Breath of Clarity

Discussion Post: RCRA Corrective Action Sites


EPA RCRA ID: CAT080011653

Site Location: HIGHWAY 1 AND DOLAN RD, MOSS LANDING, CA, 95060-0690

Controls: Human exposure (CA 725) and groundwater migration (CA 750) are under control as of 2012

According to the RCRA Corrective Action Profile, the whole site was originally assessed in 1986 and the cleanup solution was implemented in May 2012. The profile was useful in terms of having the mechanism for a community member to hover and click on all definitions of milestones/actions. I was able to learn a cleanup solution being implemented signifies the RCRA facility has completed construction of a facility’s remedy and it’s fully functional as designed, whether or not the final cleanup levels or other requirements have been achieved. As soon as the entire site’s solution was implemented, control milestones were achieved within two months. However, only providing these definitions, without information about the type of damage, encourages the public to form a perspective that only sees progress. It sheds light on the EPA. At the same time, the profile’s limited information depicts nothing improved between the original site assessment in 1986 and the Central Tank Farm Area A investigation in 2008. Particularly with the emphasis on milestones shown at the top of the page, this profile tells the story of stagnancy until the EPA solution was implemented.

Then, the whole site’s investigation wasn’t marked as completed until 2018. There was a large gap in time between the major milestone control assessments all being completed in 2012 and the clean-up activities pertaining to a portion of the site all being completed between 2014-2018. The site indicates the EPA is required to report on the two milestones under the Government Performance and Results Act. So, perhaps that explains the two year gap between major milestones and other actions.

All in all, the profile page’s strength in providing detailed information is the section that describes the cleanup status of certain portions of the site. This information is useful for Dynegy employees whose tasks are centralized to a certain section of the plot. However, it doesn’t describe how far outside the power plant the damage reaches. The RCRA Enforcement and Compliance Reports from ECHO report’s EJ Indexes show percentiles, but that doesn’t include any information on relativity to normal or a threshold that requires civilians to take self-protective measures. While there was data about the demographics of the surrounding area, it would be difficult for a community member to determine whether violations at a particular facility had significantly negative impacts on everyday public health. Also, the “interactive” map of Dynegy Moss Landing at the bottom of the page is a vague topographic map and doesn’t reflect any of the information listed above. To make the profile page more user-friendly, I would create a map of the facility divided into site portions with color coding to represent dates and/or action type.

I wanted to know the type of contaminants, and it was not easy to find. Without a thorough understanding of the problem, it’s difficult to get a sense for which elements of the action plan needed to be executed in a timely manner. I was unable to find that on the profile. The waste codes and description chart is not listed until the bottom of the Envirofacts page. While the information on profile was efficiently listed in terms of priority being at the top, the Envirofacts page lacked that strength. It also unnecessarily lists 21 permit type contacts with only 1 public contact relevant to a community member. While the profile doesn’t mention any action between 1986 and 2008, the Envirofacts page provides information about treatments and storage during that timeframe. That being said, the Envirofacts page tells an entirely different story about the relationship between original assessment, cleanup action and investigation. While the profile radiates the impression that the cleanup process is now complete, I wasn’t able to see there was significant Category 1 noncompliance of the Clean Water Act until I clicked on the ECHO link. This is concerning considering the Clean Water Act’s last inspection that it failed was in July 2018 while the profile lists the entire site’s investigation was completed in June 2018. The definition of the investigation is the event by which the State or EPA determines that the facility investigation is sufficient to support either a “No Further Action” determination or a Remedy Decision. Since there is no actions listed on the profile after June 2018, a community member may infer that the site is fully compliant. This discrepancy is misleading to the public.

Each of the three pages are useful for different purposes. I would use the profile for professional capacity in the case I am seeking a general understanding of EPA milestones controlled. It is also beneficial for understanding the time it takes in between the original assessment, cleanup solutions implemented, cleanups complete and investigation completed. It’s also helpful for envisioning the sections of a site. However, it bothered me that while the profile can customize each site to include whether a site is part of Indian County, it says that tribes help contribute to updating all sites. The Envirofacts page is beneficial for understanding volume of contaminants while comparing the generation and waste shipped over the years. The charts showing lists of “process unit information” could be organized better with a drop down search mechanism for each of the column titles. The ECHO link is useful in thoroughly depicting the site’s comprehensive story, however it is too complex for a community member to understand. I would include links to definitions of the various compliance monitoring types and delete the information not useful to a community member. Regardless, after looking at the profile and all the links it had attached, I am a more informed community member about remedies to a local power plant’s environmental impact.