— Hunters Point Naval Shipyard, SF — contamination and reports

From Committee to Bridge the Gap

A History of Extensive Radioactivity Use

ON JULY 16, 1945, THE USS INDIANAPOLIS DEPARTED Hunters Point Naval Shipyard carrying components of a bomb code-named “Little Boy,” including half of the highly enriched uranium then in existence in the world. Two hours later, after receiving word that the “Trinity” test of the first nuclear explosion on earth had succeeded earlier that day at Alamogordo, New Mexico, the Indianapolis was allowed to leave San Francisco harbor carrying its cargo to the island of Tinian in the Pacific. On August 6, a plane christened the Enola Gay left Tinian and dropped the assembled atomic bomb on Hiroshima.

About a year later, the nuclear arms race returned to Hunters Point. The first post-war nuclear tests, called OPERATION CROSSROADS, were conducted at the Bikini Atoll in the Marshall Islands in the Pacific, involving 42,000 sailors and more than 240 target and support ships. The tests went badly awry, contaminating the ships. More than 80 of the most contaminated ships, from this and subsequent tests, were brought back for “decontamination” to Hunters Point, then, as now, a predominantly low-income Black community. This process involved sandblasting the radioactivity off the ships in the open air, transferring the contamination from the ships to the surrounding area.

In 1989, Hunters Point was made a Superfund site, listed as one of the most polluted places in the country. Since then, the cleanup has been botched beyond description. CBG, working with Public Employees for Environmental Responsibility, pried out of EPA and made available to the news media EPA documents concluding that the Navy’s contractor had apparently fabricated or otherwise falsified radioactivity measurements at 90-97% of the survey units at the site. $250 million in taxpayer money was wasted; the tests would have to be redone.

CBG has issued a series of detailed reports (which you can find on the column to the left) on the problems at Hunters Point, which have been given significant press attention (e.g., front page of the San Francisco Chronicle, major TV news stories on NBC Bay Area). These studies— based on intensive research by CBG staffers Devyn Gortner, Maria Caine, Taylor Altenbern, Haakon Williams, and Audrey Ford, and a score of interns—disclosed that the problems went far beyond the fabrication of measurements. CBG revealed that radioactivity use at the site was far more extensive than generally realized, with numerous pathways for transporting contamination throughout the entire shipyard and into the neighboring community; that 90% of sites at Hunters Point had not been tested at all; that for those sites that were, 90% of the radionuclides of concern were not tested for. We showed that the cleanup standards employed by the Navy were decades out of date and far, far weaker than current EPA standards, which are required to be used at Superfund sites.

We disclosed that the Navy, after having promised to remove the contamination so that the site could be released for unrestricted residential use, shifted gears and decided to leave much of the contamination and just cover it with thin layers of soil or asphalt. Because the site is planned to be the largest redevelopment project in San Francisco history since the 1906 earthquake, those thin covers will have to be torn up and the contaminated soil beneath them excavated to build the more than 12,000 homes planned, exposing and lofting the contamination into the air. Drs. Howard Wilshire and William Bianchi prepared companion reports that showed that plant roots and burrowing animals would also bring the contamination back to the surface. We have prepared detailed critiques of testing plans by the Navy and the health department showing that they were incapable of detecting contamination at the levels requiring cleanup.

Three quarters of a century after the nuclear arms race set sail from Hunters Point, the toxic legacy remains for that impacted community, a victim of environmental injustice. We will continue our efforts to assist them, as they frankly have no one on their side from the parties responsible—the Navy, its contractors, and the captured regulators. Hunters Point is a striking reminder that the nuclear arms race threatens us globally and locally.

[This is in addtion to the Navy’s nuclear waste dump offshore San Francisco and the radioactive USS Independence which the Navy filled with nuclear waste and sank south of San Francisco, near Half Moon Bay in what is now the Monterey Bay National Marine Sanctuary.]

Hunters Point Reports

Report 1: Hunters Point Naval Shipyard: The Nuclear Arms Race Comes Home – October 2018

Report 2: The Great Majority of Hunters Point Sites Were Never Sampled for Radioactive Contamination — And the Testing That Was Performed Was Deeply Flawed – October 2018

Report 3: Hunters Point Shipyard Cleanup Used Outdated and Grossly Non-Protective Cleanup Standards – October 2018

Report 4: FROM CLEANUP TO COVERUP: How the Navy Quietly Abandoned Commitments to Clean Up Hunters Point Naval Shipyard and is Instead Covering Up Much of the Contamination – August 2019

Companion Reports Issued with Report 4:

Plant Uptake of Radionuclides and Toxic Chemicals from Contaminated Soils Below a Shallow Soil Cover by William Bianchi, PhD, August 2019

Bioturbation, Erosion, and Seismic Activity Make Shallow Soil Covers Ineffective at Isolating Contamination by Howard Wilshire, PhD, August 2019

Additional CBG Hunters Point Critiques:  

Critique of the Navy’s Draft Fifth Five-Year Review – May 2024

Critique of the Navy’s Protectiveness Review of its HPNS Building Cleanup Standards – November 2019

Critique of the Navy’s Protectiveness Review of its HPNS Soil Cleanup Standards – September 2019

Critique of the Navy’s Draft Five Year Review – September 2018

Critique of the California Department of Public Health Work Plan for a Partial Gamma Survey of Parcel A-1 Hunters Point Naval Shipyard – July 2018

Critique of the Work Plan for Retesting of Parcel G Hunters Point Naval Shipyard – August 2018

Critique of the Navy’s Parcel F Proposed Plan for Offshore Sediment Cleanup Hunters Point Naval Shipyard Superfund Site – May 2018

https://www.committeetobridgethegap.org/hunters-point-reports1/

— EPA won’t require full cleanup of Hunters Point, SF

From Public Employees for Environmental Responsibility PEER

FOR IMMEDIATE RELEASE
Wednesday, October 5, 2022
Contact:
Jeff Ruch jruch@peer.org (510) 213-7028


EPA Says Hunters Point Will Never Be Fully Cleaned  

EPA Plans to Ignore Prop P Mandate and Its Own Superfund Standards  

Oakland, CA —The U.S. Environmental Protection Agency says that Hunters Point Naval Shipyard cleanup will not be sufficient to allow unrestricted residential use, according to an agency memo sent to Public Employees for Environmental Responsibility (PEER). Instead, the agency will rely upon caps and “land use restrictions” in violation of Proposition P, the overwhelmingly approved voter initiative demanding a full cleanup for the shipyard, a Superfund site since 1989.  

In meetings with top EPA officials in August and December 2021, PEER and allied groups asked for a commitment that the soil cleanup standards for Hunters Point be strict enough to allow for unrestricted residential use. They argued that the current soil cleanup standards violated EPA’s own Superfund guidance and would leave so much radiological waste that 1 in every 473 people would get cancer or the equivalent of getting a chest X-ray every other day for decades. 

Via an unsigned September 30, 2022 memo transmitted by Silvina Fonseca, a senior official with EPA’s Office of Land and Emergency Management which oversees Superfund, the agency demurred on the groups’ request to tighten the soil cleanup standards and would instead rely upon restrictions on allowed land uses at Hunters Point contrary to the demands of Proposition P, passed by more than 86% of voters in 2000, that the shipyard “be cleaned to a level which would enable the unrestricted use of the property – the highest standard for cleanup established by the [EPA]” – 

“Regarding your recommendation that soil radiological cleanup goals be based on an unrestricted use scenario consistent with the City/County of San Francisco’s Proposition P, broadly, EPA’s policy is to achieve protective remedies consistent with reasonably anticipated future land use. Institutional controls, like land use restrictions, are a common component of Superfund remedies nationwide to ensure protection of human health but also to ensure the integrity of remedies in the long term.” 

 “The bottom line is that EPA will not commit to the full cleanup of Hunters Point,” stated PEER Pacific Director Jeff Ruch, noting that this memo was nearly one year after EPA had promised to answer the groups’ August 2021 request. “As things stand now, the plan at Hunters Point is to pave over contamination rather than remove it.”  

The EPA revelation occurred just one day after EPA testified before the Board’s Government Audit and Oversight Committee last week but failed to disclose the EPA decision to not require a complete cleanup. This revelation creates a new confrontation regarding Hunters Point. The President of the Board of Supervisors has pledged there will be no transfer of Hunters Point land to the City without a “100% complete cleanup,” and EPA has now declared there will be no such cleanup. Tomorrow, the San Francisco Board of Supervisors will resume consideration of a County Grand Jury report about rising groundwater and sea-level rise would wash much of the remaining Hunters Point contamination into San Francisco Bay. 

“On one hand, EPA talks about the importance of community input but on the other hand says it is free to ignore Prop P, one of the strongest expressions of community input imaginable,” added Ruch, pointing out this was supposed to be the biggest redevelopment in the city since the 1906 San Francisco earthquake. “After more than 30 years of EPA supervision, Hunters Point is and will likely remain a radiological waste dump.”   

### 

Read the EPA memo 

Look at the Navy/EPA plan to leave contaminated soil onsite 

View the Grand Jury report 

Examine the lack of transparency on cleanup plans 

Look at the call for a national “garden pathway” cleanup standard

https://peer.org/epa-says-hunters-point-will-never-be-fully-cleaned/

— SF Bay: Fraud and coverup by Tetra Tech, state, and feds at Superfund sites Hunters Pt and Treasure Island; Navy poured radioactive waste down drains; residential and commercial development planned by city and Navy on contaminated land

From Labornet:

Posted July 4, 2017

“Cleaning The Swamp” Hunters Point Tetra Tech Workers Blow Whistle On Criminal Cover-up & Corruption

Published on Jul 4, 2017

Hunters Point and Treasure Island Tetra Tech health and safety inspectors spoke at a press conference at the former San Francisco shipyard and superfund toxic dump site on June 27, 2017 about the systemic criminal cover-up by the company, the Navy of serious radioactive contamination at the site and failure to rectify it. They were bullied and terminated when they reported the fraud and malfeasance by the management and officers of the company. Green Action has filed an administrative petition to halt the use by the Navy of this corrupt contractor. Other community health advocates talked about the environmental racism and the serious health conditions and deaths by the residents.
They also called for a criminal investigation by the San Francisco District Attorney Gascon and California Attorney General Xavier Becerra to investigate Tetra Tech and criminally prosecute them for fraud and corruption.
Additionally, Michael Madry a former quality assurance manager of Test America who was verifying the testing procedures at Hunters Point and Treasure Island noticed serious falsification and reported this to the management and OSHA. He was terminated because of his health and safety reports and Darrell Whitman who was an investigator with OSHA and the Whistleblower Protection Program was harassed and bullied by his supervisor for investigating the case. OSHA chief David Michaels and Department of Labor Secretary Tom Perez conspired to prevent an investigation of the corruption at these agencies, supported his termination and allowed collusion with H.I.S. the then owner of test America and other companies that they are supposed to regulate.
Additional media:
http://www.nbcbayarea.com/news/local/…
https://www.youtube.com/watch?v=J_YVo…
https://youtu.be/-EbkG4aQM1w
http://sfbayview.com/2017/06/whistleb…
http://www.nbcbayarea.com/news/local/…
http://www.nbcbayarea.com/news/local/…
https://soundcloud.com/workweek-radio…
https://soundcloud.com/workweek-radio…
https://www.youtube.com/watch?v=ZzfFB…
https://www.youtube.com/watch?v=kQ3zi…
https://soundcloud.com/workweek-radio…
https://www.youtube.com/watch?v=FQiB7…
http://www.nbcbayarea.com/investigati…
http://www.dailycensored.com/ohsagate/
http://issuu.com/injuredworkersnation…
http://issuu.com/injuredworkersnation…
http://issuu.com/injuredworkersnation…
http://issuu.com/injuredworkersnation…
http://www.fairwarning.org/2016/04/ex…
https://www.youtube.com/watch?v=FQiB7…
http://www.capoliticalreview.com/capo…
http://sfbayview.com/2009/04/digging-…
https://ww2.kqed.org/news/2016/07/22/…
Production of Labor Video Project
http://www.laborvideo.org

http://www.labornet.org/

— San Francisco: EPA & Navy used wrong and unsafe standard for radioactive/toxins cleanup; EPA Superfund manager stonewalls at public meeting

Lily Lee, EPA Cleanup Project Manager, Superfund Division
Interviewed on February 8, 2017 at a community meeting on the cleanup problems and fraud at the San Francisco Superfund site. The Superfund site is located at the former Hunters Point Naval Shipyard and Naval Radiological Defense Laboratory.

Ms. Lee was interviewed by Labor Video Project, and then asked questions by Dan Hirsch, UCSC Executive Director on Environmental and Radioactive Policy, on the cleanup and EPA exposure guidelines. Her answers, as Superfund Cleanup Project Manager, are surprising.

This is why these agencies organize “poster” open house format meetings. They do not want to be asked these important questions in front of an audience, and they certainly don’t want to be forced to answer. Of course, as public employees, they don’t want to be seen as avoiding or stonewalling, and they certainly don’t want to go on the record admitting negligence or indifference in implementing rules.

In a meeting in another town on a public health issue, members of the public refused to put up with this style of format. They pulled chairs into the center of the room, sat down as a group, and demanded to have a presentation made to them as a whole. Rather than do that, the people in charge gathered up their materials and walked out. Unless forced, they will not submit to a regular meeting format.

https://youtu.be/J_YVou0kmQI

Interview of Lily Lee, EPA, begins at 29:13

This transcript begins toward the end of her interview with Labor Video Project

Lee: …We are here to say that I am doing my job every day the same way I have been and I will keep doing so to ensure that the cleanup here is meeting all of the health-based standards

LVP: I understand that 50% of the black population, African-American population, their children have asthma and other toxins from living out here. Is that of concern to you?

Lee: What we do here is that we set the standards for cleanup based on health-protective levels and then we ensure that when the Navy’s cleanup is happening, both during the process and when they’re done, that it meets our health-based standards to protect people from health conditions such as asthma.

[“Health-protective levels” and “health-based standards” — The EPA has repeatedly loosened exposure guidelines for radioactivity which they acknowledge increases the percentage of the population that will develop cancer. If the EPA uses these terms often enough, do they believe they will become accurate?

Her following interchange with Dan Hirsch reveals that she does not enforce EPA’s own standards, and she further says that steady exposure to radiation at the level of 25 millirem is something the body can cope with.]

Hirsch: Did the EPA’s criteria in effect at that time — I’m not talking about doing an analysis years later that it wasn’t that big of a mistake — why was the mistake made in the first place? Why did EPA allow clean-up standards that were contradicting EPA’s then current standards?

Lee: And again, I wasn’t there at that time and I tried to look for records about this information, and I’ve unfortunately not been able to find those records, but what I can tell you is that I am looking at the current standards, the current PRG calculator which is unfortunately in flux right now, and we are looking to see, revisit these standards to determine whether or not they would fall within the circle risk (?) range using site-specific factors.

Hirsch: I mean, you know you’re playing a game about this over and over again. The public was told you were cleaning up to a one in a million risk. You’ve seen EPA standards, but it turns out the Navy didn’t do that and used standards that are very much weaker than the ones that they said they would be using, and EPA said should be used at that time.

You’re now saying you’re seeing whether, okay it was a mistake but whether the mistake was mistake of a 300 fold. That isn’t very reassuring to the public.

I want to come back to the central issue. Do you agree that 25 millirems should not have been used, that was, even at the time, something the EPA said that was not acceptable and not protective.

Lee: I want to explain that some of the language that you saw in the footnotes referenced the 25 millrems but wasn’t necessarily the only standard that the Navy would be required to meet that

Hirsch (interrupting): In the tables, they actually estimate the dose for the other standard that they met, and for several of those, that was 25 millirem. So they actually did use 25 millirem. They shouldn’t have

Lee (interrupting) ___waste?

Hirsch: And structures.

Lee: Okay, and structures.

Hirsch: And they’re not supposed to according to EPA guidelines.

That’s 12 chest x-rays a year. They’re saying it’s okay for people to get a chest x-ray a month from the moment of conception to the moment of birth. Even the EPA says that level of radiation is outside the upper limit of your acceptable risk range.

So do you concede that they used a cleanup number that EPA said, even at the time, should not have been used?

Lee: So, I would like to talk about the chest x-ray which is an acute dose meaning a dose that people would get in one situation during the chest x-ray itself as being different from what’s relevant here at the base which would be a dose that would be over time continuously across year. So that wouldn’t be something

Hirsch (interrupting): Your own agency says there is no difference. EPA formally said that getting a chest x-ray a month is no different than getting a thirtieth of a chest x-ray every day for those months. That there is no… It’s linear, so the rate at which you get it doesn’t matter.

You know that’s your own agency’s official position.

Lee: So, if you can get a small dose that’s over a period of time, your body does have some recovery and

Hirsch (interrupting): Excuse me, are you saying that EPA believes that radiation is potentially good for you – the hormesis theory? Or that, or are you also saying that the risk is not linear with dose? Because the official position of EPA is just the opposite of what you’ve just said.

Lee: So, thank you for sharing your perspective. I am saying that those kinds of exposures are different, and I am also saying as I have said before that we are looking at the original standards to see if under the current version of the PRG calculator which is going to be changed soon, that that will still fall within the national contingency plan superfund regulation range of acceptable.

Hirsch: I want you to answer once and for all whether the standards that they chose were consistent or inconsistent with EPA’s guidance in effect at the time they chose them. Not whether going back years later and trying to say whether it was a 300 fold mistake.

Was the standard chosen by the Navy and approved by the EPA inconsistent with EPA’s Superfund guidance in effect at the time?

Lee: And I’d let you know that I don’t have information about what the standards were in effect at the time and I’m going to go back and look at that information some more. I’ve done some research

Hirsch (interrupting): ___the 25 millirem was back then considered unacceptable? Back in 2013? Do you not know the ___ in 2013 is not acceptable? So why was 25 millirem allowed to be used?

Lee: As I said, we are going to be checking the current version of EPA calculator

Hirsch (interrupting): Why was a cleanup standard allowed to be used that was not consistent with your guidance? I’m not talking about whether a post doc analysis as to whether it is too huge a mistake. I’m talking about whether it was a mistake. 25 millirem, is it not today, and wasn’t it in 2013, outside the level that EPA said was protective? It was a level that EPA said should not be used for cleanup standards. Am I not right about that?

Lee: I will go back and check to make sure.

Hirsch: Don’t you know that 25 millirem EPA has always, has said for long periods of time and certainly in the last years, is not to be used at Superfund sites?

Lee: I have seen that guidance information before.

Hirsch: Alright. Well, then, let’s just admit, can’t you, that they used a cleanup standard that was incompatible with Superfund guidance in effect at the time. Can you admit that?

Lee: As I said, I will go back and check that information.

— San Francisco Hunters Point land development on hold as falsification of toxics cleanup investigated

Earlier reporting on this situation.

From Hood Online

September 22, 2016

Hunters Point Shipyard Land Transfers On Hold As Toxic Waste Cleanup Investigated

By John Shutt

Regulators from the Environmental Protection Agency and California Department of Toxic Substances Control have told the Navy to stop transferring land from the Hunters Point Shipyard to developers while agencies investigate the extent of the falsification of data about the cleanup of toxic and radioactive materials at the site.

The regulatory action was first reported in the Ingleside-Excelsior Light last week, and stemmed from investigations into Navy contractor Tetra Tech.

NBC Bay Area reported earlier this year that a former Tetra Tech employee said he had been told to swap potentially contaminated soil samples for clean ones, dump potentially contaminated soil into open trenches around Hunters Point, sign falsified documents submitted to the government, and tamper with computer data about radiation levels. Other former workers said they were fired in retaliation after reporting violations to regulators.

The shipyard was declared a superfund site by the Environmental Protection Agency due to contamination from the Naval Radiological Defense Laboratory, located there from 1948 through 1969, and toxic waste left over from industrial use. The Navy is obligated to clean land at the shipyard before it is turned over for development.

EPA regional spokesperson Michele Huitric confirmed that investigations into Tetra Tech are ongoing, and said the EPA was aware of investigations by the Nuclear Regulatory Commission and the Navy. The Nuclear Regulatory Commission previously recommended a fine against Tetra Tech after they found the company had deliberately falsified data.

Part of the shipyard declared safe by regulators has already been transferred to developer FivePoint, a spinoff of Lennar Corporation, which is building residential housing. A FivePoint spokesman said that the Tetra Tech whistleblower reports are not related to Parcel A, the land they are building on.

“Parcel A was transferred in 2004, several years prior to the alleged soil mishandling, and after the Navy, USEPA, and State of California determined the property was cleaned up and safe for transfer,” said FivePoint spokesperson David Satterfield. “Parcel A was removed from the National Priorities List at that time and is no longer considered a federal superfund site.”

Bradley Angel from environmental activist group Greenaction said that he had confronted FivePoint officials at a recent sales event about the cleanup, and had been shown documents that indicated Tetra Tech worked on at least part of Parcel A.

“They took us into the back room and took out three big binders and opened the first one, and of course the first sentence was about Tetra Tech’s work at the Shipyard, but not, of course, about falsification of soil samples,” Angel said.

San Francisco Magazine reported yesterday that a July email from the Navy indicated that Tetra Tech may have done sampling on Parcel A.

Greenaction has called for Tetra Tech to be fired and for an independent investigation of toxin and radiation levels at the shipyard and in the surrounding area.

UC Santa Cruz researcher Dan Hirsch, part of a team preparing a report on the cleanup, said that not only had Tetra Tech falsified soil samples, the Navy has been using outdated remediation standards that allow much higher levels of toxic material than the EPA currently recommends—in some cases about 100 times higher—and radiation levels equivalent to 12 chest x-rays per year for residents.

“We found over and over again that the Navy used standards that EPA said they aren’t supposed to use,” Hirsh said.

Mayor Ed Lee and Supervisor Malia Cohen wrote to the Environmental Protection Agency on Sept. 19th requesting a meeting.

“The environmental cleanup of the property is a critical first step in the process of developing Hunters Point Shipyard—a project that will deliver desperately needed housing and long-overdue public benefits to the Hunters Point community,” read the letter. “For that reason, we are requesting a briefing with senior Environmental Protection Agency leadership, confidential if necessary, so that we may better understand the scope and timelines of the investigations, and any potential impacts to the overall schedule for the delivery of these public benefits.”

The Shipyard development is a major piece of the city’s strategy for developing the southeastern waterfront. FivePoint plans to build 1,400 units of housing on the land that has already transferred, but thousands of additional units are now in limbo.

http://hoodline.com/2016/09/hunters-point-shipyard-land-transfers-on-hold-as-toxic-waste-cleanup-investigated

— Superfund site at Lawrence Livermore Lab under review — Comment Deadline July 1

From TriValley CAREs http://www.trivalleycares.org

Site 300’s Hazardous Waste Operations- Under Review

Updated June 28, 2016

The California Department of Toxic Substances Control (DTSC) has not issued a hazardous waste permit to Livermore Lab’s Site 300 since 1997. After a failed permit process in 2007, in which public comment was taken, but then abandoned and never responded to, DTSC has recently issued a new Draft Hazardous Waste Permit for Site 300.

The High Explosives Testing done at Site 300 (in support of nuclear weapons development) produces significant quantities of hazardous waste, which contains or is contaminated with high explosives and a slurry of other toxins. Much of these wastes are burned in on-site incinerators. Site 300 is a Superfund site, with serious contamination from historical mismanagement of hazardous waste. The hazardous waste operations continue to threaten the environment and human health.

A public hearing was held in Tracy on April 27th in which the present community was given a short presentation and allowed to ask questions. The DTSC was unable to answer many of the questions. Comments were taken on the record.

The public now has until Friday, July 1st to submit their written comment to the DTSC. Tri-Valley CAREs submitted a formal written request to extend the comment period to this date. That extension was granted.

Written comments are to be postmarked or emailed by July 1, 2016 and sent to: Alejandro Galdamez, Project Manager, DTSC Office of Permitting, 700 Heinz Avenue, Suite 300, Berkeley, California 94710 or via electronic mail at Alejandro.Galdamez@dtsc.ca.gov .

Tri-Valley CAREs has drafted a short “sign and send” comment that you can sign and send electronically.

Click here for an English version of the “sign and send” comment that you can download, print and mail in.

Click here for an Spanish version of the “sign and send” comment that you can download, print and mail in. We are in the process of drafting more detailed comments.

Click here for the Draft Permit’s Environmental Review

Click here for the Summary Report of Ecological Risk Assessment for the Operation of the Explosives Waste Treatment Facility at Site 300 of the Lawrence Livermore National Laboratory

Click here for the Soil Sample Report In Support of the Site 300 Explosives Waste Treatment Facility Ecological Risk Assessment and Permit Renewal

Site 300’s Hazardous Waste Operations- Under Review