nvironmental Health Coalition (EHC) makes the following
recommendations in response to the Findings of the Final Report on Chemistry,
Toxicity, and Benthic Community Conditions in Sediments of the San Diego
Bay Region by the State Water Resources Control Board and National Oceanic
and Atmospheric Administration (NOAA) as part of the Bay Protection Toxic
Cleanup Program:
1. Regional Water Quality Control Board (RWCQB)
should require emergency cleanup actions for the four highest priority sites:
Seventh Street Channel, Laurel Street Drain and sites near the commercial
shipyards. The elevated levels of bioaccumulative and persistent chemicals
such as chlordane, PCBs, and mercury indicate the pressing need to remove
these toxic sediments in order to achieve improvement in the health of San
Diego Bay.
2. RWCQB should issue Cleanup and Abatement
Orders for the sites designated with "moderate" status, require
characterization of the extent of the contamination, and propose cleanup
plans: Navy SubBase, Campbell Shipyard, 24th Street Marine Terminal, Downtown
piers.
3. Given the bioaccumulative and persistent
nature of the chemicals of concern, Office of Health Hazard Assessment and
the County Department of Environmental Health Services should conduct a
comprehensive fish tissue study to assess the safety of consuming San Diego
Bay fish.
4. The reissuance of the General Shipyard NPDES
permit by the RWCQB should include a requirement for pollution prevention
plans, stricter discharge prohibitions, and more strict water runoff requirements
at facilities near the most toxic areas. They should further insure that
all discharges from vessels that are undergoing repair at the shipyards
be covered under the permit.
5. The new permits for Navy facilities soon
to be adopted by the RWCQB should include a requirement for pollution prevention
plans and stricter discharge prohibitions at facilities near the most toxic
areas.
6. The reissuance of the Municipal Urban Runoff
NPDES permit for the San Diego Region by the Regional Board should require
pollution prevention plans for municipal operations and residential areas
and strengthened educational plans for the general public.
7. In light of the significant contamination
from PAHs, the Air Pollution Control District should initiate aggressive
pursue pollution prevention activities in the watershed and air basin of
San Diego Bay.
8. RWQCB should utilize sediment levels listed
in the report as having impacts to marine life as interim comparison standards
for sediment cleanups until sediment quality standards are adopted.
9. A regional effort including all cities and
county governments and other agencies should establish pollution prevention
programs for all Bay dischargers and discharges to prevent future and ongoing
sediment contamination.
10. The Bay Protection and Toxic Cleanup Program
should be extended by the State Legislature as outlined in Assemblyman Sweeney's
bill AB 1479 in order to complete the work required in the original legislation.
11. In all new permits, "pollution prevention"
should be defined to mean a reduction of the generation of pollutants consistent
with existing federal and state law. Pollution prevention is accomplished
through changes in processes and materials used. This precludes the need
for traditional end-of-pipe control, treatment, disposal, and cleanup.
