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Sample Letter to Governor Newsom

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April 25, 2021
Governor Gavin Newsom
1303 10th Street, Suite 1173
Sacramento, CA 95814
Dear Governor Newsom:
We ask you to intervene on behalf of the Richmond, California and larger San Francisco Bay Area community, and future generations and all life in and near the AstraZeneca/former Stauffer Chemical site, which is located on the immediate shoreline of San Francisco Bay with estuaries inhabited by endangered species on either side.
A broad base of residents, workers, business owners, city representatives and San Francisco Bay Trail users have been advocating for 20 years to ensure a comprehensive clean-up of the AstraZeneca (aka "Campus Bay"), located in Richmond, California.
The 86-acre site is far more than a Brownfield; it is a US Environmental Protection Agency (US EPA) Superfund-qualified toxic dump burdened with the legacy of more than 100-years of extensive industrial chemical manufacturing.  The site is bordered on the south by Stege Marsh and San Francisco Bay, to the west by UC Berkeley Richmond Field Station and Meeker Slough, and on the east by a small-business area, Baxter Creek, and the radioactive contaminated Blair Landfill, and in several directions by low income housing and environmental justice-impacted residents just across I-580 which curves around the site.
Since 2004, community volunteers have worked diligently with the Cal EPA Department of Toxic Substances Control (DTSC) to ensure a robust clean-up was the final result.  However we have lost confidence that the DTSC is adequate to the job of holding AstraZeneca (the primary Responsible Party) to a standard of clean-up that is protective of human and environmental health.
Currently over 98% of the hazardous waste, much of it cancer-causing and/or linked to other health risks such as reproductive and developmental disorders, is proposed to be left in place and 4,000 residential units built densely across the site.  The approvals are rapidly moving forward with the Richmond City Council trapped in a Development Agreement the majority of current Council members, residents and widespread community oppose.
The DTSC ignored updated science of sea level rise and its impacts such as groundwater and saltwater intrusion; they also ignored new more protective health risk levels for tetrachloroethene (TCE), which is predominant throughout the site.  The 550,000 cubic yards of contaminated soil proposed to be left on site contains high levels of heavy metals (predominantly arsenic), volatile organic compounds (VOCs), polychlorinated biphenyls (PCBs), herbicides, fungicides, pesticides (many banned worldwide) and more.  Many independent experts have weighed-in on the dangers of allowing the hazards to remain on the shoreline and especially underlying development.
Deed restrictions prevent on-site day care, schools, hospitals, or other facilities for seniors or anyone under 21 years old, yet the DTSC-approved remedy to cover 65-acres with a concrete cap will allow families with children, seniors, and other vulnerable populations to live there.
When choosing a clean-up alternative in the Feasibility Study and Remedial Action Plan (FS/RAP) process, DTSC used the argument that a dig-and-haul solution would expose the nearby widespread environmental justice community to more potential harm, yet
their own documents conclude removing all the hazardous material and waste is the best long term solution.
The concrete-cap solution depends on unproven in situ remediation of widespread VOCs in soil, soil gas and groundwater with "five-year reviews" that may or may not include actual re-sampling of soil, water, etc. to check and track the status of the hazardous waste.  There is no plan for real-time measurement of VOCs under or in the proposed 4,000 residences.  There is also no plan to mitigate toxic plumes already expanding into bordering areas including Stege Marsh, San Francisco Bay, and the adjacent UC Berkeley and small-business properties, which will be all the more difficult to stop once the proposed dense housing covers the site.  There has been no consideration of the potential for groundwater intrusion caused by rising sea levels to force vertical and horizontal changes in the massive toxic mix of VOCs, including pushing them up into living spaces through foundation cracks, aging plumbing, and cracks in utility conduit seals.
The entrenched DTSC bureaucracy is failing in its charge to protect the public through illogical "greenwashing" and word-salad arguments.  The broad community demands the site be cleaned up to the highest residential standards including removal of the
hazardous waste, before any housing is built on the shoreline.
The ask:
  • Cal EPA DTSC reopen and update the Feasibility Study/ Remedial Action Plan (FS/RAP) and Human Health Risk Assessment (HHRA) to include sea level rise and seismic risks in addition to using the most protective health standards when evaluating the risks from hazardous waste left in place
  • City of Richmond reopen and update the Richmond South Shoreline Specific Plan Environmental Impact Report (EIR) to reflect sea level and seismic risks, and consider the general trend for more protective standards for the types of hazardous waste at this site
  • AstraZeneca (and other RPs) remove all the toxic waste to a certified hazardous waste facility, by rail or intermodal transport, if possible
Thank you for your prompt consideration of this urgent matter.

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