Navy’s Report on Shipyard Cleanup Draws Criticism
EPA’s Edict: Not Protective!
• • • • • • • • March 2024 • • • • • • • •
The Navy released the Fifth Five-Year Review (Draft) for the Hunters Point Naval Shipyard (HPNS) Federal Superfund Site on November 29, 2023.
Every five years, the EPA determines the success of superfund cleanup sites such as the Hunters Point Naval Shipyard in a 'Five-Year Review of Superfund Sites.' These evaluations consider human health risks, ecological risks, and the general performance of the selected remedy. These determinations are based on three questions:
- Question A -Is the remedy functioning as intended by the decision documents?
- Question B - Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy selection still valid?
- Question C - Has any other information come to light that could call into question the protectiveness of the remedy?
The Office of Solid Waste and Emergency Response (OSWER) clearly defines successful remediation efforts at superfund sites, such as Hunters Point. The EPA assigns one of five "protectiveness" categories:
- protective,
- short-term protective,
- will be protective,
- protectiveness deferred,
- and not protective.
Not Protective
The review's simple take-home message is that 15 parcels and sites under review do not fully protect residents, workers, churchgoers, playgrounds, and business owners on 3rd Street from hazardous substances, pollutants, and contaminants emanating from dirty development activities on the base.
Public Review and Feedback on the Five-Year Review (FYR) Report. The Draft Final FYR od available until March 31, 2024 for public review and feedback. Members of the community can review the Draft Final FYR Report for Hunters Point Naval Shipyard (HPNS). Instructions and frequently asked questions (FAQ) at the Navy website. All comments must be received in writing on or before March 31, 2024
Despite its colossal scope, its key findings are condensed into the first 30 pages in the Executive Summary, FYR Summary Form, Issues and Recommendations, and Protectiveness Statements for fifteen parcels and sites undergoing review.
The review is 566 pages including Appendix A - the projected impacts of climate change and extreme weather events at Hunters Point Naval Shipyard. It is the fifth FYR I have analyzed in 25 years.
The HPNS Fifth FYR Findings are corroborated by five years of community exposure research science conducted by the Hunters Point Community Biomonitoring Program (HPCBP).
HPCBP findings show residents and workers inside the half-mile perimeter of the base are endangered. This was predicted and documented in Housing for the Dead in 2007. Geospatial mappings show chemical and cancer clusters are most dense within the half-mile perimeter of the base and increase in density the closer you live or work to the base. Our biomonitoring screenings prove the severity of exposure and the likelihood that there will be dangerous chemicals in residents near the site. There are two determinants — how close and how long. How close to the base you live or work, and how long you have been exposed.
The five-year findings of Hunters Point Biomonitoring present proof that the Hunters Point Naval Shipyard Federal Superfund site is the active source of human exposure and that the chemicals detected in dangerously high concentrations in shipyard residents and neighbors match the profile of chemicals the Navy & EPA document to be present in shipyard soil.
The take-home message from the HPNS Fifth FYR is that the four original land parcels [Parcels B, C, D & E] and eleven newly created sub-parcels and sites [B-1, B-2, C, D-1, D-2, UC-1, UC-2, UC-3 and G] are all designated short term protectiveness or they will be protective in the future.
Issues and Recommendations
The Navy concluded in the FYR that radiation-contaminated landfills at IR-07/18, Parcel E, and Parcel E-2 are "sites without issues and recommendations affecting protectiveness." Independent HP Community Biomonitoring research does not support that conclusion.
The Parcel B landfills at IR-07/18 are not protectivebecause they include sites undergoing retesting as the result of the Tetra Tech fraud scandal. The Navy excluded radiological testing conducted at Parcel B IR-07/18 by Tetra Tech and EPA in 1992 and 1994 from the Fifth FYR.
The Parcel B landfills at IR-07/18 at Galvez Street are the site of the discovery of a radium dial during California Department of Public Health radiation surveys conducted in 2018.
HP Biomonitoring's geospatial mappings detect a cluster of radioactive biomarkers in residents living adjacent to Parcel B - including an artist who leases a studio in Building 115 with high levels of uranium and cesium on urine screening.
A ROD IS A MEDICAL TREATMENT PLAN FOR SICK AND DYING LAND!
The purpose of the FYR and why it is required by the Federal Superfund Amendments and Reauthorization Act
A Record of Decision - ROD - is required for Superfund parcels and sites where hazardous substances, pollutants or contaminants have been detected in concentrations so high they restrict the use of the property and pose a danger to human health and the environment. A ROD is exactly like the medical intake, evaluation, examination, testing and treatment plans doctors create every working day.
A ROD has been finalized for fifteen HPNS parcels and sites. The Fifth FYR summarizes the remedies proposed by the ROD for these parcels and sites to determine whether they remain protective of human health and the environment. Findings and conclusions derived from document reviews, site activities, analytic data, and scientific findings are presented in the FYR.
Like a physician's treatment plan, a FYR identifies issues that may prevent a remedy from functioning as designed and may affect the protection of human health and the environment from exposure to hazardous substances, pollutants, and contaminants.
Houses In The MUD!
Climate Resilience Assessment
For the first time, the HPNS FYR presents a Climate Resilience Assessment to address future effects of climate change and extreme weather events that create flooding and disseminate dangerous chemicals in soil, groundwater and fill throughout the San Francisco Bay Area.
Major findings of the Climate Resilience Assessment predict that the base of the iconic Gantry Crane on Parcel D-1 may be flooded by 2065 due to rising sea levels and Parcel D-1 contains metals in the groundwater.
According to the 2010 Redevelopment Plan (SFR 2010), Parcel G is zoned for mixed-use development, including residential use, as are Parcels D-2 and UC-1 - which were transferred to the Office of Community Investment and Infrastructure (OCII) in 2015 but are included in the FYR as sites of Tetra Tech soil fraud.
The Human Health Risk Assessment documents unacceptable human health risks to adults and children for future residents at all Parcel D sites (including those sited for residential development transferred to OCII) from exposure to metals and polycyclic aromatic hydrocarbons (PAHs) — a class of chemicals that occur naturally in coal, crude oil, and gasoline, in soils up to 10 feet below ground surface, volatile organic compounds (VOCs) in groundwater and vapor intrusion into indoor air. The 2010 Redevelopment Plan cites residential development in regions of Parcel D west of the Gantry Crane.
(Above) Fifth FYR Regions mapped in yellow, pink and bright orange are proposed for residential development under SFR 2010 in Parcels D-2, UC-1 - transferred to the City & County of San Francisco in 2015.
They include the utterly preposterous proposal to site residential development in a Parcel E Multi-Use District — or MUD immediately adjacent to the Parcel E-2 landfill.
In the Beginning was the Map
The first HPNS Base Wide Impaction Maps were published in the January 2001 Draft Hunters Point Shipyard Historical Radiological Assessment. They offer visual evidence of the extent of radiation contamination of the naval base along the western fence line (hot pink) at the intersection of Crisp Road at Palou Avenue and Griffith Street.
The radioactive panhandle region extends south to the north shore of Yosemite Slough. These original maps were excluded from the final HRA released in 2004. They are located in the offices of the Hunters Point Biomonitoring Foundation.
The Significance of the Parcel E UC-3 Utility Corridor
View from a playground in Hunters Point - Hunters View playground across the Street from the shipyards Crisp Road entry on Parcel E Utility Corridor UC-3. UC- 3 courses through dangerously contaminated HPNS Parcel E and E-2 into the Hunters Point Community parallel to Ingalls. Coursing south to Yosemite Slough Federal Superfund Site— photo: AP Sumchai
The Parcel E UC-3 - Utility Corridor 3 - is arguably the least known and highly significant parcel on the base. UC-3 is Crisp Road. It intersects with the 1000 block of Palou Avenue, coursing southwest directly into the Hunters Point community parallel to Ingalls Street. UC-3 is a direct conduit from the most contaminated regions of Parcels E and E-2.
Parcel E site UC-3 conveys toxins along a roadway that courses two blocks east of the Southeast Health Center on Keith Street.
UC-3 courses through a sacred Ohlone burial ground - a quarter of a mile west of a nest of sensitive receptors that include Bayview K.C. Jones playground, MLK swimming pool, Bret Harte Elementary School and major transit and commercial corridors at 3rd Street between Palou Avenue and Carroll Avenue.
"All concentrations were below established radiological release criteria" - Tetra Tech EC, Inc. Final Radiological Removal Action Completion Report Parcel UC-3 Hunters Point Naval Shipyard, San Francisco California, Tetra Tech EC, Inc., March 16, 2012.
Section 6.0 of the Fifth FYR for Parcels E, E-2 and UC-3 includes a Human Health Risk Assessment (HHRA) documenting unacceptable health risks from chemicals of concern to adult and child residents, industrial workers, construction workers and recreational users "from exposure to metals, VOCs and SVOCs, pesticides, PCBs and TPH in surface soil, subsurface soil, A-aquifer ground water through vapor intrusion to indoor air, from metals and in B-aquifer groundwater in domestic use.
RECOMMENDATIONS
1. Industrial-grade dust barriers block fine particulates and radioactive fugitive dust emissions and cost as little as $250 per panel.
2. If you are offered a home facing the Hunters Point Gantry Crane at a suspiciously low price — bring a handheld Geiger counter to the Open House.
3. Community relocation may sound radical, but the Deep South Center for Environmental Justice counts as a success story of the determination of a community of residents — 99% Black, poor, and lacking in higher education — who formed a bucket brigade to collect dangerous chemicals emitted by a "nuisance neighbor" nearby refinery. After submitting the chemical samples to health agencies and environmental regulators failed, they sued the refinery. Following a ten-year battle, they won, and the refinery was forced to pay for the safe relocation of the entire community.
Our Work - Deep South Center for Environmental Justice
Technical assistance includes preparing environmental justice analyses and reports on proposed or existing developments requiring environmental permits, collecting toxicological and epidemiological data, and advising on effective environmental remediation and community relocation.
Dr. Ahimsa Porter Sumchai is a climate activist living on the Westside.
March 2024
