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More on McClellan AFB wastewater problem

In a strongly worded letter to the Central Valley Regional Water Quality Control Board on September 10, Bill Jennings, CSPA's Executive Director, formally requested status as a "designated party" in the McClellan Air Force Base toxic waste disposal fiasco. CSPA's status as a "designated party" would allow the grassroots organization direct input into the renewal permit process to make sure that toxic waste is not discharged into Central Valley waterways from the base.

Magpie Creek flows through McClellan and for decades carried the effluents of the Base's domestic and industrial waste treatment plants into the Sacramento River through Steelhead Creek above the mouth of the American River. McClellan is located approximately seven miles northeast of Sacramento in Sacramento County and covers 2,952 acres. Operations at the base involved the use, storage, and disposal of hazardous materials, including industrial solvents, caustic cleaners, electroplating chemicals, heavy metals, polychlorinated biphenyls (PCBs), low-level radioactive wastes, and various fuel oils and lubricants.

Opened in 1935, for the vast majority of its operational lifetime, McClellan was a logistics and maintenance facility for a wide variety of military aircraft, equipment and supplies, primarily under the cognizance of the Air Force Logistics Command and later the Air Force Material Command. Unfortunately, McClellan also became dumping ground for the Air Force's toxic waste.

"When the base was decommissioned in the late 90's, it was found that the operations at the facility had created a toxic wasteland," said Jennings. "A major cleanup of the facility was put in place before large portions of the base were leased out to commercial enterprises. The base received a waste water treatment discharge permit as part of that clean up effort."

In reviewing the permits application for renewal, CSPA has discovered that the requirements for discharge have been relaxed, allowing for a backsliding in the treatment and isolation of numerous harmful chemicals and other toxins that would be discharged into the valley waterways. "The discharges would be in violation of numerous state and federal standards and would put the valley fisheries at risk," Jennings contends.

In his letter to Mr. Ken Landau, Assistant Executive Officer of the Water Board, Jennings documented a plethora of violations of state and federal environmental laws in the proposed permit.

For example, the proposed permit fails to contain mass-based effluent limits for toxic chemicals including Carbon Tetrachloride, Chromium VI, Dichlorobromomethane, 1,1-Dichloroethane, 1,2- Dichloroethane, 1,1-Dichloroethylene, Tetrachloroethylene, Trichloroethylene, Vinyl Chloride and cis-1, 2-Dichloroethylene as required by Federal Regulations 40 CFR 122.45(b).

The proposed Permit also contains an effluent limitation for acute toxicity that allows mortality to aquatic life that exceeds the Basin Plan water quality objective and does not comply with Federal regulations, at 40 CFR 122.44 (d)(1)(i) or the Clean Water Act.

Nor does the Permit contain effluent limitations for chronic toxicity, as required for compliance with Federal regulations, at 40 CFR

122.44 (d)(1)i) and the Policy for Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and Estuaries of California (SIP).

The release of more toxic discharges into Central Valley and California Delta waterways would only further imperil collapsing Central Valley chinook salmon and Delta fish populations. Four species of pelagic fish species, including delta smelt, longfin smelt, threadfin shad and striped bass, have declined to record low population levels in recent years, due to increased water exports from the Delta, increasing toxic chemical discharges in Central Valley waterways and an influx in invasive species.

The last thing our collapsing public trust fisheries need is for the water board to allow the increased dumping of toxic chemicals into the Sacramento River and Delta!

For the complete letter by Jennings, go to http://www.calsport.org/wq9-10-08b.pdf