. . . isn’t a solution at all. Read on:
Residents and RAB Respond to the Navy’s Proposed Change of Plan
Guest post by Susan Galleymore
More than two dozen residents attended the Navy’s public comment meeting held in the City of Alameda’s main library on April 9th. The presentation addressed the Navy’s reversal of an earlier decision to remove contamination from the “Burn Area” of the former waste dump on the north western tip of Alameda Point. Their new plan, Alternative BA-1, leaves contaminants in place topped with a soil cover and installs a Waste Isolation Bulkhead (“WIB”) to reduce the flow of contaminants into the bay. (Read the Navy’s “Proposed Plan for Modified Remedy at IR Site 1 Burn Area.”)
Residents’ comments indicate uniform disapproval of the change:
“[O]ur predecessors may not have understood [potential] damage… when they improperly disposed hazardous wastes but our generation has the awareness and the technology to make better choices.”
“We have a responsibility to ensure that future generations of Alamedans aren’t saddled with the same toxic pollution problems we fac[e].”
“[As] a homeowner…mother [and one whose] grandfather served in the Navy and held it in great esteem [I oppose] the new modified remedy…a temporary metal bulkhead, and a soil cover is not remediation but …an irresponsible, temporary patch….”
“… this dump is the ONLY thing that has ever made me want to leave [Alameda].”
“[T]he Navy is avoiding full responsibility for full cleanup [and] hedging financial and moral responsibility….”
“[Navy] modeling assumes a 77-day tidal action rather than… a 200 year flood surge…absurdly negligent in the wake of disasters in Japan and climate change dramatically increasing the frequency of “black swan” …events.”
Responding to such comments, Navy BEC Derek Robinson assures residents that “protection of human health and the environment is our number one priority….There is a lot of misinformation floating around out there. If you have any questions or would like to discuss the plan with me, feel free to call”: 619-532-0951.
BEC Robinson’s offer is generous. And, according to the EPA guidelines, the Restoration Advisory Board is the “forum for exchange of information and partnership among citizens, the installation, EPA, and State…[and the] opportunity for communities to provide input to the cleanup process” (source). However, city officials appear to consistently sideline this citizens’ forum since Alameda’s RAB began in 1997. For example, when the Navy peremptorily decided in Fall 2012 that, despite RAB and cleanup budgets set two years in advance, budgetary constraints required immediate reductions in numbers of meetings by 66%, from monthly to quarterly. City officials offered no opinion nor did they support the RAB in its desire to maintain the monthly schedule. Eventually RAB members and Navy compromised and meetings now occur every two months.
A bi-monthly schedule places more pressure on the RAB to obtain pertinent documents in a timely fashion and for the Navy to follow the delivery process outlined in the Community Involvement Plan (“CIP”).
In February 2013, three RAB members met EPA officials to seek solutions to documents tending toward no delivery, late delivery, or delivery outside the CIP process.
“Our concern,” RAB members’ stated, “is that the RAB and the CIP process will be further degraded with bi-monthly meetings.”
The delivery process followed for the new plan, Alternative BA-1, highlights the issue. In its joint public comment, the RAB’s letter states, “Thank you for the opportunity to comment on the above document.”
The discussion period provided before the public meeting [on April 9th] on the proposed plan proved very helpful to the RAB. It is unfortunate that such a meeting did not occur when the focused feasibility study was issued [last year].”
Moreover, given that Alternative BA-1 documents total about 1000 pages, one hour face-to-face with Navy personnel and a 30-day comment period is insufficient time for RAB due diligence.
Other excerpts from that letter:
“Because the original plan constructed a cap no environmental risk assessment was performed. Now that the Navy proposes a cover, isn’t a risk assessment required?”
“Since no biological survey has ever been performed, no one should assume bulldozing will not harm the environment. If the Navy’s preferred alternative moves forward, a biological survey should be performed.”
“BA-1 is not protective of the environment. The risks posed by leaving toxic waste in an area with the highest risk for liquefaction AND at a location in close proximity to an active earthquake fault are not addressed. Moreover, a severe seismic event will likely breach the WIB anchored in Merritt Sand that is subject to liquefaction. Resulting sand volcanos will likely bring contaminants to the surface.”
USGS (United State Geological Survey) map: “Liquefaction Susceptibility Map of the San Francisco Bay Area”
These geologic aspects evoke concerns about sea level rise and flooding too.
At the July 25, 2011 presentation to City Council, Ms. Barbara Hawkins, City Engineer with the Public Works Department, addressed Alameda’s 2008 Storm Drain Master Plan’s 18” sea-level rise analysis. Focusing on how an 18 inches of sea level rise would impact the city’s storm drain system, Ms. Hawkins presented maps that indicated sea-level rise could not only flood the shoreline but that water could back up through the storm drains to be deposited into the city’s downtown.
With a seismic event significant enough to breech the WIB, could not the contaminants the Navy’s preferred Alternative BA-1 plan leaves in place be carried by water through storm drains to be deposited into the city’s core too?
Even without a significant seismic event sea-level is predicted at rise at least 50 inches by the end of the century. This means the Navy’s WIB solution isn’t an effective long-term solution, and moreover, rather than reducing our exposure, it puts us at increasing risk of contamination to our bay waters over time.