[CPEO-MEF] Hunters Point (San Francisco)

[Lenny Siegel <lsiegel@cpeo.org>]

Submitted by Ahimsa Sumchai <asumchai@sfbayview.com>

Parcel A Remains Not Suitable for Transfer!

A Press Conference and demonstration will be held on Monday, October 25,
2004 at 10:00 am at the Anna B. Waden Library located at Third Street
and Revere to protest the proposed transfer of Parcel A of the Hunters
Point Shipyard. There has been a very popular response to this event in
the last 24 hours and numerous speakers have tentatively confirmed
including elected officials. The protest will specifically focus on the
environmental racism and ethical issues stemming from the San Francisco
Department of Public Healths documented role in advancing the transfer
of lead contaminated property at the Shipyard - a federal superfund
site- for residential development. This constitutes a violation of the
CERCLA act as the lead constitues a "new release" and is the
responsibility of the U.S.Navy to clean up. Additionally, Parcel A rests
adjacent to a partially capped industrial landfill for which no remedy
has been proposed under CERCLA and continues to require active
extraction to control it's production of methane gas. The public and the
press are invited.

... and that CERCLA Section 120 requires the Navy to covenant that all
remedial action necessary to protect human health and the environment
has been taken."
Anthony J. Landis, P.E.  Department of Toxic Substances Control  Letter
dated 10/6/04

On October 14, 2004 the Department of the Navy Base Realignment and
Closure Program published the Final Finding of Suitability to Transfer
for Parcel A. The FOST documents environmental findings for the property
referred to as Parcel A at the Hunters Point Shipyard in San Francisco.
Parcel A consists of 76 acres of land at HPS and is proposed for
transfer to the City of San Francisco for residential development. The
original FOST for Parcel A was submitted to regulatory agencies
including the Environmental Protection Agency and the San Francisco
Department of Public Health in 1996. In November of 1996 The Health
Department sent a letter to the Navy stating that the draft FOSt did not
adequately address DPH's concerns about lead based paint in soil.

Parcel A contains 74 buildings and the foundations of 43 former
structures. Parcel A also contains storm drains, steam lines, a sanitary
sewer system and an active natural gas distribution system that serves
several buildings. Lead based paint is commonly found in structures
built in the 1940's and 1950's. Lead was added to residential house
paint to prevent weathering.

Soil around former residential structures on Parcel A was sampled during
a 1993 lead based paint survey. Elevated concentrations of l ead were
detected in soil samples collected near a former housing unit on Parcel
A. Lead bioaccumulates in human tissues includings red blood cells, bone
and the nervous system and causes anemia, and nervous system
dysfunction. Lead is one of the oldest documented environmental
contaminants. It was first described by a physician and poet in the 1st
century in Rome. Roman aquaducts for the conveyance of water for baths
and for drinking were lined with lead. Lead is also one of the most
accurately detected environmental toxins in biomonitoring methods that
have been implemented by government health agencies like the CDC.

In a letter to the Navy dated November 14, 1996 regarding the sampling
of soil on Parcel A for lead the DPH stated, "Our primary concern is
that eight of thirty-four sample results exceed the Navy's human health
risk assessment screening value for future residential areas. Since
Parcel A is the one area of the Shipyard dedicated to residential
development, it should meet the criteria for the most protective human
health risk assessment levels for residential areas. As a result of the
SFDPH letter, the Navy collected additional soil samples for analysis of
lead at Parcel A in 1997.

In the Final FOST issued on October 14, 2004 the Health Department
representative Amy Brownell, who is not a health professional but rather
a mitigation engineer, proposes the implementation of a lead-based paint
deed restriction for future owners, developers and contractors stating
in a letter dated October 5, 2004 "we look forward to finalization of
the FOST and the pending transfer of Parcel A." 

In a letter dated October 6, 2004 the Department of Toxic Substances
Control acknowledges that "even though DTSC's draft Finding of
Suitability to Transfer comments related to lead based paint remains
unresolved, DTSC is able to support the transfer of Parcel A due to
assurances made by the City and County of San Francisco that lead-based
paint from structures will be managed in a way that is protective of
public health. These assurances were made in a letter to DTSC dated
September 30, 2004 from Dr. Rajiv Bhatia, Department of Public Health,
Medical Director, Occupational and Environmental health, City and County
of San Francisco."

In addition to lead in soil that poses risks to future child residents
living on Parcel A the following hazardous substances were used or
stored on Parcel A according to the FOST including petroleum, paint and
primers, small caliber munitions, pine tar, tritium targets, compressed
gases, asbestos, abrasive blast material, pesticides and polychlorinated biphenyls.

The Landfill In Our Living Room that won't go Away!

Arguably the most controversial proposal to site residential development
on a Federal Superfund site stems from the intent to transfer Parcel A
to a private developer for the construction of homes on a land parcel
that rests immediately adjacent to a partially capped industrial
landfill with a dynamic history of activity. Additionally, the fact that
Parcel A landlocks the most contaminated Parcel, Parcel E is a
geophysical consideration the Navy and city planners choose not to address.

The Parcel E landfill was the site of a brush fire in August of 2000
that smoldered and became a chemical fire in the ensuing weeks. The Navy
constructed a partial cap to "smother" the landfill contents and by
November of 2000 thermal scans documented no hot spots in the landfill
at the surface levels the scans were able to reliably detect.

In 2001 the Hunters Point Fire District responded to 50 fire runs and
medical emergencies at the Shipyard in a four month period from June to
September, including an incident which nearly required the evacuation of
nearby residents in Hunters Point. Flames 15 feet high were observed
emanating from the Parking lot of Building 815 adjacent to Parcel A and
moving rapidly towards the Crisp Avenue boundary of Parcel A with Parcel
E adjacent to the Parcel E landfill.

In a 2002 study the Navy discovered methane gas emanating from the
industrial landfill at Parcel E and migrating onto property owned by the
University of California at San Francisco and within 100 feet of the
Crisp avenue boundary of Parcel A. Methane gas was detected in levels as
high as 80% in air in 2002 in violation of state law which required that
methane be present in concentrations below 5 percent by volume in air.
>From October 2002 to January 2003 methane was rapidly removed using gas
extraction wells. From September to October 2002 a barrier wall and
venting system was installed to vent methane and control gas migration.
The Navy initiated an interim landfill gas monitoring and control plan
on August 13, 2004.

While the Navy claims the system is effectively venting landfill gas and
controlling its migration, the Navy has not addressed the fundamental
fact that the landfill continues to produce gas and requires active
extraction to lower the levels of methane gas, a flammable, explosive,
suffocating greenhouse gas. Additionally, the landfill cap is a partial
one and the EPA in comments submitted to the Navy's Radiological Affairs
Office asked that the Navy document the relationship of radiation hot
spots to the cap on the landfill.

Parcel A is not suitable for transfer and may never be suitable for
residential development. The Navy and the City and County of San
Francisco and the Environmental regulators charged with the protection
of human health and the environment have abandoned their mandate and
have violated the provisions of the Federal Superfund Law (CERCLA) and
the Proposition P voter initiative calling for the clean up of the
shipyard to residential standards. The presence of residual potentially
harmful contaminants including lead, asbestos and petroleum products and
the ridiculous proposal to site residential development adjacent to an
industrial landfill that four years ago was on fire and to this date
continues to produce potentially dangerous emissions of flammable,
explosive gases is an expression of the sovereign immunity of the United
States Military in its failure to respect human health and the environment.

Write or call the regulators and ask them not to sign the Finding of
Suitability to Transfer for Parcel A until health and safety issues
surrounding the proposed transfer have been publicly addressed by the
cities Health Department:

Mr. Michael Work
U.S. Environmental Protection Agency
75 Hawthorne Street
San Francisco, Calif. 94105-3901

Mr. Tom Lanphar
Department of Toxic Substances Control
700 Heinz Avenue, Bldg.F, Suite 200
Berkeley, Calif. 94710

Mr. Jim Ponton
California Regional Water Quality Control Board
1515 Clay Street, Suite 1400
Oakland, Calif. 94612
     






-- 


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
<lsiegel@cpeo.org>
http://www.cpeo.org
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