[CPEO-MEF] VOCs: Re: REUSE: Army Reserve Center at Moffett Field (CA)

[Lenny Siegel]

There is no community opposition to the planned use of much of the 
former Orion Park military housing area as an Armed Forces Reserve 
Training Center - unlike in other communities, such as Middletown, 
Connecticut.

But many of us are concerned that the plume of volatile organic 
compounds (VOCs), such as TCE, in the shallow groundwater is not being 
addressed.

The Orion Park Housing Area originally was part of the Moffett Field 
Naval Air Station. When the Navy pulled out in 1994, most of base went 
to NASA Ames Research Center, which lies between the main Navy facility 
and the housing area. But all base housing was transferred to the Air 
Force, which operates the Onizuka Air Force Station nearby. In the 1995 
round of base closures, the Air Force was told to surplus the housing, 
which was then transferred to the Army. Both the Army and Air Force made 
the residences available to other armed services and sometimes other 
federal employees.

Initially, the Army included Orion Park and two other housing complexes 
in its privatized Residential Communities initiative. That is, it 
selected a private firm to operate and rebuild its former Navy housing.

However, in the early 2000s, a previously undiscovered VOC plume was 
detected in Orion Park. The Navy contended that the housing area wasn't 
really part of the Moffett Superfund site, and it reluctantly conducted 
limited sampling. It originally argued that vapor intrusion was not 
occurring, but EPA and community oversight eventually led to sampling 
that proved that residents were exposed to unacceptable levels of TCE.

Other parties looked at the groundwater data from Orion Park, and the 
concentration pattern seemed to demonstrate conclusively that a major 
portion of the TCE on site came from a release on the property. The 
exact source is unknown, and it may have occurred before the Navy 
acquired the land in the 1950s.

The Navy, however, argued that all of the contamination was migrating 
from unknown sources south of Bayshore Freeway (U.S. 101). It said it 
could not use its funds to sample upgradient, so EPA conducted limited 
sampling confirming that some of the VOCs were coming from the south. 
Still, the high concentrations on site appear to have originated at 
Orion Park. The Navy continued to argue, because the source was off site 
and it did not consider this part of the Moffett Superfund site, that it 
did not need to conduct a Remedial Investigation and subsequent steps 
under the Superfund law.

Meanwhile, the private backers of the new housing project got cold feet, 
because of liabilities associated with the contamination, and the Army's 
partner restricted its activities to the other two housing areas. So for 
the 2005 base closure round the Army proposed successfully to construct 
a centralized regional Reserve Training Center at Orion Park.

The Army acknowledges that there is contamination on site, and that the 
contamination could potentially volatilize into the new buildings. It 
promises to build state-of-the-art vapor mitigation systems into the 
buildings, but it has revealed no long-term plans to ensure that 
building occupants are not exposed to the contamination.

In 2008, the Defense Department transferred responsibility for Orion 
Park contamination from the Navy to the Army, and the Army took up the 
Navy's argument that the contamination originated off site. I have been 
watching (on my regular bike rides along the nearby Stevens Creek Trail) 
the deconstruction/demolition of the northern portion of the old 
military housing for weeks, and on January 10 the Army broke ground for 
the new 270,000-square-foot, 39-acre facility.

That is, the Army is building a major new training center on a Superfund 
site with high levels of TCE in shallow groundwater. Yet there is no 
plan to characterize the site fully, let along clean it up. NASA Ames 
Research Center, where the Orion Park plume is migrating, is building a 
barrier remediation system at the property boundary, but its calls for 
on-site cleanup have been ignored.

Members of the Moffett Field Restoration Advisory Board (including me) 
have repeatedly called upon the Navy and now the Army to take full 
responsibility for the site. RAB members don't believe a private 
developer would be able to undertake such a major construction project 
on highly contaminated property without cleanup, or at least remediation 
plans, in place. Regulators from U.S. EPA and the regional Water Board 
have made efforts to move the cleanup process forward, but the Defense 
Department appears unwilling to accept their authority at the site.

Lenny

Lenny Siegel wrote:
> COMING UP: Army Reserve center to break ground
> 
> Daniel DeBolt
> Mountain View Voice (CA)
> Janury 9, 2009
> 
> A $79 million facility for Army reservists will have a groundbreaking 
> ceremony on Saturday morning just outside the main gate at Moffett Field.
> 
> After demolishing dozens of military housing units, the Army will now 
> begin construction of a 270,000-square-foot facility on 39 acres.
> 
> 
> ...
> 
> For the entire article, see
> http://www.mv-voice.com/news/show_story.php?id=1100
> 




-- 


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 at cpeo.org>
http://www.cpeo.org