Around 50 people took part in the first city-sponsored tour across the old naval airfield to the western shoreline of San Francisco Bay on Monday, Oct. 26.
The convoy of automobiles stopped near the future site of the Department of Veterans Affairs (VA) clinic and at the shoreline next to a restored 30-acre wetland site. The wetlands are located within the Navy’s 100-acre cleanup site known as Site 2.
While Site 2 has been known for the past 18 years as a mysterious off-limits environmental cleanup site, most of the visitors on Monday’s tour seemed more interested in the area as a scenic viewing site.
Despite the sparse showing of birds on the wetland during the visit, the group appeared awed by the vast expanse of land, water and sky that surrounded them as they stood on the embankment overlooking the wetland and the Bay.
A future leg of the San Francisco Bay Trail will eventually pass between the wetland and the shoreline, with views all the way to the Golden Gate Bridge on a clear day. The state’s Bay Conservation and Development Commission requires the VA, via its shoreline authority, to grant an easement to the city for construction and operation of the trail. No date has been set for when this process will begin.
During the stop near to the future VA clinic site, Jennifer Ott, the city’s chief operating officer for Alameda Point, informed the group about the public roadway, including underground utilities, that the VA is going construct leading to the western shoreline. The roadway will provide public access and utility hook-ups for city-owned open space property along the Oakland Estuary. The group parked at the western shoreline where the future observation point and trail access parking lot will be located at the end of the road.
The tour was arranged at the urging of Vice-Mayor Frank Matarrese. Also in attendance was Mayor Trish Spencer.
“The VA’s future home and the wetlands restoration area at Site 2 are key features of the old airfield surrounding the least tern nesting area,” said Matarrese. “It is absolutely important that people get a chance to see how these three assets work together in this huge tract of land.”
The Navy still retains some responsibilities at Site 2 — namely, for ensuring that the grassland vegetation on the landfill soil cover is successful.
“Seeing the wetlands makes me want to accelerate our wetlands efforts on city property,” said Matarrese.
The Seaplane Lagoon’s north side will be looking like its old self in a few months. The Navy has begun dismantling the waterproof concrete-walled containment system that was used for three years for dewatering and testing of soil dredged from the Seaplane Lagoon, marking a major cleanup milestone. Prior to that dredging work, much of the lagoon’s north frontage served as a staging area for replacement of storm drain lines contaminated with radium-226.
Construction of a new and improved soil cover over a waste disposal site concluded this spring, marking another milestone. The 110-acre site on the southwest corner of Alameda Point took 10 years of haggling about potential environmental impacts before a cleanup plan was adopted in 2010. Work began in early 2013. The dome-shaped soil cover required 500,000 cubic yards of barged-in soil to complete.
At the far northwestern corner of the Point, work is about to begin on another long studied and analyzed waste disposal site. In a few months, the Navy will be installing an interlocking steel retaining wall along 200 yards of the Bay shoreline to contain contaminated burned waste material that was bulldozed into the Bay more than a half century ago. Water dye tests showed no toxics are leaching into the Bay, but members of the Restoration Advisory Board (RAB) questioned whether the barrier would withstand a catastrophic earthquake. Partially covered by runway pavement, the entire 30-acre site will receive a three-foot soil cover. The work is expected to be completed in 2015. The area will be available for passive recreational use such as hiking trails when the city receives the land.
One of the longest-running and most problematic cleanup sites is at the old Naval Air Rework Facility (NARF), also known as Building 5, covering nearly one million square feet. Radium paint used for aircraft dial painting, and chemicals associated with engine repair work led to contamination that is still being remediated. The entire floor area will be scanned again for radiation in 2015, following up on at least three prior scanning surveys of walls, ceilings, pipes, and ducts. The year 2015 will also see the Navy returning to the site for a final round of groundwater cleanup treatments targeting contamination remaining after an intensive cleanup effort a decade ago.
Next door to the Bladium Sports Club on West Tower Avenue, another previously treated groundwater cleanup site will be treated again. Workers have already begun boring holes in the pavement for a network of hoses that will be used for introducing contaminant-eating bacteria into groundwater along with a bacteria food source.
On Saturday, July 12, the Navy’s annual cleanup site tour visited four of the cleanup areas. The most impressive stop was the 110-acre landfill site mentioned above. For the first time in over 15 years, members of the public were allowed to walk around and enjoy the magnificent views from the embankment that is closer to San Francisco than to city hall. The fencing is all gone, and with it the radiological warning signs. The Navy replaced an aging metal culvert that connects the site’s North Pond to San Francisco Bay with a concrete culvert.
Tour participants were able to see the area’s expanded wetland with a new tiny island. Caspian Terns started nesting on the island a few months ago, another type of milestone. “The last time Caspian Terns were seen in that area nesting was in 1999 when only one nest was detected,” said Alameda wildlife biologist and Alameda Point bird surveyor Leora Feeney. The 79-acre soil cover on the landfill will be seeded with flowering native grasses later this year. The vegetation mix was chosen by the RAB.
According to the Navy’s environmental cleanup coordinator, Derek Robinson, $513 million has been appropriated to date for Alameda Point cleanup, although some of it remains to be spent on upcoming work. His office, the Base Realignment and Closure Program, estimates another $80 million will be needed by the time remaining projects and follow-up monitoring are completed.
Later this year, the Navy is expected to transfer to the city the 33-acre North Housing site and seven-acre former Island High School site that sit next to Alameda Landing and Estuary Park, marking another milestone on the long and winding cleanup road to civilian use.
Update notes: Subsequent criticism of the Navy as to the necessity of a security fence by members of the public and regulatory agencies led to the removal of the security fence from the final work plan design. The Navy also agreed to shorten the soil gas vents to two feet, since only trace amounts of methane gas are now emitted from the landfill waste, most of which is industrial and did not produce methane in the first place. Additionally, the Navy agreed to examine the aging metal culvert that connects the North Pond of the West Wetland to San Francisco Bay. The culvert provides the water lifeline for the North Pond habitat and was at risk of collapse and being stopped up with debris. The Navy replaced the metal culvert with a concrete culvert (see photo above) and debris screen.
The city’s west side of the Seaplane Lagoon at Alameda Point is mostly pavement – acres of it – with a few old buildings abutting a wetland on the federal property. The city claims its long-range plan for this area features a conversion to a wetland habitat, but their only commitment is to continue leasing the buildings to generate revenue while allowing a sea of unnecessary pavement to remain as an environmental blight.
Opportunities for implementing ecosystem enhancement, both short and long term, have yet to be explored for this area. We need to start moving in a direction now that benefits the environment by reducing climate impacts, improves the atmosphere around nearby businesses, adds to public enjoyment, and increases wildlife habitat.
Proposal for ecosystem enhancement
Short-term plan – Remove all pavement not required for commercial tenants. Recycle the pavement at the VA’s Alameda Point project site where they will be raising elevation and need base rock and fill. Once the pavement is removed and the soil exposed, native vegetation could be planted. Native vegetation will absorb CO2, produce oxygen, eliminate the heat island effect of the former pavement, add wildlife habitat, improve the aesthetic appearance of the property, and make it attractive as a hiking, jogging, and cycling destination.
Step 1 – Set aside money from lease revenue generated on the west side of the Seaplane Lagoon for pavement removal and introduction of native plant vegetation.
Step 2 – Explore recycling pavement at Alameda Point.
Step 3 – Explore grant sources for conversion of paved areas to native vegetation, i.e., state air quality board, EPA, State Lands Commission, etc.
Long-term plan –Establish an Alameda Point Wetland Mitigation Bank, which would incorporate the west Seaplane Lagoon acreage along with 50 acres on the northwest side of Alameda Point (Northwest Territories). Investment money would provide the capital for wetland creation, with money being recouped when mitigation credits are sold to developers elsewhere in the Bay watershed to offset their project’s impacts. As a general rule, a tidal wetland is worth at least as much as it would cost to create it. That’s why businesses exist that specialize in mitigation banks. In theory at least, the wetland project could be self-funding.
Step 1 – Commission a study on wetland mitigation bank formation using lease revenue from Buildings 25 and 29.
The San Francisco Bay Conservation and Development Commission (BCDC) gave its approval for the shoreline access provisions of the Veterans Affairs’ (VA) project at Alameda Point at its January 16, 2014 meeting. The VA submitted plans that include a public road with sidewalk and bike lane leading to the western shoreline, a one-acre parking and observation area at the shoreline, restrooms, drinking fountains, long term maintenance, and a shoreline easement for the city to construct the Bay Trail. The VA’s plan reflects collaboration with BCDC staff and the City of Alameda.
Some of the BCDC commissioners were concerned about the size of the undeveloped buffer area for the California Least Terns that nest on the former airfield, and the lack of public access on the proposed Bay Trail from April 1 to mid-August while the terns are present. Other commissioners were concerned that the VA and the Army Corps of Engineers had not finalized a plan to mitigate wetlands that the VA project will cover up.
The following excerpts from the 18,000-word meeting minutes for this agenda item offer insight into the long and sometimes contentious effort to construct a VA outpatient clinic, offices, and a new national cemetery at Alameda Point.
Commissioner Geoffrey Gibbs enquired, “I would like to know from the city of Alameda how these plans are consistent with the city’s hope for a mixed-use development on or near the site.” Alameda Point Chief Operating Officer Jennifer Ott responded, “We’ve been working with the VA for several years and they are consistent with our plans,” Ott said, “and the city has planned over 150 acres of additional park space, passive, open space that by building that road will actually help us bring down the cost of our development of that space to the north. It is a huge help to us to be able to implement additional significant regional open space facilities.”
Commissioner Jim McGrath questioned the VA about the need to prohibit access to the shoreline during the Least Tern breeding season from April 1 to mid-August. McGrath said, “I’m excited that something has been found to work in the long term to manage and preserve the wildlife area. I would love to see it expanded. When I began looking at the maps I said, boy, that Least Tern colony is a long way from the shoreline, over a mile.
“While I absolutely support science-based information that protects nesting areas for endangered species as warranting the highest level of protection, I don’t necessarily see the analytical gap bridged here between the potential for impact, the need for management and the need for, on a long term, restrictions of this nature.
“Some of the research that I’ve seen for the development of habitat areas within the restoration of the South Bay Salt Ponds, the research established that predation from avian species, particularly Western Gull, were the main threats to the Least Tern successful breeding.
“I know from my own experience that there has been successful breeding at fenced sites in southern California at Playa Del Rey and in Orange County; smaller sites on beaches with much less robust buffers.
“It raises in my mind the question of, would we not be better off with some active management of the Least Tern area that is science-based looking at the sources of predation, looks at the actual colony. I don’t want to pick on this project so much as say, if under the consistency review authority which is our single shot at trying to balance wildlife protection and provision of public access, we don’t ask those questions at this stage, we may miss the opportunity to try to achieve a better balance.
“I am a little bit troubled with a mile buffer.”
Mr. Richard Crowe from the VA responded: “We spent several years negotiating with the U.S. Fish and Wildlife Service. From our research, there is no science or an adequate buffer from a development to a colony. There is science on adequate buffer between colony nests. There is a paucity of research in that area.
“The U.S. Fish and Wildlife Service was adamant and we’ve negotiated in good faith and they felt that that quarter mile, 1674 linear feet, was the necessary buffer for the human impacts potential on the Least Tern.
“We’ve negotiated as much as we could and in order to get a favorable biological opinion that those were the final buffers.”
Commissioner McGrath continued the dialogue: “I understand and sympathize with your dilemma but adamancy does not constitute peer-reviewed science. And while we don’t have the U.S. Fish and Wildlife Service here, I guess to some degree I do think of that as the independent analytical role of the staff and the Commission.
“I have no trouble with the provisions and the burden with the VA with the exception of, that may end up being de facto management of this system on a hands-off basis when that, in fact, is not the best thing for either habitat or public access.
“I don’t know what to do with that concern. It certainly bothers me.”
Mr. Crowe responded: “The biological opinion is subject to negotiated modification should any other new science come up or new position by the current managers. The development was going to be below that little bulge but the U.S. Fish and Wildlife Service felt that that was going to jeopardize the Least Tern and they were going to issue a jeopardy opinion, which would kill the project. We negotiated very well and successfully with the city of Alameda to move that development up and that satisfied the U.S. Fish and Wildlife Service and all parties agreed to that and I think that was our way forward.”
Jennifer Ott added, “From the City’s perspective we would have much rather have had a year-round trail. I can imagine the City approaching the VA at a future time, once things have settled, bringing this up again as an issue.”
The VA’s project will entail filling in about 11 acres of wetland. The VA will be required to mitigate the loss of wetland, but those plans have not yet been agreed to and approved by the U.S. Army Corps of Engineers. Some commissioners wanted to postpone the vote to approve the VA plans until they could see the wetland plans, even though the wetlands are outside BCDC’s jurisdiction.
Commissioner Kathrin Sears said, “We look at the Least Tern in a different way because the birds fly. Wetlands can become connected to the Bay and have a broader impact on areas in our jurisdiction as sea level rises. I think there are different issues there that might make it appropriate for us to look at the wetlands.
Commission Chair R. Zachary Wasserman said, “Coming back to the issue of the wetlands that are outside of our jurisdiction, that are within the Corps’ jurisdiction; the issue being raised is, will the Least Terns – we are legitimately taking that into consideration because they’re migratory, they use the Bay, they use our jurisdiction. The question that has been posed is for the wetland that is outside our jurisdiction, which theoretically is used by shore birds; is that sufficient then to bring it within our consideration just as the Least Tern issue is?”
The VA’s Doug Roaldson commented: “We appreciate the [U.S. Army] Corps [of Engineers] and we have had numerous talks with you. We are clearly interested in those wetlands. We’ve had numerous discussions about a strategy. We’re still evaluating that strategy. We don’t know what’s happening and this is outside of your jurisdictional discussion right now. What’s the VA going to do? We’re going to take care of those wetlands. We’re either going to move them and we’ve got two very high quality wetlands on the property and they are very easy to mitigate into. We’ve had these discussions with the Corps.
“We’ve had a discussion, if we mitigate do we mitigate by phase or do we mitigate the entire site?”
The last comment offers insight into why the VA and Corps of Engineers have not yet agreed on a plan. The Corps wants the entire 11 acres of wetland mitigated at the beginning of the project, even though some of those acres won’t be impacted for decades when more of the columbarium is built out. The VA, on the other hand, wants to pay for the mitigation when the wetlands are actually filled in.
Whether the wetlands are mitigated in phases or all at once, the plan will have to be agreed upon when the VA begins their project. BCDC’s approval contains special conditions that require Corps of Engineers approval of a wetland plan at the project’s commencement.
BCDC staff member Jaime Michaels said, “I just want to point out given the conversation we’ve been having [about wetland mitigation], there is also a condition and it’s Special Condition II.C that talks about the need for the VA to get other local, federal and state approvals before they begin their work. That would include the Corps of Engineers’ approval.”
A motion was made and seconded to approve the VA’s project as being consistent with state law, in this case the San Francisco Bay Plan, as required under the federal Coastal Zone Management Act. On a roll call vote, the motion passed with 13-Yes, 2-No, and 4-Abstain.
The property is slated to be transferred from the Navy to the Department of Veterans Affairs in 2014.
On August 3, 2013, the Navy’s annual environmental cleanup tour visited the worksite known as Site 2 on the southwest corner of Alameda Point. Work has been underway at the site since early this year, constructing a 79-acre soil cover atop the old waste disposal area. Due to budget cutbacks this year, only the Restoration Advisory Board was taken on the tour.
The site was closed for waste disposal in the mid-1980s and given a soil cover that did not meet landfill closure standards. For more than a decade after it was added to the Superfund cleanup program, the regulatory agencies and the Navy went back and forth about how best to close the site in an environmentally safe manner.
The slope of the soil cover is so important to the engineering design that the blades on the graders are not even controlled by the driver. Blades on the graders, and even the bulldozer, are controlled by an onboard computer that uses a GPS satellite to maintain a uniform elevation. The engineering concept for this soil cover is to minimize the slope so as to minimize movement in an earthquake, while at the same time providing for drainage.
Soon the contractor will be laying down a 200-mil-thick HDPE geonetting material to act as a barrier to burrowing animals. Next, they will add two more feet of soil before installing monitoring equipment, drainage features, access road, and seeding the soil with a variety of California native grasses. Seeding is planned for this fall before the rainy season.
The 30-acre wetland area is not contaminated, but it will receive some upgrades with additional wetland. There is both a freshwater wetland area fed by rainwater, and a saltwater wetland area connected to San Francisco Bay via an underground culvert. The culvert will be replaced due to its age.
More than 600,000 cubic yards of soil is required to complete the project. Of that amount, 110,000 cubic yards have been recycled from the Seaplane Lagoon dredging after it tested clean. The rest is being barged in from Decker Island in the Sacramento River near the town of Rio Vista.
This 110-acre project site, featuring the most scenic viewpoint in all of Alameda, will be transferred to the U.S Department of Veterans Affairs (VA) along with another 400 acres of the Nature Reserve, and 112 acres for the VA’s clinic and columbarium. A nearby public access area on the western shoreline will be developed when the VA completes their road along the northern perimeter of the columbarium to the western shore. The Bay Trail will eventually run along the shoreline.
The 4.18-acre cleanup Site 34 in the old runway area next to the Oakland estuary looks barren from a distance. But up close there are concrete slabs and pavement, reminders of its bygone days as a bustling workshop area.
This area was once part of the division known as the Naval Air Rework Facility (NARF). Everything from sandblasting and painting, to metal working, woodworking, and scaffold maintenance went on out there. More than 40 years of activity left soil around buildings contaminated with lead, arsenic, pesticides, PCBs, and aircraft and diesel fuel. Above ground fuel storage tanks and electrical transformers contributed to the contamination.
The Navy will clean up the soil in this area next year. Their draft work plan, which will be released on July 31, was discussed during a Navy presentation at the July 2012 Restoration Advisory Board (RAB) meeting.
Based on more than 200 soil samples taken in prior years and this year, the contractor created the draft work plan. Separate groundwater samples indicate contamination from the solvent trichloroethane. No remedial action is being taken on the trichloroethane, however, because 1) vapor intrusion into residences is not a factor, as this land will become Public Trust Land on which housing is not permitted; and 2) water monitoring has shown that the chemical is not migrating toward the estuary.
The northern edge of this site is part of the early westward land extension of Alameda, which allowed trains carrying freight and passengers to get out to a point where the water was deep enough for ferry connections. More fill was later added to the area. According to the Navy’s Remedial Investigation report, “In the 1920s, most of IR Site 34 was filled with estuary dredging material during construction of the Posey Tube.”
By the time the closure of the Navy base was announced in 1993, this workshop area had 12 buildings, 7 aboveground storage tanks, 2 “generator accumulation points” (waste storage), 15 transformers, and over 7,000 feet of aviation fuel line. Between 1996 and 2000 everything except the concrete pads and pavement was removed.
Building demolitions ended shortly after Alameda Point became a Superfund site in July 1999. The Superfund program, officially called the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), does not allow for land improvements such as building demolition.
Most of the soil cleanup locations are adjacent to the exterior edges of old building slabs. Much of the lead in the soil came from sandblasting lead-based paint. Other contamination came from lubricants used for metals fabrications, and the use of oils and solvents for woodwork and metal work. In addition to removing soil next to the slabs, the contractor will dig under the slabs at the hot spots to take what is called a sidewall sample to confirm that all contaminated soil is removed. They have to keep digging as long as contamination is found. Clean soil will be brought in to the areas where soil is removed.
A strip of coastal marshland running along the Oakland Estuary on the north end of the site has no contamination. Its habitat quality, however, is marred by discarded concrete, wood, and trash. It will be up to the city to initiate wetlands restoration efforts there.
A 60-day public comment period on the work plan begins when it’s released on July 31. The work plan will be finalized in January 2013. Fieldwork is anticipated to take place January through April 2013.
Site 34, located in the Northwest Territories, is expected to be given to the City of Alameda in 2014.
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