— EPA won’t require full cleanup of Hunters Point, SF

From Public Employees for Environmental Responsibility PEER

FOR IMMEDIATE RELEASE
Wednesday, October 5, 2022
Contact:
Jeff Ruch jruch@peer.org (510) 213-7028


EPA Says Hunters Point Will Never Be Fully Cleaned  

EPA Plans to Ignore Prop P Mandate and Its Own Superfund Standards  

Oakland, CA —The U.S. Environmental Protection Agency says that Hunters Point Naval Shipyard cleanup will not be sufficient to allow unrestricted residential use, according to an agency memo sent to Public Employees for Environmental Responsibility (PEER). Instead, the agency will rely upon caps and “land use restrictions” in violation of Proposition P, the overwhelmingly approved voter initiative demanding a full cleanup for the shipyard, a Superfund site since 1989.  

In meetings with top EPA officials in August and December 2021, PEER and allied groups asked for a commitment that the soil cleanup standards for Hunters Point be strict enough to allow for unrestricted residential use. They argued that the current soil cleanup standards violated EPA’s own Superfund guidance and would leave so much radiological waste that 1 in every 473 people would get cancer or the equivalent of getting a chest X-ray every other day for decades. 

Via an unsigned September 30, 2022 memo transmitted by Silvina Fonseca, a senior official with EPA’s Office of Land and Emergency Management which oversees Superfund, the agency demurred on the groups’ request to tighten the soil cleanup standards and would instead rely upon restrictions on allowed land uses at Hunters Point contrary to the demands of Proposition P, passed by more than 86% of voters in 2000, that the shipyard “be cleaned to a level which would enable the unrestricted use of the property – the highest standard for cleanup established by the [EPA]” – 

“Regarding your recommendation that soil radiological cleanup goals be based on an unrestricted use scenario consistent with the City/County of San Francisco’s Proposition P, broadly, EPA’s policy is to achieve protective remedies consistent with reasonably anticipated future land use. Institutional controls, like land use restrictions, are a common component of Superfund remedies nationwide to ensure protection of human health but also to ensure the integrity of remedies in the long term.” 

 “The bottom line is that EPA will not commit to the full cleanup of Hunters Point,” stated PEER Pacific Director Jeff Ruch, noting that this memo was nearly one year after EPA had promised to answer the groups’ August 2021 request. “As things stand now, the plan at Hunters Point is to pave over contamination rather than remove it.”  

The EPA revelation occurred just one day after EPA testified before the Board’s Government Audit and Oversight Committee last week but failed to disclose the EPA decision to not require a complete cleanup. This revelation creates a new confrontation regarding Hunters Point. The President of the Board of Supervisors has pledged there will be no transfer of Hunters Point land to the City without a “100% complete cleanup,” and EPA has now declared there will be no such cleanup. Tomorrow, the San Francisco Board of Supervisors will resume consideration of a County Grand Jury report about rising groundwater and sea-level rise would wash much of the remaining Hunters Point contamination into San Francisco Bay. 

“On one hand, EPA talks about the importance of community input but on the other hand says it is free to ignore Prop P, one of the strongest expressions of community input imaginable,” added Ruch, pointing out this was supposed to be the biggest redevelopment in the city since the 1906 San Francisco earthquake. “After more than 30 years of EPA supervision, Hunters Point is and will likely remain a radiological waste dump.”   

### 

Read the EPA memo 

Look at the Navy/EPA plan to leave contaminated soil onsite 

View the Grand Jury report 

Examine the lack of transparency on cleanup plans 

Look at the call for a national “garden pathway” cleanup standard

https://peer.org/epa-says-hunters-point-will-never-be-fully-cleaned/

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— 13 February 2020: Santa Susana Field Laboratory cleanup crisis meeting

CRITICAL SSFL WORK GROUP MEETING
“SSFL CLEANUP CRISIS: FINDING A PATH FORWARD” 

Simi Valley Cultural Arts Center
3050 E. Los Angeles Avenue, Simi Valley, CA 93065

THURSDAY, FEBRUARY 13, 2020
6:30 p.m. vigil, 7:00 pm meeting
Seating is limited – 

Click here to RSVP today

Guest speaker: CalEPA Jared Blumenfeld

Description

Boeing, the Dept. of Energy, and NASA signed agreements to fully clean up all of SSFL’s contamination by 2017, but the cleanup hasn’t begun. Recently, all three have indicated their intent to break their cleanup agreements and leave most of the contamination on the site permanently. The cleanup is now at an impasse, and the stakes couldn’t be higher.

California EPA Secretary Jared Blumenfeld will discuss cleanup efforts on February 13 at a meeting of the SSFL Work Group. The SSFL Work Group was founded in 1989 to educate and engage the community, government agencies, and elected officials in the cleanup. The meeting will include a public Q&A with a panel of experts, community members, and elected officials.

SSFL Work Group Meeting
“SSFL Cleanup Crisis: Finding a Path Forward”
Simi Valley Cultural Arts Center
Thursday, February 13, 2020
6:30 PM Candlelight vigil
7:00 PM SSFL Work Group Meeting

Hosted by SSFL Work Group, Physicians for Social Responsibility- Los Angeles, Committee to Bridge the Gap, Rocketdyne Cleanup Coalition and Parents Against SSFL.

— Helen Caldicott: The Fukushima nuclear meltdown continues unabated

Global Research, February 14, 2017
Independent Australia 13 February 2017

Global Research Editor’s Note

In 2011, with foresight and scientific analysis Dr. Helen Caldicott focussed on the implications of the Fukushima disaster at a Press Conference in Montreal organized by Global Research. The 2011 GRTV video presentation featuring Dr. Caldicott tells us the truth. This is the most devastating catastrophe in human history.  And six years ago Helen Caldicott analyzed in detail the significance of this tragic event. (M. Ch)

Dr Helen Caldicott, explains recent robot photos taken of Fukushima’s Daiichi nuclear reactors: radiation levels have not peaked, but have continued to spill toxic waste into the Pacific Ocean — but it’s only now the damage has been photographed. 

Recent reporting of a huge radiation measurement at Unit 2 in the Fukushima Daichi reactor complex does not signify that there is a peak in radiation in the reactor building. All that it indicates is that, for the first time, the Japanese have been able to measure the intense radiation given off by the molten fuel, as each previous attempt has led to failure because the radiation is so intense the robotic parts were functionally destroyed.

Satellite image shows damage at Fukushima Nuclear Power Plant (via ecowatch.com).

The radiation measurement was 530 sieverts, or 53,000 rems (Roentgen Equivalent for Man). The dose at which half an exposed population would die is 250 to 500 rems, so this is a massive measurement. It is quite likely had the robot been able to penetrate deeper into the inner cavern containing the molten corium, the measurement would have been much greater. These facts illustrate why it will be almost impossible to “decommission” units 1, 2 and 3 as no human could ever be exposed to such extreme radiation. This fact means that Fukushima Daichi will remain a diabolical blot upon Japan and the world for the rest of time, sitting as it does on active earthquake zones.

Robot image of Fukushima Daiichi Unit 2 reactor (Source: tepco.co.jp)

What the photos taken by the robot did reveal was that some of the structural supports of Unit 2 have been damaged. It is also true that all four buildings were structurally damaged by the original earthquake some five years ago and by the subsequent hydrogen explosions so, should there be an earthquake greater than seven on the Richter scale, it is very possible that one or more of these structures could collapse, leading to a massive release of radiation as the building fell on the molten core beneath. But units 1, 2 and 3 also contain cooling pools with very radioactive fuel rods — numbering 392 in Unit 1, 615 in Unit 2, and 566 in Unit 3; if an earthquake were to breach a pool, the gamma rays would be so intense that the site would have to be permanently evacuated.

The fuel from Unit 4 and its cooling pool has been removed. But there is more to fear. The reactor complex was built adjacent to a mountain range and millions of gallons of water emanate from the mountains daily beneath the reactor complex, causing some of the earth below the reactor buildings to partially liquefy. As the water flows beneath the damaged reactors, it immerses the three molten cores and becomes extremely radioactive as it continues its journey into the adjacent Pacific Ocean.

Six years later, radiation levels at Fukushima are so high not even a robot can survive inside http://buff.ly/2lzNesd 

Every day since the accident began, 300 to 400 tons of water has poured into the Pacific where numerous isotopes – including cesium 137, 134, strontium 90, tritium, plutonium, americium and up to 100 more – enter the ocean and bio-concentrate by orders of magnitude at each step of the food chain — algae, crustaceans, little fish, big fish then us. Fish swim thousands of miles and tuna, salmon and other species found on the American west coast now contain some of these radioactive elements, which are tasteless, odourless and invisible. Entering the human body by ingestion they concentrate in various organs, irradiating adjacent cells for many years.

The cancer cycle is initiated by a single mutation in a single regulatory gene in a single cell and the incubation time for cancer is any time from 2 to 90 years.

Continue reading

— San Francisco: EPA & Navy used wrong and unsafe standard for radioactive/toxins cleanup; EPA Superfund manager stonewalls at public meeting

Lily Lee, EPA Cleanup Project Manager, Superfund Division
Interviewed on February 8, 2017 at a community meeting on the cleanup problems and fraud at the San Francisco Superfund site. The Superfund site is located at the former Hunters Point Naval Shipyard and Naval Radiological Defense Laboratory.

Ms. Lee was interviewed by Labor Video Project, and then asked questions by Dan Hirsch, UCSC Executive Director on Environmental and Radioactive Policy, on the cleanup and EPA exposure guidelines. Her answers, as Superfund Cleanup Project Manager, are surprising.

This is why these agencies organize “poster” open house format meetings. They do not want to be asked these important questions in front of an audience, and they certainly don’t want to be forced to answer. Of course, as public employees, they don’t want to be seen as avoiding or stonewalling, and they certainly don’t want to go on the record admitting negligence or indifference in implementing rules.

In a meeting in another town on a public health issue, members of the public refused to put up with this style of format. They pulled chairs into the center of the room, sat down as a group, and demanded to have a presentation made to them as a whole. Rather than do that, the people in charge gathered up their materials and walked out. Unless forced, they will not submit to a regular meeting format.

https://youtu.be/J_YVou0kmQI

Interview of Lily Lee, EPA, begins at 29:13

This transcript begins toward the end of her interview with Labor Video Project

Lee: …We are here to say that I am doing my job every day the same way I have been and I will keep doing so to ensure that the cleanup here is meeting all of the health-based standards

LVP: I understand that 50% of the black population, African-American population, their children have asthma and other toxins from living out here. Is that of concern to you?

Lee: What we do here is that we set the standards for cleanup based on health-protective levels and then we ensure that when the Navy’s cleanup is happening, both during the process and when they’re done, that it meets our health-based standards to protect people from health conditions such as asthma.

[“Health-protective levels” and “health-based standards” — The EPA has repeatedly loosened exposure guidelines for radioactivity which they acknowledge increases the percentage of the population that will develop cancer. If the EPA uses these terms often enough, do they believe they will become accurate?

Her following interchange with Dan Hirsch reveals that she does not enforce EPA’s own standards, and she further says that steady exposure to radiation at the level of 25 millirem is something the body can cope with.]

Hirsch: Did the EPA’s criteria in effect at that time — I’m not talking about doing an analysis years later that it wasn’t that big of a mistake — why was the mistake made in the first place? Why did EPA allow clean-up standards that were contradicting EPA’s then current standards?

Lee: And again, I wasn’t there at that time and I tried to look for records about this information, and I’ve unfortunately not been able to find those records, but what I can tell you is that I am looking at the current standards, the current PRG calculator which is unfortunately in flux right now, and we are looking to see, revisit these standards to determine whether or not they would fall within the circle risk (?) range using site-specific factors.

Hirsch: I mean, you know you’re playing a game about this over and over again. The public was told you were cleaning up to a one in a million risk. You’ve seen EPA standards, but it turns out the Navy didn’t do that and used standards that are very much weaker than the ones that they said they would be using, and EPA said should be used at that time.

You’re now saying you’re seeing whether, okay it was a mistake but whether the mistake was mistake of a 300 fold. That isn’t very reassuring to the public.

I want to come back to the central issue. Do you agree that 25 millirems should not have been used, that was, even at the time, something the EPA said that was not acceptable and not protective.

Lee: I want to explain that some of the language that you saw in the footnotes referenced the 25 millrems but wasn’t necessarily the only standard that the Navy would be required to meet that

Hirsch (interrupting): In the tables, they actually estimate the dose for the other standard that they met, and for several of those, that was 25 millirem. So they actually did use 25 millirem. They shouldn’t have

Lee (interrupting) ___waste?

Hirsch: And structures.

Lee: Okay, and structures.

Hirsch: And they’re not supposed to according to EPA guidelines.

That’s 12 chest x-rays a year. They’re saying it’s okay for people to get a chest x-ray a month from the moment of conception to the moment of birth. Even the EPA says that level of radiation is outside the upper limit of your acceptable risk range.

So do you concede that they used a cleanup number that EPA said, even at the time, should not have been used?

Lee: So, I would like to talk about the chest x-ray which is an acute dose meaning a dose that people would get in one situation during the chest x-ray itself as being different from what’s relevant here at the base which would be a dose that would be over time continuously across year. So that wouldn’t be something

Hirsch (interrupting): Your own agency says there is no difference. EPA formally said that getting a chest x-ray a month is no different than getting a thirtieth of a chest x-ray every day for those months. That there is no… It’s linear, so the rate at which you get it doesn’t matter.

You know that’s your own agency’s official position.

Lee: So, if you can get a small dose that’s over a period of time, your body does have some recovery and

Hirsch (interrupting): Excuse me, are you saying that EPA believes that radiation is potentially good for you – the hormesis theory? Or that, or are you also saying that the risk is not linear with dose? Because the official position of EPA is just the opposite of what you’ve just said.

Lee: So, thank you for sharing your perspective. I am saying that those kinds of exposures are different, and I am also saying as I have said before that we are looking at the original standards to see if under the current version of the PRG calculator which is going to be changed soon, that that will still fall within the national contingency plan superfund regulation range of acceptable.

Hirsch: I want you to answer once and for all whether the standards that they chose were consistent or inconsistent with EPA’s guidance in effect at the time they chose them. Not whether going back years later and trying to say whether it was a 300 fold mistake.

Was the standard chosen by the Navy and approved by the EPA inconsistent with EPA’s Superfund guidance in effect at the time?

Lee: And I’d let you know that I don’t have information about what the standards were in effect at the time and I’m going to go back and look at that information some more. I’ve done some research

Hirsch (interrupting): ___the 25 millirem was back then considered unacceptable? Back in 2013? Do you not know the ___ in 2013 is not acceptable? So why was 25 millirem allowed to be used?

Lee: As I said, we are going to be checking the current version of EPA calculator

Hirsch (interrupting): Why was a cleanup standard allowed to be used that was not consistent with your guidance? I’m not talking about whether a post doc analysis as to whether it is too huge a mistake. I’m talking about whether it was a mistake. 25 millirem, is it not today, and wasn’t it in 2013, outside the level that EPA said was protective? It was a level that EPA said should not be used for cleanup standards. Am I not right about that?

Lee: I will go back and check to make sure.

Hirsch: Don’t you know that 25 millirem EPA has always, has said for long periods of time and certainly in the last years, is not to be used at Superfund sites?

Lee: I have seen that guidance information before.

Hirsch: Alright. Well, then, let’s just admit, can’t you, that they used a cleanup standard that was incompatible with Superfund guidance in effect at the time. Can you admit that?

Lee: As I said, I will go back and check that information.

– Obama approved raising permissible levels of nuclear radiation in drinking water. Civilian cancer deaths expected to skyrocket

PEER — Public Employees for Environmental Responsibility — is an exceptional organization. It protects whistleblowers and facilitates the release of government agency documents related to the public welfare and safety. They are heroes, operate on a shoestring budget, and are well worth financially supporting.

This information is from 2013 but very timely. Most people don’t know about this decision.

Global Research, September 19, 2014
Peer.org 14 April 2013
Rollback in Nuclear Radiation Cleanup

by Public Employees for Environmental Responsibility (PEER)

The White House has given final approval for dramatically raising permissible radioactive levels in drinking water and soil following “radiological incidents,” such as nuclear power-plant accidents and dirty bombs. The final version, slated for Federal Register publication as soon as today, is a win for the nuclear industry which seeks what its proponents call a “new normal” for radiation exposure among the U.S population, according Public Employees for Environmental Responsibility (PEER).

Issued by the Environmental Protection Agency, the radiation guides (called Protective Action Guides or PAGs) allow cleanup many times more lax than anything EPA has ever before accepted. These guides govern evacuations, shelter-in-place orders, food restrictions and other actions following a wide range of “radiological emergencies.” The Obama administration blocked a version of these PAGs from going into effect during its first days in office. The version given approval late last Friday is substantially similar to those proposed under Bush but duck some of the most controversial aspects:

In soil, the PAGs allow long-term public exposure to radiation in amounts as high as 2,000 millirems. This would, in effect, increase a longstanding 1 in 10,000 person cancer rate to a rate of 1 in 23 persons exposed over a 30-year period;

  • In water, the PAGs punt on an exact new standard and EPA “continues to seek input on this.” But the thrust of the PAGs is to give on-site authorities much greater “flexibility” in setting aside established limits; and
  • Resolves an internal fight inside EPA between nuclear versus public health specialists in favor of the former. The PAGs are the product of Gina McCarthy, the assistant administrator for air and radiation whose nomination to serve as EPA Administrator is taken up this week by the Senate.
  • Despite the years-long internal fight, this is the first public official display of these guides. This takes place as Japan grapples with these same issues in the two years following its Fukushima nuclear disaster.

“This is a public health policy only Dr. Strangelove could embrace. If this typifies the environmental leadership we can expect from Ms. McCarthy, then EPA is in for a long, dirty slog,” stated PEER Executive Director Jeff Ruch, noting that the EPA package lacks a cogent rationale, is largely impenetrable and hinges on a series of euphemistic “weasel words.”

“No compelling justification is offered for increasing the cancer deaths of Americans innocently exposed to corporate miscalculations several hundred-fold.”

Reportedly, the PAGs had been approved last fall but their publication was held until after the presidential election. The rationale for timing their release right before McCarthy’s confirmation hearing is unclear.

Since the PAGs guide agency decision-making and do not formally set standards or repeal statutory requirements, such as the Safe Drinking Water Act and Superfund, they will go into full effect following a short public comment period. Nonetheless, the PAGs will likely determine what actions take place on the ground in the days, weeks, months and, in some cases, years following a radiological emergency.

Copyright Public Employees for Environmental Responsibility (PEER) 2014