A hazardous substance at Alameda Point would have been cleaned up by now if its manufacturer had not withheld negative health data, and the U.S. Environmental Protection Agency (EPA) had acted sooner. Instead, a whole new cleanup process has been launched by the Navy, which could take another five years.
The PFAS (perfluoroalkyl and polyfluoroalkyl substances) class of toxic chemicals have been known to be present at several isolated underground locations around Alameda Point for a long time. There is no alarming presence of PFAS or risk to the public. Nevertheless, now that PFAS are designated a hazardous substance by the EPA, the Navy is required to conduct a time-consuming process for remediation.
In anticipation of the EPA designating PFAS as hazardous, the Navy is conducting a pilot study at the former firefighter training area where PFAS-containing fire suppression foam was used. The study will evaluate a promising method of dealing with PFAS in groundwater, which could potentially be employed at other sites.
As welcome and necessary as the cleanup is, it should not have taken decades to get here.
The late-coming regulations are affecting city plans for selling one of the valuable buildings at Alameda Point. Also, the Department of Veterans Affairs (VA) abruptly halted work on its project pending investigation for PFAS in 2022.
The 2024 regulations of chemicals known as PFAS are coming online after the Navy’s 25 years of cleanup decisions were already made, including for the property turned over to the VA. Based on past experiences, the Navy’s newly instituted cleanup process for PFAS on city property could take around five years to complete. It is unknown how long it will take the VA to address any PFAS issues it discovers.
PFAS chemicals, used in hundreds of retail products like non-stick skillets and industrial products like firefighting foam, have been known to be a human health risk since the last century. But because the manufacturer (3M) stonewalled information for decades about the widespread presence of its chemicals in human blood, and the EPA dragged its feet on regulating the chemicals despite having data warning of the risks, we are only now seeing regulations catch up with the risk.
The Navy’s 2023 PFAS Site Inspection Report for Alameda Point provides details of previous groundwater sampling, going back to 2016, that flagged five existing cleanup sites with PFAS. But the information did not lead to any cleanup work for PFAS because it was not yet designated a hazardous substance by the EPA, a prerequisite for spending money on cleanup under the Superfund law.
Valuable hangar in limbo
One of the sites known to have PFAS in groundwater is Site 6, where the Building 41 hangar is located on West Tower Avenue. The City owns the building, which sits mostly vacant.
“Our plan for Building 41 was always to engage in a long-term lease with an option to purchase to address the uncertainty associated with PFAS,” said Abby Thorne-Lyman, Director of Base Reuse and Economic Development.
The uncertainty stems from not having an official legally binding cleanup document, called a Record of Decision, that spells out how the Navy will clean it up. Without a Record of Decision, the city could be held liable for a PFAS injury by a future owner. While the current investigation plan for PFAS is indicative of the Navy’s intentions, those intentions would not release the city from exposure to litigation.
Building 41 is not currently being marketed for lease or lease with option to purchase on the City’s Alameda Point web page, where other buildings are offered for lease.
Navy belatedly required to clean it up
It was not until 2018 that the Navy formally acknowledged that PFAS could be a problem for future construction workers at Building 41 by modifying the Record of Decision to include so-called “emerging contaminants,” namely PFAS, that were “emerging” in scientific data as a real health risk. The modification did not, however, require cleanup. It was only a cautionary note for anyone digging below the surface to be aware of PFAS.
The Navy became officially responsible for cleaning up PFAS in April 2024, when the EPA finally designated PFAS as hazardous. If the EPA had designated PFAS as hazardous 20 years ago, when it was fully aware of its widespread presence in human blood and likely to cause cancer, it would have been part of the Building 41 cleanup process that started in 2010 when the Navy began remediating solvent in the groundwater.
3M Manufacturing suppressed PFAS health data
How 3M, the manufacturer of PFAS, discovered and then concealed the health dangers of PFAS chemicals for decades is documented in this May 2024 investigative report. One of the concealed red flags in early research at 3M showed that PFAS was showing up in blood bank samples all across the country. The report reveals how company executives withheld internal data showing that one of their PFAS chemicals caused liver abnormalities in factory workers, and that they ignored warnings by a respected toxicologist.
EPA and Department of Defense minimized health risks
In 2005, an EPA advisory panel concluded that one of the PFAS chemicals widely used in consumer products is a likely human carcinogen, according to this brief history. And for many years both the EPA and the Department of Defense used an outdated testing method that minimized the health risks of PFAS in water samples, rather than utilize a newer more sophisticated method, according to this investigative report.
Navy’s PFAS investigation plan unveiled at cleanup meeting
On September 12, 2024, the Alameda Point Restoration Advisory Board heard a presentation on detailed plans to investigate the extent of PFAS contamination and develop plans for remediation. The investigation phase, including installing new groundwater monitoring wells and taking some 138 soil and groundwater samples, will begin in November and be completed next July. Then a laboratory will take four months to analyze the soil and groundwater samples.
The lab results will inform the preparation of a draft report due in March 2026 that will include alternatives for remediating the various sites. This will be followed by regulatory agencies commenting on the report and eventual selection of remedies that will be incorporated into a Record of Decision for PFAS. Once signed by the Navy and regulatory agencies, the Record of Decision is the point in the timeline when the city will finally be shielded from liability when it sells Building 41, even if the cleanup work has not yet been completed.
With the Record of Decision signed, the Navy will then select a contractor to perform the work. Once the work has been completed, a period of perhaps a year of monitoring groundwater will take place.
If all remediation works as planned, it will take a period of many months to prepare a PFAS cleanup action completion report. PFAS remediation will then be deemed complete. The long process of getting there could take five years, passing the 30-year mark from when the base closed in 1997.
Contributing writer Richard Bangert posts stories and photos about environmental issues on his blog Alameda Point Environmental Report. His writing is collected at AlamedaPost.com/Richard-Bangert.