Jennifer Lawrence, Principal Planner
Physical and Environmental Planning Office
1 A&E Building (1382)
University of California, Berkeley CA 94720-1382
Re: Northeast Quadrant Science and Safety Projects and 1990
Long Range Development Plan Amendment, Draft Environmental Report (June
2001) for the following Building Projects: Stanley Hall Replacement
Building (SHRB), Davis Hall North Replacement Building (DHNRB), Soda
Hall II New Development, Cory Hall Renovations, Navel Architecture Building
(NAB) Seismic Retrofit, Davis Hall South (New Davis Hall) Seismic Retrofit
and Lower Hearst Parking Structure. State Clearinghouse # 2001022038
Dear Ms. Lawrence:
Thank you for the opportunity to make comments on the University of
California’s Northeast Quadrant Science and Safety Project (NEQSS).
It first should be noted that this project is comprised of several large
projects and that each individual project should have its own environmental
review. In fact, it appears that this project, NEQSS, is the largest
project ever undertaken by the University, under a single construction
initiative.
However, it seems as though this project is being purposefully fast
tracked so as to bypass both the University’s New Century Plan
(NCP) and the new Long Range Development Plan (LRDP) of the Lawrence
Berkeley National Laboratory (LBNL). This results in a grossly incomplete
NEQSS review, which fails to analyze or even recognize the fact that,
geographically, LBNL and its chemical, radiological and nuclear labs
constitute a major part of the University’s northeast quadrant.
Consequently, this current project should not proceed isolated from
the University’s New Century Plan and LBNL’s LRDP because
attempting to consider the NEQSS project separately from the UC’s
NCP and LBNL’s LRDP would be improper project segmentation (“piecemealing”)
in violation of both CEQA and the National Environmental Policy Act
(NEPA). Having said this, please consider the following:
Geology, Soils and Seismicity
The majority of chemicals transported to the University’s Hazardous
Waste Handling Facility are generated in the northeast part of the central
campus, close to Stanley Hall. Hence, the northeast quadrant is the
University’s Chemical Quadrant. This area, around Stanley Hall
is already highly congested with a combination of pedestrians, campus
vehicular traffic and bicyclists. Nearby academic and administrative
buildings, which include classrooms and lecture halls filled with students,
create a very high daytime population. This already existing large number
of people using the area around Stanley Hall would increase both conflicts
created by congestion and possible exposures to an accidental release
of chemicals.
In 1994 the Stanley Hall site was part of an environmental evaluation
for a replacement hazardous waste facility on the campus. In the review
document (Draft Environmental Impact Report for the Environment, Health
and Safety Replacement Facility, State Clearinghouse #93091039), it
was stated that in the event of a major earthquake on the Hayward Fault,
the building (Stanley Hall) could be subjected to violent ground shaking
(p. 6-19). This is one of the central reasons why the Stanley Hall site
was rejected as a viable alternate location.
The current NEQSS environmental review fails to acknowledge this very
critical fact. The enclosed EIP Associates’ map clearly shows
that portions of both the existing Stanley Hall, and Department of Energy
(DOE)/ LBNL’s Donner Laboratory are within the bounds of the Alquist-Priolo
Fault-Rupture Hazard Zone of the Hayward Fault. (See attachment 1).
The Alquist-Priolo Fault Zoning Act was adopted in 1973. The act states
that “cities and counties (such as Berkeley and Alameda county)
affected by zones must regulate certain development projects within
the zones. They must withhold development permits for sites within the
zones until geologic investigations demonstrate that the sites are not
threatened by surface displacement from future faulting.” It appears
that no such required geologic investigations were included in the draft
NEQSS EIR.
The San Francisco Chronicle article (June 27, 2001) titled Shaky Ground,
which describes the University’s plans regarding the 100 million
dollar Memorial Stadium retrofit, states: “experts interviewed
at the State Seismic Safety Commission and Division of Mines and Geology
said they knew of no serious efforts to withstand the tremendous force
of the earth ripping apart. No one knows how much the Hayward Fault
would tear. The ground on one side of a fissure in the 1992 Landers
quake in the Mojave Desert jumped 21 feet relative to the other side.”
A recent Daily Californian article (July 27, 2001) subtitled Volatile
Chemicals, Delicate Light Fixtures Potential Hazards states the following:
At UC Berkeley “labs compose thirty percent of the campus. In
the Northridge Earthquake there was a lot of damage at Cal State Northridge...in
the chemistry buildings, some of the chemicals reacted with each other
and started fires.” Where in the draft EIR is the detailed review
and hazard analysis for the inevitable earthquake, “the BIG ONE”
on the Hayward Fault, and the evaluation relating to the potential for
a chemical firestorm?
Stanley Hall (and Donner Laboratory next door) should be decommissioned
and no replacement facilities should be located at the site given the
potential for a catastrophic earthquake on the Hayward Fault. The impact
of such an event would go far beyond the central campus and would be
horrific enough to manage, without the added threat of chemical and
radioactive releases from the proposed development and activities at
Stanley Hall, other NEQSS building projects and existing central campus
laboratory buildings.
Hazards and Hazardous Materials
During the 50 years of operations at Stanley Hall, (according to the
draft EIR) radionuclides were used in its laboratories. The final EIR
for NEQSS should list the inventory of all the radioisotopes and hazardous
chemicals that have been used in Stanley Hall, during its life time,
as well as all other buildings under consideration in the NEQSS project
(i.e., Davis Hall North, Cory Hall, Soda Hall, Naval Architecture Building
and Davis Hall South). In addition, a complete Hazardous Materials Work
Plan should be provided for identifying the degree of contamination
in the many ducts, fume hoods, glove boxes, and exhaust systems of the
various laboratories as well as for the safe removal of the contaminated
equipment. The Stanley Hall Replacement Building would also require
the removal of 101,000 cubic yards of earth and Davis Hall another 66,000
cubic yards. The Hazardous Materials Work Plan and site characterizations
should include comprehensive soil and groundwater testing to determine
the degree of contamination at all NEQSS sites. Disposal options should
also be outlined for each site.
The Work Plan should require agency (California Department of Health
Services and California Department of Toxic Substances Control) and
public review prior to the commencement of any demolition. As stated
above, the area around Stanley Hall is already highly congested. From
a transportation point of view, the movement of hazardous and radioactive
waste is problematic given that the proposed Stanley Hall is located
next to the East entrance of the central campus and has inferior transit
accessibility. The draft EIR fails to evaluate the many problems related
to the movement of hazardous and radioactive materials and waste to
and from the Stanley Hall area.
The proposed replacement of Stanley Hall is about 10 stories high, plus
an additional two stories for cooling towers. At 285,000 square feet,
it is more than 4 times the size of the existing building. This large
increase in size will also mean increases in the use and storage of
hazardous chemicals, radionuclides and nuclear materials (sources) at
the site. The final EIR should list the inventory of all the radioisotopes
and hazardous chemicals proposed to be used and stored in the new Stanley
Hall as well as in all the other buildings under consideration in the
NEQSS development.
It should be noted that the Stanley Hall is located next door to DOE/LBNL’s
Donner Laboratory and close to the Melvin Calvin Laboratory, all of
which use radioactive materials such as: Tritium (H-3), Carbon-14, Phosphorus-32,
Sulfur-35, and Iodine-125, etc. as part of their research work. The
draft EIR does not describe methods for capturing radionuclides not
consumed in the experiments in laboratories at Stanley Hall, Davis Hall
North, etc. The draft NEQSS EIR also fails to address the cumulative
impacts from all the chemicals and radioisotopes used at the various
existing and proposed campus laboratories within the northeast Chemical
Quadrant. A serious shortcoming of this draft EIR is its complete failure
to address issues related to radioactive waste generation, treatment,
storage, emissions and disposal.
The draft EIR fails to describe in detail any of the research activities
proposed for the first three floors (basement level) of Stanley Hall
reserved for “imaging” and NMR’s. What types of imaging
are involved in advanced medical imaging technologies? Do they include
positron emission tomography, single photon emission computed tomography,
nuclear magnetic resonance imaging, gamma irradiators, and cyclotrons?
How many curies of Cs-137 and Co-60 will be located onsite as sources?
How and where will the gamma radiation field be measured? What other
radiological activities will be carried out at the proposed Stanley
Hall and other NEQSS project sites? How and where are the emissions
going to be monitored?
Where is the evaluation of the potential environmental impacts from
the cooling towers on the Stanley Hall rooftop? Will LBNL or any biotech
corporation/business/institution occupy research space at this new building
or other NEQSS project buildings? If so, then who and what percentage
of these new buildings will they occupy/lease? Will there be corporate
sponsorship, i.e. such as the recent NOVARTIS contract with UCB’s
College of Natural Resources?
Within the proposed activities at Stanley Hall is provision for animal
research. The draft EIR claims that animals will be held only for short-term
(p. 2-16) What does this mean? Are the animals going to be killed within
24 hours after experimentation? How are they going to be killed and
how will the carcasses be disposed of? As hazardous waste or radioactive
waste? How many animals are going to be processed (used in experiments)
in a year? Will there be independent (of all users) monitoring of animal
research to ensure humane treatment of laboratory animals?
The draft EIR states that much of the hazardous materials handled at
Stanley and Davis Hall North are consumed through use. (p. 3.5-7) This
appears not to be factual because much of the hazardous and radioactive
materials used in lab activities will actually escape these buildings
through fume hoods, which are designed to keep poisonous fumes from
intoxicating lab researchers (students). This will have a serious impact
on the local campus environment, Girton Hall Childcare Center, Stern
Hall, other student dormitories and residential neighborhoods, all of
which the draft EIR fails to address.
According to the October 1,1997 Contract between the United States of
America and the Regents of the University of California of the Management
of LBNL, Appendix I, LBNL currently occupies 105, 503 square feet of
space in fifteen (15) various central Berkeley campus buildings (See
attachment 2). Most of these labs are positioned in the Northeast Quadrant.
There is no oversight by the University’s Office of Radiation
Safety (ORS) or the State Department of Health Services (DHS) at any
of these DOE/LBNL occupied/leased laboratories. These on campus laboratories
have no restrictions regarding inventory and/or use of radioactive materials.
The impact of these DOE/LBNL activities have been overlooked and consequently
excluded from all University of California, Berkeley generated campus
environmental evaluations such as this draft EIR currently under review.
Therefore, all labs on campus, whether University or LBNL occupied should
be brought under the regulatory jurisdiction and oversight of the ORS
and DHS. This would enhance both the health and safety of students and
nearby residents. It would also provide a much needed campus wide comprehensive
inventory of chemicals and radionuclides which, for the first time would
identify and factor in both LBNL’s and the University’s
labs activities and their cumulative health and safety risks
.
Recommendations
The proximity of the proposed NEQSS project to an active earthquake
fault, the Hayward Fault, has the great potential to cause hazardous
and radioactive materials releases from existing and proposed buildings,
a chemical/radioactive firestorm in an already densely populated urban
center. We strongly recommend that no buildings be constructed along
the Alquist-Priolo Hazard Rupture Zone, where a portion of the Stanley
Hall is located.
This northeast corner of the campus should be dedicated as an open green
space. This would relieve congestion and improve the area’s air
quality by reducing the chemical inventory and chemical emissions in
this quadrant, thus, minimizing risks to students and neighbors. The
NEQSS project should not be approved as proposed, and no further evaluations
should be conducted on these building projects outside the context of
the LBNL Long-Range Development Plan.
Sincerely,
Pamela Sihvola, Co-Chair Committee to Minimize Toxic Waste
L A Wood, Community Environmental Advisory Commission*
*For identification only
cc: Gray Davis, Governor, State of California
Steve Arthur, Acting Director, California Department of Conservation
James Davis, State Geologist, Division of Mines and Geology
Weldon Rucker, City Manager, City of Berkeley
Mayor and Members of the Berkeley City Council
Attachments:
1. Alquist-Priolo Fault-Rupture Hazard Zone Map (EIP)
2. Appendix I, USA and U.C. Regents 1997 Contract of the Management
of LBNL
