2003 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 12 Jul 2003 07:44:54 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] Housing on old range at Miramar
Facing a severe housing shortage in the San Diego region, the Department
of the Navy is proposing the construction of 1,600 military family
housing units at Miramar Marine Corps Air Station. The Draft
Environmental Impact Statement (DEIS) for this project is open for
public comment until August 12, and the Navy plans two public meetings
near the base in late July. The notice of availability for the DEIS, as
well as the 525-page document itself, are available as PDF files from
http://www.efdsw.navfac.navy.mil/environmental/NEPA/Miramar.htm. The
DEIS file is approximately 40 megabytes in size!

The DEIS analyzes three Military Family Housing alternatives at Miramar,
as well as the required No Action Alternative. As required under the
National Environmental Policy Act, the DEIS evaluates the impact of each
alternative on biological, cultural, and visual resources; public
services (including schools); infrastructure, traffic, and
socioeconomics; and air, noise, and hazardous waste pollution. It puts
forward a preferred alternative, largely based on the need to minimize
the conflicts between the housing and both ground training and air
operations that the Marines conduct at Miramar, but the document says
relatively little about Marine training requirements. The preferred site
is within a "Research Natural Area," but the DIES concludes that none of
the alternatives threatens natural resources, such as special status
species - an issue elsewhere on the base.

The preferred alternative would place 1,600 housing units, two
elementary schools, and recreational facilities on about 300 acres in
the southeastern portion of East Miramar near the community of
Tierrasanta. My interest in the site is based upon the knowledge that
the housing site, like Tierrasanta, is situated on the munitions impact
areas of former Camp Elliot. Not far away, two boys died in 1983 after
they disturbed unexploded ordnance in an open area at the end of their
Tierrasanta cul-de-sac.

The Marines currently manage the area as an "inactive range," but in
preparation for the project, the Navy sponsored a series of record
searches and partial geophysical surveys of the property. It determined
that the land contains "small quantities" of large caliber unexploded
ordnance (UXO), as well as ordnance scrap and the remnants of small arms
fire. It plans to conduct a cleanup under CERCLA, the Comprehensive
Environmental Response, Compensation, and Liability Act, although it's
not clear whether the Navy plans a Removal Action or a Remedial Action
complete with a Remedial Investigation and Feasibility Study. It's not
clear how much regulatory oversight the Navy expects under CERCLA at
this site. It knows of no chemical contamination - such as explosive
constituents and byproducts - on the proposed housing footprint, and the
DEIS offers no hint of any plans to sample for it. The DEIS doesn't
indicate which Navy budget will support the munitions response, but such
documents rarely discuss financial issues.

According to the DEIS, the Navy plans to take a conservative - that is,
unusually protective - approach to minimize the chance of any encounters
with unexploded ordnance on or near the proposed family housing area.
Though the response is subject to the CERCLA decision-making process,
the Navy currently plans to conduct a geo-referenced geophysical survey
of the entire site, including a 100-foot firebreak around its margins.
Following that survey, it will remove the top three feet of soil and
conduct a second survey. If, after removing another three feet of soil,
it still finds ordnance, it is prepared to excavate again. (It doesn't
expect to need to go too deep however. The Army Corps' investigations in
Tierrasanta suggest that ordnance did not penetrate very far into the
ground.) The resulting land will be capped with two feet of
ordnance-free soil.

Much of the property will be bordered by a buffer zone. The Navy plans
an eight-foot fence between the firebreak and the buffer zone, as well
as a fence or other engineering control at the exterior edge of the
buffer zone. Within the buffer zone, "Site clearance would consist of a
detector-aided visual acquisition of surface MEC [munitions and
explosives of concern] materials and removal of any UXO and MEC scrap
materials. No intrusive investigation or removal of subsurface anomalies
would be undertaken." Following the initial response, the Navy expects
to have ordnance technicians conduct periodic sweeps of the buffer zone.

Finally, the Navy plans to complement its clearance activities with
institutional controls - presumably restrictions on excavation - in the
Base Management Plan, continued monitoring, educational programs,
notices in rental agreements, and five-year reviews under CERCLA.


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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