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November 2001

Army Ordered To Clean Up Hamilton Toxics?

By Elena Belsky

The San Francisco Bay Regional Water Quality Control Board (RWQCB) is preparing to issue a Clean Up and Abatement Order to the US Army Corps of Engineers (USACoE) for pollution caused by Landfill 26 to the soil and groundwater on the former Hamilton Air Force Base (HAFB). This article describes the Tentative Order, which is slated to be approved by the Regional Board of Directors on November 28. The draft Order is expected to be approved as written, and if the Board holds true to form, this will be a major victory for those with environmental concerns regarding Hamilton.

Citing a long and ongoing history of violations, and lack of action by the Army Corps, the Clean Up and Abatement Order mandates a series of tasks, corrective measures, toxics sampling, and timelines, with penalties for failure to complete each one, of up to $10,000 per day: Completion of the tasks in this Order is necessary to alleviate the pollution and threatened pollution of surface water and groundwater posed by the migration of pollutants from the Landfill.

Environmental advocates working on Hamilton issues have long complained about the lack of monitoring and inadequate closure work done on Landfill 26, citing numerous possible routes for toxics to escape the hazardous waste landfill: known sand channels underneath the landfill, groundwater saturation, old utility pipes, and surface water runoff. Landfill 26's proximity to Pacheco Pond and the wetlands project on the nearby airfield are also a major concerns.

Regarding the issuance of the RWQCB, says Friends of Novato Creek director, Sue Lattazio, "This is a win. Friends of Novato Creek and San Francisco BayKeeper have been lobbying for more comprehensive monitoring and corrective measures for nearly a year now. This is a toxic landfill, and it's polluting the environment."

A Brief History of Landfill 26

Opened in the 1940s, the unlined Landfill was mostly used for solid waste, including hazardous and non-hazardous materials of approximately 150,000 cubic yards on 29 acres. Also of note in the RWQCB was the addition of information that there was approximately 26,000 cubic yards of oily sludge dumped in the Landfill. The entire landfill and its contents are in the groundwater table; aerial photos show historic flooding of low areas of Hamilton, including Landfill 26, the Runway, and adjacent properties, from 1942 era to present. Documented toxic chemicals are stated in the Board's Clean Up and Abatement Order and "include volatile and semi-volatile organics, petroleum hydrocarbons, pesticides, PCBs, and metals."

Closed in the 1970s, the Landfill underwent and "interim remediation" and was "capped" in 1994, but without addressing groundwater and surface water issues and without a proper venting system for methane. In the Fall of 1999, the gas monitoring probes installed around the perimeter of the landfill began detecting methane gas exceeding the regulatory health and safety limits, yet no action was proposed by the Army Corps until early 2001, when conditions became critical and began impacting a nearby subdivision under construction-over a thousand feet away.

US Army Corps/Landfill 26 Violations

The RWQCB states a multitude of violations by the USACoE and Landfill 26, including: failure to address the methane situation adequately and promptly, dismantling a Board required water treatment system for the landfill, refusing to provide a long-term solution to the landfill's illegal discharges, and polluting the waters of the state, among others.

In the Fall of 2000, monitoring on private property adjacent to the landfill showed methane levels consistently above the 5% regulatory limit and, "Detectable concentrations of sulfur compounds and volatile organic compounds, including 2-Butanone, 1,1,1-Trichloroethane, vinyl chloride, chloroform, MTBE, toluene, ethylbenzene, xylenes, and benzene have been detected" a direct violation of the Waste Discharge Order, which states "the waste management unit shall prevent migration of wastes to adjacent geologic materials, groundwater, or surface water, throughout the closure and post-closure periods." Contaminants such as diesel hydrocarbons are also present in a monitoring well down-gradient (towards Pacheco Pond and the wetlands project) of Landfill 26 "suggesting that groundwater pollution is not contained to the Landfill."

During the discovery and subsequent public outrage regarding the hazardous methane condition being produced by Landfill 26, community members and environmental groups specifically pointed out that only 1/3 of the landfill had actually been tested for methane problems, without studying the other 2/3rds of the Landfill. It seems that the Regional Board as well has problems with this approach, and addresses it in the Clean Up and Abatement Order a number of times: "Data show that methane and volatile organic compounds are present in soil gas and groundwater outside the Landfill boundary to the south. Impact to groundwater and soil gas is unknown on the other three sides (west, north, and east) of the Landfill."

The Tasks Assigned

The Regional Board has assigned five specific, time-dated tasks to the Army Corps of Engineers for Landfill 26 and the areas immediately surrounding it. Penalties will be levied if each task is not completed by the mandated deadline, and correspond to the amount estimated for the Regional Board to complete the task if the Army Corps fails to do so.

Task 1 is a Corrective Action Study mandating a technical report detailing possible corrective actions for the entire methane problem at Landfill 26. Task 2 implements the chosen remediation from the Study in Task 1. Task 3 mandates that the Army Corps investigate, sample, and evaluate Groundwater/Surface Water and Soil Gas migration and contamination issues, within, underneath, and surrounding Landfill 26. And perhaps most importantly to the environmental advocates, "The analytical [series of tests]shall include the full suite of chemical constituents reportedly contained within the Landfill. Furthermore, the surface water, groundwater and soil gas monitoring program shall ensure that all potential migration pathways are monitored and that the data quality are representative of the groundwater and soil gas in the area of the waste management unit." Task 4 implements the monitoring program after the construction of the methane remediation is complete.

Task 5 is a Report of Waste Discharge that pulls all the previous Tasks together in one document, demands evaluation of all studies, effectiveness, cost, construction plans and a time schedule for all of the above. "The technical report will evaluate the adequacy and, if necessary, the need for additional control (Landfill gas, groundwater, and surface water)based on: a) Evaluation of all geologic, hydrologic, and soil gas and water quality data historically associated with Landfill 26 and collected as part of this Order; and, b) Title 27 regulations." California Code of Regulations, Title 27 deals with Environmental Protection, including Solid Waste treatment, storage, processing, and disposal.

Holistic Approach

While the Regional Board has finally taken the Army Corps of Engineers to task for their past malfeasance, and is attempting to correct the worsening situation at Landfill 26, which is critical, there is still a larger issue. The entire picture of groundwater, surface water and hydro-geologic status on Hamilton is unknown, and has never been put together and evaluated from a "holistic" viewpoint. Landfill 26 is a hazard, no doubt, but all the "pieces"" at Hamilton need to be assessed together soon, as their overall effect on adjacent and neighboring projects is essential to the health of the humans and environment.

 

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