Hunters CleanPoint up at Naval Shipyard Presented by: Maria Caine, Lucien Martin, Flora Lu, and Daniel Hirsch Program on Environmental and Nuclear Policy College 10 - University of California, Santa Cruz Introduction 1940 - Navy owns shipyard 1946 - United States’ Naval Radiological Defense Laboratory 1974 - Triple A Machine Shop, Inc. Triple A Machine Shop was indicted and convicted for illegal disposal of hazardous substances at Hunters Point. 1989 - EPA placed the Shipyard on its National Priority List 27 years ago Introduction What is an EPA Superfund site? Who holds responsibility? Navy, EPA, DTSC, and San Francisco Key Findings Superfund law requires Hunters Point must be cleaned up consistent with EPA Superfund guidance Cleanup has been using standards that violate this requirement and are substantially less protective The public is therefore potentially exposed to greater risks than would be the case if the law had been followed Key Findings The Navy is using a standard of 25 millirem per year, the equivalent of the public receiving 12 additional chest x-rays each year EPA either didn’t catch this or allowed it to happen Key Findings The Navy is using a 42 year old regulatory guide from the Atomic Energy Commission which no longer exists EPA says the guide is not to be used EPA either didn’t catch this or allowed it to happen Key Findings The Navy is shipping out for recycle and disposal, waste with radioactive contamination to sites not licensed or designed to receive it EPA either didn’t catch this or allowed it to happen Key Findings Navy is using RESRAD model even though EPA guidance requires the use of its Calculator EPA either didn’t catch this or allowed it to happen Key Findings Navy says it is using EPA preliminary remediation goals as its cleanup standards, but it is using them from 1991-a quarter of a century old- rather than current PRGs EPA either didn’t catch this or allowed it to happen Results The Hunters Point cleanup standards are far more lax than EPA’s current remediation goals recommend. Sometimes 100s of times more lax Tetra Tech: False Samples April 2014 Tetra Tech was caught Red-Handed “Deliberately Falsified Radiation Readings” - NRC Can any Tetra Tech measurements then be trusted? Tetra Tech continues working. This means they continue work even after being caught. How could this be considered safe? eh. us rrec sures NUCLEAR REGULATORY OOHHISSION a: -- 5 REGIOHI print?? I, . m??s 21m censusesch sure. suns 10:: ems OF PRUSSIA. PA isms?2m Febniary 11. EDIE Occket NO- D3D331SS License hid. Elli-31396411 5-23l] Andrew N. President Tetra Tech Elli1 Inc. was The American Ftcad Mcn'is Plains, New Jersey GTSBO SUBJECT: HRS OFFICE OF INVESTIGATIONS REPORT NO. Dear Mr. Salt: This letter refers tc an investigaticn ccnducted by the US. Nuclear Regulath Ocmmissicn Of?ce cf Investigaticns between April 29, 2D14, and September 2015. to determine, in part, whether employees at Tetra Tech EO, Inc. [Tetra Tech]1 deliberately falsi?ed soil sample smeys the area referred in as 'Parcel at the US. Navy?s Hunter's Faint Naval Shipyard (HFNS) in San Francisco. Oalifcmia. A Factual Summary cf OI Investigaticn Repcrt Nd. is 1} with this letter. The NRC, which is known to be lax, found Tetra Tech’s behavior to warrant investigation and intervention. CERCLA 120(a)(2) “No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this chapter.” It’s time for your Monthly Check Up 25 mrem/yr = 1 chest x-ray/month Does this feel safe? Is this necessary? Can you live like this? Old Guides AEC Regulatory Guide 1.86 (1974) How trustworthy is a 42 year old guide? This guide is so outdated, that the agency which issued it no longer even exists! EPA says that the guidance is not to be used, and yet the Navy is using it. It’s Trash Day: But where does it go? Transportation of waste concerns Standards for Waste Removal Problems with Navy Transparency The Mess is Spreading Level I and Level II Waste Disposal Sites m. Comparison of EPA PRGs and Hadienuelide Hunters Paint Hemediatian Gnal Current EPA Residential PEG Faetnr by which Standards are Relaxed [ptig?g] Hemediatien Geal ?nals 115m pared ta EPA P3135 cesium-131" 11.113 11.11455 1.4 eebalt?EEI 11.151 11.11313 1.9 plutnniu m-233 1.511 11.11351r 11.5 radium-225 1.533 11.111153 1.59.1 strentiun'l-EIEI 11.331 11.11533 5.1 thnriurn-131 1.511I 11.111134]r 431' uranium-235 11.1115 11.1141'5 4.1 arnerieium-241 1.35 11.114? 13.3 eurnpiu m-152 11.13 11.1131'5 3.5 eumpiu m-154 11.13 11.11452 5.1 Clean up: Contamination Hunters Paint Hemadiatian Gaals us EPA Currant Preliminary Hemadiatian Gaals 1.5 .2 calla-ED mas pCi/g U1 {alum-?? rasllurrI-IIE mm?um-S? ?mun-1'31 [radial-ES- euruplurn-ISI Elm-.151 I Haw Clean Up Standard I EPA PraliminaryRemediatinnG-aal EPA/Navy Cleanup Plan for Hunters Point ● “Durable Cover Solution” ● Cover Up vs. Clean Up ● What does this mean to you? ● Long Term Problems Rather than clean up the contamination, the Navy is relying upon ?Institutional Controls? *l . r! 13.ru? Conclusions Clean up efforts at Hunters Point Naval Shipyard are not consistent with EPA guidelines Old/Out-of-date Standards that don’t comply with current EPA Guidance Safety Concerns Disposal of Radioactive Materials in Unlicensed Sites Clean Up vs. Cover Up