Critique by CBG of the Navy’s Draft Fifth Five-Year Review of Hunters Point

Click here to read our critique.

Click here for the appendix to our critique.

Every five years, the United States Navy is required by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as Superfund), to review the protectiveness of cleanup remedies at the Hunters Point Naval Shipyard (HPNS) Superfund site in light of current information and knowledge. At the core of this requirement is the recognition that new developments – e.g., evolving scientific findings about toxicity, tighter modern cleanup standards, discoveries of failures of cleanup actions taken at a site – can mandate going back and undertaking more cleanup in order to protect public health and the environment.

The Navy’s draft Fifth Five Year Review is yet another failure in a long line of them. The draft review fails to include multiple fundamental aspects of the cleanup, as well as new developments which clearly should have been reviewed. If key facets of the cleanup do not shift, current and future residents of the Hunters Point-Bayview area will be adversely impacted by the effects of weak cleanup standards, contamination in numerous parcels, and an oversight entity that does not seem interested in carrying out its obligations to clean up the site.