EHC's action plan for toxic hot spots in San Diego bay

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.