Dear San Francisco Board of Supervisors,
On behalf of our many members and constituents in Bayview Hunters Point, we thank you for holding a hearing in response to Tetra Tech’s fraud at the Hunters Point Naval Shipyard Superfund site. During the hearing, the Board of Supervisors sent a loud and clear message to the Navy, its contractors, state and federal regulatory agencies, and the San Francisco Department of Public Health.
Now it is imperative that we do everything in our collective power to ensure the Hunters Point Superfund site remediation is comprehensive, transparent and trustworthy. In addition to the Tetra Tech issue, there are other major problems with the Superfund remediation plan that also pose a serious threat to public health and the environment.
However, we are extremely disappointed and concerned that since that hearing, Mayor Farrell and SFDPH official Amy Brownell made public statements promoting the alleged safety of the shipyard despite knowing that retesting needs to be done due to the massive fraud. Without comprehensive retesting and a proper cleanup, it is irresponsible and reckless for our elected officials and agencies to assert that this radioactive and toxic contaminated site is safe.
Mayor Farrell and SFDPH seem more interested in promoting Lennar-Five Points’ giant upscale gentrification project (falsely promoted as much needed housing for San Francisco residents) instead of protecting our health and environment.
To achieve the goal of a comprehensive cleanup that protects the health and environment of our community, we call on our city agencies and leaders to support the following community demands.
- Full retesting of the entire Shipyard and adjacent areas, including parcels already transferred – not just scanning
Retesting must include the entire original shipyard site footprint, parcels that have already been transferred and adjacent areas such as Mariner’s Village. Tetra Tech worked in many areas of the Shipyard, including Parcel A. Recent information indicates that massive fraud may have occurred on other parcels already transferred to the city as well. Merely scanning a few parcels is not acceptable.
- Testing methodology
a. Radiological core sampling must be conducted of the entire site and adjacent areas. It is imperative that all core samples go at least 9 feet beneath the surface.
b. The core sampling should create a 2m x 2m mapping grid.
c. All core sampling must follow split sampling protocols.
d. All ground water should be tested for radiation contamination, including Aquifers A and B.
e. Immediately begin working with the state of California and the Bay Area Air Quality Management District to develop and implement standards for fugitive radiological dust.
f. Color code potential radiated soil with an orange colored dye. Applying this would explicitly identify important areas, help prevent accidental shipments of radioactive soil to landfills, and act as a dust suppression measure.
- Eliminate conflicts of interest
The Board of Supervisors must rescind the contract that the City entered into with Lennar for them to pay the San Francisco Department of Public Health to work on this project. The current SFDPH staff engaged at Hunters Point and other land development sites should be removed from these areas. Only staff who are not indirectly or directly subsidized by the developer should have supervision and oversight on these projects.
No laboratory that is affiliated or has a financial relationship with the City, the Navy or EPA should be allowed to perform the testing analysis as to avoid any potential conflicts of interest.
- Community oversight
Since the Hunters Point Naval Shipyard Superfund Site Remediation Advisory Board was disbanded, the testing and cleanup process moving forward must include independent community oversight. This component must also be without conflict of interest. Therefore, no one affiliated with OCII, the Navy, CAC or anyone who receives or received financial benefit from the Lennar project should serve in this role.
Funding for this must be secured from Tetra Tech, the Navy, EPA and/or the City.
Our organizations with deep ties to the community (and with no financial ties to the developer Lennar-Five Points) should receive funding to hire independent technical experts to review the testing plan, test data, and to assist the community in understanding the testing data.
- Support the community in opposing the USEPA’s ‘remedy’ for Parcel E/E2
The USEPA’s “remedy” under the Superfund law’s Five Year Statutory Review is reckless and a direct threat to public health and safety and the health of San Francisco Bay. The government plans to leave high levels of radioactive and hazardous wastes, above health screening levels, at the waterfront at the Shipyard that would become “open” recreational space and be located near thousands of homes.
This “remedy” is particularly reckless and violates common sense, and science. Current governmental projections of rising sea levels were never considered when EPA developed this so-called remedy. While a sea wall revetment is now part of the plan, it is terribly inadequate as rising sea levels will also cause a rise in groundwater, threatening to inundate the radioactive waste from below.
We need the City to support our call for the government to remove as much of the radioactive and hazardous waste as feasible, and to prohibit use of this heavily contaminated area for any public use.
- No more homes should be built at the Shipyard site
It is a fact that this Superfund site, one of the most contaminated sites in the nation, is heavily contaminated with radioactive and hazardous wastes. The fact that a fire burned for months underground is proof that the extent of the contamination problem is enormous.
- City must comply with its Precautionary Principle Ordinance
In July 2003, the San Francisco Board of Supervisors adopted the Precautionary Principle Ordinance which became Chapter 1 of the San Francisco Environment Code. The ordinance states in part: “Where threats of serious or irreversible damage to people or nature exist, lack of full scientific certainty about cause and effect shall not be viewed as sufficient reason for the City to postpone cost effective measures to prevent the degradation of the environment or protect the health of its citizens … There is a duty to take anticipatory action to prevent harm.”
The City’s bias and support for Lennar’s gentrification project, instead of calling for comprehensive retesting and comprehensive cleanup of radioactive and toxic waste at and near the shipyard, violates the Precautionary Principle, civil rights and environmental justice.
We therefore respectfully request – and demand – that our city support the steps identified above.
We also request your presence at the Bayview Hunters Point Emergency Community Meeting to be held on Wednesday, June 13, 6 p.m., at the Huntersview Phase 1 Community Room. This will be an important opportunity for you to learn, listen and respond to community concerns.
Bradley Angel, Executive Director, Greenaction for Health and Environmental Justice
Michelle Pierce, Executive Director, Bayview Hunters Point Community Advocates
Mavis Williams and Leaotis Martin, Co-Directors, Bayview Hunters Point Mothers & Fathers Committee for Health and Environmental Justice
Contact them via firstname.lastname@example.org.