel wrote:
COMING UP: Army Reserve center to break ground

Daniel DeBolt
Mountain View Voice (CA)
Janury 9, 2009

A $79 million facility for Army reservists will have a groundbreaking ceremony on Saturday morning just outside the main gate at Moffett Field.

After demolishing dozens of military housing units, the Army will now begin construction of a 270,000-square-foot facility on 39 acres.


For the entire article, see


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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