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Regulation of Deconstruction Materials in Berkeley's Transfer Station is Overdue

Jim McGrath
Monday October 09, 2023 - 01:56:00 PM

I write as a former Board member of the San Francisco Regional Water Quality Control Board who has participated in the long-stalled planning process for Berkeley's transfer station. While I am sure the current proposal on your agenda is meant to be constructive and innovative, it unfortunately ignores the recent history of the transfer station, and the plan which began in about 2014 and has not proceeded to adoption or even completion. There are two urgent issues with the transfer station--it is prone to flooding from Codornices Creek, and runoff from the site carries fine particles with very high levels of PCB's into the Bay. Despite the requirements of the city's stormwater permit, there are no solutions in place for these problems. 

A number of years ago, when water quality monitoring by Alameda County required under Berkeley's municipal stormwater permit began, the contaminant levels discharged from the storm drain at the base of Gilman had the highest levels of PCB's of any point sampled in the Alameda County stormwater sampling program. I spoke with one of the city engineers--long gone--who surmised that the discharge of contaminants was associated with back-flooding from Codornices Creek. I documented this concern, and the background materials that established that the undersized culverts at the freeway and railroad caused water to flow backwards along the railroad berm and frontage road towards the transfer station and the Gilman stormwater outlet. I testified to that effect in a workshop on the reconstruction of the transfer station in, I believe, May of 2014 at the library on University, and followed it up with an e-mail to Zero Waste staff. Unfortunately, the new city web site no longer has links to the original planning efforts for redesign of the transfer station--the best site for the history of this planning effort is now Berkeleyside. 

Nothing has been done to my knowledge about the flood and runoff hazards at the transfer station. Last winter, Second street had minor flooding but fortunately the transfer station was not flooded.  

Last week Berkeleyside included a story on the poor maintenance of the existing transfer station. But it did not include coverage of previous flooding and discharge of hazardous materials.  

PCB's were commonly used as an additive to the sealing caulks that were used in the buildings now being demolished. There may also be local sources of PCB's and other contaminants for the industrial areas south of Gilman and west of San Pablo identified as a new area for a specific plan. 

I would urge the city to make a priority of reducing the risk of contaminant discharge. Proceeding to recycling of building materials without a program to identify the presence of contaminants in those materials seems to me to be irresponsible. Ignoring the flood risk, and associated discharge of contaminants at high levels, also seems to be irresponsible.