This January 3, 2000 document is the “Final Report — Phase I Environmental Site Assessment — Brentwood School Lease Area” by URS Greiner Woodward Clyde for Coastal Safety & Health Services under contract by the VA. Following are excerpts of this “ESA” with comments.
This ESA’s advice here may be some that the VA had wish it had taken. There is no way to know if it has as EnviroReporter.com has not been successful in getting the VA to respond to its queries.
“As mentioned previously this ESA does not address concerns previously expressed to you by phone concerning which California Education Codes are applicable to private schools located on federal facilities. URS Greiner Woodward Clyde recommends the VA seek legal council to determine whether there are potential issues associated with leasing this property to the school for the proposed land use. Some form of indemnification by the VA might be sought.”
The following section is inaccurate: “Prior to 1960, there were no regulations governing the disposal of radioactive biomedical waste, therefore no records exist for dumping that occurred from 1952 to 1960.”
Actually, regulations began in 1957, even though they were considerably more lax than they are today. This statement also gives the false impression that the reason there were no records prior to 1960 is because there were no regulations. The reasons the VA has given, over the years, for not maintaining pre-1960 records have ranged from ‘we didn’t keep any’ to ‘maybe they got lost.’ Also, there is evidence that the dump began four years earlier, in 1948, so the entire lifespan of the waste disposal site was two decades: 1948 to 1968. It is notable that some of that evidence appears on page 17 of this document.
Groundwater at the dump site has not been tested for “hazardous substances.”
The dump did indeed start in 1948, a fact missed by the very folks who created this report.
“Disposal sites at the VA Hospital had been listed on early (1948 and 1954-1956) landfill maps under the designation 19-AR-5108.”
“The syringes were often in plastic bags,” the report said. “The foreman indicated that there was so much unsuitable material (refuse) that the project was temporarily shut down until directed by a federal official (name unknown) not to excavate further and continue with a modified installation plan. The modified plan provided for the use of 3 to 4 feet of crushed asphalt to be placed over those areas with remaining unsuitable material to support the drain pipe.”
“Mr. Crockett indicated that prior to 1971 the whole arroyo was used as a general dump by three VA facilities…” is certainly notable because “the whole arroyo” means the land stretching up into what’s been flattened and filled to form the so-called “lower bench” of Brentwood School’s athletic complex: their football field.
Crockett also extends the time the dump was active to “prior to 1971″ which suggests the dump was active for 22 years: 1948 to 1970.
“Also, Mr. Crockett indicated that prior to when he began work with the Engineering Group dumping may have occurred in areas to the east of the arroyo” is troubling. Those area include what is now MacArthur Field, where hundreds of kids play soccer, and the so-called “upper bench” of the Brentwood School athletic complex. This also means that it is possible that the VA’s golf course and Japanese garden could have also been used for dumping.
“The subject property was listed on the Solid Waste Feasibility/Landfill…” meaning that the Brentwood School Shared Property, now their 20-acre athletic complex, was officially listed:
Based on interviews, in part, with “employees of private firms working for the VA and Brentwood School the following site conditions were ascertained: 1. The arroyo was used as the general disposal area for VA Hospital facilities up until at least the early 1970s. The nature, total quantity, and disposition of the refuse buried during the years of operation are unknown.”
When Brentwood Head of School, Michael Pratt, wrote in his letter to the parents and colleagues of Brentwood School that the PricewaterhouseCoopers “report was wrong to the extent it indicated that radioactive materials were ever buried under the school’s athletics complex,” Pratt must not have been aware of the following section of this report about his own school, which seems unusual at best.
Dr. Pratt also reflected this viewpoint in his letter to then-VA Secretary R. James Nicholson when he wrote “(L)ocal VA have officials have assured us that no such materials ever were buried under the land we share and that MicroTech simply made a mistake.”
10/22/56: “well marked waste containers and dumped and buried with at least 15 feet of dirt over the top of the dry waste.”
12/3/69: 50% of the dump animal carcasses and the last burial was 10/28/68
3/95: Groundwater is 14 to 25 feet below ground surface: