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  1. Ahimsa Porter Sumchai MD - Founder Director Hunters Point Biomonitoring Foundation
    October 6, 2022 @ 3:30 pm

    As a former elected member of the Hunters Point Naval Shipyard Restoration Advisory Board and founder of the Radiological Subcommittee I contributed to finalization of the Historical Radiological Assessment and commented on numerous US Navy remediation documents. Many of the hard bound and virtual documents are in my library and digital archive. The EPA Contaminant List for the Hunters Point Naval Shipyard Federal Superfund Site is 25 pages in length and can be found here: https:/// The memo you cite from EPA to the parties OLEM, PEER et al is extremely valuable at a time when the Agency has clearly failed in oversight and public accountability. As an aside, I am scheduled to meet with EPA Superfund Manager John Chesnutt and representatives of ATSDR & DTSC on October 17, 2022 to discuss the findings of urinary biomonitoring screening detecting carcinogenic and radioactive heavy metals and chemicals on the State of California Proposition 65 list of carcinogens amplified by geospatial mappings of chemical and cancer clusters that center around the main entry to the shipyards radiation laboratory complex and landfill on the Crisp Road southern shoreline.
    EPA expresses greatest concern about the reliability of radiological data collected by Tetra Tech EC, Inc and the expectation that resampling will continue through 2025. In response to selected soil clinic levels chosen in the draft Addendum Five-Year Review EPA responded to in 2019 concluding:” We could not verify that the selected radiological soil cleanup goals are protective of human health for the long-term for several reasons including lack of confirmatory sampling of residual radiological contamination concentrations, confirmation of background radiological concentrations and co-location of radionuclides of concern related to cumulative risk. Radiological remediation goals for thorium -232 and radium – 226 are questionably protective. EPA states “Any cumulative risk will be evaluated following collection of new radiological data during the soil retesting.”
    Of note, the youth group Literacy for Environmental Justice conducted random soil testing in regions within the one mile buffer zone of the Hunters Point Naval Shipyard with a focus on lead and as an incidental finding detected thorium.
    I commend PEER for its strong advocacy on behalf of the health protectiveness remediation goals and the urgent need to install regulators committed to the Bayview Hunters Point Community given mounting irrefutable human biomonitoring and environmental health mapping data proving residents and workers are being actively exposed to fugitive dust, groundwater, landfill and media at the system of Federal Superfund Sites spawned by historic activities at the Hunters Point Naval Shipyard.
    On November 7, 2000, 86.4% of the San Francisco electorate voted in support of the nations first codification of Federal Superfund law requirement that Community Acceptance be included as one of nine criteria guiding remediation and reuse at a former military installation. Proposition P was sponsored by 8 of 10 district supervisors along with the San Francisco Democratic, Republican and Green Parties. In 2001 it was codified as a resolution and in 2018 250 community residents sent a letter to the Navy BRAC calling for reinstatement of the HPNS RAB. Today we are looking at a future in which Proposition P will be the Law of the Land!