Re: Old Fueling Station & Contaminated Site at 2700 San Pablo Avenue
To City of Berkeley
L A Wood, August 7, 1995

Last week we met to discuss the case file and the remediation work plan for 2700 San Pablo Avenue, the Pahlmeyer Family Trust property. As you may recall, our conversation was focused on three central issues: 1) off-site migration of contaminants, 2) on-site treatment schemes, and 3) the Health Risk Assessment.

1) Off-site migration of contaminants

Past investigations of 2700 San Pablo Avenue and other associated properties indicate variations in gradient, and that the ground water flows from south to the west. An ongoing toxic characterization of the adjoining site, 2720 San Pablo Avenue has shown off-site migration of contaminants which suggests the likelihood of a similar off-site problem at the Pahlmeyer site.

The city's request for removal of contaminants under the existing building at 2700 San Pablo Avenue also supports this contention. However, all site investigations have excluded the properties lying due west of the Pahlmeyer property. The toxic plume will remain undefined until these properties, directly downstream, are included in the soil and ground water investigations.

In a letter to the City of Berkeley dated January 5, 1995, from Environet, who represents the Pahlmeyer remediation plan, indicated that they had attempted to gain the residents' approval to drill borings on the adjacent property. Environet claims that this request was denied. That inquiry was to have taken place sometime around November of 1993. It was also suggested that the City of Berkeley had been asked by Environet for assistance in securing the necessary permission to "access these properties to the west.

The residents at 1034 and 1036 Carleton Street who are directly west of the Pahlmeyer property were never notified of any such request, as is legally required in any remediation plan. The question as to how or why these Carleton Street residents have been excluded from the investigation remains unanswered. The failure to properly notify those most likely to be affected by off-site contamination, this alone, should justify halting the scheduled toxic cleanup until a complete work plan can be developed.

2) On-site treatment schemes

The 2700 San Pablo Avenue site has once again entered an active phase of its toxic cleanup. The work plan calls for an aggressive on-site aeration treatment scheme which challenges the sensibility of the health assessment. This "total" aeration plan has apparently paid more attention to the costs of remediation than the possible health impact to the adjacent neighbors or environment.

The Pahlmeyer site can barely afford to manage the large stockpile of soils it is currently holding, especially when the site is shared with a large open air Baker tank. This style of on-site remediation is more suited for an industrial area with no residential housing in close proximity. Furthermore, when soils are high mounded onto a site, as is the case at the Palhmeyer property, soils can easily become airborne which adds substantially to the health risk.

3) Community Health Risk Assessment

The approval for the on-site aeration plan was contingent upon a Community Health Risk Assessment. In April of this year, City staff challenged the Palhmeyer Health Risk Assessment because of its distorted evaluation of potential community exposure to the soil removal and aeration project. Berkeley staff have also questioned the certification of the toxicologist who drafted this report.

The adopted risk assessment required the subject property to give notice to the community about related health concerns. A single notice was distributed by Mr. Perry Pahlmeyer to the surrounding neighborhood in the form of a flyer on April 25,1995. It failed to mention benzene or any other on-site contaminants by name, or the related health impacts such as respiratory disease, cancer and leukemia. The flyer also neglected to mention possible problems associated with exposure to such volatile compounds. As you well know, this exposure is significantly increased by the aeration process.

The site currently has no provision for the posting of this information for the nearby community. It should be noted that in October 1994 the City of Berkeley reported that the 2700 San Pablo Avenue property was being kept in poor condition and that soil was exposed. As recently as last week, your department directed contractors working on-site to remove soils that were encroaching on the city sidewalk.

Obviously, there are many problems concerning the contaminated site at 2700 San Pablo Avenue which need to be addressed before this flawed work plan is allowed to proceed.

It is requested that your department undertake an immediate review of the site plan for 2700 San Pablo Avenue, as well as those questions that have been raised by the property owners at 1034 and 1036 Carleton Street. It is urgent that the above residential properties be included in all related discussions regarding the Pahlmeyer property site plan including access to all communications between your department, Environet, and the Pahlmeyer Family Trust fiduciary.

At the conclusion of your investigation, we want to meet with you again so that we can au. begin to resolve these difficult matters. Please call me if I can be of any assistance to your efforts.
L A Wood and West Berkeley neighbors