Environmental Justice Progress Report

Volume 9, October 1998

ARRA Proposes School on Toxic Site! Ignorance or Expectations?

Preliminary Results of Environmental Baseline Surveys

News in Brief

ARRA Proposes School on Toxic Site! Ignorance or Expectations?

The Alameda Redevelopment and Reuse Authority's (ARRA's) current reuse map shows a school and public park proposed for Installation Restoration Site 13, the former location of a Chevron oil refinery and the location of numerous Navy hazardous material spills. Does this land reuse map demonstrate ARRA's ignorance of the effect of land pollution on reuse and redevelopment, or is ARRA simply setting expectations for a complete and risk-free cleanup by the Navy?

A recent press release issued by the California Environmental Protection Agency Department of Toxic Substances Control creates significant concern with developing schools on Navy property. The September 29, 1997, DTSC press release indicates that polychlorinated biphenyls (PCBs) were found at Southern California's Burroughs High School, a public school constructed on land leased from the Navy. DTSC expressed concern over the Navy's refusal to participate in follow-up PCB and dioxin testing at the school.

The Navy's has assured Alameda that it will address any contamination that is overlooked at the former Alameda Naval Air Station, but based on the experience at Burroughs High School, the Navy won't respond to requests by a public health agency like DTSC, much less the City of Alameda. Should public funds be risked on redevelopment and reuse under these circumstances?

Preliminary Results of Environmental Baseline Surveys

The Environmental Baseline Survey (EBS) program is classifying land parcels at Alameda Point into one of seven BRAC Categories, based on the environmental condition of the property. The EBS program which began in 1994 will be used to determine which properties be transferred to the Alameda Redevelopment and Reuse Authority. Zones 20, 21, and 23 are the first areas of Alameda Point were property has been fully evaluated for transfer.

The EBS program has identified environmental risks which create a disproportionate pollution burden for West End residents.

Contrary to Executive Order No. 12898, the Environmental Baseline Survey program does not recommend doing anything about this burden.

Tiered Screening

During Phase 2 of the Environmental Baseline Surveys soil and groundwater samples were collected from select parcels. Chemical analysis results from these samples were used in a Tiered Risk Screening process to evaluate human health risks.

A Tier 1 risk screening involves comparing chemical analysis results to a Table of Preliminary Remediation Goals estimated by the US Environmental Protection Agency for a typical Superfund site. If this comparison indicates that one of six criteria is exceeded a more detailed Tier 2 risk screening was to be performed. The Navy, however, failed to perform Tier 2 risk screening on six parcels that exceeded these criteria. Tier 2 screening should have actually been performed on 51 percent of the property.

Tier 2 screening estimated site specific chemical exposure under different property use scenarios (residential, industrial, recreational). No screening was performed on parcels from which no samples were collected and no screening was performed on property with petroleum contamination only.

BRAC Category Descriptions

As part of the EBS process, parcels in the Installation Restoration Program were assigned to BRAC Category 6. All other base property was classified as BRAC Category 7 - Further Investigation Required or CERFA - No Evidence of Hazardous Material Storage. The EBS program is evaluating the BRAC Category 7 parcels and reclassifying them as BRAC Category 1, 2, 3, or 6. Parcels in BRAC Categories 1, 2, 3, 4, and 5 can be transferred to the ARRA.

BRAC7 Additional evaluation required. No Transfer
BRAC6 Cleanup of hazardous material spill required to reduce cancer risk below 10-4 or Hazard Index below 1.0. No Transfer
BRAC5 BRAC6 Site is reclassified when cleanup plan has been successfully initiated. Dirty Transfer
BRAC4 BRAC5 Site is reclassified to BRAC4 when the cleanup plan has been completed. Transfer Okay
BRAC3 Evidence of a hazardous material spill. Below tiered screening levels of Cancer Risk = 10-4 and Hazard Index = 1.0. Transfer Okay
BRAC2 Evidence of a petroleum spill only. Below tiered screening levels of Cancer Risk = 10-4 and Hazard Index = 1.0. Transfer Okay
BRAC1 No evidence of a hazardous material spill. Transfer Okay
CERFA No records of hazardous material storage or activity. Transfer Okay

Residual Risks

The EBS indicated that land uses on 25.7 acres of property would be restricted. These residual risks include:
Acreage Human Health Risk Proposed Action
1.0 hazard index exceeds 1.0 BRAC 6 - Cleanup
3.5 cancer risk exceeds 1-in 10,000 BRAC 6 - Cleanup
6.7 cancer risk exceeds 1-in-100,000 BRAC 3 - No Action
15.5 cancer risk exceeds 1-in-1,000,000 BRAC 3 - No Action

The results of the Tiered Screening provide a preliminary picture of the environmental condition of property that will be transferred to the Alameda Redevelopment and Reuse Authority. For 51 percent of the property, reuse and redevelopment would be restricted. These restrictions would be recorded in the property deed. These restrictions would devalue the contaminated property and surrounding properties, as well as limit reuse opportunities.

This percentage of contaminated property is too great an economic, environ-mental and public health burden on AlamedaÕs West End.

News in Brief

Base Cleanup Team Members Resign:

Both Thomas Lanphar, Department of Toxic Substance Control, and James Ricks, US Environmental Protection Agency Region IX have announced their plans to move to different positions in their departments which will remove them from the Alameda Point Base Cleanup Team. Both regulators have spent over four years on the project. These two regulators have been strong advocates on behalf of the community

Radioactive Pollution Cleanup:

A large cleanup project is proposed to remove radioactive contamination from a storm drain leading from Building 5 to the Sea Plane Lagoon. It its suspected that the contamination resulted from the use of radium in paint, a practice that was ended in the 1960's. Paint wastes were commonly disposed of in drains that led to the Bay. The entire storm drain system will be excavated and replaced in the area targeted for cleanup.

Navy sets date for Toxic Sites Tour:

The Navy and Restoration Advisory Board will hold a tour and open house on 10 am - 2 pm, Saturday, November 15, 1997, at Building No. 1, 950 West Mall Square, former Alameda Naval Air Station.

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Revised January 27, 1998