[CPEO-MEF] VOCs, REGULATION: Moffett Field (CA) 5-Year Review debate

[Lenny Siegel <lsiegel@cpeo.org>]

We've had a back and forth here at California'a Moffett Field (former 
Moffett Naval Air Station) about the protectiveness of the remedy for 
Site 28, the Westside Aquifer, also known as the Regional Plume shared 
with other responsible parties. On February 12, 2010 the Navy concluded:

"This Five-Year Review found that the remedy for Site 28 is currently 
protective of human health and the environment because on-site 
contaminant plumes are stable or decreasing, contaminated groundwater is 
being treated by WATS [Westside Aquifer Treatment System], and potential 
exposure pathways that could result in unacceptable risks are being 
controlled."

In May, the Restoration Advisory Board voted to challenge that finding, 
and on July 7 U.S. EPA officially disagreed with the Navy, stating:

"The remedy at the Site 28, WATS Area; is not protective because it does 
not adequately address potential health risks from long-term exposure to 
trichloroethene (TCE) and tetrachloroethene (PCE) through the vapor 
intrusion pathway."

The Navy defended its position in a July 20 response to EPA, calling its 
finding "appropriate" and explaining:

"The Navy's protectiveness statement acknowledges EPA's concerns for 
long term exposure by concluding that to ensure long term protectiveness 
of the remedy, follow-up actions need to be taken."

More interestingly, the Navy complains, "No current EPA guidance exists 
on how to address [vapor intrusion] issues and protectiveness statements 
in Five Year reviews.... As such the EPA's non-concurrence determination 
was issued in an area where no guidance exists on an appropriate manner 
in which to address it."

In this regard, the Navy is right. This is one more reason why EPA 
should act without delay to issue a complete vapor intrusion guidance.

Lenny



--


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
<lsiegel@cpeo.org>
http://www.cpeo.org



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