Thirty-five years after the Navy stopped disposing of toxic waste in unlined pits next to San Francisco Bay on Alameda Point’s southwest shoreline, the final actions to comply with state and federal laws are finally being implemented this year.
Decades of wrangling between the Navy and regulatory agencies over how to handle the West Beach Landfill, dubbed Site 2, were finally ironed out this spring. The U.S. Environmental Protection Agency (EPA), the Regional Water Quality Control Board (Water Board), and the California Department of Toxic Substances Control (DTSC) have agreed to a plan that calls for leaving the estimated 1.6 million tons of industrial waste in place and adding more soil to the existing soil cover.
The Navy began dumping waste in the area in 1952, four years before they surrounded the area with a seawall. The dump was closed in 1978, but early efforts to comply with state environmental laws for landfill closure were not to the satisfaction of the Water Board.
In its May 2012 draft engineering work plan for the landfill, the Navy cited a decade of groundwater monitoring along the shoreline that proved the toxic chemicals of concern are not migrating toward the Bay. Instead, the chemical concentrations are either stable or declining. The contents have been sitting in water-saturated subsurface soil since the disposal program began 60 years ago.
Radiological hotspots of debris and soil, including a small storage building, were removed after an earlier scan of Site 2. Before the current two feet of clean soil is put in place, the soil will again be scanned down to a depth of one foot, and elevated concentrations will be removed. Radium-226 paint waste was disposed of in the landfill.
One of the major concerns about leaving this landfill in place is the consequence of a major earthquake. The Navy responded to a comment from a DTSC engineer by acknowledging that in the event of a maximum credible earthquake, the riprap boulders forming the “seawall is conservatively assumed to be non-existent, instantaneously whisked away and replaced with a 25-foot vertical face of liquefiable sand subject to plastic flow without being constrained by a rigid shell (sea wall).” The Navy’s earthquake model predicts that the earthen embankment above the seawall at the perimeter of the landfill, composed of clay and not sand, will glide into the Bay and “will not be overtopped by the waters of San Francisco Bay and freeboard of about 5 feet above mean sea level will remain, and so the refuse will remain isolated.”
The Navy removed a perimeter security fence from their plans following objections from regulators and the public. “Navy’s design and [Superfund] requirements for this project do not preclude future use of the site for limited public access or passive recreational purposes,” said the Navy. Simple “Habitat Restoration Project” and “Stay on trail” signs were deemed adequate.
In an unusual move, the Navy offered the Restoration Advisory Board the opportunity to select the new vegetation that will anchor the 60 acres of clean soil. In the fall of 2013, the Navy will seed the new soil with 13 native grasses, most of them flowering. The Navy has permanently removed the 12-foot high embankment on the eastern, inland side of the landfill site, which will make the grassland visible from the mixed-use area.
The 30-acre wetland area on Site 2 was not contaminated, but will receive improvements to the quality of several acres. The culvert connecting the wetland to San Francisco Bay will be regularly inspected and permanently protected.
The Navy often hears calls to increase its environmental cleanup effort. Now, the community and regulators are hearing a call from the Navy to eliminate one cleanup effort altogether.
Since 2009, several acres of the area north of Bayport that includes the Shinsei Gardens affordable housing development, former Coast Guard and military housing, the closed Island High School, and the Woodstock Child Development Center have been undergoing groundwater treatment to eliminate hot spots of benzene and naphthalene vapors. Shinsei Gardens also included special building slab engineering in its design as an extra precaution against vapor intrusion. The Navy now says that its groundwater treatment system is unnecessary and should be shut down.
In a report issued in December 2012, the Navy said the underground vapor extraction system called biosparging is not making the area any safer for human habitation. Biosparging is a form of bioremediation that uses air and oxygen injections to stimulate the growth of naturally occurring bacteria, which break down toxics. In this case, the contamination is composed of waste material discharged from an Oakland coal gasification plant and an Alameda oil refinery that operated long before the area was filled in. The contamination layer has been dubbed the Marsh Crust.
The Navy’s report points to the initial studies in the area that showed no risk from vapors. The only justification for the remediation in the first place was the limited risk of contact with water through non-potable uses, since drinking water will always be supplied by East Bay Municipal Utility District.
Now the Navy says that even non-potable uses are impractical and off the table due to high levels of minerals such as salt. With no way of coming in contact with water containing benzene and naphthalene, the Navy decided to review the data for vapor exposure and concluded there is plenty of evidence to turn off the pumps. The biosparge system was designed to run for eight years in order to reach its cleanup goals.
The Navy’s December 2012 Technical Memorandum is seeking to amend the original cleanup decision — known as the Record of Decision (ROD) — for this cleanup area. They will need the concurrence of the regulatory agencies: the regional Water Board, state Department of Toxic Substances Control (DTSC), and the Environmental Protection Agency (EPA). But the EPA and DTSC are not ready to agree without further testing.
According to EPA’s Chris Lichens, “The Navy’s conclusions are not based on current data, site conditions, or investigation methods. Before proceeding with a ROD Amendment,” he said, “the agencies would like the Navy to collect additional data to verify that vapor intrusion would not present a significant risk in the absence of biosparging.” Lichens added, “Along those lines, EPA and DTSC jointly prepared recommendations for additional groundwater, soil vapor, and indoor air sampling and provided those recommendations to the Navy. The Navy has not yet agreed to collect additional data, although we are still discussing it with them,” he said.
The environmental remediation work plan for the Site 2 waste disposal area was finally introduced for public comment in early May after a decade on the Superfund list. During the 60-day public comment period that ended July 9, numerous agencies, groups, and individuals offered their critique of the Navy’s plans to install a suitable soil cover over the substandard soil cover that currently overlays the waste. Digging up the waste and hauling it away was ruled out in 2010 because of the $900 million price tag. Exclusionary security fencing, soil gas vents, wetlands, and geological/seismic stability due to close proximity to the Bay are issues receiving attention.
The Navy’s industrial waste dump on Alameda Point’s southwestern corner has been the subject of environmental concern since the 1980s when the Water Board ordered the dump closed. The mid-1980s were a little more than a decade after passage of the federal Clean Water Act and the emerging environmental awareness and new regulations requiring underground waste sites to be lined. The Alameda Point dump is composed of various unlined cells, or pits, where all manner of aircraft parts and maintenance chemicals and debris were dumped, along with waste material from the luminescent dial and marker painting that used radium-226.
The Navy’s work plan includes a security fence and tall PVC pipes to vent methane gas. Golden Gate University’s Center on Urban Environmental Law (CUEL) has been following open space planning at Alameda Point and offered comments on the proposed security fence and the 10-foot tall soil gas vents. With collaboration from UCLA’s Landscape Architecture Department they created two composite drawings illustrating the stigmatizing effect that a fence would have on this wild open space with the Bay and San Francisco skyline in the background. The Navy has proposed the fence, even though the newly seeded clean soil cap will be safe to walk on. Protection of the soil, gas vents, and monitoring equipment was the reason given for the fence.
The law group also secured the help of Pangea Environmental Services to investigate the necessity of the security fence and obtrusive gas vents. Pangea interviewed city employees and other personnel responsible for oversight of four closed Bay Area landfills that have been converted to open space and recreational uses: Shoreline Park in the City of Mountain View; Sunnyvale Landfill in Sunnyvale; Oyster Point Park in San Leandro; and Cesar Chavez Park in Berkeley. Only the Sunnyvale site has a fence, but the gates are open during the day and allow free access. “The interviewees all reported that they could not recall encountering any vandalism or other damage associated with public use to either monitoring wells/vapor probes, landfill cover materials or landfill gas venting systems during the periods (generally exceeding a decade) for which they had roles in managing the landfills.”
Pangea goes on to say, “[T]he proposed post-construction installation of permanent exclusionary fencing surrounding Site 2 is considered to contradict the ‘open space and recreational use’ land use restriction proposed in the RAWP (Remedial Action Work Plan), since a closed fenced area cannot be considered open space or be used for recreation. [T]here appears to be no technical basis for installation of a permanent exclusionary fence restricting public access to Site 2.”
The City of Alameda pointed to the Record of Decision for Site 2 that specifies certain land use restrictions such as “land disturbing activities,” which would prohibit digging, disturbing monitoring equipment, or building construction. Referring to the proposed fence, the city said that these restrictions “explicitly do not prohibit recreational uses.”
Site 2 (outlined in yellow on map above), comprising 110 acres, lies within the larger 549-acre parcel commonly known as the wildlife refuge in the runway area of the former Naval Air Station. The refuge is home to a nesting site for the endangered California Least Tern, which lies a few hundred yards east of Site 2. The US Fish & Wildlife Service currently manages the refuge and the tern colony. Continuing management of the refuge to protect the terns and their nesting area will mean that a fence and gates will always be necessary around the greater refuge boundaries to limit the introduction of mammals such as raccoons, opossums, skunks, and feral cats that could pose a threat to the terns during nesting season. The perimeter fence will also serve to control human access. Thus, a secondary fence within the refuge would be redundant in controlling access.
Both the US Environmental Protection Agency (EPA) and the Regional Water Quality Control Board (Water Board) called on the Navy to look for alternatives to the fence. The Water Board stated, “Although protection of human health and the environment is our primary goal, we request that alternatives be evaluated for the fence line and methane gas venting so that public concerns and environmental health might more naturally coexist with the other beneficial uses that are planned for the area.”
Landfill gas venting
PVC piping will be installed to vent methane gas created by decay of organic matter. Thirty of the proposed vents will be 10 feet high. However, since the predominant waste is industrial and not organic, the amount of methane produced is minimal. And after more than 25 years, methane production would be expected to be near the end of its life. The Navy’s project manager recently said that the current methane out-gassing is so low that it wouldn’t keep a flame lit if there was a flaring system, calling into question the number of vents required and their height.
The Water Board questioned the gas vents saying, “[I]t is unclear why the methane vents need to be so high.” The EPA, Pangea, and the City of Alameda echoed this concern suggesting that the methane gas venting system could be reengineered into a lower profile system.
The Bay Conservation and Development Commission (BCDC) had similar concerns about shoreline access and the visual experience of future trail users. They also called for more specifics on the overall design, including how the shoreline is suited to withstand sea level rise impacts, and specifics about drainage and other impacts on the wetlands from the new soil cover.
Wetlands connection to Bay
When the Navy extended the size of the base over 50 years ago to create the landfill site, they installed an underground 36” metal culvert that connects the North Pond on Site 2 to San Francisco Bay. Because the aging culvert does not enter the landfill portion of the site, the Navy is not addressing the soundness of the culvert, even though they are addressing wetlands issues at the site. The Navy’s presumed argument is that culvert improvements would be a “land improvement” that is outside the scope of environmental remediation requirements.
Both the Water Board and the EPA are arguing for the Navy to address the culvert issue. The Water Board stated, “We are very concerned about the age and integrity of the culvert that is the sole source of Bay water to the tidal wetlands. It is our understanding that the aged culvert is in very poor shape and may collapse any time. The value of this culvert became painfully apparent a year ago when some driftwood or other material clogged it up and impeded all tidal flow of brackish water to the wetland. In a matter of days the tidal wetland started drying up. Should that culvert collapse, the delays in rebuilding, from getting contracts to actual physical work, could be devastating and even fatal to the wetland flora and fauna.”
The EPA said, “[T]here is no evaluation of the culvert to demonstrate that the culvert is appropriately sized or constructed to minimize the potential for future blockages, nor is there any provision for the periodic inspection and maintenance.” EPA went on to say, “Either the connection to the Bay needs to be reconstructed to reduce the potential for blockage or an obligation to periodically inspect the culvert and clear blockages needs to be included in the Operations and Maintenance plan. The details for the inspection and maintenance should be reviewed with BCDC as part of the Navy’s compliance with the substantive provisions of Bay Plan.”
Further addressing wetlands issues, the Water Board questioned, “Will there be an adequate number of wells effectively placed to monitor landfill leachate concentrations that might adversely affect the adjacent wetland species?”
The hazardous waste pits on the south end of the site come within a few dozen yards of the Bay. The two longstanding concerns about proximity to the Bay have been chemical leaching into the water table, and failure of the seawall during an earthquake along the Hayward Fault. Well monitoring over the past 16 years shows that toxic chemical leaching is not a problem. However, the EPA is questioning the stability of the seawall and the earthen berm that surrounds the landfill containment area.
The EPA said, “It should be noted that based on the presented analyses the seawall along the southern coastal margin which is founded on liquefiable hydraulic fill and coarse-grained Young Bay Mud is prone to edge failure and lateral spreading.” They go on to say, “No remedial actions are proposed in the [Work Plan] to address these issues,” and they continue by saying, “[I]f the seawall is prone to failure and lateral spreading, it is unclear how further lateral spreading will be localized and will not distort the cover and result in depressions, drainage reversals or similar effects. Please address potential edge failure on spreading on southern coastal margin.” They also point out that the soil make-up of the berm around the landfill has not been characterized, leaving another question mark about seismic stability.
The EPA mentions reinforcement options such as “cement deep soil mixing and jet-grouting,” and calls on the Navy to clarify whether they think perimeter slope failure in an earthquake is an acceptable long term risk, in lieu of underground seismic reinforcements. They also point out that the work plan does not analyze consequences of future expected sea level rise.
The Navy has until August 24 to respond to comments and incorporate changes or additions to the plan in their final draft. The regulators and the Navy will meet periodically prior to the August 24 deadline. A 30-day final review by the Navy and regulatory agencies will follow. Work on the site is scheduled to begin on October 1 and be completed by summer of 2013. Completion could be delayed if the seeding of the soil cover cannot be accomplished during the rainy season.
Below is a photo gallery of Palo Alto’s Byxbee Park, which is built over a landfill waste site at the edge of San Francisco Bay. No exclusionary fencing.
“The Navy provided a more current explanation of the future redevelopment of IR Site 2, indicating that even under Department of Veterans Affairs (VA) ownership that IR Site 2 would be a wildlife refuge.”
“[T]he purpose of the multilayer soil cover is to control specific site risk through the prevention of direct contact by either humans or ecological receptors (e.g., burrowing animals).”
January 15, 2008, Minutes from regulatory agency and Navy “Resolution Meeting” on the Feasibility Study for Site 2
The past year had some high points and low points in the cleanup process at Alameda Point. Added delays, including a pile-driving surprise, were balanced out by steady progress.
The year saw, among other things, completion of a second Point-wide radiological survey of buildings and structures that identified two building interiors needing radium remediation, a new soil scan for radium on a section of the western runway area, replacement of a storm drain segment next to the Seaplane Lagoon, and preparation of the environmental document for the Berkeley Lab site, which will be useful whether we get the Lab or not.
The contractor preparing to cover the old dump with rocks and soil at the northwest tip of Alameda Point delivered some embarrassing news to the Navy. In the normal course of their duties, work-plan design testing revealed that the shape of part of the contamination did not match the official description. You would think they could just process a work-order change. But the Superfund law requires an additional two-year review process, which will push the completion of this open space opportunity to 2015.
At another cleanup project, the Navy drove over four dozen 30-foot steel electrodes into the ground to heat up the toxins and capture the vapor. But before turning on the electricity, the contractor discovered they had hit a sewer line. The project has since been idle for months awaiting a decision on how to proceed.
The big Seaplane Lagoon dredging project that began in January is certainly one of the most dramatic displays of cleanup. Both the northeast and northwest corners of the lagoon were supposed to have been dredged by April and final soil disposal completed by year’s end. But the contractor failed to meet the deadline and was let go. A new contractor has been testing and removing existing soil, as well as doing extensive set-up over the past two months for the dredging of the northwest corner that will begin in January.
Another dredging project has just begun under the dock area next to the maritime ships. They’re removing mud contaminated from two storm drain lines. That project is on schedule. It’s worth visiting the area to get a glimpse of the elaborate engineering needed to capture and clean water runoff from the mud.
Less dramatic and seldom seen work is always ongoing. Groundwater is monitored at cleanup sites to ensure cleanup goals are being met. One example is the monitoring of the removal of benzene and naphthalene under Shinsei Gardens and vicinity.
Evidence of the Petroleum Program is also seldom seen, other than some white PVC pipes in the ground. But besides the big fuel extraction projects, there is ongoing testing of pipelines and oil/water separators in order to develop a remedial plan.
Finally, and perhaps most important, getting the first, very large, no-cost land conveyance from the Navy next year appears to be on schedule. To help make it happen, the Navy and regulators are planning on modifying cleanup goals by enacting restrictions against future ground-floor residential development near the east entrance to Alameda Point.
The Site Management Plan (SMP) for the proposed site of the Berkeley Lab Second Campus at Alameda Point was finalized on November 18. Prepared by the city’s longtime environmental consultant, and signed off on by the Navy and regulatory agencies, the document was prepared in order to mitigate potential risks associated with development of the 45-acre parcel near the ship docks. Its primary purpose is to provide direction to construction contractors and workers so that their digging, dewatering, and soil handling activities do not jeopardize the environment or the health of the surrounding community.
Crash Course on Cleanup
The document offers a crash course on the 20-plus years of environmental cleanup of the area, including areas that barely intersect the Site on the margins. Even if the area were never to have been polluted by Navy activities, the SMP would still be required because of a decade-old city ordinance governing digging into a subsurface layer called the Marsh Crust that contains petroleum-related pollution.
What is the Marsh Crust?
Before 1900, the areas now occupied by Alameda Point and Bayport were tidal marshlands. In the late 1800s and early 1900s, before the health effects of industrial pollution were known, two industries nearby dumped their waste into the water. One of those industries was a coal gasification plant in Oakland. The other was the Pacific
Coast Oil Refinery located at what was then the tip of Alameda, not far from Encinal High School. Much of the petroleum-related waste, classified as polynuclear aromatic hydrocarbons (PAHs), settled in the marsh. Between 1900 and 1940, these marshlands were filled with dredge material to create more land.
PAH contamination created the “marsh crust” layer at four to fifteen feet below ground surface, which is a thin layer of PAHs and oil believed to come from historical waste discharges prior to infill.
No one was concerned about this marsh crust caused by former private industrial activity until the Navy decided to close down the base.
By the time the Navy was ready to close down the base, including the area that is now Bayport and the future Alameda Landing, soil boring and groundwater testing was routine. Underground tests in the late 1990s are what led to the Remedial Action Plan and Record of Decision that were signed in 2000. (If these documents were drafted today, they would probably have the term “carbon sequestration” in them because this carbon waste is best left where it is – sequestered in the earth.)
Those two documents led to the creation of Alameda’s “permit-before-you-dig” Marsh Crust Ordinance. The city’s ordinance requires a permit only for digging projects that dig deep enough to potentially encounter the marsh crust — that is, for digging deeper than the threshold depth. The ordinance is in place so that excavated soil containing petroleum-related waste is properly handled. The Marsh Crust extends from the Bayport/Main Street area about halfway out onto the Point at 4 to 15 foot depths. A significant portion of the proposed Lab site (see maps below) does not have any Marsh Crust underneath.
Cleanup of Navy contamination at Site in final stages
Some work, including groundwater remediation, is in the final stages. And some groundwater is past the active remediation stage and now in the stage during which contaminants will be degraded by natural processes.
The land will be cleaned to commercial standards ahead of the Lab’s timeline for occupancy. If any digging, trenching or excavating encounters a treatment zone, then more stringent handling procedures and protocols would come into play.
It will be the duty of the contractors to develop a site-specific Health and Safety Plan for their workers based on the disclosures in the Site Management Plan. These health and safety plans have to be submitted to the Navy and regulatory agencies for review.
The SMP describes the protocols for handling soils from the Marsh Crust, such as dust and erosion control. The SMP includes protocols for dewatering excavated soil, handling of asbestos and lead-based paint during building demolition, and an air monitoring system. In certain areas, vapor intrusion measures will be required, which could include a vapor barrier, passive venting systems under slabs, and podium-level (partially above-ground) garages with natural venting.
Paint stripping building (Building 410) with white cleanup pipe stubs in ground. Active cleanup completed. Looking northwest.
Navy’s Environmental Investigations
The Navy began comprehensive investigations of the area being offered to the Lab starting in the late 1980s. They analyzed for metals, petroleum-related compounds, PCBs, pesticides, chemicals that evaporate, and a form of hydrocarbon called PAHs (polycyclic aromatic hydrocarbons.) More than a dozen above ground storage tanks containing paint stripping chemicals and fuel were removed from the area. Underground fuel storage tanks from an adjacent area were excavated. Soil has been excavated. Leaked jet and diesel fuel has been removed using vapor extraction, chemical neutralizers, and bioremediation. Monitoring wells and former injection/extraction wells (evident as PVC stubs in the ground) dot the area.
Concerted Cleanup Effort
Considering the contamination history, the concerted cleanup effort over the past two decades, starting before the EPA became involved, has come a long way. The suitability of the site for commercial or residential uses has been, or will be, satisfied by the remediation programs under the Comprehensive Environmental Response and Liability Act (CERCLA) and the Petroleum Program. Furthermore, when discounting the fact that no groundwater would ever be used for drinking water, the site would meet the even higher unrestricted residential use standard much sooner.
Dr. Peter Russell, the city’s environmental consultant, made a presentation to the Alameda Reuse and Redevelopment Authority on November 2, 2011, updating them on the status of cleanup at Alameda Point.
This video is an edited version with added images.
(Note: The phrase “closed site” used in the presentation does not mean off limits. It means active cleanup is finished.)