December 13, 2019 letter to EPA providing additional comments on the Fourth Five Year Review and related documents which must analyze whether the cleanup is protective of human health and the environment: the Navy’s risk assessment should consider consumption of produce grown on the former shipyard; the Navy must provide rationale for the remedial goal used for radium-223; the retesting must use adequate sensitivity to detect radioactivity far below the current remedial goals which are not protective, and; the Navy continues to make unfounded assertions about the protectiveness of the remedy. (6 pages)
Golden Gate University School of Law, "CERCLA Cleanup 2019.12.13 Letter to EPA on its November Comments to the Draft FYR Addendum for Soil" (2019). Environmental Law and Justice Clinic - Hunters Point Naval Shipyard Documents. 37.